THE SECRETARY OF TRANSPORTATION WASHINGTON , D
.C
. 20590

The Honorable Lois Frankel U
.S. House ofRepresentatives Washington, DC 20515 Dear Congresswoman Frankel: April 03, 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 ofinterested 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 ofthe pleadings filed on the record before we reach a determination in this matter. As is our standard practice, I amplacing a copy ofyour letter and my response in Docket DOT-OST -2013-0204, as a contact outside the record ofthis case. You may trackthe progress ofthis case and viewthe publicly available documents filed in the docket by accessing the Federal Docket Management System at www.regulations.gov and searchingfor Docket DOT-OST-2013-0204. I hope this information is helpful. Sincerely,

Anthony R. FoxxLOIS FRANKE L 22ND D ISTRICT, FLORIDA
1037 LONGWORTH HOUSE OFFICE BUILDING WASHINGTON, DC 20515 (202) 225-9890 2500 NORTH MILITARY TRAIL SUITE #490 BOCA RATON, Fl 33431 (561) 998-9045 TOLL FREE (866) 264-0957 

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### llCIC 20515-0922 frankel.house.gov

The Honorable Anthony R. Foxx Secretary U.S. Department ofTransportation 1200 New Jersey Ave, SE Washington, DC 20590 January 8, 2014 COMMITTEE ON FOREIGN AFFAIRS M IDDLE EAST AND NORTH A FRICA COMMITTEE ON TRANSPORTATION AND INFRASTRUCTURE HIGHWAYS AND TRANSIT

WATER RESOURCES AND ENVIRONMENT COAST GUARD AND MARITIME TRANSPORTATION

Re:Application of NorwegianAirInternationalLimited, DocketDOT-OST-2013-0204. Dear Secretary Foxx: I write to express my concern overthe application by Norwegian AirInternational Limited (NAI) for exemption authority and a foreign air carrier permit. As you are aware, approval ofthe application would allow NAIto conduct commercial air transportation operations to and from the United States. Approval ofNAI's application would not be in the public interest for the following reasons. Behind the NAI application is a global outsourcing business model for its pilots and flight attendants (or "aircrew") that will putU.S. airlines and their employees at a competitive disadvantage. Indeed, this airline bearing the name "Norwegian" describes itselfin the application as "a foreign carrier oflreland." NAI's application provides little information about itselfor its plans. Based on media reports, it appears to be in the same corporate family with Norwegian Air Shuttle (NAS), a rapidly-growing low-cost airline. I am concerned that the publicly-stated desire ofNAS is to circumventNorwegian labor law. NAS has stated that, to conduct its new long-haul operations, including those to the U.S., it will seekto 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 otherEU points to the United States with outsourced lower-wage aircrew, based in SoutheastAsia, under individual employment contracts governed by Singapore law. It appears thatNAS may now intend to use NAI as its Irish affiliate to bring its plan to fruition. In addition to undermining fair wages and working conditions, NAI/NAS'sbusiness model would put U.S. carriers in direct competition at a competitive disadvantage. Accordingly, approval ofNAI's application for authority would be inconsistent with the Congressionally-establishedpublic interest as set forth in the aviation statutes.



# s10-140108-013 PRINTED ON RECYCLED PAPER

### Thank you for your careful consideration ofmy request. I look forward to working with you on this and other important transportation issues facing our'great nation.



# s10-140108-013 Sincerely,

Lois Frankel Member ofCongress



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