### November 7, 2012
VIA FEDERAL EXPRESSAND E-MAIL


### Samuel Podberesky Assistant General Counsel for Aviation Enforcement and Proceedings, C-70 U.S. Department ofTransportation 1200 NewJersey Avenue, S.E.-Room W96-322 Washington, D.C. 20590
Re: Supplementto LAN Colombia's request for EquivalentAlternative under 14C.F.R. 382.67- Docket 

### OST-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 tostore passengers' wheelchairs. This request is ofthe essence to ensure the flexibility ofLAN Colombia's operations. Since our initial requestfor equivalent alternative determination, the company has received three additionaiA320s, bringing ourtotal to four (4) A320s, that we intend to operate to the United States and thatdo not have the required priority in-cabin space for an adult-sized wheelchair as required under §382.67. In support ofthis request, LAN Colombia hereby confirms thefollowing: To provide a similar accessibility to passengers requesting use ofthe 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 ho\ds ofA320s inthefleet.The designated priorityspace will be used forthe stowage of up to two manualfolding 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 forthe stowage of up to two wheelchairs to the first two passengers with a disability requesting the onboard stowage ofthe wheelchair. No additional items will be stored in the Wheelchair Priority Space when anywheelchair 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 protectthe wheelchairs from the effects of weather.Further, and as deemed necessary, the wheelchairs and their respective protective bags will be secured with the use oftie-downs in the priorityspace ofthe cargo hold. Any individuals with a disability who request in-cabin stowage for a manual folding wheelchair will be informed ofthe available Wheelchair Priority Space, includingthe 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 properlycare forthe 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 thefirst items removed from the aircraft. In the event of a delay, loss or damage of a wheelchair, LAN Coiombia 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 saicf temporary replacement and/or reimbursement will be provided in addition to any other reimbursements available to the passengers as a result ofthe delay, loss ordamage, like 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 wheelchairwith orwithoutwheels. 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 requestfor equivalentalternative in April, LAN Colombia has incorporated three additional A320 aircraft, bringingthetotal to four aircraft are unable to operatetothe United States. Wetherefore appreciate the Department's expeditious consideration ofthis matter. LAN Colombia believes thatthe request is reasonable and providesthe same orgreater accessibility to passengers with a disability as provided underthe Air CarrierAccess Act. We remain available to respond to any questions that may arise regarding the previous. We also understand the Department's favorable ruling on ourapplication may be subjectto otherconditions not setforth in this supplement, and we inviteyou to open aconversation about any such conditions at anytime.

Pablo Chiozza VP Sales North America and the Caribbean as US GSA for LAN Colombia

### ANNEX 1 CARGO HOLD DIAGRAM

f{l:.f.fl (!lLLK.) Co\f<(i{J HOLll**(·:~Ot'."ARINI:.~** I**~)** '
. ' fORW.4R3**C.~RG::l HO~D** 

(CO!>'F·AR**l!~c**'il :}**A~** i C:\RGO HDLD**(COt•1PARTf~lNI** 3 Al<O 4) 

# I**3~** .003 !fl



### (lzzo.s'l 

## trTFigure No.1. Cargo Hold Distribution ,' ,'

This isthe AFT cargo hold portionto be used to stowthe wheelchairs

As previously stated, the wheelchairs will be located on theforward section oftheAft Cargo Bulk Camp No.5.

Figure No.2. Comp 5-Cargo Bulk Hold

### ANNEX 2 CARGO COMPARTMENTDOOR

Figure 3. BulkCargo 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 protectthe Bulk Compartment Door.



### Figure 4. Cargo Diverders Net Comp 5 11

### Bulk"ANNEX 4TIE-DOWN POINTS

f·JET ATI ACHt1EIH S

### At-JO TIE DOV•If'l POINTS

Figure 5. NetAttachments and Tie Down Points

REFERENCE POINTS FOR NETATIACHMENTS ANDTIE DOWN POINTS 

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## -Y 

# ----, 

# ,- ---··-- ·- N:

I

# l



# ' c B 

## A A B 

# c - -I 

# II· (I. 

## I I 

## i I j / f I ( ' 

### I
. 

# lj

Figure 6. Reference Pointsfor Bulk Cargo Hold Compartment Thefiguresshown in this annexwere takenas referencefrom the weightandbalance manual fortheA320FAMopplicoble to LAN Colombia.

### ANNEX 5 DEDICATED WHEElCHAIR lOCATION

Dedicated '.'.'heelchair location



### Figure 7. Dedicated wheelchair's location