March 20, 2015

Docket Management Facility

U.S. Department of Transportation

West Building, Ground Floor

Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

~ COZEN

~)O/CONNOR

1"),.vidHeffeman_

Mr. Michael Crook

Office of Transportation Disaster Assistance

National Transportation Safety Board

490 L'Enfant Plaza East, SW

Washington, DC 20594

Re: Family Assistance Plan of T'way Air (Docket DOT-OST-1998-3304\

Dear Mr. Crook:

Enclosed please find the Family Assistance Plan of T'way Air Co., Ltd. ("T'way Air") filed

in accordance with the requirements of 49 U.S.C. Section 41113, as amended by the Wendell

H. Ford Aviation Investment and Reform Act for the 21st Century (AIR-21) and the Vision 100-

Century of Aviation Reauthorization Act.

Additionally, please be advised that the telephone numbers to reach T'way Air's

operations staff 24 hours a day in the event of an emergency is [REDACTED] or [REDACTED].

Please contact me if you have any questions.

Sincerely,

COZEN O'CONNOR

By: David Heffernan

Counsel for

T'way Air Co., Ltd.

Enclosure

~6271Street, NW Suite 1lOa Washinaton. D.C ?OMA. .
T'way Air Co., Ltd.

Plan to Address the Needs of Families of Passengers

Involved in Foreign Air Carrier Accidents

T'way Air Co., Ltd. (hereinafter referred to as "T'way Air") is a Korean passenger scheduled

and charter air carrier. The Plan below summarizes the procedures that T'way Air has instituted

in order to meet the needs of the families of passengers involved in any aircraft accident

involving a T'way Air aircraft and resulting in a major loss of life, in accordance with the U.S.

Aviation Disaster Family Assistance Act of 1996 (49 U.S.c. SS 1136 & 41113) ("the Act") and

the Foreign Air Carrier Family Support Act of 1997, (49 U.S.C. S 41313), as amended by the

Wendell H. Ford Aviation Investment and Reform Act for the 21st Century (April 5, 2000) and

the Vision 100 - Century of Aviation Reauthorization Act.

The purpose ofT'way Air's Family Assistance Plan is to:

Effectively implement its Emergency Response Plan;

• Coordinate Emergency Response efforts with the National Transportation Safety

Board (NTSB);

• Act in the best interests of the survivors and families of the victims;

• Treat survivors and families with dignity; and

• Respect the cultural traditions and religious beliefs of the survivors and families.

This document and its assurances are part of a larger process outlined in the T'way Air

Emergency Response Manual (ERM), which includes coordination with the NTSB and other

government agencies to assist survivors and families in the event of an aviation disaster within

U.S. territories. The ERM contains the procedures and family assistance services which T'way

Air will provide in the event of an aviation disaster. T'way Air recognizes that in the event of

an accident or an operational incident, no person may impede the ability of government

authorities to carry out their responsibilities.

1. Toll-Free Telephone Number. In case of an aircraft accident or incident that occurs within

the U.S. and involves injuries to passengers, crew members and any other persons (hereinafter

collectively referred to as "passengers") on board an aircraft operated by T'way Air, the carrier

will publicize a reliable, toll-free, direct dial telephone number, and will provide suitably trained

staff, either employees of the company, or of independent contractors, to handle calls from the

families of all passengers on board the T'way Air aircraft.

The toll-free number will be provided to the DOT, the NTSB and the organization designated for

an accident or incident under 49 U.S.C. S I I 36(a)(2), which is expected to be the American Red

Cross. The number will also be released to the news media, local fire departments, and the

relevant local airport authority if the accident or incident happens on or near an airport where the

aircraft is taking off or landing. The toll-free number will be provided to these groups as soon

as T'way Air has confirmed that one of its aircraft was involved in an accident or incident. All
information provided to the media will include a request that any report on the accident include

T'way Air's toll-free number.

T'way Air will provide a reliable publicized toll-free telephone number with suflicient capacity

to handle the anticipated call volume.

