Federal Comments

The Labor Parties hereby reply to the comments filed in response to DOT’s August 4 Notice (“Notice”) requesting comments on the views expressed by DG MOVE on the meaning and applicability of Article 17 bis of the U.S.‐EU Air Transport Agreement (“ATA” or “Agreement”) as it pertains to consideration of a foreign air carrier’s application for operating authority. For the reasons set forth below, the Labor Parties believe that DOT should reject the narrow view of Article 17 bis advanced by DG MOVE and deny NAI’s application for an exemption on the ground that the application does not meet the standards set out in 49 U.S.C. § 40109, and should issue a show cause order stating that it proposes to deny NAI’s application for a foreign air carrier permit on the ground that approval would be inconsistent with Article 17 bis.

The Association of Flight Attendants-CWA (AFA), the International Association of Machinists and Aerospace Workers (IAM), the Transport Workers Union (TWU), and the Transportation Trades Department, AFL-CIO (TTD) submit this reply to comments filed in response to DOT’s August 4 Notice (“Notice”) requesting comments on the views expressed by DG MOVE on the meaning and applicability of Article 17 bis of the U.S.-EU Air Transport Agreement (ATA).

The AFA, IAM and TWU submit this joint statement to articulate our unions’ shared opposition to the application of Norwegian Air International (NAI) for a foreign air carrier permit and exemption (Docket: DOT-OST-2013-0204). We call on the U.S. Department of Transportation (DOT) to deny NAI’s application for an exemption so that the proper evaluation and adjudication processes can be completed.

The AFA, IAM and TWU submit this joint statement to articulate our unions’ shared opposition to the application of Norwegian Air International (NAI) for a foreign air carrier permit and exemption (Docket: DOT-OST-2013-0204). We call on the U.S. Department of Transportation (DOT) to deny NAI’s application for an exemption so that the proper evaluation and adjudication processes can be completed.

The ETF and TTD join in this submission to express our serious objections and concerns outlined below. As indicated, in addition to the submissions we have made separately regarding the severe negative impacts that this matter will have on fair competition, jobs and labor rights, we have deep and profound concerns that the business model being pursued by Norwegian Air International (NAI) raises significant security concerns. Among other things, we believe that critical policies and regulations adopted following the terrorist attacks of September 11, 2001, by the U.S. and EU to ensure the safety of its citizens could be at risk.

The Air Line Pilots Association, the Transportation Trades Department, AFL-CIO, and the European Cockpit Association hereby submit the following comments in response to DOT’s August 4 Notice regarding the views voiced by the Director of Aviation of the European Commission’s Directorate of General Mobility and Transport (“DG MOVE”) on the applicability of Article 17 bis of the U.S.-EU Air Transport Agreement (“ATA” or “Agreement”) to NAI’s application. For the reasons set out below, the Labor Parties believe that DOT should reject DG MOVE’s interpretation of Article 17 bis and promptly deny NAI’s application for an exemption on the grounds that approval would be inconsistent with the public interest and with Article 17 bis.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to comment on the Federal Motor Carrier Safety Administration’s (FMCSA) Notice of Proposed Rulemaking (NPRM) to Prohibit the Coercion of Commercial Motor Vehicle Drivers. By way of background, TTD consists of 32 affiliated unions that represent workers in all modes of transportation, including those who operate over-the-road buses and other commercial motor vehicles, and therefore have an interest in this rulemaking.

The Honorable Michael P. Huerta Administrator Federal Aviation Administration 800 Independence Avenue, SW Washington, DC  20591 RE:   Drug and Alcohol Testing of Certain Maintenance Provider Employees       Located Outside of the United States      Docket No. FAA-2012-1058; Notice No. 14-02      RIN 2120-AK09      Federal Aviation Administration Dear Administrator […]

Ms. Amanda Huetinck Mobility Division, Wireless Telecommunications Bureau Federal Communications Commission 445 12th ST SW Washington, DC 20554 RE:    Expanding Access to Mobile Wireless Services Onboard Aircraft           WT Docket No. 13-301; FCC 13-157           Notice of Proposed Rulemaking           Federal Communications […]

BEFORE THE U.S. DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C. ____________________________________________ Application of DREAMJET SAS Docket No. OST-2014-0063 for an exemption pursuant to 49 U.S.C. § 40109 and a foreign air carrier permit pursuant to 49 U.S.C. § 41301 (US-EU Open Skies _____________________________________________ REPLY OF AIR LINE PILOTS ASSOCIATION (ALPA), TRANSPORTATION TRADES DEPARTMENT, AFL-CIO (TTD) AND EUROPEAN […]