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T ourisro ai)CI Sport 

July, 2014 

Mr. Paul Gretch, 

Director, 

Office of International Aviation, 

U.S. Department of Transportation, 

1200 New Jersey Ave, SE, 

Washington, DC 20590, 

USA. 

Dear Mr. Gretch 

Priomh Oifig 

44 Sraid Chill Dara, Baile Atha Cliath 2, Eire. 

Head Office 

44 II I a Street, Dublin 2, Ireland. 

) lo-Call R90-4ll3.;._l J ..,.;-,:J3 l-670 7444 

. 3!.>3-1 670 9633 '1J www.dttas:c 

I am writing to you in relation to the application by Norwegian Air International 

(NAI) to the Department of Transportation for a Foreign Air Carrier permit and 

exemption authority. 

I wish to express this Department's concern at some of the comments relating to 

NAI's application which appear to question Ireland's capability to provide 

effective safety oversight ofNAI's operations. 

I want, therefore, to take this opportunity to place on the record the facts 

concerning Ireland's aviation safety oversight regime. I do so to alleviate any 

unnecessary concerns that ill-informed commentary may have raised. 

As you will be aware, NAI was granted an Air Operator Certificate (AOC) and 

an Air Carrier Operating Licence (ACOL) by the competent licensing 

authorities in Ireland on 12 February 2014. The authority responsible for the 

grant of an AOC in Ireland is the Irish Aviation Authority (IAA). In order to 

secure approval for an AOC in Ireland, NAI was subject to a rigorous 

assessment process over a number of months. The IAA only issued the AOC to 

NAI when it was fully satisfied that the companyfully met all EU safety 

regulatory criteria. 

Ireland has a very strong reputation in aviation at a global level and a robust 

regulatory regime for safety oversight that complies with all requirements of the 

European Aviation Safety Agency (EASA) and the International Civil Aviation 

Organisation (ICAO). Like all EU Member States, Ireland's safety oversight 

capabilities are regularly reviewed by EASA and by ICAO and these 
reviews/audits have consistently ranked Ireland's safety oversight regime as 

amongst the best in the world. 

Every airline licenced in Ireland, is subject to safety oversight in accordance 

with EU Ops Regulations. IAA personnel routinely travel to wherever in the 

world Irish operators carry out approved activities in order to conduct safety 

oversight. This includes on-going inspections of base/line stations, aircraft and 

flight crew during flights. These audit programmes are performed to ensure 

operators comply with all relevant EU Regulations and are part of the IAA's 

safety regulation regime employed on a daily basis. 

The IAA uses these principles to provide safety regulation for all of its 

operators including one of the largest international airlines in the world, which 

operates a point to point system from 64 bases across Europe and North Africa 

carrying 81m passengers per annum. The majority of the flights operated by 

this airline do not operate out of Ireland and the IAA' s safety oversight is 

conducted in the respective foreign jurisdictions. This system of oversight has 

been in operation successfully for a number of decades and proven very 

effective. Some other national regulatory authorities in the EU are also 

accustomed to providing oversight of other large international airlines which 

operate a majority of their services outside of the licencing jurisdiction. This is 

not unusual in an EU context. 

There are approximately 1200 aircraft on the Irish aircraft register. The IAA has 

conducted safety regulatory oversight of long-haul operators with services to 

North America for many years as well as safety regulation of aircraft on the 

Irish register from other regions in the world. In the context of the IAA' s 

existing safety regulation activities, the oversight of NAI does not constitute a 

significant expansion of its existing international aviation safety oversight 

programme and is, in fact, one of the smallest AOCs issued to date in Ireland. 

The Department and the IAA reject suggestions that, on the basis that NAI will 

not be operating from this country, Ireland will be unable to effectively oversee 

the safety of the company's operations. Such commentary represents a 

misunderstanding of how the safety oversight of international airlines operates 

in practice and how it is successfully carried out by EU civil aviation regulators 

in full accordance with EU law. 

Claims have also been made in some of the comments in the on-line docket that 

NAI's Irish AOC is a 'flag of convenience', a claim that the Department also 

rejects. The facts are that NAI is an Irish domiciled business entity and is a 

subsidiary of the parent company, Norwegian Air Shuttle. All accountable 

post-holders of NAI are based in Ireland, with a significant number of staff 
based at its Irish office at Dublin airport. The IAA would not support the 

maintenance of an AOC to any operator unless this safety requirement was fully 

adhered to. 

The Irish and U.S. aeronautical authorities have a strong record of successful 

collaboration and I know that concerns about our regime are not shared by the 

Department of Transportation or the Federal Aviation Administration. 

Nonetheless, the Irish authorities consider it necessary at this point to set the 

record straight and protect the reputation of Irish airlines and Irish aviation. I 

would be grateful, therefore, if a copy of this letter could be placed in the online docket. 

Finally, it would be appreciated if the Department of Transportation could 

process NAI' s applications as expeditiously as possible in accordance with the 

EU-US Open Skies Agreement. This Department and the relevant licensing 

authorities are available to assist your Department should any further 

information be required. 

I look forward to your response and to a continuation of our successful 

collaboration on aviation matters that has been sustained over many decades. 

Yours sincerely 

John J. Fearon 

Director General of Civil Aviation