T'way Air will issue press releases asking the media to request that the toll-free number be used

only by those who have reason to believe a family member or friend was a passenger on the

accident flight.

T'way Air will emphasize in the press releases that, upon initial contact with T'way Air, family

members will receive basic accident flight and point-of-contact information as the first steps of

T'way Air's humanitarian support.

T'way Air will ask the media to reemphasize the name of the carrieres) involved, the accident

flight number, airport of origination, connection, and final destination.

T'way Air will provide the media with continuous updates on the progress of the notification

process, such as providing the number of victims' families notified as of a certain time and the

number remaining to be notified. This process will continue until all victims' families have

been notified.

T'way Air will modify its normal "on-hold" messages during an accident to eliminate music,

sales information, and similar non-accident related messages.

T'way Air will provide timely notification to family members of passengers, before providing

any public notice of the names of the passengers. At a family member's request, T'way Air will

inform the family if the passenger's name appears on a preliminary manifest for the accident

flight. Updated information on passengers will be provided to family members as it becomes

available.

T'way Air will provide notification to family members. T'way Air will not release passenger

names to the public. T'way Air will request that families designate one primary contact point

for purposes of sharing information. T'way Air is under no obligation to release the victim's

name if family members request otherwise.

T'way Air will inform family members at the time of notification of the availability of family

care and crisis assistance by the American Red Cross at the Family Assistance Center (FAC) and

after families return home. T'way Air will also relay requests tot crisis assistance to the

American Red Cross representative, where practical.

All U.S. stations used by T'way Air will be notitied of an aircraft accident or incident requiring

activation of this plan. These stations will contact their local airport authority and provide a

telephone number where station managers may be contacted in the event that families of victims

and/or survivors require assistance at airports other than the origin or destination airports of the

aircraft involved.

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In the event that T'way Air is operating sub-service for another air carrier, T'way Air will

coordinate with that carrier to determine which toll-tree number should be released for additional

information.

2. Notification oLFamilies. Following an aircraft accident or incident in the U.S., families of

the passengers will be notified as rapidly as possible, in person if possible, before providing any

public notice of the names of the passengers, by T'way Air's Emergency Response Manager or

other suitably trained individuals employed by the carrier, or subcontracted emergency service.

Notification to families will be provided to the family of a passenger as soon as T'way Air has

verified that the passenger was aboard the aircraft, whether or not the names of all the passengers

have been verified and not be delayed pending verification of the entire crew list or passenger

manifest. In the event that contact cannot be made with the family, T'way Air will request

assistance from the organization designated for the accident uhder S 1I36(a)(2). In the event

that contact cannot be made within a reasonable period, the list of passengers may be made

public at the carrier's discretion. A list of the names of the passengers aboard the aircratl

(whether or not such names have been verified), addresses and telephone numbers will be

provided by T'way Air to the director of family support services designated for the accident

under S II36(a)(I) and to the organization designated for the accident under S 1136(a)(2), likely

the American Red Cross.

3. Notification ofPronertv Owners. In the case of an accident that results in significant

damage to a manmade structure or other property on the ground that is not government-owned,

T'way Air will promptly provide notice, in writing, to the extent practicable, directly to the

owner of the structure or other property about liability for any property damage and means for

obtaining compensation.

At a minimum, the'written notice provided by T'way Air shall advise an owner (I) to contact the

insurer of the property as the authoritative source for information about coverage and

compensation; (2) to not rely on unofficial information offered by air carrier representatives

about compensation by the air carrier for accident-site property damage; and (3) to obtain

photographic or other detailed evidence of property damage as soon as possible after the

accident, consistent with the restrictions on access to the accident site.

4. List of Passengers. On flights carrying U.S. citizen or permanent resident passengers to,

from, or within the U.S., T'way Air's Operations Department will have collected full details of

the passengers to be carried on the flight, including the passengers' full names and contact details

of their next of kin. U.S. citizen or permanent resident passengers will be refused carriage if

this information is not provided.

