## “Petition for Exemption” in order to use a Crelling **- Model 27**  **(Houdini) Harness** I am writing to request an ex emption from 14 CFR §§ 121.311(b) and 135.128(a) to the extent required for Miss Mia Fong to be able to use a **Crelling -**  **Model 27 (Houdini) Harness**  as a restraint sy stem during all phases of flight while aboard an aircraft. In addition, if my petition is granted, I request that any U.S. air carrier operating under part 121 or part 135 while Mia is aboard its aircraft is granted an exemption from 14 CF R § 121.311(b) and (c) or 135.128(a) and (b), as appropriate, to the extent necessary to allow Mia to use a **Crelling****** **Model 27 (Houdini) Harness** as a restraint sy stem during all phases of flight while aboard an aircraft in operations under either 121 or 135

. We plan to fly on part 121 operators and also plan to take a helicopter tour under part 135. I believe the pertinent section s from 14 CFR from which we seek relief are Section 121.311 Seats, safet y belts, and shoulder harnesses and Section 135.128 Use of Safety Belts and child restraint s ys tems. My daughter is 10 years old, weighs 48 pounds and is 52 inches tall. My daughter’ s phy sical condition is as follows : Mia has cerebral palsy and is designated as a spastic quadriplegic. She does not have control o f her trunk and is unable to sit without supports. She also does not walk so she uses a wheelchair for mobility and that and her chairs at home are equipped with lateral supports and a chest harness. As a result of her ph ys ical condition, she needs the sup port and securit y provided by the **Crelling -**  **Model 27 (Houdini) Harness** . Furthermore, because of her disability , Mia is not able to communicate in any form

– verbal or sign language

– and is therefore incapable of literal compliance with the regulation. I am also submitting the following contact information: Mrs Janice Fong, 1 Fair View, Dalton in Furness, Cumbria LA15 8RZ, United Kingdom

– janice@cowlinginsurance.co.uk I understand that the regulation is written to create a high level of safety for each ind ividual 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 Mia be allowed to occup y a **Crelling -**  **Model 27 (Houdini) Harness ,**  wh ich will be securel y strapped around a passenger seat with two straps . Mia will then be secured with the front straps of the **Crelling -**  **Model 27 (Houdini) Harness** 

. Although Mia will use the **Crelling -**  **Model 27 (Houdini) Harness** to provide safet y, security and upper body support, the aircraft seat belt will also be used as the primary method of restraint. The **Crelling -**  **Model 27 (Houdini) Harness**  will not block any passenger’s view of the “Fasten Seat Belt” sign, “No Smoking” sign or any required exit sign. It will also be placed in such a manner that its location will not restrict access to, or use of, an y required emergency exit, or of the aisle in the passeng er compartment. The **Crelling**

**- Model 27 (Houdini) Harness**  is used to offer postural support, a certain degree of restraint, as well as assist ance in seating the occupant in an upright sitting position. The **Crelling -**  **Model 27 (Houdini) Harness** is designed for the use of perso ns with phy sical disabilities where extra support and positioning is required during travel. The harness consists of a full body harness which is fitted horizontally around the seat back with two horizontal fixing straps.T his proposal wi ll satisfy the intended purpose of the regulations b y ensuring that Mia is

securel y restrained by

the aircraft seat belt , but is also provided additional safet y, security and support by

the **Crelling**

**- Model 27 (Houdini) Harness**  internal restraint s. This ens ures a high level of safety

for Mia and a high level of safety for the other passengers and cre w on the airplane. In fact, in Mia ’s case, safet y is greatly enhanced b y the extra support and security that the **Crelling**

**- Model 27 (Houdini) Harness**  will provide during the entire flight. Enhancing safety

for Mia is in the public interest. In addition, the public interest is also served b y the fact that the use of the **Crelling -**  **Model 27 (Houdini) Harness** allows her to use commercial air transportation. Without the support and securit y of this specia lly designed restraint s ys tem, she would be unable to fl y 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 safety to that provided by the affected regulation. As stated previousl y, the **Crelling -**  **Model 27 (Houdini) Harness** will be securely strapped around the passenger seat with two straps. Iunderstand that with th e additional weight of Mia attached to the seatback, the seatback may move forward more quickly in an accident scenario . I also understand that this might cause a higher Head Injury Criteria ( HI C ) load for the person seated in the seat behind the pas senger using the **Crelling -**  **Model 27 (Houdini) Harness**  (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 **Crelling**

**- Model 27 (Houdini) Harness** 

. In order to achieve an equivalent level of safety as that provided by the affected regulation, I propose that the FAA establish a limitation i n a grant to this petition that Mia only sits in a passenger seat with no passenger seated behind her. Therefore, no unsafe condition would exis t for a passenger seated behind Mia whilst she i s using the **Crelling -**  **Model 27 (Houdini) Harness** **.** I also propose that all operations under the exemption be conducted with at least one of Mia’s pare nts or a caregiver accompanying her. In addition, Ipropose that Mia’s par ent or caregiver be required to carry

a copy of the exemption with them during the flight and to advise the operator about the contents of the exemption at least 48 hours before the date of each flight. I also request that the processing of this petition n ot be delayed for publication and comment in the Feder al Register. We want to travel on 19 July 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 necessary to put a summary in the Federal Register, I submit the following: This is a request for an exemption from 14 CFR § 121.311(b) and (c) , as well as § 135.128(a) and (b), to the extent required for a person to use a **Crelling -**  **Model 27 (Houdini) Harness** on an a ircraft. Due to phy sical challenges, without the support and security of the **Crelling**

  ** Model 27 (Houdini) Harness** , this person would be unable to fl y. In this case, the safet y of this person is greatly

enhanced by

the extra support and security that the **Cr elling**  **- Model 27**  **(Houdini) Harness** will provide for her during the flight