I am writing to request an exemption from 14 CFR § 121.31 1(b) to the extent required for Erica Bennett to be

able to use an FAA

A pproved Child Restraint Sy stem even though she exceeds the weight limits for the CRS. In addition, if m y petition is granted, I request that any air carrier or commercial operator operating under part 121 while Erica Bennett is aboard its aircraft is granted an exemption from 14 CFR § 121.31 1(b)(2)(iii)(B) to the extent necessary to allow Erica Bennett to exceed the specified weig ht limit for an F AA

- 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 which we seek relief is Section 121.31 1 Seats, safety belts, and shoulder harnesses.

My daughter is 7 ye ar ’s old, weighs 38 pounds, and is 42 inches tall. My daughter ’s physical condition is as follows: Dandy

Walker V

ariant Syndrome, Cerebral Palsy, Failure to Thrive, Low To ne, Scoliosis, Periventricular Leukomalacia, and Tr acheostomy

. As a result of her phy sical condition, she needs the support and security provided by an FAA

A pproved Child Restraint, but because of her height is incapable of compliance with the regulation. **I am also submitting the following contact information: Donna Cr**  **owder ,**  **604 Leonard Rd., Lagrange, Ga. 30241,**  **dcrowder22@hotmail.com** I understand 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 airplane by being thrown into them during turbulent or emergency conditions.

I propose that Erica Bennett be allowed to occupy an FAA A pproved Child Rest raint (CARES, manufactured by Am Safe, Inc.), even though she exceeds the manufacturer ’s weight limits. This ensures a high level of safety for Erica Bennett and a high level of safety for the other passengers and crew on the airplane. In fact, in Erica Ben nett ’s case, safety is greatly enhanced by the extra support and security that the FAA A pproved Restraint Sy stem will provide during the entire flight. Enhancing safety for Erica Bennett is in the public interest. In addition, the public interest is also s erved by the fact that the use of this FAA A pproved Child Restraint System allows her to use commercial air transportation. Wi thout the support and security of the FAA A pproved 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

- 4 4 pounds. However , the components of the CARES restraint are the
sam e 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 est ablished 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 im pact of the person seated behind the person using the CARES restraint).In order to achieve an equivalent level of s afety as that provided by the affected regulation, I propose that the

FAA establish a limitation in a grant to this petition that Erica Bennett only sits in a passenger seat with no passenger seated behind her . T herefore, no unsafe condition would exist fo r a passenger seated behind Erica Bennett while she is using the CARES restraint. I also propose that all operations under this exemption be conducted with at least one of Erica Bennett ’s par ents or a caregiver accompanying him or her . In addition, I propo se that Erica Bennett ’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 . W e want to travel on May 28, 2015and return travel on J une 1, 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 F AR 121.31 1 (b) to the extent required for a child to use an F AA 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 A pproved Child Restraint System, this child would be unable to fly

. We request that this child be allowed to occupy an F AA A pproved Child Restraint (CARES, manufactured by Am Safe, Inc.), even though she exceeds the manufacturer ’s height limit of 4 0 inches

. 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.