THE SECRETARY OF TRANSPORTATION 

WASHINGTON, D.C. 20590 

The Honorable Paul Cook 

U.S. House of Representatives 

Washington, DC 20515 

Dear Congressman Cook: 

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 filed on the record before we reach a 

determination in this matter. 

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

DOT-OST-2013-0204, as a contact outside the record ofthis 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-2013-0204. 

I hope this information is helpful. 

Sincerely, 

Anthony R. Foxx 
. PAUL COOK 

8TH DISTRICT. CALIFORNIA 

February 10,2014 

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The Honorable Anthony Foxx 

Secretary 

U.S. Department of Transportation 

1200 New Jersey Avenue SE 

Washington, D.C. 20590 

1222 LONGWORTH HOUSE OFFICE 8UILOI~G 

WASIIINGTON, DC 20515 

(202) 225-5861 

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 I explain 

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 "a foreign carrier oflreland." 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 ofNAI, 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 deep 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 laws, 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. 

NAl!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, approval ofNAI's application for authority would be inconsistent 

s 1 0-140220-0 17 PRINTED ON RECYCLED PAPER 
with the Congressionally-established public interest as set forth in the aviation statutes. Thank 

you for your consideration. 

Sincerely, 

IJ~ Col. Paul Cook (Ret.) 

Member of Congress 

510-140220-017 

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