**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 Kristina Onaindia to be able to use an FAA Approved Chil d 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 Kristina Onaindia is aboard its aircraft is granted an exemption from 14 CFR § 121.311(b)(2 )(iii)(B) to the extent necessary to allow Kristina Onaindia 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 section from 14 CFR part 121 from which we seek relief is Section 121.311 Seats, safet y belts, and shoulder harnesses. My Kristina Onaindia is _ 18 _ y ear’s old, weighs _62_ pounds, and is _54

_inches tall. My **daughter’s** p hy sical condition is as follows, unable to sit independently ( is p hy sically and mentally disabled). As a result of her ph ys ical condition, she needs the support and securit y 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 fol lowing contact information:**  **Shelly Onaindia. 1004 High Point Loop, Longwood, FL 32750**
**- sdonaindia@gmail.com**  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 securel y res trained 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 Kristina Onaindia 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 safety for Kristina and a high level of safety for the other passengers and c re w on the airplane. In fact, in Kristina ’s case, safet y is greatly enhanced b y the extra support and security that the FAA Approved Restraint Sy stem will provide during the entire flight. Enhancing safety

for Kristina Onaindia 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 Kristina to use commercial air transportation. Without the support and security of the FAA Ap proved Child Restraint Sy stem, Kristina 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 cer

tified 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 p ounds.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 per son 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 res traint). 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 Kristina only sits in a passenger seat with no passenger seated behind he r. Therefore, no unsafe condition would exist for a passenger seated behind Kristina while she is using the CARES restraint. Ialso propose that all operations under this exemption be conducted with at least one of Kristina’s parents or a caregiver accompanying him or he r. In addition, I propose that Kristina’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 8/8/15

– 8/14/15 . I f 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 Sy stem 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 allowed to occupy an FAA Approved Child Restraint (CARES, manufactured by AmSafe, Inc.), even though she exceeds the manufacturer’s weight limit s 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 FAA Approved Res traint S ys tem will provide for Kristina Onaindia during the flight. Thank y ou for y our consideration of this request.