From: Christofano, David (OST)

To: Lynch, Michael (OST)

Cc: Finamore, Robert (OST); Gaynes, Jeffrey (OST); Gretch, Paul (OST)

Subject: FW: Response to your e-mail regarding the Norwegian Air International Limited (NAI) case.

Date: Thursday, April 17, 2014 4:20:48 PM

Good afternoon Michael,

Below is the e-mail response to Mr. Steve Jackson’s e-mail regarding the Norwegian Air

International Limited (NAI) case. The control number for Mr. Jackson’s original e-mail is S10-

140314-001.

Thank you,

David Christofano

X-45

366-0584

From: Christofano, David (OST) 

Sent: Thursday, April 17, 2014 4:17 PM

To: Jackson, Steve (MARAD)

Subject: Response to your e-mail regarding the Norwegian Air International Limited (NAI) case.

Dear Mr. Jackson:

Thank you for your e-mail to Secretary Foxx regarding the application of Norwegian Air

International Limited (NAI) for authority to conduct U.S. services. I am responding on

behalf of the Secretary. 

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

application and this matter is currently pending before the Department, I am sure you

understand that I cannot comment on the merits of NAI’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 e-mail (with attachment) 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 yours,
 Susan L. Kurland

 Assistant Secretary for

Aviation and International Affairs

s 10-140314-001 
From: Jackson, Steve (MARAD) 

Sent: Thursday, March 13, 2014 2:39 PM

To: Anthony Foxx (OST)

Subject: DOT and the US Airline Industry

Secretary Foxx,

I am an employee of the Maritime Administration (MARAD) within DOT and over the past 30 years I 

have experienced the collapse of the US Maritime Industry due to foreign flag shipping. My brother 

Mark Jackson is a Captain for Delta Airlines and he informed me that Delta (and other US Airlines) is 

unfortunately facing a similar threat now in the form of Norwegian Air International (NAI) which is 

described in the attached letter. Apparently, NAI is in the process of requesting a foreign air carrier 

permit and the Delta family is asking that you seriously consider all the possible ramifications of granting 

this permit and not allow it to happen. Any assistance that you can offer regarding this matter would be 

greatly appreciated. Thank you for your time and I hope you have a nice day.

Regards,

Steve

Steve Jackson

MARAD – Norfolk, VA

Steve.jackson@dot.gov

Office 757-322-5822

Cell 757-287-2385
March 1, 2014

My fellow pilots,

In many of our recent communications, we have gone to great lengths to illuminate 

the threats our profession faces from around the world, as well as the remedies to 

mitigate those threats. The volume and frequency of these communications may lead 

some of you to the mistaken impression that we are crying wolf.

But here is the reality, and make no mistake; the wolf is real, he’s scratching at our 

door, and if we ignore him our government is about to let him in.

I am referring to the scheme known as Norwegian Air International, or NAI. This

regulatory con game now has all the pieces assembled, including the approval from 

the Irish government to pose as an Irish airline (even though NAI won’t fly 787s to 

Ireland). If we do nothing, there is a fair chance that by the end of March, DOT 

Secretary Foxx will issue NAI a foreign air carrier permit, allowing this flag of 

convenience scheme to carry passengers from Europe to the United States.

Norwegian and its flags of convenience scheme could undo all the gains we have 

accomplished in the prior decades in just a few years. In historical terms, the 

maritime industry of the past is our paradigm for the present – a booming postwar 

industry, but laid low by foreign registry of ships, and the offshoring of American jobs. 

Over two thousand vessels reduced to just less than four hundred, and over 100,000 

maritime jobs shrunk to barely 2,500. I am showing you the threat to our profession, 

and I am showing you the means to fight.

If NAI is given a pass by our government, it is certain that more will follow. They will 

use Ex-Im bank-financed aircraft crewed by the cheapest non-union pilots available, 

paying the lowest taxes, facing little to no regulatory burden in their “home” nations 

of registry. Our widebody flying will get backed into a corner, fighting to overcome 

the competitive advantage, conferred by our own government - to foreign airlines 

using flag of convenience schemes. Our industry will undoubtedly be spurred to react, 

and the result will as usual, be carnage in the work force.

Now is the time for action! Educate yourself and your family by watching our video at

http://youtu.be/Qj9_jt_5jHY . We are sending a petition to DOT Secretary Anthony 

Foxx, who is now considering Norwegian’s application. Sign that petiton by visiting 

http://takeaction.alpa.org and help us reach the 100,000 mark. Call or write your 

Congressman and your Senators, and ask them to contact the Department Of 

Transportation – let the DOT know in no uncertain terms that their constituents oppose 

this scheme. Donate to ALPA-PAC; your money speaks for your issues, ignores party 

politics, and only goes to the candidates who support airline pilots.
These are not scare tactics, and this is not crying wolf. For our industry to survive, you 

and your family need all the facts that support your resolute action. By working 

together and encouraging our families to speak up, we will influence the outcome. 

Silence is consent. Can you afford to consent to this grim future?

Watch the video: http://youtu.be/Qj9_jt_5jHY and decide for yourself. If you 

conclude, as I believe you will, that this flag of convenience scheme is a threat to you 

and your family, act on it. The time is now.

Fraternally,

Captain Mike Donatelli

Delta MEC Chairman