**Request to Use CARES Child Restraint System for Larger/Older Persons**

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

- approved child restraint system 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 5 year’s old, weighs 45 pounds, and is 43 inches tall. My **daughter** ’s ph ys ical condition is as follows : multiple disabilities including ADHD, autism, difficulty w alking & sitting for extended periods of time . As a result of her phy sical condition, 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 submi tting the following contact**  **information: Jennifer Tatoris**  **, 159 Hillcrest Avenue, Phoenixville, PA 19460**  **and jld1997psualum@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 securel y restrained in their seats during all phases of flight. The regulation 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 Cad y Tatoris be allowed to occup y an FAA Approved Child Restraint (CARES, manufactured by

AmSafe, Inc.), even though she exceeds the manufacturer’s weight limits. This ensures a high level of safety for Cad y Tatoris and a high level of safet y for the o ther passengers and crew on the airplane. In fact, in Cady Tatoris ’s case, safet y is greatly enhanced b y the extra support and securit y that the FAA Approved Restraint Sy stem will provide during the entire flight.

Enhancing safety

for Cady Tatoris is in the public interest. In addition, the public interest is also served b y the fact that the use of this FAA Approved Child Restraint Sy stem allows ( **her/him** ) to use commercial air transportation. Without the support and security of the FAA Approved Chi ld Restraint Sy stem, she would be unable to fl y commerciall y.

I also believe that, with certain limitations 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 CARE S restraint has been certified by the manufacturer for use by children 22

- 44 pounds. However, the components of the CARES restraint are the same as those used in restraints for adults on aircraft and would maintain their integrit y if used b y someone who w eighed several hundred pounds.

I believe that the limit of 44 pounds was established because, with the additional weight of the child attached to the seatback, the seatback would move forward more quickly in an accidentscenario and this might cause a high er HIC load for the person seated in the seat behind the

passenger using the CARES restraint (because the seatback moving forward more quickly would mean that it would not be there to attenuate the energy from the impact of the person seated behind the per son using the CARES restraint).

In order to achieve an equivalent level of safety as that provided by the affected regulation, I propose that the FAA establish a limitation in a grant to this petition that Cady Tatoris only sits in a passenger seat with no passenger seated behind her. Therefore, no unsafe condition would exist for a passenger seated behind Cad y Tatoris while she is using the CARES restraint. I also propose that all operations under this exemption be conducted with at least one of Cady ’s par ents or a caregiver accompanying him or her. In addition, Ipropose that Cady’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 on September 23 and 27, 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 Sy stem 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 fl y. We request that this child be allowed to occupy an FAA Approved Child Restraint (CARES, manufactured by 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 Res traint S ys tem will provide for her during the flight.

Thank you for your consideration of this request.