Request to U se CARES Child Restraint Sys tem for L a rg e r/Older Pe rsons I am writing to request an exemption from 1 4 CFR 

### § 12 1.3 11(b) to the extent requ i red for Jared Herana to be able to use an FAA Approv ed Child Restraint System even though he exceeds the weight limits for the CRS. I n addition, if my petition is granted, I request that any air carrier or commercial operator operating under part 121 whi le Jared H erana is aboard its aircraft is g ranted an exemptio n from 14 CFR 

### § 121.311 (b)(2)(iii)( B ) to the extent necess ary to all ow Jared Herana to exceed the specified weight limit for an FAA-approved ch ild restraint system during use of that ch i ld restraint system aboard an aircraft.
I beli eve the pertinent section from 14 CFR part 121 from wh ich we seek re l ief is Section 121 .311 Seats , safety belts , and shou lder harn esses. My son is 14 year's old, weigh s 78 pounds, and is 62 inches tall. My son 's physical conditio n is as foll ows: Spastic Quadriplegic Cerbral Pal sy and Levoscoliosis , . As a result of his physica l condition , he needs the support and security provided by an FAA Approved Ch i ld Restraint , but because of his weight is incapable of compl ia nce with the regulation. I am al so submitting the fo ll owing co ntact information: Yvette T

akash im a, 134 Rosemary Place , Chula Vista, CA 91910 and yvettemortega@g m ail
. com .
I understand that th e regulati on is written to create a high leve l of safety fo r each i nd ividual passenger by ensuring that they are securel y restrained i n their seats during all phases of flight. The regul ation also en s ures that an ind ivid ual does not cause harm to othe r passengers on the airplan e by being thrown into them du ring turbulent or emergency condition s.
I propose that J ared Herana be all owed to occupy an FAA Approved Chi ld Restraint (CA RES , manu factured by AmSafe, In c.), even though he exceeds the manufacturer's weight limits. Thi s ensures a high level of safety for Jared Herana an d a h ig h level of safety for the other passengers and crew on the airplane. In fact , in J ared 's case , safety is greatl y enhanced by the extra support and security that the FAA Approved Restraint System w ill provide during th e enti re flig ht. Enhancing safety for Jared Heran a is in t he public interest. In additio n , th e public interest is also served by the fact that th e use of this FAA Approved Chi ld Restraint Syste m all ows him to use commerc ial airtransportation. Without the support and security of the FAA Approved Child Restraint System, 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 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 for 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 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 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 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 Jared Herana only sits in a passenger seat with no passenger seated behind her. Therefore, no unsafe condition would exist for a passenger seated behind Jared while he is using the CARES restraint. I also propose that all operations under this exemption be conducted with at least one of Jared Herana's parents or a caregiver accompanying him. In addition, I propose that Jared Herana'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 20th, 2016. 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 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 RestraintSystem , this child would be unabl e to fly. We re quest that th is chil d be allowed to occupy an FAA App roved Chi ld Restra int (CARES , manufactured by AmSafe , Inc.), even though he exceeds th e manufacturer' s weight lim its of 44 pounds. In this case , the safety of this child is greatly enhanced by the extra support and security that the FAA Approved Restraint System wi ll provide for him du ring the flight.
Thank you for you r consideration of this request.

Respectfully ,

Yvette Takashima