For the carriage of non-U.S. citizen or permanent resident passengers, T'way Air will have

collected the full names of any such passengers to be carried on board a T'way Air aircraft. The

list will be cross-checked as passengers on board the aircraft. The carrier's Operations

Department will be notified of any changes to the previous information supplied.

T'way Air will have on file names and contact information on any T'way Air employees or

agents who are carried aboard the aircraft.

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In the event of an aircraft accident or incident, the full passenger details will be made available to

the Director of Family Support Services designated for the accident under S 1136(a)(I) of the

Act and, in the case of U.S. citizens or permanent residents, to the American Red Cross.

Manifest Policies and Procedures

On request from the NTSB, T'way Air will provide the most updated copy of the Passenger and

Crew Manifest to the Director-In-Charge of the NTSB. The list will be marked by a version

number (i.e., vI, v2, etc.) and stamped as "confidential" - and "Not for Public Dissemination".

The Passenger and Crew Manifest will be updated as confirmations occur, and updates will be

provided periodically to the NTSB.

The internal policy ofT'way Air strictly prohibits anyone within the company to release

passenger manifest information in the event of an emergency. Upon receiving notification of an

aircraft incident or accident, access to computer passenger lists will be restricted to prevent any

unauthorized use in accordance with company policy.

5. Consultation Regarding Disposition of Remains and Effects. T'way Air will consult with

families of passengers concerning the disposition of the passengers' remains and personal effects

that are under control of the carrier. Wishes of the families will be honored as much as possible.

6. Return of Possessions. Ifrequested by the family ofa passenger, any of the passengers'

possessions and/or personal effects under the control ofT'way Air will be returned to the

families unless the possession is needed for the accident investigation or any criminal

investigation.

7. Unclaimed Possessions Retained. Any of the passengers' unclaimed possessions and/or

personal effects will be retained by T'way Air for a period of eighteen (18) months after the date

of the accident or incident.

8. Monuments. T'way Air will consult with the,family of each passenger about the

construction by T'way Air of any monument to the passengers built in the United States,

including any inscription on the monument.

9. Equal Treatment of Passengers and Victims. T'way Air will provide equal treatment to

the families of all passengers and victims of the accident, regardless of citizenship, class of

service, or revenue status, to the extent permitted by applicable law.

to. Service and Assistance to Families of Victims. T'way Air will work with the NTSB or

any organization designated under S 1I36(a)(2) of the Act on an on-going basis to ensure that

families of all passengers receive an appropriate level of services and assistance following an

accident or incident involving T'way Air aircraft.

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Facilities at Departure, Arrival, and Connecting Airports

T'way Air will secure facilities at departure, arrival, and connecting airports for family members

and friends who may be gathering .. This facility is designed to allow family members to grieve

in private, shielding them from the media and solicitors; it serves as a secure location where

families can receive continuous updates regarding the reconciliation of the passenger manifest

and other accident information. T'way Air will be prepared to provide the necessary assistance

to special needs populations per the Americans with Disabilities Act (ADA). T'way Air will

arrange for one of its representatives who has been trained in crisis response to meet privately

with family members once they have arrived at the facility.

Family Assistance Center (FAC)

T'waY'Air will secure a facility to be used as the Family Assistance Center (FAC). Factors to

consider in selecting a facility are quality of rooms and size offacility, privacy for family

members, ability to secure the facility, and proximity to the accident site and medical treatment

facilities.

T'way Air will provide logistical support to family members who desire to travel to the accident

city (or to a hospital location) that includes, but is not limited to, transportation, lodging, meals,

security, communications, and incidental expenditures so as to provide for the physical care of

the family while the family is staying at the accident city (or hospital location).

Transportation, lodging, meals and incidental costs for survivors and families will be arranged

through T'way Air. A Family Assistance team member will be assigned to each family to meet

family members as they arrive, provide support while at the FAC, and assist family members as

they depart. A Family Assistance team member will also be assigned and maintain contact with

those fiunily members who do not travel to the FAC.

T'way Air will assist family members as they travel to and from the city by informing flight

crews and airport personnel about family members aboard particular flights.

