1

BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C. ________________________________________

)

Application of )

)

NORWEGIAN AIR INTERNATIONAL LIMITED )

) Docket No. OST-2013-0204

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

a foreign air carrier permit pursuant to )

49 U.S.C. § 41301 (U.S.-E.U. Open Skies) ) ________________________________________ )

MOTION FOR PERMISSION TO FILE AND

COMMENTS OF THE TRAVEL TECHNOLOGY ASSOCIATION

IN SUPPORT OF NORWEGIAN AIR INTERNATIONAL LIMITED

Communications with respect to this document should be addressed to:

Stephen Shur

President

THE TRAVEL TECHNOLOGY ASSOCIATION

1250 Connecticut Avenue, N.W., Suite 825

Washington, DC 20036

Tel: (202) 503-1423

E-mail: sshur@traveltech.org

January 22, 2014
2

BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C. ________________________________________

)

Application of )

)

NORWEGIAN AIR INTERNATIONAL LIMITED )

) Docket No. OST-2013-0204

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

a foreign air carrier permit pursuant to )

49 U.S.C. § 41301 (U.S.-E.U. Open Skies) ) ________________________________________ )

MOTION FOR PERMISSION TO FILE AND

COMMENTS OF THE TRAVEL TECHNOLOGY ASSOCIATION

IN SUPPORT OF NORWEGIAN AIR INTERNATIONAL LIMITED

MOTION

The Travel Technology Association (Travel Tech) hereby moves for permission to

file these comments in support of the application of Norwegian Air International Limited

(Norwegian Air) for an exemption and a foreign air carrier permit, filed with the Department

on December 3, 2013.1 Consideration of these comments will provide the Department with

a more complete record on which to base its decision in this proceeding. COMMENTS

The Travel Technology Association fully supports Norwegian Air’s application for

an exemption and foreign air carrier permit and urges the Department to approve the

application.

Travel Tech’s members are the world’s leaders in online travel. Comprised of

online travel agents (OTA) and global distribution systems (GDS), Travel Tech’s member

companies are on the front lines of travel and tourism and recognize the great benefit that

1 Travel Tech files this motion pursuant to Rule 6 of the Department’s Rules of Practice.
3

affordable travel brings to consumers, suppliers and the travel and tourism economy.

Today, approximately one third of all air travel is booked through an OTA and nearly all

air bookings touch a GDS at some point in the booking and traveling process.

Travel Tech’s support of Norwegian Air’s application is based on the following:  Competition Benefits Consumers: Increased competition from

foreign low cost carriers is good for consumers and good for travel and

tourism economies

 Economic Boon for US Economy: Norwegian Air is investing in US

goods and services

 Job Creation: The approval of Norwegian Air’s application will create

thousands of direct and indirect US Jobs.  Consumer demand is driving the expansion of service to US: The

world marketplace for travelers is expanding and the US should take

advantage of this growth.  Rejection of the application would be inconsistent with Open

Skies Agreement’s letter, spirit, intent and history: The EU/US

Open Skies Agreement was created to foster growth in international

travel. Competition Benefits Consumers Competition among air carriers benefits

consumers and the cities and countries served by the proposed additional flights. When

traditional US airlines have to compete with low-cost carriers, they are forced to be more

price competitive, offer better services and make their products more attractive. This holds

true in the case of Norwegian Air’s application. Norwegian Air has already proven how a

low-cost carrier can positively impact the marketplace by offering consumers attractive

choices to desirable destinations on new, state of the art aircraft. Carriers already
4

providing service to those markets must now compete for customers. This is a win for all

consumers who will be offered lower cost options and new non-stop routes, prompting

increases in travelers coming to the US, which in turn, benefits the US economy due to

additional foreign visitors who spend money on US soil.

Economic Boon for US Economy Norwegian Air’s application brings significant

economic gain to the US not only through the foreign travel they facilitate but the

investment in US goods, services and citizens. Norwegian Air recently ordered 122 Boeing

737s and six 787 Dreamliners, airplanes built in the United States by US workers. In

establishing new routes to the US, Norwegian Air will be investing in airport operations

infrastructure, office space and contracts with countless US-based vendors and suppliers

who serve the airline industry. Norwegian’s investment in US operations can and should

be welcomed and embraced.

In 2010, President Obama announced that his goal was to double US Exports

within five years. Dollars spent by foreign tourists in the US are defined as a US export of

services and are a component of the calculation of total US exports. Norwegian Air’s

application to provide additional service to the US would contribute millions toward

meeting President Obama’s goal.

Job Creation Approval of Norwegian Air’s application will create direct and

indirect jobs in the US. Norwegian Air recently (January 13, 2014) announced the hiring

of 170 US-based crew members in New York and Florida with plans to hire hundreds

more.

