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Dieuwer
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BREXIT: Norwegian banned from UK-USA?

Tue Apr 02, 2019 5:09 pm

In the case of a hard Brexit, will Norwegian (as an European company) be banned from flying UK-USA?
 
Murdoughnut
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Re: BREXIT: Norwegian banned from UK-USA?

Tue Apr 02, 2019 5:11 pm

Most of Norwegian's transatlantic fleet is G (UK) registered, so there wouldn't be any sort of impact.
 
PlymSpotter
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Re: BREXIT: Norwegian banned from UK-USA?

Tue Apr 02, 2019 5:18 pm

Norwegian is actually comprised of seven different airlines, each with a local AOC

Norwegian Air Argentina
Norwegian Air International
Norwegian Air Norway
Norwegian Air Shuttle
Norwegian Air Sweden
Norwegian Air UK
Norwegian Long Haul

The flights will continue unaffected as they are all (now the MAX is grounded) operated by Norwegian Air UK.
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sonicruiser
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Re: BREXIT: Norwegian banned from UK-USA?

Tue Apr 02, 2019 5:29 pm

Murdoughnut wrote:
Most of Norwegian's transatlantic fleet is G (UK) registered, so there wouldn't be any sort of impact.


Amazing to see just how far ahead of the curve they really were. They were ready for Brexit way before anyone else.
شما می توانید مردم را تحریم کنید ، اما نمی توانید سبک تحریم را اعمال کنید

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adamblang
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Re: BREXIT: Norwegian banned from UK-USA?

Tue Apr 02, 2019 5:32 pm

sonicruiser wrote:
Amazing to see just how far ahead of the curve they really were. They were ready for Brexit way before anyone else.

Eh, that's more of a happy coincidence. Their interest with all these AOCs is more in making sure their labor groups can't possibly organize.
 
Dieuwer
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Re: BREXIT: Norwegian banned from UK-USA?

Tue Apr 02, 2019 5:38 pm

Do other European LLCs do this as well? EasyJet-UK, EasyJet-France, Easyjet-Germany?
 
FlapsOne
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Re: BREXIT: Norwegian banned from UK-USA?

Tue Apr 02, 2019 5:42 pm

Dieuwer wrote:
Do other European LLCs do this as well? EasyJet-UK, EasyJet-France, Easyjet-Germany?


easyJet was always two airlines: easyJet Airline Co. Ltd and easyjet Switzerland. Now its easyJet UK, easyJet Europe and easyJet Switzerland.

WIZZ have a UK AOC and I believe more than one EU AOC.

Ryanair are now Ryanair DAC, Ryanair Sun in Poland (soon to be BUZZ) and Ryanair UK.
 
oslmgm
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Re: BREXIT: Norwegian banned from UK-USA?

Tue Apr 02, 2019 6:18 pm

adamblang wrote:
sonicruiser wrote:
Amazing to see just how far ahead of the curve they really were. They were ready for Brexit way before anyone else.

Eh, that's more of a happy coincidence. Their interest with all these AOCs is more in making sure their labor groups can't possibly organize.

Did you make that up? As far as I know, many of them are organized.

According to CEO Bjørn Kjos, the main reason for the different AOCs is that the various countries they operate in have different treaties with countries they (want to) fly into.
 
oslmgm
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Re: BREXIT: Norwegian banned from UK-USA?

Tue Apr 02, 2019 6:23 pm

Dieuwer wrote:
Do other European LLCs do this as well? EasyJet-UK, EasyJet-France, Easyjet-Germany?

They don't do long haul, so they don't have the issue of treaties to deal with. No issue within the EU/EEA.
 
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zkojq
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Re: BREXIT: Norwegian banned from UK-USA?

Tue Apr 02, 2019 7:13 pm

PlymSpotter wrote:
Norwegian is actually comprised of seven different airlines, each with a local AOC

Norwegian Air Argentina
Norwegian Air International
Norwegian Air Norway
Norwegian Air Shuttle
Norwegian Air Sweden
Norwegian Air UK
Norwegian Long Haul


Can anyone explain to me how Norwegian Air Norway fits into everything?
First to fly the 787-9
 
oslmgm
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Re: BREXIT: Norwegian banned from UK-USA?

