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# January 26, 2015

BY ELECTRONIC SUBMISSION Docket DOT-OST-199B-3304 Docket Operations Facility U.S. Department of Transportation West Building Ground Floor, Room W12-140 1200 New Jersey Avenue, SE Washington, DC 20590 Hogan Lovells US LLP 

# Columbia Square 555 Thirteenth Street, 

# NW Washinaton. DC 20Dll4



# BY ELECTRONIC MAIL Michael Crook Coordinator, Transportation Disaster Operations Transportation Disaster Assistance Division National Transportation Safety Board 490 L'Enfant Plaza East, SW Washington, DC 20594
Re: Plan to Address the Needs of Families of Passengers Involved in Aircraft AccidentsSubmission of Plan for Air Busan Co., Ltd. •

Ladies and Gentlemen: Pursuant to 49 U.S.C. ~ 41313 and DOT's Notice dated January 20,2004, Air Busan Co., Ltd. ("Air Busan") hereby submits a plan to address the needs of families of passengers involved in accidents within the United States that involve aircraft under the operational control of Air Busan ("Plan"). The enclosed Plan describes procedures that comply with the requirements of the Foreign Air Carrier Family Support Act of 1997, as amended by the Wendell H. Ford Aviation Investment and Reform Act for the 21 st Century (AIR-21 land the Vision 100-Century of Aviation Reauthorization Act. Please contact me if you need additional information regarding Air Busan's Plan. Sincerely,

Partner

Counsel for Air Busan Co., Ltd.
Enclosure

Hagan LDllu!1s US 

# LlP Is 8 

# Umiled Ifablity partnership registered In the 

# District of 

# ColUmbla. 'Hogan Lovell" 

# IS an international legal 

# prselie& thai incluclfls Hogan Lovetls US LlP and 

# Hogan Loyell. tnt8ml'ltionaJ LlP, WIthoffices in: A1icanle Amllerdllm Baltimore Ba~1ng BNlSels Carlcal Colorado Springs Denver Oublll Dusseldorf Ffllnkfurt Hamburg Hanel 

# Ho Chi 

# MOnn Diy HongKong Houston JDhannesbu; 

# London Lot Angeles 

# luxembourg Madrid 

# MexIco Clly Mlaml 

# Milan Monterrey Moscow Munich NewYork NorthamVirginia Pari, Philadelphia Rio d. 

# Janeiru Rome San F1'8nd5COSio Paulo Shanghai SIliconVaney SingapOre Tokyo U18an~atar War~ Wsshinglon DC Msociated offices:Budapest Jakarta Jeddatl Riyadh lagreb. Formore InfomNltlonGOGwww.hogEll1ovellscomAIR BUSAN CO., LTD

. FAMILY ASSISTANCE PLAN 1. Overview 1.1. The .P.urpose
of the Air Busan Co., Ltd ("Air Busan") Family Assistance Plan
is to proVIde company personnel with the guidelines, procedures and training that will enable them to act m the best interests
of the families
of passengers involved

in any aircraft accident that occurs within the United States involving Air Busan aircraft and resulting

in a major loss of life, to treat survivors and families with dignity, and to respect the cultural and religious backgrounds

of survivors and families. 

### Air Busan will commit sufficient resources

to carry out this Plan

. 1.2. This document

is a part of a larger effort, which includes the National Transportation Safety Board, other government entities and appointed independent non-profit organizations,

to assist survivors and families

in the event of an aviation disaster. 2. Pre-Response Planning 2.1. In accordance with the Foreign Air Carrier Family Assistance Act of 1997 (49 U.S.C. Section 1136
& Section41313),

as amended
**~y** Vision 100-Century

of Aviation Reauthorization

Act

, Air Busan will publish this Family Assistance Plan and insert this plan into all appropriate
Air Busan manuals. 2

