### THE SECRETARY OF TRANSPORTATION WASHINGTON , D.C

. 20590

The H o nora bl e T im R yan U.S. Hou se o f R ep res entatives Wa s hington , D C 2 0515 D ea r Co n g re ss m a n R y an : April 04 , 2014 ·

Th a nk yo u f o r yo ur le tte r regardin g th e a p p li cati o n ofNo rweg ia n A ir In ternat io na l Li mite d (NAI ) f o r auth or it y t o co ndu c t U. S
. se rv ices. G iv en th a t a num ber o f inte res t e d p a rti es have file d res p o n sive pleadings to NA I 's ap p licati o n and thi s m atte r i s c urrentl y p e ndin g b efor e th e Depar tme nt , I am s ure yo u un derstan d that I cann o t co mme nt o n the m er it s ofNA I 's appl icati o n . I ass ure yo u , however, th a t we w ill g ive full an d care ful c o n si d e r atio n to a ll of the pl ead ings fil ed on t h e record before we reac h a d ete rmin ati o n in thi s m a tte r. A s is o ur s tandard pra cti ce, 1 a m pl ac in g a co py of yo ur le tte r a n d m y res p o n se in D ocket DOT-OST-201 3

- 02 04 , as a co n tact o ut s id e the reco rd of thi s case. Yo u m ay track th e prog ress of thi s case and v i ew th e pu b licly avai lab le doc um e nt s fil ed i n the docket b y accessi n g the Fe dera l D oc k et M an age m e nt System at www. reg ul a ti o n s . gov and searc hin g for Docket DOT-O ST- 2 0 1 3- 0 2 04
. I ho p e t h i s info rm ati o n i s h e lpf ul. S in ce re ly,

A nth o ny R
. Foxx02-06-14 ; 06:01PM ;T ;m Ryan # 1/

1421 LONGWORTH BUILDIN G WASHINGTON , DC 20515 202-225-5261 202-225-3719 FAX 

# • COMMITTEE ON APPROPRIATIONS 

## TIM RYAN February 6, 2014 CONGRESS OF 

### THE UNITED STATES Secretary Anthony Foxx Department ofTransportation 13TH DISTRICT, OHIO 1200 New Jersey Ave, SE I-1, W85-300 Washington, DC 20590 United States 'I)v.NSPORTATION, HOUSING, AND URBAN DEVElOPMENT SUBCOMMITTEE COMMITTEE ON THE BUDGET

Re: Application of Norwegian Air International Limited, Docket DOT-OST-2013-0204. Dear Secretary Foxx, I am writing 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 below. Behind 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 Ita 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 of NAI, 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 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 Jaws, 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. NAI/NAS'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, I believe that approval of NAI's application for authority would be inconsistent with the Congressionally-established public interest as set forth in the aviation statutes. Thank you for your consideration. Sincerely,

## ~ Tim Ryan 197 WEST MARKET STREET

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