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

**Angelica Pelissier** 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 grant ed, I request that an y air carrier or commercial operator operating under part 121 while Angelica Pelissier is aboard its aircraft is granted an exemption from 14 CFR § 121.311(b)(2)(iii)(B) to the extent necessary to allow Angelica Pelissier to exceed the specified weight limit for an FAA

- approved child restraint s ys tem during use of that child restraint s ys tem 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 shou lder harnesses.

My ( **daughter**) is ___ 18 __ y ear’s old, weighs __ 96 ___ pounds, and is ___ 51

___ inches tall. My **daughter** ’s ph ys ical condition is as follows : C2 spinal cord complete transaction, quadriplegic, v entilator dependent with tracheostom y . As a result of **her** phy sical condition, **she** needs the support and security provided b y an FAA Approved C hild Restraint, but because of **her** weight is incapable of compliance with the regulation. **I am also submitting the following contact information: Renee Pelissier**  **, 8613 192**  **nd Dr**  **SE , Snohomish Wa. 98290, and email** 

**- millgirl49@verizon.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 securely restrained in their seats during all pha ses 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 Angelica Pelissier 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 safet y for ( **Angelica Pelissier**) and a high level of safet y for the other passengers and crew on the airplane. In fact, in ( **Angelica** )’s case, safet y is greatly enhanced by the extra support and securit y that the FAA Approved Restraint Sy stem will provide during the entire flight.

Enhancing safety

for ( **Angelica Pelissier**) is in the public interest. In addition, the p ublic 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 securit y of the FAA Approved Child Restraint System, (**she** ) would be unable to fly commerciall y.

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 manufactur er 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 th e limit of 44 pounds was established because, with the additional weight

of the child attached to the seatback, the seatback would move forward more quickl y in an accident scenario and this might cause a higher HI C load for the person seated in the seat be hind the passenger using the CARES restraint (because the seatback moving forward more quickl y 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 achi eve 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 ( **Angelica Pelissier**) only sits in a passenger seat with no passenger seated behind her. Therefore, no unsafe condition would exist for a passenger seated behind ( **Angelica Pelissier** ) while ( **she** ) is using the CARES restraint. Ialso propose that all operations under this exemption be conducted with at least one of ( **Angelica ’s**  ) parents or a caregiver acco mpan yi ng him or her. In addition, I propose that ( **Angelica ’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 Federal Register. We want to travel ( **September or October 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 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 phy sical challenges, without the support and securit y 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 b y 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 b y the extra support and security that the FAA Approved Restraint Sy stem will provide for ( **her** ) during the flight.

Thank y ou for y our consideration of this request.