**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 **Devin Allen**  to be able to use an FAA Approved Chil d Restraint Sy stem even though **he** 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 **Devin Allen** is aboard its aircraft is granted an exemption from 14 CFR § 121.311(b)(2)(iii) (B) to the extent necessary to allow Devin Allen to exceed the specified weight limit for an FAA

- approved child restraint system during use of that child restraint s ys tem aboard an aircraft. I believe the pertinent section from 14 CFR part 121 from which w e seek relief is Section 121.311 Seats, safet y belts, and shoulder harnesses. My **son** is ___ 14 __ y ear’s old, weighs __ 60 ___ pounds, and is __ 54

____ inches tall. My **son** ’s phy sical condition is as follows ( **Lesh Nyhan Sysdrome** ). As a result of **his** phy sical co ndition, **he** needs the support and securit y provided b y an FAA Approved Child Restraint, but because of **his** weight is incapable of compliance with the regulation. **I am also submitting the following contact information:**  **Carol & Jim Allen , 44460 Highgate Dr**  **., Clinton Township, MI. 48038 and**  **cuallen95@aol.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 r egulation 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 Devin Allen be allowed to occup y an FAA Approved Child Restraint (CARES, manufactured b y AmSafe, Inc.), even though **he** exceeds the manufacturer’s weight limits. This ensures a high level of safety for Devin Allen and a high level of safet y for the other passengers and crew on the airplane. In fact, in Devin Allen ’s case, safet y is greatly enhanced by

the extra support and securit y that the FAA Approved Restraint Sy stem will provide during the entire flight. Enhancing safety

for Devin Allen is in the public interest. In addition, the public interest is also served b y the fact that the use of this FAA Approved Child Restraint Sy stem allows **him** to use commercial air transportation. Without the support and security of the FAA Approved Child Restraint Sy stem, **he** would be unable to fl y commerciall y. I also believe that, with certain lim itations 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 integrit y if used b y 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 thepassenger using the CARES restraint (becau se 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 Devin Allen only sits in a passenger seat with no passenger seated behind him . Therefore, no unsafe condition would exist for a passenger seated behi nd Devin Allen while **he** is using the CARES restraint. I also propose that all operations under this exemption be conducted with at least one of **Devin Allen’s** parents or a caregiver accompanying him . In addition, Ipropose that **Devin Allen’ s**  parent or careg iver must carry

a copy 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 April 5 th

- 9 th

. 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 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 child 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 he exceeds the manufacturer’s weight limits of 44 pounds. In this case, the safet y of this child is greatl y enhanced by the extra support and securit y that the FAA Approved Restraint S ys tem will provide for him during the flight. Thank you for your consideration of this request.