1 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 transatla ntic 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 ai r 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 econ omic 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. Economie s 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

.2

For many years, the WATF strongly supported creation of the U

. S

. - E

. U

. O pen 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 Internati onal 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 tra vel, 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 purpo ses 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 agreement s have been liberalized , the resulting increase in travel essentially becomes a n 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 th e 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 competition3

is only sustained because we are blessed with three airports

– Washington Dulles Intern ational 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 carrie d 41% of the region’s international O&D traffic in 2012 (the most recent full calendar year of data) , mostly vi a IAD. Mean while , U.S. carriers transporte d 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. c ities.

Should Norwegian Air International decide to inaugurate service to the Washington area, t he 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 stimulu s 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 Airp orts 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 benefit s for the region’s tourism industry, universities, companies and residents ; in summary, to the benefit of the economic and cultural life of the region.4 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, 20145 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 Perm it 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 @ a a.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.go v ejames@jamhoff.com6

elytle@portoakland.com kgeorge@broward.org sshur@traveltech.org edw@ttd.org mrichardson@swapa.org

_________________________ Leo J. Schefer February 13, 2014