THE SECRETARY OF TRANSPORTATION 

WASHINGTON, D.C. 20590 

The Honorable Tim Ryan 

U.S. House of Representatives 

Washington, DC 20515 

Dear Congressman Ryan: 

April 04, 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 currently 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 fil ed on the record before we reach a 

determination in this matter. 

As is our standard practice, 1 am placing a copy of your letter and my response in Docket 

DOT-OST-201 3-0204, 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-20 13-0204. 

I hope this information is helpful. 

Sincerely, 

Anthony R. Foxx 
02-06-14 ; 06:01PM ;T ;m Ryan # 1/ 

1421 LONGWORTH BUILDING 

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 

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