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 21 st 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 ofFamilies ofPassengers 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 II36(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 ifthe 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. Allinformation provided to the media will include arequestthat any report on the accident include

T'way Air's toll-free number. T'way Air will provide areliable publicized toll-free telephone number with suflicient capacity to handle the anticipated call volume. T'way Air will issuepress releases asking the media to request that the toll-free number beused only bythose who have reason to believe afamily member orfriend was apassenger on the accident flight. T'way Airwill emphasize in thepress releases that, upon initial contact with T'way Air, family members will receive basic accident flightand 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 ofthe carrieres) involved, the accident flight number, airport oforigination, connection, and finaldestination. T'way Air will provide the media with continuous updates on the progress ofthe notification process, such as providing the number ofvictims' families notified as ofa certain time andthe number remaining tobe 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 ofpassengers, before providing any public notice ofthe names ofthe passengers. At afamily member's request, T'way Air will inform the family ifthe passenger's name appears on apreliminary manifest forthe accident flight. Updated information onpassengers willbe provided to family members as itbecomes available. T'way Air will provide notification to family members. T'way Airwill notrelease passenger names to the public. T'way Airwill request that families designate one primary contactpoint forpurposes of sharing information. T'way Airis under no obligation to release thevictim's name iffamily members request otherwise. T'way Air will inform family members atthe time ofnotification ofthe availability offamily care and crisis assistance by the American RedCross atthe Family Assistance Center (FAC) and after families return home. T'way Airwill alsorelay requests 

## tot crisis assistance to the American Red Cross representative, wherepractical.
All U.S. stations used byT'way Air will be notitied ofan aircraft accident or incidentrequiring activation ofthis plan. These stations will contacttheir local airport authority and provide a telephone number where station managers may be contacted inthe eventthat families ofvictims and/or survivors require assistance at airports otherthan the origin or destination airports ofthe aircraft involved.

2In the event that T'way Air is operating sub-service for another air carrier, T'way Airwill

coordinate with that carrier to determine which toll-tree number should bereleased for additional information.
2. Notification oLFamilies. Following an aircraft accident or incident inthe U.S., families of the passengers will be notified as rapidly as possible, inperson ifpossible, before providing any public notice ofthe names ofthe passengers, by T'way Air's Emergency Response Manager or other suitably trained individuals employed bythe carrier, or subcontracted emergency service. Notification to families will beprovided to the family ofapassenger as soon as T'way Airhas verified that the passenger was aboard the aircraft, whether ornotthe names ofall the passengers have been verified and notbe delayed pending verification ofthe entire crew list orpassenger manifest. Inthe event that contact cannot be made with the family, T'way Air will request assistance fromthe organization designated forthe accident uhder 

## S 1I36(a)(2). Inthe event that contact cannot be made within areasonable period, the list ofpassengers may be made public atthe carrier's discretion. A listofthe names ofthe passengers aboard the aircratl (whether or not such names have been verified), addresses and telephone numbers willbe provided by T'way Air to the director offamily support services designated for the accident under 

## S II36(a)(I) and to the organization designated forthe accident under 

## S 1136(a)(2), likely the American Red Cross.
3. Notification ofPronertv Owners. In the case ofan accident that results in significant damage to amanmade 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 ofthe structure or other property about liability forany property damage and means for obtaining compensation.
At aminimum, the'written noticeprovided by T'way Air shall advise an owner (I) to contact the insurer ofthe property as the authoritative source forinformation about coverage and compensation; (2) to notrely onunofficial 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 ofproperty damage as soon as possible after the accident, consistent with the restrictions on access to the accident site.
4. List ofPassengers. On flights carrying U.S. citizen orpermanent resident passengers to, from, orwithin 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 oftheir next ofkin. U.S. citizen orpermanent resident passengers willbe refused carriage if this information is notprovided.
Forthe carriage ofnon-U.S. citizen orpermanent resident passengers, T'way Air will have collected the full names ofany suchpassengers to be carried onboard aT'way Air aircraft. The listwillbe cross-checked as passengers onboardthe aircraft. The carrier's Operations Department will benotified ofany changes to the previous information supplied. T'way Air will have on file names and contact information on anyT'way Airemployees or agents who are carried aboard the aircraft.

3In the event ofan aircraft accident orincident, the full passenger details will be made available to

the Director ofFamily Support Services designated forthe accident under 

## S 1136(a)(I) ofthe Act and, in the case ofU.S. citizens orpermanent residents, to the American Red Cross. Manifest Policies and Procedures On request from theNTSB, T'way Airwill provide the most updated copy ofthe Passenger and Crew Manifest to the Director-In-Charge ofthe NTSB. The listwillbe marked by aversion number (i.e., vI, v2, etc.) and stamped as "confidential"

- and "Not forPublic Dissemination". The Passenger and Crew Manifest will beupdated as confirmations occur, and updates willbe provided periodically to the NTSB. The internal policy ofT'way Air strictly prohibits anyone within the company to release passenger manifest information inthe event ofan emergency. Upon receiving notification ofan aircraft incident or accident, access to computer passenger lists willberestricted to prevent any unauthorized use in accordance with company policy.
5. Consultation Regarding Disposition ofRemains and Effects. T'way Air will consult with families ofpassengers concerning the disposition ofthe passengers' remains and personal effects that are under control ofthe carrier. Wishes ofthe families will be honored as much as possible.
6. Return ofPossessions. Ifrequested by the family ofa passenger, any ofthe passengers' possessions and/or personal effects underthe control ofT'way Airwill bereturned to the families unless the possession is needed forthe accident investigation or any criminal investigation.
7. Unclaimed Possessions Retained. Any ofthepassengers' unclaimed possessions and/or personal effects will be retained by T'way Air for aperiod ofeighteen (18) months after the date ofthe accident orincident.
8. Monuments. T'way Air will consult with the,family ofeach passenger about the construction by T'way Air ofany monument to the passengers built inthe United States, including any inscription on the monument. 9. Equal Treatment ofPassengers and Victims. T'way Air will provide equal treatment to the families ofallpassengers andvictims ofthe accident, regardless ofcitizenship, class of service, or revenue status, to the extent permitted by applicable law. 

