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

- approved child restraint s ys tem during use of that child restraint sy st em 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. My **daughter** is 13 ye ar’s old, weighs 95 pounds, and is approximately 58 inches tall. My **d aughter**  ’s ph ys ical condition is as follows : she has cerebral pals y and is unable to sit or stand on her own without 100% assistance . As a result of **her** phy sical condition, **she** needs the support and securit y 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**  **information: Parent: Sandra S Newby** 
**Address: 433 Sutters Mi ll Road, Saint Peters, MO 63376** 
**Email Address: bsnewby@gmail.com**  I understand that the regulation is written to create a high level of safety for each individual passenger b y ensuring that they are securel y restrai ned 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 being thrown into them during turbulent or emergency conditions. I propose that **Sierra Alexis Newby** be allowed to occup y 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 **Sierra Alexis Newby** and a high level of safety for the other passengers and crew on the airplane. In fact, in **Sierra Alexis Newby** ’s case, safety is greatl y enhanced b y the extra support and security that the FAA Approved Restraint Sy stem will provide during the entire flight. Enhancing safety

for **Sierra Alexis Newby** 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 System allows **her** to use commercial air transportation. Without the support and securit y of the FAA Approved Child Restraint Sy stem, **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 manufacturer for use by children 22

- 44 pounds. However, thecomponents of the CARES restraint are the same as those used in restraints for adults on aircraft

and would maintain thei r 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, 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 **Sierra Alexis Newby**  only sits in a passenger seat with no passenger seated behind her. Therefore, no unsafe condition would exist for a passenger seated behind **Sierra Alexis Newby** while **she** is using the CARES restraint. I also propose that all operations under this exemption be conducted with at least one of **Sierra Alexis Newby ’** 

**s** parents or a caregiver accompanying him or her. In addition, Ipropose that **Sierra Alexis Newby ’s**  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. We want to travel between September 2014 and 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 trave l 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 stem on an aircraf t, 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 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 by the extra support and security that the FAA Approved Re straint S ys tem will provide for **her** during the flight. Thank you for your consideration of this request. Sandra S Newby