According to Florida’s Swedish-American Chamber of Commerce, Scandinavian

visitors to Florida stay nearly twice as long and spend 25% more than other European
5

tourists.2 Further, Fort Lauderdale and Oakland have both stated that Norwegian is a key

driver of economic growth for their surrounding communities.

Consumer demand is driving the expansion of service to US Currently,

transatlantic flights are dominated by the three major air carrier alliances. While capacity

has not increased over the previous three to five years, prices have.3 Consumers want

access to low-cost transatlantic flights, just as low-cost carriers have proven in the

domestic market. When low-cost alternatives are offered, more people travel. Norwegian

Air’s desire to bring more travelers to the US on more affordable flights will result in an

increase in travel by foreigners to the US. Importantly, Norwegian Air’s proposed service

will open the transatlantic market to leisure travelers in new and welcomed ways – making

air travel accessible to a significantly broader demographic on both sides of the Atlantic.

Rejection of the application would be inconsistent with the EU/US Open

Skies Agreement’s letter, spirit, intent and history Former Secretary of State Hillary

Rodham Clinton characterized the goals of the US Open Skies policy as follows: “Work to

'democratize' aviation continues to allow millions more Americans the opportunity to fly to

international destinations each year and for countless foreign tourists to visit our country.”4

The Department of State’s website reflects the Obama Administration’s view of the

benefits of the EU/US Open Skies Agreement:

What Are Open Skies?

Open Skies agreements between the United States and other countries

expand international passenger and cargo flights by eliminating

government interference in commercial airline decisions about routes,

capacity and pricing. This frees carriers to provide more affordable,

convenient and efficient air service to consumers, promoting increased

travel and trade and spurring high-quality job opportunity and economic

2 Wall Street Journal “Are Air Mergers a Handout to Big Labor”, 12/20/13

3 Travel Daily News 1/13/14 http://www.traveldailynews.com/news/article/58497/norwegian- opens-crew-bases-in#sthash.WqbKqH1u.dpuf

4 US Department of State website: http://www.state.gov/r/pa/pl/159347.htm
6

growth. Open Skies policy rejects the outmoded practice of highly

restrictive air services agreements protecting flag carriers.5

And,

A private study found that new direct service between a U.S. city and a

point in the European Union generates up to $720 million annually in new

economic activity for the U.S. city and its local region, depending on the

size of the markets.6

Norwegian Air’s application speaks directly to the spirit and intent of the Open

Skies Agreement.

Conclusion

As leaders in the online travel industry and the world’s leaders in booking and

managing international travel, we fully support increased competition from low-cost

carriers. The net result of such growth is an increase in the number of travelers which has

a direct correlation to the travel and tourism economy.

We urge the DOT to uphold and maintain the spirit and intent of the Open Skies

Agreement by approving Norwegian Air’s application to provide service to the United

States.

Respectfully submitted,

Stephen Shur

President

THE TRAVEL TECHNOLOGY ASSOCIATION

1250 Connecticut Avenue, N.W., Suite 825

Washington, DC 20036

Tel: (202) 503-1423

E-mail: sshur@traveltech.org

January 22, 2014

5 US Department of State website: http://www.state.gov/r/pa/pl/159347.htm

6 US Department of State website: http://www.state.gov/r/pa/pl/159347.htm
CERTIFICATE OF SERVICE

I certify that today I transmitted this answer electronically to the following:

steve.morrissey@united.com

thomas.bolling@united.com

dan.weiss@coair.com

sascha.vanderbellen@delta.com

howard.kass@usairways.com

mlbenge@zsrlaw.com

rpommer@atlasair.com

russell.bailey@alpa.org

jonathan.cohen@alpa.org

edw@ttd.org

clytle@portoakland.com

kgeorge@broward.org

mrichardson@swapa.org

robert.wirick@aa.com

francis.heil@aa.com

jesse.elliot@faa.gov

nicholas.tsokris@faa.gov

john.chen@faa.gov

john.allen@faa.gov

anita.mosner@hklaw.com

jennifer.nowak@hklaw.com

nssparks@fedex.com

gbleopard@fedex.com

dberg@airlines.org

jcasey@airlines.org

kglatz@airlines.org

cc@eurocockpit.be

ejames@jamhoff.com

romanow@pillsburylaw.com

peter.nelson@pillsburylaw.com

urskr@state.gov

eugene.alford@trade.gov

Matthew.Baldwin@ec.europa.eu

Felix.LEINEMANN@eeas.europa.eu

David.Batchelor@sesarju.eu

Ottar.Ostnes@sd.dep.no

John.Hanlon@ELFAA.com

paul.gretch@dot.gov

Robert.Finamore@dot.gov

/s/Stephen Shur