July 4, 2015

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

I am writing to request an exemption from 14 CFR section121.311(b) Seats, Safety Belts, and Shoulder Harnesses to

the extent required for Maria Rose Humphrey (birthdate 06/23/2004) to use an FAA-Approved Child Restraint

System (CARES, manufactured by AmSafe, Inc.) even though she exceeds the weight limits. In addition, I request

that any air carrier operating under part 121, while Maria Humphrey is aboard its aircraft, be granted an exemption

from 14 CFR § 121.311(b)(2)(iii)(B) to the extent necessary to allow her to exceed the specified weight limit for an

FAA-Approved Child Restraint System during use of that child restraint system aboard an aircraft.

The CARES 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 integrity if used by someone who weighed several hundred pounds.

Our daughter, Maria Humphrey, is 11 years old, weighs 78 pounds, and is 54 inches tall. Her physical condition is as

follows: she has been diagnosed with cerebral palsy; she is unable to stand or walk independently; and although she

can sit up straight due to a complete spinal fusion, she does better with some support.

As a result of her physical condition, she needs the support and security provided by an FAA-Approved Child

Restraint. Therefore, I request an exemption for Maria Humphrey to use the FAA-Approved CARES system, even

though she exceeds the manufacturer’s weight limits. Maria’s safety will be enhanced by the extra support and

security the CRS provides during the entire flight, which in turn is safer for the other passengers and crew.

I understand that the limit of 44 pounds was established because, with the additional weight of the child attached to

the seat back, the seat back would move forward more quickly in an accident, which might cause a higher Head

Injury Criteria (HIC) load for the person seated behind the passenger using the CARES restraint (because the seat

back 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 person using the CARES restraint). 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

Maria Humphrey only sits in a seat with no passenger seated behind her. Therefore, no unsafe condition would exist

for a passenger seated behind Maria while she is using the CARES restraint. I also propose that all operations under

this exemption be conducted with at least one of Maria’s parents accompanying her, and that Maria’s parent(s) 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 in November 2015. If you 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 physical

challenges, without the support and security of this FAA Approved Child Restraint System, this child would be

unable to fly. 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 safety of this child is greatly enhanced by the extra support and security that the FAA Approved Restraint

System will provide for her during the flight.

Thank you for your consideration of this request.

Sincerely,

Maria’s parents

Catherine Humphrey and Emmanouil Kritsotakis

3609 W Mariposa Grande

Glendale, AZ 85310
July 4, 2015

623-322-4440 / 2cathy4maria@gmail.com