HISTORY OF FLIGHT On December 31, 2008, about 1259 eastern standard time, an Embraer EMB-145LR, N844MJ, registered to Wells Fargo Bank Northwest Trustee, and operated by Freedom Airlines, Inc., as a Delta Connection flight, was impacted by a tug while sitting at the gate loaded and ready for pushback. There were no injuries to the airline transport-rated pilot, first officer, flight attendant, and 50 passengers onboard. The airplane incurred substantial damage. The pilot stated that the airplane was parked at Gate M, and they were in the process of calling for pushback from the gate when the airplane's right aileron and wing assembly were struck by a baggage cart attached to a ground tug. The tug operator stated that due to heavy winds and pelting sleet his vision was impaired and that he had closed his eyes just prior to his tug nearing the wing. DAMAGE TO AIRPLANE The airplane sustained substantial damage to the right wing, which included cracking and tearing of the upper and lower wing skin panels and splice plates. A portion of the wingbox web upper and lower flange on the right wing was also bent and cracked at the aft end. In addition, the aileron hinge bracket was bent, and the composite splice plate in the outerwing area of the right wing, from the leading edge to the wing tip, delaminated at its forward radius. ADDITIONAL INFORMATION The operator reported a number of factors that contributed to the tug driver's collision with the parked airplane including failure to follow procedures when operating motorized equipment inside the Diamond of Safety, failure to properly position safety cones on the right wing, failure to ensure safe driving in inclement weather, and failure to take a safety time out when unsure of the intended path of the moving vehicle.