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 ofinterested 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 ofthe pleadings filed on the record before we reach a determination in this matter. As is our standard practice, I am placing a copy ofyour letter and my response in Docket DOT-OST-2013-0204, as a contact outside the record ofthis case. You may track the progress ofthis 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. FoxxALAN GRAYSON 9TH DISTRICT, FLORIDA
COMMITTEE ON FOREIGN AFFAIRS SUBCOMMITTEE ON WESTERN HEMISPHERE SUBCOMMITTEE ON MIDDLE EAST AND NORTH AFRICA

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### 20515-0909 COMMITTEE ON SCIENCE , SPACE, AND TECHNOLOGY SUBCOMMITTEE ON ENERGY SUBCOMMITTEE ON ENVIRONMENT REGIONAL DEMOCRATIC WHIP Secretary Anthony Foxx Department ofTransportation 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 101 NORTH CHURCH STREET 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 mydeep concern over the application before your Department byNorwegian Air International Limited (NAI) for exemption authority and a foreign air carrierpermit. Approval ofthis application would not be in the public interest for the reasons I explain below. Bt:hind the NAI application lies a global outsourcingbusiness 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 itselfinthe application as "a foreign carrier ofIreland." NAI's application provides little information about itselforits 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 ChiefOperating Officer of NAS. For another, NAI is seeking an operating license from Irish aviation authorities, a step that NAS previously signaled in the mediait would take. The cause ofmy 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'sbusiness 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 beinconsistent



### 510-140107-012 PRINTE D ON RECYCLED PAPERwith the Congressionally-established public interest as set forth in the aviation statutes. Thank you for your consideration.
Sincerely,

# ~~~ Alan Grayson Member ofCon::



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