I am writing to request an exemption from 14 CFR § 121.311(b) to the extent required for Joanna Esther Hunter 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 Joanna Esther Hunter is aboard its aircraft is granted an exemption from 14 CFR § 121.311(b)(2)(iii)(B) to the extent necessary to 

allow Joanna Esther Hunter 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’s physical condition is as follows she has severe Cerebral Palsy and although she has little muscular control at 15 years old and at 70 

pounds. 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 she 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 Joanna Esther Hunter 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 Joanna Esther Hunter and a high level of safety for the other passengers 

and crew on the airplane. In fact, in Joanna'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 Joanna 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 Joanna only sits in a passenger seat with no passenger seated behind her. Therefore, no unsafe condition would exist for a passenger seated 

behind Joanna while she is using the CARES restraint. I also propose that all operations under this exemption be conducted with at least one of Joanna’s parents

or a caregiver accompanying him or her. In addition, I propose that Joanna’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 March 26, 2012 for my 

daughter’s wedding. 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.