U.S. Department 

of Transportation 

Federal Aviation 

Administration 

February 5, 2016 

Ms. Dawn Dillon 

Parent of Luke Dillon 

2 Ward Hill Road Extension 

Westford, MA 01886 

Dear Ms. Dillon: 

Exemption No. 14660 

800 Independence Ave . S W 

Washington. DC 2059 1 

Regulatory Docket No. FAA-2015-8265 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and lists the conditions and limitations of the exemption, 

including the date it ends. 

The Basis for Our Decision 

By letter posted to the docket on December 21, 2015, you petitioned the Federal Aviation 

Administration (FAA) on behalf of your son Luke Dillon for an exemption from § 12 1.3 11 (b) 

of Title 14, Code of Federal Regulations (14 CFR). That exemption, if granted, would allow 

Luke to exceed the specified weight and/or height limit for an FAA-approved child restraint 

system (CAReS, manufactured by Am Safe Corporation) during use of that child restraint 

system (CRS) aboard a United States (U.S.)-registered aircraft. 

In Luke's case, although he is currently 14 years old, he will be over 18 years old before this 

exemption terminates, therefore, an exemption must also be granted from the requirement in 

§ 121.3ll(b ), that the individual be a "child" . However, the reasons for requesting this 

exemption do not differ materially from those presented by other petitioners and the reasons 

stated by the FAA for granting other exemptions also apply to the situation you present. The 

FAA has detem1ined that good cause exists for not publishing a summary of the petition in the 

Federal Register, because the requested exemption would not set a precedent, and any delay in 

acting on this petition would be detrimental to Luke. 

The FAA has issued grants of exemption in circumstances similar in all material respects to 

those presented in your petition. In Grants of Exemption Nos. 7831 and 8264 (copies 

enclosed), the FAA found that numerous people with physical challenges had previously 

completed flights using restraint systems. 

AFS-16-4068-E 
2 

The use of these restraint systems addressed unique physical needs regarding safety, support, 

and security in the same manner of operations as described in this petition. The FAA further 

found that the petition would not set any new precedents regarding the use of restraint systems 

by persons with disabilities. 

Having reviewed your reasons for requesting an exemption, l find that-

• they are similar in all material respects to relief previously requested in the enclosed Grant 

of Exemption Nos. 783 1 and 8264 · 

• the reasons stated by the FAA for granti ng the enclosed Grant of Exemption Nos. 7831 

and 8264 also apply to the situation you present; and 

• a grant of exemption is in the public interest. 

Our Decision 

Under the authority contained in 49 U.S.C. §§ 106(f), 40113 and 44701, which the FAA 

Administrator has delegated to me, I hereby grant Luke Dillon an exemption from 

§ 121.31 1 (b). In addition, any air carrier or commercial operator operating under part 121 

while Luke is aboard its aircraft is granted an exemption from 14 CFR § 12 1.3 11 (b) to the 

extent necessary to allow him to exceed the specified weight and/or height limit for an FAAapproved CRS during use aboard a U.S.-registered aircraft. 

All operations under this exemption must be conducted with Luke's parent or a caregiver 

accompanying him. Luke may only occupy a passenger seat with no passenger seated behind 

him. In addition, Luke's parent or caregiver must carry a copy of this exemption and advise 

the air carrier about the contents of the exl!mption at least 48 hours before the date of each 

flight. 

This exemption terminates on January 31, 2021 , unless sooner superseded or rescinded. 

Enclosures