European Low Far es Airline Association

46 Avenue des Arts

B

- 1000 Brussels

Belgium

tel: +32 (0)2 504 90 05

– fax: +32 (0)2 732 71 76

- info@elfaa.com

- www.elfaa.com

Registered address: 21

- 23, 1 st Floor, West Street, Oundle, Cambridgeshire, PE8 4EJ, United Kingdom

Registered in England & Wales No. 5882574 

### 13 February , 2014

The Honourable Anthony R. Foxx

Secretary

U.S. Department of Transportation

1200 New Jersey Avenue, S.E.

Washington, DC 20590

Re: ANSWER BY EUROPEAN LOW FARES AIRLINE ASSOCIATION

TO U.S. DEPARTMENT OF TRANSPORTATION IN SUP PORT OF

APPLICATION BY NORWEGIAN AIR INTERNATIONAL

LIMITED IN ACCORDANCE WITH EU/U.S. OPEN SKIES

AGREEMENT.

Docket No. OST

- 2013

- 0204

Dear Secretary Foxx,

The European Low Fares Airline Association (ELFAA) notes the 30 January N otice filed

in Docket DOT

- OST

- 2013

- 0204 regarding the application by Norwegian Air International

Limited for an exemption and a foreign air carrier permit.

Airline members of the European Low Fares Airline Association, including Norwegian,

have, since liberalisation of market access as part of the European single market,

introduced the intended and sorely

- needed competition to air transpo rt within the

EU/EEA, which was the primary intent of deregulation.

Safe, reliable air transportation has become affordable to many millions more citizens,

who justifiably regarded it previously as the preserve of a small, wealthy elite, able to

afford the high fares, charged by the uncompetitive established carriers.

Committed to increasing competition in air transport, ELFAA welcomed the conclusion of

the EU

- US Open Skies Agreement, which offered the possibility to any EU registered

carrier to operate be tween the EU and the US.tel: +32 (0)2 504 90 05

– fax: +32 (0)2 732 71 76

- info@elfaa.com

- www.elfaa.com

Registered address: 21

- 23, 1 st Floor, West Street, Oundle, Cambridgeshire, PE8 4EJ, United Kingdom

Registered in England & Wales No. 5882574 

### Norwegian has played a major contribution to opening up the skies of Europe to increased

competition and now seeks to avail of the very freedom extended by the EU

- US Open

Skies Agreement, which was held by the parties to the Agre ement to be its raison d’etre.

Parties to the Open Skies Agreement further committed to mutual recognition of

designation by appropriate regulatory bodies in both the EU and US.

ELFAA fully supports the EU position that the US should, in accordance with t he

Agreement, recognise Ireland’s determinations regarding NAI under Article 6 bis of the

EU

- US Agreement.

Ireland has an unmatched record in the regulation of aviation safety and, indeed, regulates

one of ELFAA’s largest airline members with over 66 base s in Europe and beyond. Irish

regulated carriers have also long served the US without let or hindrance, further

evidencing US acknowledgement of Ireland’s competence and excellent record in the

regulation of aviation safety.

Now that Ireland has issued th e AOC and Operating Licence , for which Norwegian has

applied, ELFAA urges the DOT to proceed immediately and without further procedural

delay, to issue the necessary operational authority.

Sincerely,

John Hanlon

Secretary General, ELFAA

cc : steve.morrissey@united.com

thomas.bolling@united.com

dan.weiss@coair.com

sascha.vanderbellen@delta.com

howard.kass@usairways.com

mlbenge@zsrlaw.co m

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

joh n.allen@faa.gov

anita.mosner@hklaw.com

jennifer.nowak@hklaw.comtel: +32 (0)2 504 90 05

– fax: +32 (0)2 732 71 76

- info@elfaa.com

- www.elfaa.com

Registered address: 21

- 23, 1 st Floor, West Street, Oundle, Cambridgeshire, PE8 4EJ, United Kingdom

Registered in England & Wales No. 5882574 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

ur skr@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