**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 ERIN DONALDSON to be able to use an FAA Approved Child Restraint System even though she exceeds the weight limits for the CRS. In addition, if my petition is granted, Irequest that any air carrier or commercial operator operating under part 121 while ERIN DONALDSON is aboard its aircraft is granted an exemption from 14 CFR § 121.311(b)(2)(iii)(B) to the extent necessary to allow ERIN DONALDSON to exceed the specified weight limit for an FAA

- approved child restraint s ys tem during use of that child restraint system aboard an aircraft.
I believe the pertinent section from 14 CFR part 121 from which we s eek relief is Section 121.311 Seats, safety belts, and shoulder harnesses. My daughter is 8 ye ars old, weighs 77 pounds, and is 55 inches tall. My daughter’s physical condition is as follows : she is unable to sit independentl y and without assistance and cannot walk due to her medical diagnosis of Cerebral Palsy because she has very

low muscle tone. As a result of her physical condition, she needs the support and security p rovided by

an FAA Approved Child Restraint, but because of her weight is incapa ble of compliance with the regulation. **I am also submitting the following contact information:** Parents: Marija and James Donaldson Mailing Address: 29 Aspen Summit Green SW

Calgary, AB T3H 0T6 Canada Parent email address: mdonalds@shaw.ca
I understand that the regulation is written to create a high level of safety f or each individual passenger by

ensuring that they

are securel y restrained in their seats durin g 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 ERI

N DONALDSON be allowed to occupy 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 f or ERIN DONALDSON and a high level of safety for the other passengers and crew on the airplane. Inf act, in ERIN DONALDSON’s case, safety i s greatl y enhanced by

the extra support and security that the FAA Approved Restraint System will provide during the entire flight. Enhancing safety for ERI N DONALDSON is in the public interest. In addition, the public interest is also served by the fact that the use of this FAA Approved Child Restraint System allows her to use commercial air transportation. Without the support and security o f the FAA Approved Child Restraint System, she would be unable to fly commercially

.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 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 b y someone who weighed 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 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 the seatback moving forward more quickly would mean that it would not be there to attenuate the energy f rom the impact of the person seated behind the person using the CARES restraint).
Inorder to achi eve 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 ERI N DONALDSON only sits in a passenger seat with no passenger seated behind her. Therefore, no un safe condition would exist for a passenger seated behind ERI N DONALDSON while she is using the CARES restraint. I also propose that all operations under this exemption be conducted with at least one of ERI N DONALDSON’s parents or a caregiver accompanying her. In addition, I propose that ERI N DONALDSON’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 from April 8 , 2015 to April 14, 2015. 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 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, In c.), even though she exceeds the manufacturer’s wei ght 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 S ys tem will provide for her during the flight. Thank you for your consideration of this request. Sincerel y, Marija Donaldson (parent of Erin Donaldson)