ZUCKERT SCOUTT 6- RASENBERGER, L.L.P. 

WILLIAM H. CALLAWAY, JR. 

BY HAND 

Samuel Podberesky 

\ • : ;. '; ! :_ ..... ~ '• .• ·~· 

.888 Seventeenth Street, NW;Washington, DC 20006-3309 

Telephone [202] 298-8660 Fax [202] ~2-0683 

wwwzsrlawcom 

February 23, 2012 

Assistant General Counsel for 

Aviation Enforcement and Proceedings 

U.S. Department of1 :ansportation 

1200 New Jersey Av,., S.E. 

Washington, D.C. 20~i90 

Re: Equivalent Alternative Determination 

Requests Concerning 14 CFR 382.61 

Dear Mr. Podberesky: 

whcallaway@zsrlaw.com 

.. ....... J 

We are writing on behalf of Korean Air Lines Co., Ltd. ("Korean") to request approval 

for seat configuration changes planned tor aircraft covered by Korean's June 3, 2010 equivalent 

alternative determination ("Determination'') concerning 14 CFR 382.61 (movable aisle 

armrests). · · '' ... 

Condition 2 of the Determinations requires the Department's prior approval for any 

seating configuration changes and/or seat dimension changes to be made on any aircraft subject 

to the Determination's approval. By means of this letter Korean requests the Department's 

approval for planned modifications to the business class seats of Korean's A330-200 Enhanced 

("A330-200E") aircraft. 

More specifically, Korean plans to convert the Prestige Plus1 business class seats in five 

A330-200E to Prestige Sleeper2 seats. Korean will utilize conversion kits (consisting of 

hardware and software modifications) in order to accomplish this change. In its Determination, 

the Department approved the Prestige Sleeper seats installed in Korean's B777-300ER, A380-

800, and B787-8 aircraft as equivalent to seats with movable aisle armrests. Korean also plans to 

1 Details of the Prestige Plus seats are set forth in Exhibit KE-5 of Korean's March 1, 2010 

Application for an Equivalent Alternative Determination. 

2 Details of the Prestige Sleeper seats are set forth in Exhibit KE-4 of Korean's March 1, 2010 

Application for an Equivalent Alternative Detern1ination. 

'i 
,, 'ZUCKERT SCOUTT & RASENBERGER, L.L.P. 

Samuel Podberesky 

February 23, 2012 

Page 2 

move the fore and aft business class cabin partitions to create more space in the business class 

cabin.3 With the partitions moved and the seats converted to Prestige Sleeper configuration, 

there will be a significant increase in pitch: from 60" at present to 74" (with no changes in aisle 

width). See Exhibit KE-A attached hereto. This conversion is planned for Korean's five A330-

200E aircraft, four of which have been delivered and one of which is scheduled for delivery in 

early 2013. 

Korean respectfully requests that the Department extend its Determination to the seat 

configuration changes discussed above. The Department has previously approved both the 

Prestige Plus and Prestige Sleeper seats. Korean's planned conversion (changing the seat from a 

170 degree "almost flat" to 180 degree ''full nat" configuration and adding a full 14 inches of 

pitch) will only serve to increase passenger c· •mfort and convenience and will ease seat transfers 

for mobility impaired passengers. 

If you require any additional informcjon concerning this request, please do not hesitate to 

contact us. 

Respectfully submitted, 

/;()Ail~,~- h 

William H. Callaway, Jr. 

Lonnie A. Pera 

David M. Endersbee 

Counsel for Korean Air Lines Co., Ltd. 

3 The pitch ofthe first class cabin's Sleeper seats will not change as a result of the repositioning 

of the partition between the first and business class cabins. 
Korean Air Lines Co., Ltd. 

Exhibit KE-A 
.· ,. 

~- \ .. \; 

,. \ ~- 1 

c 

0 

:p 

'(/) 

~ 

O'l 

-~ 0. 

(1) 

(1) 

lJ} 

I 
..c: 

...... 

"0 .!: 

(1) 

(i) ..c: ·- () ro ...... 

"c.t-

~0 ;::!N