November 7, 2012 

VIA FEDERAL EXPRESS AND E-MAIL 

Samuel Podberesky 

Assistant General Counsel for 

Aviation Enforcement and Proceedings, C-70 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E.-Room W96-322 

Washington, D.C. 20590 

AN 

Re: Supplement to LAN Colombia's request for Equivalent Alternative under 14 C.F.R. 382.67-

Docket OST-2008-0272 

Dear Mr. Podberesky: 

Aerovias de lntegracion Regional Aires SA d/b/a LAN Colombia ("LAN Colombia"} hereby respectfully 

submits this supplement in support of its April 2012 request for an equivalent alternative determination related 

to priority space in the cabin to store passengers' wheelchairs. This request is of the essence to ensure the 

flexibility of LAN Colombia's operations. Since our initial request for equivalent alternative determination, the 

company has received three additionaiA320s, bringing our total to four (4) A320s, that we intend to operate to 

the United States and that do not have the required priority in-cabin space for an adult-sized wheelchair as 

required under §382.67. 

in support of this request, LAN Colombia hereby confirms the following: 

To provide a similar accessibility to passengers requesting use of the in-cabin priority space requirement 

for its A320 aircrafts, LAN Colombia developed a comprehensive procedure that provides an equivalent 

method of wheelchair storage. The said equivalent method involves a designated priority area in the 

cargo holds of A320s in the fleet. The designated priority space will be used for the stowage of up to two 

manual folding wheelchairs. For space details, see Annexes 1-5 below. 

The priority space in the cargo holds of LAN Colombia's A320 aircraft (the "Wheelchair Priority Space") 

will provide sufficient space for the stowage of up to two wheelchairs to the first two passengers with a 

disability requesting the onboard stowage of the wheelchair. No additional items will be stored in the 

Wheelchair Priority Space when any wheelchair is transported. 

Protective bags to further protect each wheelchair in the event of movement during flight will be used, 

completely separating the wheelchairs from other items in the cargo hold. These bags will also protect 

wheelchairs from weather conditions (for example, rain) during the loading and unloading process, 

although LAN Colombia will in all ways use its best efforts to protect the wheelchairs from the effects of 

weather. 
Further, and as deemed necessary, the wheelchairs and their respective protective bags will be secured 

with the use of tie-downs in the priority space of the cargo hold. 

Any individuals with a disability who request in-cabin stowage for a manual folding wheelchair will be 

informed of the available Wheelchair Priority Space, including the stowage procedures and services, and 

will be permitted to pre-board the aircraft. For a passenger that does not take advantage of the 

opportunity to pre-board, LAN Colombia will make a reasonable effort to stow the passenger's 

wheelchair in the priority space. Additional requests for the priority stowage of other disabled 

passengers' wheelchair will be considered by LAN Colombia, and a reasonable effort will be made to 

properly care for the said passenger's wheelchair. 

LAN Colombia will offer passengers with a disability the flexibility to continue to use their wheelchairs 

and will return the wheelchairs to them at any reasonable location of their choosing, including at the 

aircraft door, at the gate, or at the baggage claim area. Furthermore, irrespective of the place where 

the passenger requests the wheelchair to be delivered upon arrival to his/her final destination, the 

wheelchairs will be the first items removed from the aircraft. 

In the event of a de\ay, loss or damage of a wheelchair, LAN Colombia will make its best efforts to 

promptly provide the passenger, free of charge, with a comparable device of similar quality, or at the 

passenger's request, a reimbursement for the rental cost. The said temporary replacement and/or 

reimbursement will be provided in addition to any other reimbursements available to the passengers as 

a result of the delay, loss or damage, like the original purchase price of the wheelchair. 

LAN Colombia notes that the overhead compartments in the aircraft are not large enough to fit a 

manual folding wheelchair with or without wheels. 

LAN Colombia will properly train ground handling personnel and others in accordance with the 

conditions of the equivalent alternative determination to ensure proper handling and stowage of 

mobility aids presented by passengers while traveling aboard its A320 aircraft. 

Since the original request for equivalent alternative in April, LAN Colombia has incorporated three additional 

A320 aircraft, bringing the total to four aircraft are unable to operate to the United States. We therefore 

appreciate the Department's expeditious consideration of this matter. LAN Colombia believes that the request 

is reasonable and provides the same or greater accessibility to passengers with a disability as provided under the 

Air Carrier Access Act. We remain available to respond to any questions that may arise regarding the previous. 

We also understand the Department's favorable ruling on our application may be subject to other conditions not 

set forth in this supplement, and we invite you to open a conversation about any such conditions at any time. 

Sincerely, 

Pablo Chiozza 

VP Sales North America and the Caribbean 

as US GSA for LAN Colombia 
/ 

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ANNEX 1 CARGO HOLD DIAGRAM 

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t_-r_·-- · .. -~ -,C~~L _;01 i 

.... :.~----~·!,..._ 1. i. f\-,7 IT. ····-·------... ; 1092.99 l ~) 

Figure No. 1. Cargo Hold Distribution 

This rs the AFT cargo hold portion to 

be used to stow lhe wheelchairs 

As previously stated, the wheelchairs will be located on the forward section ofthe Aft Cargo Bulk Comp No.5. 

Figure No.2. Comp 5-Cargo Bulk Hold 
ANNEX 2 CARGO COMPARTMENT DOOR 

[FWD 

Figure 3. Bulk Cargo Compartment Door 
ANNEX 3 CARGO HOLD DIVIDERS NET 

This Bulk compartment hold comprises of two set of nets, one net is to divide the AFT Compt Hold (3 -4) over 

the 59 frame section as it is shown on the Figure 4. The second set of net is to protect the Bulk Compartment 

Door. 

Figure 4. Cargo Diverders Net Comp 5 "Bulk" 
ANNEX 4 TIE-DOWN POINTS 

fJET ATTACH1.1E!JTS AIJO 

TIE OO',V!J P::Jl!JTS 

Figure 5. Net Attachments and Tie Down Points 

REFERENCE POltJTS FOR NET ATTACHMENTS AND TIE DOWN POINTS 

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A A B c 

Figure 6. Reference Points for Sulk Cargo Hold Compartment 

The figures shown in this annex were taken as reference from the Wf'ight and balance manual for the A320 FAM applicable to LAN Colombia. 
ANNEX 5 DEDICATED WHEELCHAIR LOCATION 

Dedrcated ':tlleelctla!r IJcatio'l 

Figure 7. Dedicated wheelchair's location