**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 Rachel Pierce to be able to use an FAA Approved 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 an y air carrier or commercial operator operating under part 121 while Rachel Pierce is aboard its aircraft is granted an exemption from 14 CFR § 121.311(b)(2)(ii i)(B) to the extent necessary to allow Rachel Pierce to exceed the specified weight limit for an FAA

- approved child restraint sy stem during use of that child restraint sy stem aboard an aircraft. I believe the pertinent section from 14 CFR part 121 from whi ch we seek relief is Section 121.311 Seats, safet y belts, and shoulder harnesses. My daughter is 12 year’s old, weighs 59 pounds, and is 49 inches tall. My **daughter** ’s ph ys ical condition is as follows: Rachel has scoliosis, and also cannot walk unassisted, and uses a wheelchair for transportation

. She also has cognitive delay s, and is at a developmental level of a two y ear old, and would benefit from using a safety restraint sy stem, such as CARES. As a result of her phy sical condition, she needs the support and securit y 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 :**  Parent: L ori Callahan, Stepfather

– Chris Callahan; 3101 Sprucew ood Drive, McKinney , Texas, 75071. Email: lori.callahan@pepsico.com

. I understand that the regulation is written to create a high level of safety for each individual 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 propose that Rachel Pierce be allowed to occupy an FAA Approved Child Re straint (CARES, manufactured b y AmSafe, Inc.), even though she exceeds the manufacturer’s weight limits. This ensures a high level of safety for Rachel, and a high level of safety for the other passengers and crew on the airplane. In fact, in Rachel ’s case, safety is greatl y enhanced by the extra support and securit y that the FAA Approved Restraint System will provide during the entire flight. Enhancing safety

for Rachel is in the public interest. In addition, the public interest is also served by the f act that the use of this FAA Approved Child Restraint Sy stem allows her to use commercial air transportation. Without the support and security of the FAA Approved Child Restraint Sy stem, she would be unable to fl y commerciall y. I also believe that, with ce rtain limitations established by the FAA in a grant to this petition, there can be an equivalent level of safet y to that provided by the affected regulation. The CARES restraint has been certified by the manufacturer for use by children 22

- 44 pounds. Howe ver, the components of the CARES restraint are the same as those used in restraints for adults on aircraft and would maintain their integrit y if used b y someone who weighed several hundred pounds.I believe that the limit of 44 pounds was established becau se, 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 restrai nt (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 safet y as that provided by the affected regulation, I propose that the FAA establish a limitation in a grant to this petition that Rachel onl y sits in a passenger seat with no passenger seated behind her. Therefore, no unsafe condition would exist for a passenger seated behind Rachel while she is using the CARES restraint. Ialso propose that all operations under this exemption be conducted with at least one of Rachel’s parents or a caregiver accompan yi ng him or he r. In addition, I propose that Rachel’s parent or caregive r must carry a cop y of this exemption.
I also request that the processing of this petition not be delay ed for publication and comment in the Federal Register. We want to travel November 23, 2014 and November 28, 2014 . If you take the time to put this in th e 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 req uired for a child to use an FAA Approved Child Restraint Sy stem on an aircraft, even though the child exceeds the weight limits for the CRS. Due to phy sical challenges, without the support and securit y of this FAA Approved Child Restraint Sy stem, this chil d would be unable to fl y. 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 safet y of this child i s greatl y enhanced by the extra support and security that the FAA Approved Restraint S ys tem will provide for her during the flight. Thank you for your consideration of this request.