### 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 **Tijs Djaiden Mattson** to be able to use an FAA Approved Child Restraint System even though he exceeds the height and 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 Tijs Mattson is aboard its aircraft is granted an exemption from 14 CFR § 121.31 1(b)(2)(iii)(B) to the extent necessary to allow Tijs Mattson to exceed the specified height and weight limit for an FAA

- approved child restraint system during use of that child restraint system aboard an aircraft.

I believe the pertinent section from 14 C FR part 121 from which we seek relief is Section 121.311 Seats, safety belts, and shoulder harnesses.

My son is 5 year’s old, weighs 44 pounds, and is 45 inches tall. My son ’s physical condition is as follows: cerebral palsy (spastic quadriplegia) where he has limited trunk control and difficulty using his arms and legs. As a result of his physical condition, he needs the support and security provided by an FAA Approved Child Restraint, but because of his length is incapable of compliance with the regulatio n. I am also submitting the following contact information: **An na Lamers & Brian Mattson, Nieuw**  **Voordorpstraat 7, 2251SZ Voorschoten, Netherlands, amattson@ash.nl** 

I understand that the regulation is written to create a high level of safety for each individu al passenger by ensuring that they are securely 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 by being thrown into them during turbulent or emergency conditions.

I propose that Tijs Djaiden Mattson be allowed to occupy an FAA Approved Child Restraint (CARES, manufactured by AmSafe, Inc.), even though he exceeds the manufacturer’s length and weight limits. This ensures a high level of safety for Tijs and a high level of safety for the other passengers and crew on the airplane. In fact, in Tijs’ case, safety is greatly enhanced by the extra support and security that the FAA Approved Restraint System will provide during the entire flight.Enhancing safety for Tijs 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 him to use commercial air transportation. W ithout the support and security of the FAA Appro ved Child Restraint System, he 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. Th e 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 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 t he 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 Tijs Mattson only sits in a passenger seat w ith no passenger seated behind him. Therefore, no unsafe condition would exist for a passenger seated behind Tijs while he is using the CARES restraint. I also propose that all operations under this exemption be conducted with at least one of Tijs’ parents or a caregiver accompanying him. In addition, I propose that Tijs’ 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. W e want to travel **June 24** 

**- Jul**  **y 25,2014**  . 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 thefollowing:

This i s 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 and height limits for the CRS. Due to physical challenges, without t he support and security of this FAA Approved Child Restraint System, this child would be unable to fly. Werequest that this child be allowed to occupy an FAA Approved Child Restraint (CARES, manufactured by AmSafe, Inc.), even though he exceeds the manufa cturer’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 him during the flight.

Thank you for your consideration of this reques t.

Sincerely,

Anna Lamers & Brian Mattson

(parents of Tijs Djaiden Mattson)