European Low Fares 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, 1st 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 SUPPORT 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 Notice 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 transport 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 registeredcarrier to operate between 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, 1st 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 Agreement 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 the 

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 bases in Europe and beyond. Irishregulated 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 the 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.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
tel: +32 (0)2 504 90 05 – fax: +32 (0)2 732 71 76 - info@elfaa.com - www.elfaa.com

 

Registered address: 21-23, 1st 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

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