. 2 . The treatment

of families
of non-revenue passengers (and any other victim of the accident) will be the same as the treatment
of the famtlies
of revenue passengers. 2.3. The Air Busan Emergency Response Team will be utilized

to respond

to likely needs of survivors and families

. 2.4

. Tra

i ning will be based upon employee

' s responsibilitie

s and Air Busan will provide lo gist

i c al support

to the Response Team. 2.5. Training
of Family Assistance Personnel will be conducted

in conjunction with



### Air Susan's training recognizing that: 2.5.1. list of trained Family Assistance Personnel will be maintained

in the 

### Air Busan Emergency Response Plan. 2

. 5

. 2. Personnel who are in public contact positions need to know how to respond

to inquiries and facilitate responses

to them. 2

. 5.3

. may seek assistance from 

### Air Busan

at airports that are neither the origin nor the destination

of the flight. 2

. 5.4

. Simulations

of the Plan will be held annually

in addition

to participation

in local disaster drills. 2.5.5. After an aviation disaster involving

an 

### Air Busan aircraft , a toll-free "800" number will be published, and staff will be assigned

to take calls to such number, for the use of families

to inquire about passengers. 2

. 5

. 6 . 2.5

. 7 . It is Air Busan

's policy that manifest information
will only be released
by the designated
Air Busan Coordinator

to the proper NTSB authorities

, the director of family support services designated
for the accident under section 1136(a)(1), the organization designated
for the accident under section 1136(a)(2);
the Air Busan NTSB Family Assistance Coordinator,

Air Susan's President

, Executive Vice President

, Vice President
of Flight Operations

or Vice President of Human Resources and Administration

or their authorized representatives.
Any other release of manifest information

is considered unauthorized
and prohibited. Air Busan will inform family members
(or family friends or clergy who are with the family)

at an appropriate time

, but as early as possible after being notified

, that it is critical that they contact their family dentlst
to obtain the dental records and dental x-rays of their loved one

. Air Busan will ask the family

to have the records and x-rays sent by special courier

to the address of the hotel where the

# 2

. 5.8

. joint family support operations center will be located. Packages should be addressed

to the Director

1 

# Family SuiJport Services

1 

# NTSB.
If the family

is coming

to the site the next day

I 

# the family may arrange

to hand-carry these documents.

If the family

is already

at the accident site or arrives without making these arrangements

1 

# the Disaster Mortuary Team personnel will coordinate with the family's dentist
to obtain dental records and dental

x - rays

. Air Busan will ensure that its employees and agents receive adequate training

to meet the needs of survivors and family members following

an acctdent. 3 . Passenger Manifest, Ticket Reconciliation

and Notification 3.1. In order
to determine which passengers actually boarded the flight

, 

# Air Busan personnel immediately after the accident will begin

a review of the following

: 3.1.1. On board Passenger Manifest. 3.1.2. Standby passengers. 3.1.3. Non-revenue passengers. 3.1.4

. Re-routed passengers. 3

. 1.5. Passengers who cancelled their reservation. 3.1.6. Jump seat riders. 3

. 2. Air Busan will release

I 

# upon request

, to the NTSB Family Services Director and the American Red Cross or other organization designated
for the accident under section 1136(a)(2)

a **passen~er** 

# list. This would be upon the firm understanding

that the list reflects the best avatlable information

at the time of the request

1 

# that
it may have i naccuracies
and

i t ma y n o t be c omp lete

. 3

. 2.1

. All personnel involved

w i th h andling the manifest will be briefed

as to the confidential

/ sen si t iv e n a ture of thi s information

. 3

. 2.2

. All **a_piJrOJ>riat~** 

# manifest lists will be stamped "PRELIMINARY
AND UNCONFIRMED"

with date

1 

# time and list number

. 3

. 2

. 3. Air Busan wi 11 update the list periodically

or upon request. 3.2.4

. Upon request

, 

# Air Busan will provide

to the Department

of State information

in its possession about U.S

. passengers. 3.2.5. Air Busan will coordinate

as necessary with the Department

of Justice for family meetings

to explain Department

of Justice services. 3.3. Notification Procedures 3

. 3

. 1. As 

# soon as information becomes available
on each IJassenger

, that passenger's family will be notified, whether
or not the names of all of the passengers have been verified. 3.3.1.1. Notification

to family members will be made prior
to release
of the passenger's name to the public and

