**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 Tei

Anna Cirtwell to be able to use an FAA Approved Child Restraint System even though she exceeds the weight limits for the CRS. In addition, if my petition is granted, I request that any air carrier or commercial operator operating under part 121 while Miss Cirtwell is aboard its aircraft is granted an exemption from 14 CFR § 121.311(b)(2)(iii )(B) to the ext ent necessary to allow Miss Cirtwell 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 whic h we seek relief is Section 121.311 Seats, safety belts, and shoulder harnesses. Tei

-Anna Cirtwell is 12 year’s old, weighs 88 pounds, and is 52 inches tall. Her physical condition is as follows : Cerebral Palsy ( Spastic hypertonic quadriplegia ). Global D evelopmental Deficits, Microcephaly, Partial Complex Seizure activity

. She is G

-Tub fed, wheelchair dependent and non

-verbal As a result of her physical 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 am also submitting the following contact information: **Rhonda Thacker, Foster**  **Mother 33183 Dalke Ave**  **Mission, BC, V2V 0A3 tamnibroc@shaw.ca**  **Katie Spencer -** **Lim, Children’s Wish Foundation, Wish Coordinator**  **450 –**  **319 West Pender St Vancouver, BC, V6B 1T3**  **Katie.spencer**

**- lim@childrenswish.ca**  I u nderstand 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 regulation also ensures that an individual does not cause harm to other passengers on the a irplane by being thrown into them during turbulent or emergency conditions. I p ropose that Tei

-Anna Cirtwell be allowed to occupy an FAA Approved Child Restraint (CARES, manufactured by AmSafe, Inc.), even though she exceeds the manufacturer’s weight limit s. This ensures a high level of safety for Miss. Cirtwell and a high level of safety for the other passengers and cre w on the airplane. In fact, in Miss Cirtwell ’s case, safety is greatly enhanced by the extra support and security that the FAA Approved Res traint System will provide during the entire flight. Enhancing safety for Tei

- is in the public 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. Without the support and security of the FAA Approved Child Restraint System, 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 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 fo r adults on aircraft and would maintain their integrity if used by 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 wou ld 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 t here 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 safety as that provided by the affected regulation, I propose that the FAA establish a limitation in a grant to this petition that Tei

- Anna Cirtwell only sits in a passenger seat with no passenger seated behind her. Therefore, no unsafe condition would exist for a passenger seated behind Miss. Cirtwell while she is using the CARES restraint. I also propos e that all operations under this exemption be conducted with at least one of Tei

Anna Cirtwell’s parents or a caregiver accompanying him or her. In addition, I propose that Miss Cirtwell’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 August 2014. If you take the time to put this in the Federal Register, it will delay the process and we may not be abl e 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 System on an aircraft, even though the child exceeds the weight limits for the CRS. Due to physical challenges, without the support and security of this FAA Approved Child Restraint System, this child would be unable to fly. 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 limits of 44 pounds. In this case, the safety of this child is greatly enhanced by the extra support and security that the FAA A pproved Restraint System will provide for her during the flight. Thank you for your consideration of this request. Katie Spencer

- Lim, Wish Coordinator Rhonda Thacker, Foster Mother of Tei

-Anna Cirtwell