September 3, 2014

Mr. and Mrs. Chris Guerrero

Parent of Ryan Guerrero

1133 South Whippoorwill Lane

Palatine, IL 60067

Dear Mr. and Mrs. Guerrero:

This letter is to inform you that we are unable to process your request for an extension of

Exemption No. 10655 from § 121.311(b) of Title 14, Code of Federal Regulations (14 CFR).

This letter explains why we can not process your request and what you should in the next 20 

days.

Why We Cannot Process Your Request

We entered your August 25, 2014 extension request into the Federal Docket Management 

System (FDMS) under docket number: FAA-2012-1179; but we are unable to process your 

request any further. The information you provided does not comply with the requirements of

§ 11.81 (copy enclosed). For the FAA to consider your request any further, please visit 

http://kidsflysafe.com/instructions/cares-for-special-needs-flyers/ and scroll down until you 

see template letter #2 “Request for an Extension of a Previously Granted Exemption to use 

CARES for Larger/Older Persons”. Cut and paste that information into a letter, fill in all of 

the necessary blanks and bold items and after you finish the letter go to the FDMS at 

www.regulations.gov and type your docket number (FAA-2012-1179) to upload your letter.

What You Should Do

If you want us to process your extension request any further, you must send the information 

described earlier to reach us within 20 days, in order for us to attempt to positively overlap the 

expiration of your active current Exemption. We will consider the docket on your request 

open for the 20 days noted to give you time to provide the required information.

If We Do Not Hear From You

If we do not hear from you within 20 days, we may close the docket without notifying you 

further.
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If We Do Hear From You

Once the FAA receives your complete request, processing the extension (technical analysis, a 

decision regarding a grant or denial of the extension and transmitting the grant or denial to 

you) typically takes about 45-60 days. When the FAA grants this type of extension, it is 

usually effective for five years.

However, in the event that you do not secure the extension on time and you wish to fly before 

you secure an extension, we wanted to give you some information and options so you can 

make informed choices regarding your travel. 

 

If a child exceeds the weight limit or the height limit for CARES, FAA regulations prohibit 

the use of CARES during taxi, takeoff and landing on U.S. aircraft. However, even if a child 

exceeds 44 pounds or 40 inches, he or she can use CARES anytime except for taxi, takeoff 

and landing (which means there is no regulation that prohibits use of CARES during cruise 

flight).

You may also wish to think about using an FAA Approved Child Restraint System (CRS) that 

can accommodate a larger child. Air carriers are required to allow the use of approved CRSs

if a child is within the approved weight and height requirements and a ticket has been 

purchased for the child. The FAA does not recommend any particular CRS; however, below 

we have provided some websites where you can find CRSs (approved for use in automobiles 

and aircraft) that can be used with children up to 150 pounds and five feet tall. The FAA 

considers anyone who has not reached their 18th birthday to be a child for the purpose of our 

regulations regarding CRSs; therefore, a child could use a CRS that accommodates their 

weight and height on any US airline until they turn 18 years of age.

Websites listing FAA Approved CRS that can accommodate a larger child--

(1) Columbia Medical--http://www.columbiamedical.com (Phone- 1-562-282-0244) --

Child TheraPedicâ Positioning Seat, CM2000-- Accommodates users up to 102 lbs and up 

to 5 feet tall- FAA Approved for use in aircraft.

(2) Carrie Tumbleforms--(Adaptive Mall- http://www.adaptivemall.com (Phone- 1-800-

371-2778) Elementary Carrie Seat 4641M--For children up to 60 lbs--FAA approved for use 

in aircraft.

(3) Brittax--http://www.britaxusa.com (Phone- 1-888-427-4829) (High Capacity 

Convertibles- Up to 65 lbs- Models: Marathon, Marathon CS, Decathlon, Boulevard, 

Boulevard CS, Advocate CS) (One model- Frontier 85 SICT accommodates users up to 85 

lbs. and 4 feet nine inches tall- http://www.britaxusa.com/car-seats/frontier-85-sict#)--All 

models are FAA approved for use on aircraft.
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(4) Diono- (http://us.diono.com/en/car-seats/radian-rxt) Radian RXT (Approx $250-280) 

(Phone- 253-268-2500 or 855-463-4666) accommodates users up to 80 lbs. and 4 feet nine 

inches tall - Is FAA approved for use in aircraft.

(5) Special Tomato- -Adaptive Mall- http://www.adaptivemall.com (Phone- 1-800-371-

2778) --Small MPS accommodates users up to 80 lbs. and 50 inches tall, Large Â MPS 

accommodates users up to 150 lbs. and 60 inches tall--Both models are FAA approved for use 

in aircraft.

I have also included an image of the labeling on a CRS that indicates that it is FAA approved 

for use in aircraft.

Sincerely,

/S/ Valentine Castaneda

Valentine Castaneda

Program Analyst, Rulemaking Division