October 15,2012 

VIA FEDERAL EXPRESS AND E-MAIL 

Samuel Podberesky 

Assistant General Counsel for 

Aviation Enforcement and Proceedings, C-70 

U.S. Department ofTransportation 

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

Washington, D.C. 20590 

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

DotketOST -2008-0272 

Dear Mr. Podberesky: 

Aerovias de lntegracion Regional Aires S.A. 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 incabin 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 equivalentmethod of wheelchair storage. The said equivalent method involves a 

designated priority area in the cargo holdsof A320s in the fleet. The designated priority space 

will be usedfor 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 on board 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 

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

Legal Department 

6500 NW 22"' Street Miami florida 33122 

Tel: (786) 265 6091 Fax: (305) 871 8736 

www.lan.com 
Any individuals with a disability whose wheelchairs are transported in the Wheelchair Priority 

Space will be informed of the available stowage procedures and services and given the ability to 

pre-board the aircraft. For a passenger that does not take advantage of the opportunity to preboard, 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 delay, 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, including to the extent 

required by 14 CFR 254, the original purchase price ofthe 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 to ensure proper service 

to passengers with a disability traveling 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 that are unable to operate to the United 

States. We therefore appreciate the Department's expeditious consideration ofthis 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. 

Pablo Chiozza 

VP Sales North America and the Caribbean 

as US GSA for LAN Colombia 
ANNEX 1 CARGO HOLD DIAGRAM 

FORWARD CARGO ~OLD 

(COMPAIITMEW l) AFT CARGO 1-h'l LD {C~ARlMENi 3 lmll4) 

Figure No. 1. Cargo Hold Distribution 

This is the AfT cargo hold portion to 

b& used to stow the wbeekbairs 

As previously stated, the wheelchairs will be located on the forward section of the Aft Cargo Bulk 

Comp No.5. 

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

A-A 

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

This Bulk compartment hold comprises oftwo 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 

NET ATIACHMENTS AN.D 

TIE 00\.i'i/N. POUlTS 

Figure 5. Net Attachments and Tie Down Points 

REfERENCE PO'INTSfORNH AITACHMENTSANOTIE DOWN POfNTS 

Figure 6. Reference Points for Bulk Cargo Hold Compartment 

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

Figure 7. Dedicated wheelchair location 
From: (786) 265-6091 

AnitaMeza 

LAN Airlines 

Legal Department 

6500 NW 22 Street 

Miami, FL 33122 

Origin 10: CTYA 

J12201207160325 

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