### Request to Use CA **RES for Larger/Older Persons**

I am writing to request an exemption from 14 CFR § 121.311(b) to the extent required for **Kierra Grace AubriAnne Thompson**  to be able to use an FAA Appro ved Child Restraint System even though **she** exceeds the weight limits for the CRS. In addition, if m y petition is granted, I request that any air carrier or commercial operator operating under part 121 while **Kierra Grace AubriAnne Thompson** is aboard its aircraft is granted an exemption from 14 CFR § 121.311(b)( 2)(iii)(B) to the extent necessary to allow **Kierra Grace AubriAnne Thompson** to exceed the specified 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 CFR part 121 from which we seek relief is Section 121.311 Seats, safety belts, and shoulder harnesses.

My **daughter's** me ntal condition is severe global developmental delay, mixed language disorder, and severe autism to where she functions, understands, and acts as a 1 yr old child. **Kierra Grace AubriAnne Thompson**  is a 7.5 yr old girl who weighs approx 50 lbs. As a result of **her mental** 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 understand that the regulation is written to create a high level of safety for each individual passenger by ensuring that they are securely restrained in their seats during all phases of flight. The regulat ion 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 **Kierra Grace AubriAnne Thompson** be allowed to occupy an FAA Approved Child Restra int (CARES, manufactured by AmSafe Corporation), even though **she** exceeds the manufacturer’s weight limits. This ensures a high level of safety for **Kierra Grace AubriAnne Thompson** and a high level of safety for the other passengers and crew on the airplane. In fact, in **Kierra Grace AubriAnne Thompson**  **'s** 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 **Kierra Grace AubriAnne Thompson** is in the p ublic interest. In addition, the public interest is also served by the fact that the use of this FAA Approved Child Restraint System allows **her** to use commercial air transportation. W ithout the support and security of the FAA Approved Child Restraint Syste m, **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 be en 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 hun dred 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 mi ght cause a higher HIC load for th e 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 CARE S 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 **Kierra Grace AubriAnne Thompson** only sits in a passenger seat with no passenger seated behind her. Therefore, no unsafe condition would exist for a passenger seated behind **Kierra Grace AubriAnne Thompson** while **she** is using the CARES restraint. I also propose that all operations under this exemption be conducted with at least one of **Kierra Grace AubriAnne Thompson**  parents or a caregiver accompanying her. In addition, I propose that **Kierra Grace AubriAnne Thompson** parent or caregiver must carry a copy of this exemption.

I also request that the processing of this petition n ot be delayed for publication and comment in the Federal Register. W e want to travel For Christmas Holiday . 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 nec essary 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 me ntal challenges, without the support and security of this FAA Approved Child Restraint System, this child would be unable to fly. W e request that this child be allowed to occupy an FAA Approved Child Restraint (CARES , manufactured by AMSAFE INC.), even though **she** exceeds the
ma nufacturer’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 **her** during the flight.