**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 Jeffrey Piazza

- Bolton to be able to use an FAA Approved Child Restraint Sy stem even though he 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 Jeffrey Piazza

- Bolton is aboard its aircraft is granted an exemption from 14 CFR § 121.311(b)(2)(iii)(B) to the extent necessary to allow Jeffrey

Piazza

- Bolton to exceed the specified weight limit for an FAA

- approved child restraint s ys tem during use of that child restraint sy stem aboard an aircraft. I believe the pertinent section from 14 CFR p art 121 from which we seek relief is Section 121.311 Seats, safet y belts, and shoulder harnesses. My son is 6 year s old, weighs 45 pounds, and is 46 inches tall. My son ’s phy sical condition is as follows : he has developmental delay s, ADHD with elopement, and multiple other behavior and developmental disorders . As a result of his ph ys ical condition, he needs the support and securit y provided b y an FAA Approved C hild Restraint, but because of his weight is incapable of compliance with the regulation. **I am al so submitting the following contact information:**  **Jennifer Piazza ,**  **275 Woodhaven Drive, Vacaville CA, 95687 and**  **jenniferLpiazza@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 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 b y being thrown into them during turbulent or emergency conditions. I propo se that Jeffrey

Piazza

- Bolton be allowed to occup y an FAA Approved Child Restraint (CARES, manufactured by AmSafe, Inc.), even though he exceeds the manufacturer’s weight limits. This ensures a high level of safety for Jeffrey Piazza

- Bolton and a high level of safet y for the other passengers and cre w on the airplane. In fact, in Jeffrey Piazza

- Bolton ’s case, safet y is greatl y enhanced b y the extra support and security that the FAA Approved Restraint Sy stem will provide during the entire flight. Enhancin g safety

for Jeffrey

Piazza

- Bolton 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 him to use commercial air transportation. Without the support and secu rit y of the FAA Approved Child Restraint Sy stem, 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 safet y to that provided by the af fected regulation. The 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 integri ty 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 thepassenger 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 p erson 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 i n a grant to this petition that Je ffrey Piazza

- Bolton o nly sits in a passenger seat with no passenger seated behind her. Therefore, no unsafe condition would exist for a passenger seated behind Jeffrey Piazza

- Bolton while he is using the CARES restraint. I also propose that all operations under this exemption be conducted with at least one of Jeffrey Piazza

- Bolton’s parents or a caregiver accompanying him. In addition, Ipropose that Jeffrey Piazza

- Bolton parent or caregiver must carry a copy of this exemption. I also request that the processing of this petitio n not be delay ed for publication and comment in the Federal Register. We want t o travel June 19

- 27, 2015 . 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 neces sary

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 th e 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 he 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 securit y that the FAA Approved Res traint S ys tem will provide for him during the flight. Thank you for your consideration of this request. Jennifer Piazza