, to the extent practical

, in person. 3.3.2. Air Busan personnel making the notification will be suitably trained
as noted
in Paragraphs
2.4 and
2

. 5.8 of this document. 3

. 3.3. Air Busan will secure

a facility for family members that will ensure privacy from solicitors and the media

. 3.3.4. After coordination with NTSB

, Air Busan will provide

a joint support operations center
to provide logistical support

to the federal staff. 3

. 3

. 5. As appropriate

I 

# Air Busan will continually update the public on the progress
of family notification.

# 3.4. Confidential/Sensitive Information 3.4.1. As stated
in paragraph 2.5.6 of this document

1 

# any unauthorized release of manifest information

ts prohibited. 4. Passenger Identification 4

. 1. Medical Examiner

/ Coroner 4

. 1
. 1. The medical examiner

or coroner

is responsible

for the positive identification

of fatalities

. 4.1.1.1.
If the victim has died

I 

# the medical examiner will coordinate with the Disaster Mortuary Team Commander

to provide official notification

of death to family. 4.1.1.2. For injured passengers

1 

# the hosP.ital

is responsible

for status updates and either the hospital

or 

# Air Busan wtll advise tlie families. 

# 5. Family Access

to the Accident Site. 5

. 1. The NTSB has accident site jurisdiction. 5.2. Within the limits established

by the authorities

1 

# Air Busan will respond

to family requests for access
to the accident scene. 5.3. Air Busan will assist the family of a passenger traveling

to the location
of the accident and provide for the physical care of the family while the family

is staying

at such location (normally,

up to two family members, but exceptions would be made as individual cases and cultural oifferences would have to be considered). 5

. 3

. 1. For purposes
of this plan

1 

# ·· Family" shall mean legal or c o mm on

l aw

s pouse

I 

# parents
or children
of the injured/deceased

. If the passenger has no Family

as defined

1 

# up to two close living relatives wo u ld be co nsid

e r ed "F amily.

" 5

. 3.2. Physical care

. 5.3.2.1. Transportation

to and from accident city. 5.3

. 2.2. Transportation

to and from accident site. 5

. 3

. 2

. 3 . Hotel accommodations

at accident city for
a reasonable time period. 5.3

. 2.4. Meal voucher during hotel stay and day of travel
to and from the accident city. 6. Human Remains and Personal Effects 6.1. The medical examiner

is responsible

for the disposition

of identifiable
and unidentifiable human remains and for consulting with the family of each passenger about such dispositions. 6.2. Authorities should return identifiable personal effects

to victim's family rather than having Air Busan become

a custodian

of them

; authorities should determine disposition of unidentifiable personal effects. 6

. 3 . Personal effects that come into the control of 

# Air Busan will be handled

in the following manner after release from the NTSB: 6.3.1. Air Busan will consult with each family about the disposition

