Ryan International Airlines 

4949 Harrison Ave. 

Rockford, IL 61108 

October 20, 2011 

Docket Operation 

U.S. Department of Transportation 

West Building Ground Floor, Room W12-140, 1200 New Jersey Avenue, SE 

Washington, DC 20590 

Subject: Petition for exemption for a portion of Federal Aviation Regulation 14 CFR §121.344(f) 

and Appendix M – Airplane Flight Recorder for Airbus A330-343 Aircraft MSN 1231 operated 

by Ryan International Airlines. 

Reference: 

Attachment ‘A’ - Current FAR rules 121-344 (f) and Appendix M –Digital Flight Data Recorder 

Regulations (DFDR), final Rule. 

Attachment ‘B’ – Airbus Comments to docket No. FAA-2005-20245. Notice No. 10-01, 

extension of the compliance date for cockpit voice recorder and digital flight data recorder 

regulations. 

Note: Please refer to Section 1 (attachment B). DFDR Sampling Rates for additional technical 

information provided by Airbus. 

 Ryan International Airlines, a FAR 121 Operator is requesting this exemption to Appendix M 

to part 121 – Airplane Flight Recorder Specifications items 12-18 and 88, specifically note 18 

which states, “For all aircraft manufactured on or December 6, 2010, the seconds per sampling 

interval is 0.125. Each input must be recorded at this rate. Alternately sampling inputs 

(interleaving) to meet this sampling interval is prohibited.” Please reference Attachment “A” to 

this document. Currently the aircraft is recording these required parameters, however they are 

recorded at 0.25 second sampling interval. 

 Ryan International Airlines is planning to receive its first A330-343 aircraft MSN 1231, and 

has been informed by the aircraft manufacturer (Airbus) that the current configuration of the 

aircraft will not comply with the requirements of the sampling rate specified in Appendix M 

(attachment A), as it was originally configured to EASA requirements which differ substantially 

from the current FAA requirements. Airbus has previously commented on the time period to 

implement a new sampling rate and has previously submitted information to explain the complex 

retrofit to the airframe in order to comply with the ruling by the deadline specified (Attachment 

B). 

The retrofit options to make the aircraft capable of meeting the regulation are not 

currently available, but are being worked by the manufacturer and will be installed on this aircraft 

once released. Those options to retrofit the aircraft include replacing the SSFDR with one capable 

of meeting a 1024 Word Per Second (WPS) sampling rate or 0.125 second sampling interval, in 

conjunction with replacing the FDIMU software, a redesign of other critical aircraft systems 

which include the Flight Control Data Concentrator, System Data Acquisition Concentrator, plus 

possibly others such as the Flight Warning System, and Display Management Computers. This 

may also entail installing new FCDC computers in both positions, and possibly making wiring 

changes to the data bus. 
October 9, 2011 

Page 2 

Therefore, Ryan International Airlines respectfully requests an exemption to these rulings 

until such time as the retrofits and components are available from the aircraft manufacturer, 

which we expect to be available prior to December, 2012. Once these are available, the aircraft 

can be retrofitted to the approved configuration to meet the necessary sampling interval, required 

by the regulation. We have queried the manufacturer for the exact date of the release of these 

service bulletins and expect to have that information available soon, but are under the impression 

it will not be prior to our technical acceptance of the aircraft. This exemption if granted would not 

jeopardize airplane safety because the current equipment, does record the required parameters at a 

rate that has been previously acceptable, and the aircraft does record each of parameters shown at 

025 second sampling interval. 

 This exemption request is in interest of the United States public, as Ryan International airlines 

is a operator which provides support of government contracts, in addition to transporting US 

passengers to their destinations for business and tourism. A delay in adding this aircraft to the 

Operations Specifications will no doubt have an adverse effect, causing distress to the airline, the 

DOD, and several US passengers which would have used this aircraft for service. In addition, it 

will allow Ryan International a small business entity the ability to compete for contracts in the 

international market, open additional long range routes and expand operations. 

 Please contact Ryan International Airlines if you any questions or need additional information 

to provide this exemption. 

Sincerely, 

Gerald (Jim) Miller 

Avionics Systems Engineer 

Ryan International Airlines 

JimMiller@flyryan.com 

Tel: 520-940-2179 

Fax: 520-844-1188 

CC: Mr. John Medeiros 

 Director Of Quality 

 Ryan International Airlines 

 

 Edy Mentor 

 Principal Avionics Inspector 

 Federal Aviation Administration 

 Chicago Flight Standards District Office