BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

Application of ) 

) 

Norwegian Air International Limited ) 

) Docket DOT-OSTfor an exemption under 49 U.S.C. § 40109 ) 2013-0204 

and a foreign air carrier permit pursuant ) 

to 49 U.S.C. § 41301 ) 

ANSWER OF FEDERAL EXPRESS CORPORATION 

IN SUPPORT OF NORWEGIAN AIR INTERNATIONAL LIMITED'S 

MOTION FOR LEAVE TO FILE AND EXPEDITED TREATMENT 

Communications with respect to this document should be sent to: 

Nancy S. Sparks 

Managing Director 

Regulatory Affairs 

FEDERAL EXPRESS CORPORATION 

1700 Pennsylvania Avenue, N.W. 

Suite 950 

Washington, D.C. 20006 

(202) 393-9286 (phone) 

(202) 628-0654 (fax) 

Email: nssparlcs@fedex.com 

M. Rush O'Keefe, Jr. 

Senior Vice President & General Counsel 

Steven H. Taylor 

Vice President 

Regulatory Affairs 

Courtney E. Felts 

Senior Counsel — Regulatory Affairs 

FEDERAL EXPRESS CORPORATION 

3620 Hacks Cross Road 

Building B, 3rd Floor 

Memphis, Tennessee 38125 

(901) 434-8632 (phone) 

(901) 434-8283 (fax) 

Email: cefelts@fedex.com 

Attorneys for 

FEDERAL EXPRESS CORPORATION 

Dated: June 9, 2015 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

Application of 

Norwegian Air International Limited 

for an exemption under 49 U.S.C. § 40109 

and a foreign air carrier permit pursuant 

to 49 U.S.C. § 41301 

Docket DOT-OST2013-0204 

ANSWER OF FEDERAL EXPRESS CORPORATION 

IN SUPPORT OF NORWEGIAN AIR INTERNATIONAL LIMITED'S 

MOTION FOR LEAVE TO FILE AND EXPEDITED TREATMENT 

Pursuant to 14 C.F.R. § 302.11(e), Federal Express Corporation ("FedEx") 

files this Answer in Support of Norwegian Air International Limited's (NAI) Motion 

for Leave to File and Expedited Treatment, served June 1, 2015, relating to NAI's 

pending application in this Department of Transportation (the "Department") docket 

for a foreign air carrier permit. 

FedEx has outlined its support, in previous filings in this docket, lof the 

issuance of a foreign air carrier permit to NAI. No reason exists for the rejection of 

NAI's application, and the Department should approve NAI's application without 

delay. FedEx incoiporates by reference the arguments and points contained in its 

Answer and Reply filed in this docket, as if fully set forth herein. 2FedEx also 

' See Answer of Federal Express Corporation, Docicet DOT-OST-2013-0204, February 12, 2014 

(http://airlineinfo.com/ostpdf89/692.pdf ); and Repiy of Federal Express Corporation, Docket DOTOST-2013-0204, February 21, 2014 (http://airlineinfo.com/ostpdf89/781.pdf ). 

2I!a 

2 
specifically reiterates its contention that rejecting NAI's application for a foreign air 

carrier permit would be a clear violation of the U.S.-European Union ("EU") Air 

Services Agreement (the "U.S.-EU Open Skies Agreement"). 

In addition, even though there are no grounds for rejecting NAI's application 

as far as safety, ownership and control, and pertinent labor standards are concerned, 

NAI nonetheless provided a letter from its parent company's (Norwegian Air 

Shuttle, "NAS") Chief Executive Officer indicating that NAI will only use U.S. and 

European crew personnel on NAI's transatlantic flight operations. 3FedEx submits 

that this voluntary commitment from NAI/NAS effectively nullifies the primary 

objection of opponents to NAI's application. 

Moreover, FedEx must emphasize its grave concern with any potential 

Department action that could result in a disruption of the aviation marlcetplace and a 

decrease or even cessation of some U.S. carrier operations. FedEx maintains its 

position that the Department's failure to approve the NAI application will constitute 

a breach of the U.S.-EU Open Skies Agreement, and the extensive benefits of the 

U.S.-EU Open Skies Agreement will be immediately endangered. Such a result 

would cause irreparable harm to the U.S. travelers, consumers, employees, and 

companies who have significant dependence on a fully liberalized U.S.-EU aviation 

network. Accordingly, FedEx urges the Department to uphold the U.S.-EU Open 

Skies Agreement by approving NAI's application and to do so without delay. 

3See, Exhibit I at 2, Motion of Norwegian Air International Limited for Leave to File and Expedited 

Treatment, Docket-DOT-OST-2013-0204, June 1, 2015. 

3 
Respectfully submitted, 

FEDERAL EXPRESS CORPORATION 

~• `~ ~ , 

Courtney E. Felt 

Senior Counsel 

Regulatory Affairs 

June 9, 2015 

CERTIFICATE OF SERVICE 

A copy of the foregoing Answer has been served this 9 thday of June, 2015, upon the 

following persons via email: 

romanow@pillsburylaw.com paul.gretch@dot.gov 

peter.nelson@pillsburylaw.com robert.finamore@dot.gov 

russell.bailey@alpa.org brian.hedberg@dot.gov 

steve.morrissey@united.com englets@state.gov 

dan.weiss@united.com cristinasa@state.gov 

sascha.vanderbellen@delta.com eugene.alford@trade.gov 

howard.kass@aa.com info@airlineinfo.com 

robert.wirick@aa.com dberg@airlines.org 

francis.heil@aa.com jcasey@airlines.org 

robert.land@jetblue.com kglatz@airlines.org 

rpommer@atlasair.com cbethke@airlines.org 

anita.mosner@hklaw.com mrichardson@swapa.org 

jennifer.nowak@hklaw.com edw@ttd.org 

mlbenge@zsrlaw.com sshur@traveltech.org 

ejames@jamhoff.com rdow@ustravel.org 

clytle@portoakland.com kgeorge@broward.org 

leo@washingtonairports.com keith@washingtonairports.com 

Courtney E. Felt