of personal effects that are in Air Busan

's control. 6

. 3

. 2 . Air Busan will return
to the family

I 

# if requested

I 

# any passenger's possession that is under the control of 

# Air Busan, regardless

of its condition. 6.3.3. Air Busan will retain for 18 months any unclaimed property
of a passenger that is under Air Busan's control.6.3.4.AirBusanwillconsultwiththefamiliesabouttheconstructionbyAirBusanofanyplannedmonument1includingtheinscriptiononit.6.3.5.AirBusanwillonlybeabletoreturnpersonaleffectsthatcomeintoAirBusan'scontroloncepermissionoftheNTSBand/ortheFBIhasbeenobtainedastheitemsmayhavesomebearingontheaccidentinvestigation,oracriminalinvestigation,ifapplicable.7.LiabilityforMan-MadeStructures7.1.Inaccordancewiththe49U.S.C.Section41313(c)Iintheeventofanaccidentresultinginsignificantdamage toman-madestructuresornon-government-ownedpropertyontheground1AirBusanshallpromptlyprovidewrittennotificationdirectlytotheownerofliabilityforanypropertydamageandthemeansforobtainingcompensation.SuchnoticeshalladVIsetheowner:(a)tocontactthepropertyinsurerastheauthoritativesourceforcoverageandcompensationinformation;(b)tonotrelyonunofficialinformationofferedbyAirBusan'srepresentativesaboutcompensationbyAirBusanforaccident-sitepropertydamage;and(c)toobtaindetailedevidenceofpropertydamageassoonaspossiblefollowingtheaccident1consistentwithrestrictionstotheaccidentsite.8.SimultaneousElectronicTransmissionofNTSBHearings8.1.Inaccordancewith49U.S.C.Section41313(c)1intheeventofanaccidentinwhichtheNTSBconductsapublichearingorcomparableproceedingatalocationmorethaneighty(80)milesfromtheaccidentSite1AirBusanshallensuretheproceedingismadeavailablesimultaneouslybyelectronicmeansatalocationopentothepublicattheorigincityanddestinationcityoftheAirBusanflight1ifthatcityislocatedintheUnitedStates.9.RelationshipwithDesignatedIndependentOrganization9.1.AirBusanwillworkwiththeindependentnonprofitorganizationthatisdesignatedunder49U.S.C.Section1136(a)(2)toprovideanappropriatelevelofservicesandassistance,includingmentalhealthandcounselingservices,tofamilies.9.1.1.MentalhealthservicescanbecoordinatedonalocalbasisthroughthenonprofitorganizationortheseservicescanbebroughtinfromanothercitywheretheairlinemayhaveaMentalHealthProfessionalonretainer.9.1.2.Shouldlong-termcounselingberequired1AirBusanwillcoordinatewiththenonprofitorganizationappomtedbytheNTSB1thefamilyandthecompanyprovidingtheservice.9.2.AirBusanwillpayreasonablecompensationtotheNTSB-designatedindependentnonprofitorganizationasrequiredby49U.S.C.Section41313(c)(ll)wheretlienatureandscopeofitsworkandthekindofcoststobeincurredhavebeendiscussedandagreedinadvance.9.3.AirBusanwillcoordinatewithfamilymembersastotheirneedforAmericanRedCrossforassistance.9.4.AirBusanwillparticipateinthedailycoordinationmeetingstoreviewdailyactivitiesIresolveproblemareasIandsynchromzefuturefamilysupportoperationsandactivities.10.FilingofthisdocumentwithNTSBandDOT10.1.PursuanttotheForeignAirCarrierFamilyAssistanceActof1996149U.S.C.Section41313(b)1thisdocumentwillbefiledwiththeNationalTransportationSafetyBoardandtheDepartlnentofTransportation.11.RevisionsandCode-ShareAgreements11.1.AirBusanreservestherighttointroducechangestothisplanfromtimetotime.11.2.AirBusandoesnotpresentlyhaveanapprovedcode-sharearrangementwithanyUnitedStatescarrier.IfAirBusanweretoenterintosuchanagreementanditwereapprovedIAirBusanmayrevisethisplan.12.AccidentsNotCoveredbythisPlan12.1.AirBusanwillconsultwiththeNTSBandtheDepartmentofStateifitvoluntarilyprovidesassistancetoU.S.citizensintheUnitedStateswithrespecttoaccidentsoutsidetheUnitedStatesnotcoveredbythisplaninvolvinglossoflife.13.EmergencyContactInformation13.1.AirBusan's24-hour1365daysayearcontactislocatedinBusan1RepublicofKorea.AnyagentoftheU.S.governmentmaycontactoperationscenterpersonnelatanytimebydia.J.ing•.ThetelephonenumberhasbeensubmittedtotheNTSBandcanbeusedbytheNTSB24hoursperdayIsevendaysperweek.