I am writing to request an exemption from 14 CFR § 121.311(b) to the extent required for Sophie

Kreher 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 Sophie Kreher is aboard its aircraft is granted an exemption from 14 CFR § 121.311(b)(2)(iii)(B) to the extent necessary to allow Sophie Kreher to exceed the specified weight limit for an FAA

- approved child restraint sy stem during use of that child restraint sy stem 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. The wish child is10 y ear’s old, weighs 58 pounds, and is52 inches tall. The wish child’s phy sical condition is as follows, Sophie has Rett Sy ndrome, Epilepsy

and Scoliosis. Sophie cannot support herself on her own and needs the assistance of a harness dev ice. As a result of her phy sical condition, she needs the support and security 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:**  **Amy & Andrew Kreher**

**- Legal Guardians**  **240 Bristol Drive Troy, IL 60094 akreher@att.net**  I understand that the regulation is written to create a high level of safet y for each individual passenger b y ensuring that they are securel y restrained in their seats d uring 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 Sophie Kreher be allowed to occupy an FAA Approved Child Restraint (CARES, manufactured b y AmSafe, Inc.), even though she exceeds the manufacturer’s weight limits. This ensures a high level of safety for Sophie Kreher and a high level of safet y for the other passengers and crew on the airplane. In fact, in Sophie Kreher’s case, safety is greatly enhanced by the extra support and securit y that the FAA Approved Restraint System will provide during the entire flight. Enhancing safety

for Sophie Kreher 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 to use commercial air transportation. Without the support and security of the FAA Approved Child Restraint Sy stem, she would be unable to fl y commercia lly

.I also believe that, with certain limitations established by the FAA in a grant to this petition, there can be an equivalent level of safet y to that provided by the affected regulation. The CARES restraint has been certified by the manufacturer for us e 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 weighed several hundred pounds. I believe that the limit o f 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 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 person using the CARES restraint). In order to achieve an equivalent level of safet y as that provided by the affected regulation, I propose that the FAA establish a limitation in a grant to this petition that Sophie Kreher onl y sits in a passenger seat with no passenger seated behind her. Therefore, no unsafe condi tion would exist for a passenger seated behind Sophie Kreher while she is using the CARES restraint. I also propose that all operations under this exemption be conducted with at least one of Sophie Kreher’s parents or a caregiver accompan yi ng him or her. In addition, Ipropose that Sophie Kreher’s parent or caregiver must carry a cop y of this exemption.
I also request that the processing of this petition not be delay ed for publication and comment in the Federal Register. We want to travel October 19 th

- 25 th , 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 exe mption 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 F AA 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 securit y that the FAA Approved Restraint S ys tem will provide for her during the flight. Thank y ou for y our consideration of this request.