- Template #1 BEGIN

**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 Naaman Prince to be able to use an FAA Approved Chil d Restraint Sy stem even though he exceeds the weight limits for the CRS. In addition, if my petition is granted, Irequest that an y air carrier or commercial operator operating under part 121 while Naaman Prince is aboard its aircraft is granted an exempti on from 14 CFR § 121.311(b)(2)(iii)(B) to the extent necessary to allow Naaman Prince to exceed the specified weight limit for an FAA

- approved child restraint sy stem during use of that child restraint s ys tem aboard an aircraft. I believe the pertinent sect ion from 14 CFR part 121 from which we seek relief is Section 121.311 Seats, safet y belts, and shoulder harnesses. My son is 12 y ear’s old, weighs 65 pounds, and is 47 inches tall. My **son** ’s ph ys ical condition is as follows he has Cerebral Palsy since birth with very

poor upper body

control and is unable to sit up in a seat without aid or support. As a result of his phy sical condition, he needs the support and securit y provided b y an FAA Approved C hild Restraint, but because of his weight is incapable of compliance with the regulation. **I am also submitting the following contact information:**  **Parents: Donald Bryan Prince & Erin K. Prince ,**  **3801 Stearns Hill Rd. Waltham, MA. 02451and haveyarnwilltravel@yahoo.com.**  I understand that the regulation is written to cr eate a high level of safet y 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 be ing thrown into them during turbulent or emergency conditions. I propose that Naaman Prince be allowed to occupy an FAA Approved Child Restraint (CARES, manufactured by

AmSafe, Inc.), even though he exceeds the manufacturer’s weight limits. This ensures a high level of safety for Naaman Prince and a high level of safet y for the other passengers and cre w on the airplane. In fact, in Naaman Prince ’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 Naaman Prince 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 him to use commercial air transportation. Without the support and security of the FAA Ap proved Child Restraint Sy stem, he 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, th ere 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 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 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, th e 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 Naaman Prince onl y sits in a passenger seat with no passenger seated behind her. Therefore, no unsafe condition would exist for a passenger seated behind Naaman while he is using the CARES restraint. Ialso propo se that all operations under this exemption be conducted with at least one of Naaman Prince’s parents or a c aregiver accompanying him. In addition, Ipropose that Naaman Prince’s parent or 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 Feder al Register. We want to travel December 18, 2014 to January 3, 2015 . If you take the time to put this in the Federal Register, it will delay the process and we may

not b e 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 ste m 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 allowe d to occupy an FAA Approved Child Restraint (CARES, manufactured by AmSa fe, Inc.), even though he 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 F AA Approved Res traint S ys tem will provide for him during the flight. Thank y ou for y our consideration of this request

Erin K. Prince