US. Deportment 

of Transportation 

Federal Aviation 

Administration 

August 27. 20 15 

Exemption No. 12642 

800 Independence Ave . S w w ash1ngton. DC 20591 

Regulatory Docket No. F AA-20 15-3026 

Mr. James Freeman and Mrs. Eli zabeth Freeman 

Parents ofElise ··Ellie" Freeman 

808 Canyon Springs Drive 

Cedar Park, TX 786 13 

Dear Mr. and Mrs. Freeman: 

This letter is to in form you that we have granted your request for exemption. lt 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 July 20, 20 15, you petitioned the Federal Aviation 

Admi nistration (FAA) on behalf of your daughter Elise ·'Ellie'· Freeman for an exemption 

from § 121.3 ll (b) ofTitle 14, Code of Federal Regulations (14 CFR). That exemption, if 

granted, would allow Ellie to exceed the speci lied weight and/or height limit for an FAAapproved child restraint system (CAReS, manufactured by ArnSafe Corporation), during use 

o f that child restraint system (CRS) aboard a United States (U.S.)-registcred aircraft. 

The FAA has determined that good cause exists lo r 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 Ellie. 

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

those presented in your petition. In Grant of Exemption No. 9834 (copy enclosed), the FAA 

to und that numerous persons with physical challenges had previously completed flights using 

restraint systems that addressed unique physical needs regarding safety, support, and security 

in the same manner of operations as descri bed in this petition. The FAA further fo und that the 

petition would not set any new precedent regarding the use of restraint systems by persons 

with disabilities. 

AFS- 15-3 106-E 
2 

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

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

of Exemption No. 9834; 

• the reasons stated by the FAA for granting the enclosed Grant of Exemption No. 9834 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(t), 40113 and 44701, which the FAA 

Administrator has delegated to me, I hereby grant Elise "Ellie" Freeman an exemption from 

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

while Ellie is aboard its aircraft is granted an exemption from 14 CFR § 121.311(b) to the 

extent necessary to allow her to use an FAA-approved CRS aboard a U.S.-registered aircraft. 

All operations under this exemption must be conducted with one of Ellie's parents or a 

caregiver accompanying her. Ellie may only occupy a passenger seat with no passenger seated 

behind her. In addition, Ellie's parent or caregiver must carry a copy of this exemption and 

advise the air carrier about the contents of the exemption at least 48 hours before the date of 

each flight. 

This exemption terminates on July 31 , 2020, unless sooner superseded or rescinded. 

Sincerely, 

John Barbagallo 

Deputy Director, Flight Standards Service 

Enclosure