### 1 BEFORE THE U.S. DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

_____________________________________ ___ ) Application of ) ) NORWEGIAN AIR INTERNATIONAL LIMITED ) ) Docket No. OST
- 2013
- 0204 for an exempti on 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:
Ste phen 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 , 201 4

### 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 Depart ment 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 me mber 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 applicatio n 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 travele rs 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 w ill 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, Presi dent 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 to urists. 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 opport unity 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 Ag reement: 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 pr ovide 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 inte nt 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,
Ste phen 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.htmCERTIFICATE 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/Ste phen Shur