**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 ( **Trinity Sumlin**

) 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 (

**Trinity Sumlin**

) is aboard its aircraft is granted an exemption from 14 CFR § 121.311(b)(2)( iii)(B) to the extent necessary to allow ( **Trinity Sumlin**

) 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 fro m which we seek relief is Section 121.311 Seats, safety belts, and shoulder harnesses.

My (**daughter**

) is ___11_year’s old, weighs ___58 pounds, and is 43____ inches tall. My **daughter** ’s physical condition is hypotonia and developmental delay. As a resul t 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: (Sheryl**  **Su mlin)**  **, (7943 Bluefin Trail, Union City Georgia 30291), (sherylsuml@yahoo.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 al l 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 (

**Trinity Sumlin**

) be allowed to occupy an FAA Appro ved Child Restraint (CARES, manufactured by AmSafe, Inc.), even though ( **she** ) exceeds the manufacturer’s weight limits. This ensures a high level of safety for ( **Trinity Sumlin)** and a high level of safety for the other passengers and crew on the airplane. In fact, in ( **Trinity Sumlin** 

)’s case, safety is greatly enhanced by the extra support and security that the FAA Approved Restraint System will provide during the entire flight.

Enhancing safety for (

**Trinity Sumlin**

) 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 manufactu rer 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 t he 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 b ehind 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 ach ieve 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 ( **name** ) only sits in a passenger seat with no passenger seated behind her. Therefore, no unsafe co ndition would exist for a passenger seated behind ( **Trinity Sumlin**

) while ( **she** ) is using the CARES restraint. I also propose that all operations under this exemption be conducted with at least one of ( **Trinity Sumlin**

) parents or a caregiver accompanying him or her. In addition, I propose that ( **Trinity Sumlin**

) parent orcaregiver 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 (**June 20 , 2014**  ). 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 e xemption 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 Approved Restraint System will provide for (**her)** during the flight.

Thank you for your consideration of this request.