us. Department 

of Trcrtsportotion 

Federal Aviation 

Administration 

October 15, 2014 

Ms. Lori Callahan 

Parent of Rachel Pierce 

3101 Sprucewood Drive 

McKinney, TX 75071 

Dear Ms. Callahan: 

Exemption No. 11079 

800 Independence Ave .. S W 

Washington. D.C. 20591 

Regulatory Docket No. F AA-20 14-0634 

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

our decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

The Basis for Our Decision 

By letter posted August 25, 2014, you petitioned the Federal Aviation Administration (FAA) 

on behalf of Rachel Pierce for an exemption from§ 121.3ll(b) of Title 14, Code ofFederal 

Regulations (14 CFR). That exemption, if granted, would allow Rachel to exceed the 

specified weight and/or height limit for an FAA-approved child restraint system (CAReS, 

manufactured by AmSafe Corporation) during use of that child restraint system (CRS) aboard 

a United States (U.S.) aircraft 

The FAA has determined 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 Rachel. 

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. 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. 

AFS-14-437-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 Nos. 7831 and 8264; 

• the reasons stated by the FAA for granting 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 Rachel Pierce an exemption from 

§ 121 .311 (b). In addition, any air carrier or commercial operator operating under part 121 

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

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

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

accompanying her. Rachel Pierce may only occupy a passenger seat with no passenger seated 

behind her. In addition, Rachel'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 October 31, 2019, unless sooner superseded or rescinded. 

Sincerely, 

J ohn S. Duncan 

Director, Flight Standards Service 

Enclosures