T'way Air will provide a contact person to meet family members as they arrive and accompany

them at the accident city. This person will be responsible for assisting the family while in the

accident city and should continue to be the air carrier interface with the family until the family

returns to their residence. At that time, T'way Air may decide to designate a single contact

person for all family members. This point of contact should be available through a toll-free

phone number.

T'way Air will maintain daily contact with family members who do not travel to the accident

city by providing a contact person until the on-site investigation has concluded.

T'way Air will establish an exclusive badge system to identify family members at the FAC.

T'way Air will make provisions for private areas within the hotel for medical examiner

personnel and the DMORT FAC Team to collect ante mortem information and DNA reference

samples from families.

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Joint Family Support Operations Center

T'way Air will make provisions for a Joint Family Support Operations Center (JFSOC) at the

FAC to include a senior T'way Air representative as liaison with the Director of the NTSB TDA.

T'way Air will also provide space with furnishings, communication and logistical support for the

JFSOC, in coordination with the NTSB.

The senior T'way Air representative will participate and provide operational updates during daily

coordination meetings to review daily activities, resolve problems, and synchronize future family

support operations and activities at the FAC. This information is helpful in planning logistical

support (such as meals, lodging, and transportation) and allows for an update of current and

future support operations.

11. Compensation to Service Organizations. T'way Air will provide reasonable

compensation to any organization designated under S 1136(a)(2) of the Act for services provided

by the organization on behalf of the carrier. For expenses related to implementing this plan, the

organization designated under S 1136(a)(2) of the Act shall obtain invoices or other records for

all outside services and/or materials arranged on behalf of T'way Air.

12. Travel and Care Expenses. T'way Air will provide reasonable accommodation and

transportation for the families of passengers who wish to travel to the accident site. Upon

request, the carrier will work with the responsible authorities to arrange family visits to the

accident site or to the hospital(s), unless access to the site is limited by terrain, biohazard and/or

hazardous materials concerns, security measures, or other unforeseen conditions.

13. Access to NTSB Proceedings. In the case of an accident in which the National

Transportation Safety Board conducts a public hearing or comparable proceeding at a location

greater than 80 miles from the accident site, T'way Air will ensure that the proceeding is made

available simultaneously by electronic means at a location open to the public at hoth the origin

city and destination city of the carrier's flight if that city is located in the United States.

14. Training. T'way Air has trained personnel to meet the needs of survivors and family

members following an accident. When an agent of the airline is expected to provide assistance

to passengers and families of passengers following an accident, T'way Air will ensure that the

agent has been provided with adequate training.

T'way Air provides appropriate training to its employees and agents to meet the needs of

survivors and family members following an aircraft accident. T'way Air recognizes that any

employee in a public contact position may be called upon to respond to inquiries and requests in

the event of an accident. Public contact employees, including but not limited to reservations,

airport, and cargo personnel, will participate in the basic emergency response training. Topics

will include information on how to respond to inquiries and requests trom the survivors and

families of victims.

T'way Air will provide appropriate training for volunteers with family assistance responsibilities.

Training will be mandatory for employees who have volunteered to provide humanitarian

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assistance to survivors and families of victims. Confidentiality, care and concern for the

families and other related issues will be discussed in the training.

Employees with emergency response responsibilities will be required to participate in annual

recurrent training.

T'way Air will conduct periodic rehearsal of emergency response plans, including activation of

the Family Assistance team. Where possible, simulations will be held in conjunction with

airport authorities.

15. Consultation Concerning Assistance to United States Citizens. T'way Air will, where it

volunteers assistance to United States citizens within the United States with respect to an aircraft

accident outside the United States involving a major loss of life, consult with the National

Transportation Safety Board and the Department of State on provision of assistance.

16. Resources for Plan. T'way Air will ensure that sufficient resources are committed to carry

out this plan in the event of an accident or incident involving a T'way Air aircraft.

17. Coordination with the Department of Justice. If the airline disaster is officially declared

a criminal act, T'way Air will coordinate, as necessary, with the Federal Bureau of Investigation

(FBI) Office of Victim Assistance (OVA) in arranging for family assistance.