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BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, DC

____________________________________________

 )

Application of )

NORWEGIAN AIR INTERNATIONAL LIMITED ) Docket DOT-OST-2013-0204

for an exemption and foreign air carrier permit )

____________________________________________)

COMMENTS OF

THE WASHINGTON AIRPORTS TASK FORCE

The Washington Airports Task Force (WATF) strongly supports the grant of authority to Norwegian Air 

International Ltd. to operate transatlantic air service to destinations within the United States. The 

WATF submits the following in support of Norwegian Air International's application for an exemption 

and a foreign air carrier permit:

1) The Washington Airports Task Force fosters the role of air transportation in the economic and 

cultural life of the National Capital Region and its neighboring states. The WATF cultivates 

relationships and promotes airline competition and regional collaboration in order to create 

sustainable air service and economic growth. The WATF is goal-oriented and works in concert with 

the public and private sectors to catalyze hundreds of millions of dollars in economic return.

2) The U.S.-E.U. Open Skies agreement essentially deregulated the transatlantic market. Economies on 

both sides of the Atlantic are entitled to reap the benefits, just as they have done from deregulation 

of the U.S. domestic market, and much later, the European domestic markets.
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For many years, the WATF strongly supported creation of the U.S.-E.U. Open Skies agreement as 

part of the United States Airports for Better International Air Service caucus.

The transatlantic Open Skies agreement was finally achieved by the U.S. in 2007, just before the 

worst recession since 1929 struck the world’s economy, chilling initiatives to take full advantage of 

the new groundbreaking transatlantic Open Skies agreement. As the economies have slowly 

recovered, so has the opportunity to take full advantage of the U.S.-E.U. Open Skies agreement. 

Norwegian Air International is the first major example. There will undoubtedly be others.

3) Airline concentration over the last few years within the U.S., and indeed within the broader 

worldwide air transport industry, has increased fares and further depressed the demand for travel, to 

the detriment of passengers and the economies of the United States and other countries.

People don’t travel for the sake of travel; they travel for the purpose at the end of the trip, whether 

leisure, business or discretionary. Those myriad purposes form what we call the economy. 

Consequently, transportation has a tremendous economic multiplier effect, and any initiatives to 

stimulate increased travel should be encouraged. As we have seen when restrictive aviation bilateral

agreements have been liberalized, the resulting increase in travel essentially becomes an economic

stimulus package created at the stroke of a pen, and with no cost to the taxpayer, other than the 

salaries of those engaged in the negotiation.

4) The National Capital Region is the fourth largest air travel market in the United States. However, 

just four airlines now control more than 92% of the region’s air travel, and our level of competition 
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is only sustained because we are blessed with three airports – Washington Dulles International 

Airport (IAD), Ronald Reagan Washington National Airport (DCA), and Baltimore-Washington 

International Thurgood Marshall Airport (BWI). While domestic competition has been reduced by 

four mergers among major airlines since 2008, the region enjoys very strong international 

competition. It is currently served by 25 foreign airlines (with a 26th starting in June 2014) who 

collectively carried 41% of the region’s international O&D traffic in 2012 (the most recent full 

calendar year of data), mostly via IAD. Meanwhile, U.S. carriers transported the remaining 59% of 

the international O&D volume on a combination of nonstop flights, largely on United from IAD, and 

via connecting flights from IAD, DCA and BWI to their international gateways in other U.S. cities.

Should Norwegian Air International decide to inaugurate service to the Washington area, the 

introduction of a European low-fare carrier into the current mix of U.S. and foreign airlines offering 

international service here would be a healthy stimulus to transatlantic travel in the United States'

fourth largest economic unit – the National Capital Region and its neighbors – a stimulus whose 

originator should be allowed to either succeed or fail in a free market.

For these reasons, the Washington Airports Task Force strongly supports the application of Norwegian 

Air International for authority to operate transatlantic air service in the belief that further developments 

in low-fare transatlantic service will benefit growth, air service choice and the U.S. economy. For the 

Washington metropolitan area, this will result in significant benefits for the region’s tourism industry, 

universities, companies and residents; in summary, to the benefit of the economic and cultural life of the 

region.
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Respectfully Submitted,

_________________________

Leo J. Schefer, President

Washington Airports Task Force

44701 Propeller Court, Suite 100

Dulles, Virginia 20166

Phone: 703-572-8714

FAX: 703-572-8418

leo@washingtonairports.com

February 13, 2014
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CERTIFICATE OF SERVICE

I hereby certify that I, Leo J. Schefer, have today served a copy of these Comments of the Washington 

Airports Task Force in support of the Application of Norwegian Air International Limited for 

Exemption Authority and a Foreign Air Carrier Permit by electronic mail upon the following:

info@airlineinfo.com

romanow@pillsburylaw.com

peter.nelson@pillsburylaw.com

russell.bailey@alpa.org

steve.morrissey@united.com

dan.weiss@united.com

sascha.vanderbellen@delta.com

howard.kass@usairways.com

robert.wirick@aa.com

francis.heil@aa.com

robert.land@jetblue.com

rpommer@atlasair.com

nssparks@fedex.com

anita.mosner@hklaw.com

jennifer.nowak@hklaw.com

mlbenge@zsrlaw.com

dberg@airlines.org

jcasey@airlines.org

kglatz@airlines.org

ebethke@airlines.org

paul.gretch@dot.gov

brian.hedberg@dot.gov

reese.davidson@dot.gov

esta.rosenberg@dot.gov

brett.kruger@dot.gov

john.allen@faa.gov

jesse.elliot@faa.gov

douglas.schwab@faa.gov

nicholas.tsokris@faa.gov

urskr@state.gov

cristinasa@state.gov

eugene.alford@trade.gov

ejames@jamhoff.com
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elytle@portoakland.com

kgeorge@broward.org

sshur@traveltech.org

edw@ttd.org

mrichardson@swapa.org

_________________________

Leo J. Schefer

February 13, 2014