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

required for my daughter, Anna Cawthra, 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 Anna Cawthra is aboard its aircraft is granted an exemption from 

14 CFR § 121.311(b)(2)(iii)(B) to the extent necessary to allow Anna Cawthra 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 16 years old, weighs 81 pounds, and is 51 inches tall. My daughter’s 

physical condition is as follows Anna has Wolf-Hirschhorn Syndrome. She is profoundly 

physically and mentally handicapped. She cannot remain in a sitting position for more 

than 5 minutes with out support. 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: Lisa Cawthra, 16862 Jackal Street NW, Ramsey, MN 

55303, 612-306-7131, lmcawthra@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 Anna Cawthra 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 Anna and a high 

level of safety for the other passengers and crew on the airplane. In fact, in Anna’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 Anna Cawthra 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 

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

unsafe condition would exist for a passenger seated behind Anna while she is using the 

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

with at least one of Anna’s parents or a caregiver accompanying him or her. In addition, 

I propose that Anna’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 June 11 - 18, 2015. 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. 

Sincerely,

Lisa M. Cawthra