August 17, 2013

To Whom It May Concern:

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

extent required for myself (Jean-Marie Lawrence) to be able to use an FAA 

Approved Child Restraint System even though I exceed 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 I am aboard 

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

the extent necessary to allow myself 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 I seek 

relief is Section 121.311 Seats, safety belts, and shoulder harnesses.

I am 26 year’s old, weigh 176 pounds, and am 66 inches tall. My physical 

condition is as follows: I have Limb Girdle Muscular Dystrophy, resulting in 

limited muscle strength, which deteriorates over time. I have no use of my 

legs, and little strength in my arms and torso, making it impossible for me 

to hold myself upright. As a result of my physical condition, I need the 

support and security provided by an FAA Approved Child Restraint, but 

because of my weight is incapable of compliance with the regulation. I am 

also submitting the following contact information: Jean-Marie 

Lawrence, 4417 Oakwood Dr., Apt. 1102, Chattanooga, TN 37416, 423-

893-3311, and jm.lawrence1986@gmail.com

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 I be allowed to occupy an FAA Approved Child Restraint 

(CARES, manufactured by AmSafe, Inc.), even though I exceed the 

manufacturer’s weight limits. This ensures a high level of safety for myself,
and a high level of safety for the other passengers and crew on the 

airplane. In fact, in my 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 me 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 me to use commercial air transportation. Without 

the support and security of the FAA Approved Child Restraint System, I 

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 I only sit in a passenger seat with no passenger seated 

behind her. Therefore, no unsafe condition would exist for a passenger 

seated behind me while I am using the CARES restraint. In addition, I 

propose that I 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 16, 2013-September 23, 2013. 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 an adult to use an FAA Approved Child Restraint System on 

an aircraft, even though the adult exceeds the weight limits for the CRS. 

Due to physical challenges, without the support and security of this FAA 

Approved Child Restraint System, this adult would be unable to fly. We 

request that this adult 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 adult 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.

Sincerely,

Jean-Marie Lawrence