THE SECRETARY OF TRANSPORTATION 

WASHINGTON, D.C. 20590 

The Honorable Lois Frankel 

U.S. House of Representatives 

Washington, DC 20515 

Dear Congresswoman Frankel: 

April 03, 2014 

Thank you for your letter regarding the application of Norwegian 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 of this 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 
LOIS FRANKEL 

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 

(!Congress of tbe mtntteb ~tates 

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~a£)bington, llCIC 20515-0922 

frankel.house.gov 

The Honorable Anthony R. Foxx 

Secretary 

U.S. Department of Transportation 

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 

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AND ENVIRONMENT 

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TRANSPORTATION 

Re: Application of Norwegian Air International Limited, Docket DOT-OST-2013-0204. 

Dear Secretary Foxx: 

I write to express my concern over the application by Norwegian Air International 

Limited (NAI) for exemption authority and a foreign air carrier permit. As you are 

aware, approval of the 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 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. 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 circumvent 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. 

In addition to undermining fair wages and working conditions, NAI/NAS's business 

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-established public interest as set forth in the aviation statutes. 

s 10-140108-013 PRINTED ON RECYCLED PAPER 
Thank you for your careful consideration of my request. I look forward to working with 

you on this and other important transportation issues facing our' great nation. 

s 10-140108-013 

Sincerely, 

Lois Frankel 

Member of Congress 

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