Carola Pirsig

Axel Vogt

An der Eiche 52

25421 Pinneberg

Tel. 04101 8529248

mobil 0172 6724737 oder 0151 22209424

Fax 04101 8529258

Mail carola.pirsig@gmx.de oder avo1@gmx.de

Carola Pirsig - Axel Vogt - An der Eiche 52 - 25421 Pinneberg

to whom it may concern

25. Oktober 2014

Request to Use CARES Child Restraint System for Larger/Older Persons

We are writing to request an exemption from 14 CFR § 121.311(b) to the extent required for Fabian

Constantin Vogt to be able to use an FAA Approved Child Restraint System even though he exceeds the

weight limits for the CRS. In addition, if our petition is granted, we request that any air carrier or commercial

operator operating under part 121 while Fabian is aboard its aircraft is granted an exemption from 14 CFR §

121.311(b)(2)(iii)(B) to the extent necessary to allow Fabian to exceed the specified weight limit for an

FAA-approved child restraint system during use of that child restraint system aboard an aircraft.

We believe the pertinent section from 14 CFR part 121 from which we seek relief is Section 121.311 Seats,

safety belts, and shoulder harnesses.

Our son is 11 year’s old, weighs 46 pounds, and is 47 inches tall. Our son’s physical condition is as follows:

cerebral palsy

Need help by sitting

Can't going

As a result of his physical condition, he needs the support and security provided by 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:

Carola Pirsig and Axel Vogt

An der Eiche 52

25421 Pinneberg

Germany

carola.pirsig@gmx.de or

avo1@gmx.de

phone +4941018529248

We 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.

We propose that Fabian be allowed to occupy an FAA Approved Child Restraint (CARES, manufactured by

AmSafe, Inc.), even though he exceeds the manufacturer’s weight limits. This ensures a high level of safety

for Fabian and a high level of safety for the other passengers and crew on the airplane. In fact, in Fabian’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 Fabian 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 him to use commercial air transportation.
Without the support and security of the FAA Approved Child Restraint System, he would be unable to fly

commercially.

We 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.

We 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, we propose that

the FAA establish a limitation in a grant to this petition that Fabian only sits in a passenger seat with no

passenger seated behind him. Therefore, no unsafe condition would exist for a passenger seated behind

Fabian while he is using the CARES restraint. We also propose that all operations under this exemption be

conducted with at least one of Fabian's parents or a caregiver accompanying him or her. In addition, we

propose that Fabian’s parent or caregiver must carry a copy of this exemption.

We also request that the processing of this petition not be delayed for publication and comment in the

Federal Register. We want to travel from 7/21/15 to 8/13/15. 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, we 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 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 he 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 him during the flight.

Thank you for your consideration of this request

Axel Vogt Carola Pirsig