## to. Service and Assistance to Families ofVictims. T'way Air will work with the NTSB or any organization designated under

## S 1I36(a)(2) ofthe Acton an on-going basis to ensure that families ofall passengers receive an appropriate level ofservices and assistance following an accident or incident involving T'way Air aircraft.

4Facilities at Departure, Arrival, and Connecting Airports

T'way Air will secure facilities at departure, arrival, andconnecting airports for family members and friends who maybe gathering

.. This facility is designed to allow family members to grieve in private, shielding them fromthe media and solicitors; it serves as a secure location where families canreceive continuous updates regarding the reconciliation ofthe passenger manifest and other accident information. T'way Air will beprepared to provide the necessary assistance to special needs populations per the Americans with Disabilities Act (ADA). T'way Air will arrange for one ofits representatives who has beentrained in crisis response to meetprivately with family members once they have arrived atthe facility. Family Assistance Center (FAC) T'waY'Air will secure afacility to beused as the Family Assistance Center (FAC). Factors to consider in selecting afacility are quality ofrooms 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 ahospital location) that includes, but is not limitedto, transportation, lodging, meals, security, communications, and incidental expenditures so as toprovide for the physical care of the family while the family is staying atthe accident city (orhospital location). Transportation, lodging, meals and incidental costs for survivors andfamilies 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 atthe 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 donot travel to the FAC. T'way Air will assist family members as they travel to and fromthe 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 atthe accident city. This person will beresponsible for assisting the family while inthe accident city and should continue to bethe air carrier interface with the family until the family returns to their residence. Atthat time, T'way Air may decide to designate a single contact person for all family members. This point ofcontact should be available through atoll-free phone number. T'way Air will maintain daily contact with family members who do not travel to the accident city by providing acontact person until the on-site investigation has concluded. T'way Air will establish an exclusive badge system to identify family members atthe FAC. T'way Air will make provisions forprivate areas within the hotel formedical examiner personnel and the DMORT FAC Team to collect ante mortem information and DNA reference samples from families.

5Joint Family Support Operations Center

T'way Air will make provisions for aJoint Family Support Operations Center (JFSOC) at the FAC to include a senior T'way Airrepresentative as liaison with the Director oftheNTSB TDA. T'way Air will also provide space with furnishings, communication and logistical support for the JFSOC, in coordination with theNTSB. The senior T'way Airrepresentative will participate and provide operational updates during daily coordination meetings to review daily activities, resolve problems, and synchronize future family support operations and activities atthe FAC. This information is helpful inplanning logistical support (such as meals, lodging, andtransportation) and allows for anupdate ofcurrent and future support operations.
11. Compensation to Service Organizations. T'way Airwill provide reasonable compensation to any organization designated under 

## S 1136(a)(2) ofthe Act for services provided by the organization on behalf ofthe carrier. For expenses related to implementing this plan, the organization designated under 

## S 1136(a)(2) ofthe Act shall obtain invoices or other records for all outside services and/or materials arranged onbehalfofT'way Air.
12. Travel and Care Expenses. T'way Air will provide reasonable accommodation and transportation forthe families ofpassengers who wishto travel to the accident site. Upon request, the carrier will work with the responsible authorities to arrange family visits to the accident site orto the hospital(s), unless access to the site is limited byterrain, biohazard and/or hazardous materials concerns, security measures, or other unforeseen conditions.
13. Access to NTSB Proceedings. Inthe case ofan accident in which theNational Transportation Safety Board conducts apublic hearing or comparable proceeding at a location greater than 80 miles from the accident site, T'way Airwill ensure that the proceeding is made available simultaneously by electronic means at alocation open to the public athoth the origin city and destination city ofthe carrier's flight ifthat city is located inthe United States.
14. Training. T'way Air has trained personnel to meet the needs ofsurvivors and family members following an accident. When an agent ofthe airline is expected to provide assistance to passengers and families ofpassengers following an accident, T'way Air will ensure thatthe 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 ina public contact position maybe called uponto respond to inquiries and requests in the event ofan accident. Public contact employees, including but not limitedto reservations, airport, and cargo personnel, will participate inthe basic emergency response training. Topics will include information on how to respond to inquiries and requests trom the survivors and families ofvictims. T'way Air will provide appropriate training for volunteers with family assistance responsibilities. Training will be mandatory foremployees who have volunteered to provide humanitarian

6assistance to survivors and families ofvictims. Confidentiality, care and concern forthe

families and other related issues will be discussed inthe training. Employees with emergency response responsibilities will berequired to participate in annual recurrent training. T'way Air will conduct periodic rehearsal ofemergency response plans, including activation of the Family Assistance team. Where possible, simulations will be held inconjunction 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 amajor loss oflife, consult with the National Transportation Safety Board andthe Department of State on provision ofassistance.
16. Resources for Plan. T'way Air will ensure that sufficient resources are committed to carry out this plan in the event ofan accident or incident involving aT'way Air aircraft. 17. Coordination with the Department ofJustice. Ifthe airline disaster is officially declared a criminal act, T'way Air will coordinate, as necessary, with the Federal Bureau ofInvestigation (FBI) Office ofVictim Assistance (OVA) inarranging for family assistance.