Request to Use CARES for Larger/Older Persons

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

Carrissa Anne Price 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 Carrissa Anne Price is 

aboard its aircraft is granted an exemption from 14 CFR § 121.311(b)(2)(iii)(B) to the extent 

necessary to allow Carrissa Anne Price to exceed the specified weight limit for an FAAapproved 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's physical condition is as follows Carrissa is a 17 year old quadruple amputee due 

to meningococcemia at age three. Her residual lower limbs are too short for her to be safely 

restrained in a lap belt only, it is therefore necessary for her to use the Cares harness system to 

fly safely.. 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 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 Carrissa Anne Price be allowed to occupy an FAA Approved Child Restraint 

(CARES, manufactured by AmSafe Corporation), even though she exceeds the manufacturer’s 

weight limits. This ensures a high level of safety for Carrissa Anne Price and a high level of 

safety for the other passengers and crew on the airplane. In fact, in Carrissa Anne Price'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 Carrissa Anne Price 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 Carrissa Anne Price 

only sits in a passenger seat with no passenger seated behind her. Therefore, no unsafe 

condition would exist for a passenger seated behind Carrissa Anne Price while she is using the 

CARES restraint. I also propose that all operations under this exemption be conducted with at 

least one of Carrissa Anne Price parents or a caregiver accompanying him or her. In addition, I 

propose that Carrissa Anne Price 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 on April 3,2012 and return on April 13,2012. 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.