**Request to Use CARES for Larger/Older Persons**

I am writing to request an exemption from 14 CFR § 121.311(b) to the extent required for Emerson Keohane to be able to use an FAA Approved Child Restraint Sy stem even though she exceeds the weight limits for th e CRS. In addition, if my petition is granted, I request that an y air carrier or commercial operator operating under part 121 while Emerson is aboard its aircraft is granted an exemption from 14 CFR § 121.311(b)(2)(iii)(B) to the extent necessary to allow Emerson Keohane to exceed the specified weight limit for an FAA

- approved child restraint s ys tem during use of that child restraint s ys tem aboard an aircraft.

I believe the pertinent section from 14 CFR part 121 from which we seek relief is Section 121.311 Seats, safet y belts, and shoulder harnesses.

My daughter is __ 8 ___ year’s old, weighs __ 52 ___ pounds, and is __48

____ inches tall. My **daughter** ’s ph ys ical condition is as follows , she has a mitochondrial disorder with seizures, As a result of **her** phy sical c ondition, she needs the support and securit y provided b y an FAA Approved Child Restraint, but because of her weight is incapable of compliance with the regulation. **I am also submitting the following contact information:**  **Karen Keohane at 29 Morningside Dr W ilm**  **ington, MA 01887 and**  **KarenKeohane@yahoo.com.**

I understand that the regulation is written to create a high level of safety for each individual passenger b y ensuring that they are securely restrained in their seats during all phases of flight. The regulat ion also ensures that an individual does not cause harm to other passengers on the airplane b y being thrown into them during turbulent or
emergency

conditions.

I propose that Emerson Keohane be allowed to occupy an FAA Approved Child Restraint (CARES, manu factured by AmSafe, Inc.), even though she exceeds the manufacturer’s weight limits. This ensures a high level of safety for Emerson and a high level of safet y for the other passengers and crew on the airplane. In fact, in Emerson ’s case, safet y is greatl y enhanced b y the extra support and security that the FAA Approved Restraint Sy stem will provide during the entire flight.

Enhancing safety

for Emerson Keohane is in the public interest. In addition, the public interest is also served b y the fact that the u se of this FAA Approved Child Restraint Sy stem allows her to use commercial air transportation. Without the support and securit y of the FAA Approved Child Restraint Sy stem, she would be unable to fl y commercially.

I also believe that, with certain limitati ons established by the FAA in a grant to this petition, there can be an equivalent level of safety to that provided by the affected regulation. The CARES restraint has been certified by the manufacturer for use by children 22

- 44 pounds. However, the compo nents of the CARES restraint are the same as those used in restraints for adults on aircraft and would maintain their integrity if used by someone who weighed several hundred pounds.I believe that the limit of 44 pounds was established because, with the a dditional weight

of the child attached to the seatback, the seatback would move forward more quickl y in an accident scenario and this might cause a higher HI C load for the person seated in the seat behind the passenger using the CARES restraint (because th e seatback moving forward more quickl y would mean that it would not be there to attenuate the energy from the impact of the person seated behind the person using the CARES restraint).

In order to achieve an equivalent level of safety as that provided by th e affected regulation, I propose that the FAA establish a limitation in a grant to this petition that Emerson Keohane onl y s its in a passenger seat with no passenger seated behind her. Therefore, no unsafe condition would exist for a passenger seated behin dEmerson while she is using the CARES restraint. I also propose that all operations under this exemption be conducted with at least one of Emerson’s parents or a caregiver accompanying him or her. In addition, I propose that Emerson’s parent or caregiver must carry a copy of this exemption.

I also request that the processing of this petition not be delayed for publication and comment in the Federal Register. We want to travel the end of January 2014. If you take the time to put this in the Federal Register , it will delay the process and we may

not be able to travel in this timeframe.

If it is necessary

to put a summary

in the Federal Register, I submit the following:

This is a request for an exemption from FAR 121.311 (b) to the extent required for a child to use an FAA Approved Child Restraint System on an aircraft, even though the child exceeds the weight limits for the CRS. Due to phy sical challenges, without the support and securit y of this FAA Approved Child Restraint Sy stem, this child would be unable to fly . We request that this child be allowed to occupy an FAA Approved Child Restraint (CARES, manufactured b y AmSafe, Inc.), even though she exceeds the manufacturer’s weight limits of 44 pounds. In this case, the safet y of this child is greatl y enhanced by

the extra support and security that the FAA Approved Restraint Sy stem will provide for her during the flight.