### 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 Helen Guzman 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 my petition is granted, I request that any air carrier or commercial operator operating under part 121 while Helen Guzman is aboard its aircraft is granted an exemption from 14 CFR § 121.311(b)(2)(iii) (B) to the extent necessary

to allow Helen Guzman 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, safety

belts, and shoulder harnesses. My mother is 59 y ear’s old, weighs 120 pounds, and is 62 inches tall. My mother ’s phy sical condition is as follows a quadriplegic and requires a motorized wheelchair and a ventilator . As a result of her phy sical condition, she needs the support and security provided by

an FAA Approved Child Restraint, but because of her weight is incapable of compliance with the regulation. **I am also submitting the following contact informa**  **tion: Susanna Guzman**  **, 17101 La Cantera Pkwy**  **Apt 7403, San Antonio, TX 78256**  **and pinkpearl2888@yahoo.com**  I understand that the regulation is written to create a high level of safety for each individual passenger by

ensuring that they

are securely

restraine d 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 by being thrown into them during turbulent or

emergenc y c onditions. I propose that Helen Guzman 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 for Helen Guzman and a high level of safety for the other passengers and crew on the airplane. In fact, in Helen Guzman ’s case, safety is greatly enhanced by

the extra support and security that the FAA Approved Restraint Sy stem will provide during the entire flight. Enhancing safety

for Helen Guzman is in the public interes t. In addition, the public interest is also served by

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 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 by 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 HIC load for the person seat ed in the seat behind the passenger using the CARES restraint (because the seatback movingforward 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 safety as that provided by

the affected regulation, I propose that the FAA establish a limitation in a grant to this petition that Helen Guzman only

sits in a passenger seat with no passenger seated behind her. T herefore, no unsafe condition would exist for a passenger seated behind Helen Guzman while she is using the CARES restraint. I also propose that all operations under this exemption be conducted with at least one of Helen Guzman caregiver accompanying him

o r her. In addition, I propose that Helen Guzman’s caregiver must carry a copy 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 November 14

- November 18 . 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 exempt ion 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 security

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 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 Sy stem will provide for her during the flight. Thank you for your consideration of this request.