THE SECRETARY OF TRANSPORTATION 

WASHINGTON, D.C. 20590 

The Honorable Alan Grayson 

U.S. House ofRepresentatives 

Washington, DC 20515 

Dear Congressman Grayson: 

April 03, 2014 

Thank you for your letter regarding the application ofNorwegian Air International Limited 

(NAI) for authority to conduct U.S. services. 

Given that a number of interested parties have filed responsive pleadings to NAI's application 

and this matter is cuiTently pending before the Department, I am sure you understand that I 

cannot comment on the merits ofNAI's application. I assure you, however, that we will give full 

and careful consideration to all of the pleadings filed on the record before we reach a 

determination in this matter. 

As is our standard practice, I am placing a copy of your letter and my response in Docket 

DOT-OST-2013-0204, as a contact outside the record of this case. You may track the progress 

of this case and view the publicly available documents filed in the docket by accessing the 

Federal Docket Management System at www.regulations.gov and searching for Docket 

DOT-OST-2013-0204. 

I hope this information is helpful. 

Sincerely, 

Anthony R. Foxx 
ALAN GRAYSON 

9TH DISTRICT, FLORIDA 

COMMITTEE ON FOREIGN AFFAIRS 

SUBCOMMITTEE ON 

WESTERN HEMISPHERE 

SUBCOMMITTEE ON 

MIDDLE EAST AND NORTH AFRICA 

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wmtasbtngton.tD~ 20515-0909 

COMMITTEE ON SCIENCE, SPACE, 

AND TECHNOLOGY 

SUBCOMMITTEE ON ENERGY 

SUBCOMMITTEE ON ENVIRONMENT 

REGIONAL DEMOCRATIC WHIP 

Secretary Anthony Foxx 

Department of Transportation 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

January 7, 2014 

430 CANNON HOUSE OFFICE BUILDING 

WASHINGTON, DC 20515 

(202) 225- 9889 

ORLANDO DISTRICT OFFICE 

5842 SOUTH SEMORAN BOULEVARD 

ORLANDO, FL 32822 

(407) 615-8889 

KISSIMMEE DISTRICT OFFICE 

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SUITE 550 

KISSIMMEE, Fl 34731 

(407) 518-4983 

grayson.house.gov 

Re: Application ofNorwegian Air International Limited, Docket DOT-OST-2013-0204 

Dear Secretary Foxx: 

I write to express my deep concern over the application before your Department by Norwegian 

Air International Limited (NAI) for exemption authority and a foreign air carrier permit. 

Approval of this application would not be in the public interest for the reasons I explain below. 

Bt:hind the NAI application lies a global outsourcing business model for its pilots and flight 

attendants (or "aircrew") that will put U.S. airlines and their employees at a competitive 

disadvantage. Indeed, this airline bearing the name "Norwegian" describes itself in the 

application as "a foreign carrier of Ireland." NAI's application provides little information about 

itself or its plans, but from media reports it appears to be in the same corporate family with 

another carrier, a rapidly-growing low-cost airline, Norwegian Air Shuttle (NAS). For one thing, 

the CEO ofNAI, named in the application as Asgeir Nyseth, is the Chief Operating Officer of 

NAS. For another, NAI is seeking an operating license from Irish aviation authorities, a step that 

NAS previously signaled in the media it would take. 

The cause of my deep concern is NAS' publicly-stated desire to avoid the obligations of 

Norwegian labor law. NAS has stated that, to conduct its new long-haul operations, including 

those to the U.S., it will seek to register its aircraft in, and receive an air operator's certificate 

from, a European Union country whose labor laws, unlike Norway's, will allow outsourcing of 

aircrew beyond the EU. NAS/NAI has chosen Ireland. NAS has stated that it plans to operate 

this Irish subsidiary-registered aircraft to fly from Norway and other EU points to the United 

States with outsourced lower-wage aircrew, based in Southeast Asia, under individual 

employment contracts governed by Singapore law. It appears that NAS may now intend to use 

NAI as its Irish affiliate to bring its plan to fruition. 

NAIINAS's business model is designed expressly to undermine fair wages and working 

conditions. It would also put U.S. carriers who have to compete against it at a competitive 

disadvantage. Accordingly, approval ofNAI's application for authority would be inconsistent 

510-140107-012 PRINTED ON RECYCLED PAPER 
with the Congressionally-established public interest as set forth in the aviation statutes. Thank 

you for your consideration. 

Sincerely, 

Alan ~~~ Grayson 

Member of Con:: 

S10-140107-012