I am writing to request an exemption from 14 CFR § 121.311(b) to the extent required for 

Angelica Pelissier 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 

Angelica Pelissier is aboard its aircraft is granted an exemption from 14 CFR § 

121.311(b)(2)(iii)(B) to the extent necessary to allow Angelica Pelissier 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 ___18__ year’s old, weighs __96___ pounds, and is ___51___ inches 

tall. My daughter’s physical condition is as follows: C2 spinal cord complete 

transaction, quadriplegic, ventilator dependent with tracheostomy. 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: Renee Pelissier, 

8613 192nd Dr SE, Snohomish Wa. 98290, and email- millgirl49@verizon.net 

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 Angelica Pelissier 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 (Angelica Pelissier) and a high level 

of safety for the other passengers and crew on the airplane. In fact, in (Angelica)’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 (Angelica Pelissier) 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).

In order to achieve an equivalent level of safety as that provided by the affected 

regulation, I propose that the FAA establish a limitation in a grant to this petition that 

(Angelica Pelissier) only sits in a passenger seat with no passenger seated behind her. 

Therefore, no unsafe condition would exist for a passenger seated behind (Angelica 

Pelissier) while (she) is using the CARES restraint. I also propose that all operations 

under this exemption be conducted with at least one of (Angelica’s) parents or a 

caregiver accompanying him or her. In addition, I propose that (Angelica’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 (September or October 2014). 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.