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 

Amanda Sarensen 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 

Amanda Sarensen is aboard its aircraft is granted an exemption from 14 CFR § 

121.311(b)(2)(iii)(B) to the extent necessary to allow Amanda Sarensen 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 from which we seek relief is Section 

121.311 Seats, safety belts, and shoulder harnesses.

My daughter is 17 year’s old, weighs 80 pounds, and is 4’11 inches tall. My daughter’s 

physical condition is as follows; she has cerebral palsy, a seizure disorder and diabetes. 

As a result 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: Stacey 

Sarensen, 19413 8th Ave E, Spanaway WA 98387 and slsarensen@aol.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 Amanda Sarensen be allowed to occupy an FAA Approved Child 

Restraint (CARES, manufactured by AmSafe, Inc.), even though she exceeds the 

manufacturer’s weight limits. This ensures a high level of safety for Amanda Sarensen

and a high level of safety for the other passengers and crew on the airplane. In fact, in 

Amanda Sarensen’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 Amanda Sarensen 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 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.
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 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).

I propose that all operations under this exemption be conducted with at least one of 

Amanda Sarensen’s parents or a caregiver accompanying her. In addition, I propose 

that Amanda Sarensen’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. We want to travel October 23rd to the 29th, 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 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

Best Wishes,

Trina

Trina Cottingham

Vice President, Wishes

Make-A-Wish Alaska and Washington

811 First Ave, Suite 520

Seattle, WA 98104

206-623-5320

trina@akwa.wish.org