Tue Apr 02, 2019 7:21 pm

zkojq wrote:
PlymSpotter wrote:
Norwegian is actually comprised of seven different airlines, each with a local AOC

Norwegian Air Argentina
Norwegian Air International
Norwegian Air Norway
Norwegian Air Shuttle
Norwegian Air Sweden
Norwegian Air UK
Norwegian Long Haul


Can anyone explain to me how Norwegian Air Norway fits into everything?

Good question. From the articles linked from Wikipedia, I found this:

https://standbynordic.com/norwegian-air ... -go-ahead/
(...) the group is implementing corporate restructuring (...), so that Norwegian Air Shuttle will become a holding company with little or no operational activities while NAN will become the main airline operating flights in the US.

That last part "...in the US" makes no sense to me, if it's going to take over operations from Norwegian Air Shuttle, which is the short haul operation in Europe/Norway.
 
Humberside
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Re: BREXIT: Norwegian banned from UK-USA?

Tue Apr 02, 2019 7:43 pm

Dieuwer wrote:
In the case of a hard Brexit, will Norwegian (as an European company) be banned from flying UK-USA?

From an ownership as opposed to an AOC perspective, existing Norwegian flights will be unaffected - I'm pretty certain the initial reference to EU majority owned airlines should be EU/EEA, thus covering Norwegian
"Under the deal, EU majority-owned airlines that are operating between the UK and US will be able to continue to fly existing routes as long as they remain owned and controlled by EU/EEA nationals or UK nationals. But any airline that is not owned and controlled by UK nationals and wants to start offering transatlantic routes after Brexit would need to seek a waiver from the US government."
https://www.bbc.co.uk/news/business-46380463

It's maybe worth noting as well that the UK government is considering abolishing ownership rules, though doing so unilaterally won't mean anything, only if other countries/blocs do the same
https://mlexmarketinsight.com/insights- ... -uncertain
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YIMBY
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Re: BREXIT: Norwegian banned from UK-USA?

Wed Apr 03, 2019 6:01 am

Humberside wrote:

It's maybe worth noting as well that the UK government is considering abolishing ownership rules, though doing so unilaterally won't mean anything, only if other countries/blocs do the same
https://mlexmarketinsight.com/insights- ... -uncertain


Considering? The news is from 16 November 2018.

The official link to the official page of her Majesty's government is here

https://www.gov.uk/guidance/air-services-from-the-eu-to-the-uk-in-the-event-of-no-deal

It still is quite conditional. The Kingdom intends to abolish ownership rules, but apparently has not yet done it, as it expects reciprocity. I am about to lose track what the parliament has accepted, what the government has proposed and what they are able to decide in the given timeframe. EU apparently has not changed its rules per se but planned to give some months to adapt, but I am not sure of it's legal status.

No-deal is really no deal and bases on mutual unilateral decisions. Neither the Kingdom nor the Union is appropriately prepared for no-deal.

Tickets are being sold as usual so the airlines seem to be confident. Maybe no disaster will happen for air traffic.

Changes in travel patterns may be, however, a larger threat for airlines than direct regularization (but may also give an opportunity to some)
 
ELBOB
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Re: BREXIT: Norwegian banned from UK-USA?

Wed Apr 03, 2019 6:37 am

YIMBY wrote:
It still is quite conditional. The Kingdom intends to abolish ownership rules, but apparently has not yet done it, as it expects reciprocity.


And I am glad the UK plans to do so as it was one of the most blatently protectionist laws in the EU. What does it matter who owns an airline, so long as it adheres to local regulatory requirements?

The second most blatent piece of protectionism was the requirement to seek wet-leases from with the EU before looking elsewhere.
 
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scbriml
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Re: BREXIT: Norwegian banned from UK-USA?

Wed Apr 03, 2019 7:14 am

ELBOB wrote:
YIMBY wrote:
It still is quite conditional. The Kingdom intends to abolish ownership rules, but apparently has not yet done it, as it expects reciprocity.


And I am glad the UK plans to do so as it was one of the most blatently protectionist laws in the EU. What does it matter who owns an airline, so long as it adheres to local regulatory requirements?

The second most blatent piece of protectionism was the requirement to seek wet-leases from with the EU before looking elsewhere.


Isn't that the same as the USA?
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FabDiva
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Re: BREXIT: Norwegian banned from UK-USA?

Wed Apr 03, 2019 7:36 am

USA is even more restrictive. Jones act means a US airline can't hire in from a Non US carrier at all. I also recall Virgin America having issues getting approval from US authorities because of 25% Branson stake.
 
787Driver
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Re: BREXIT: Norwegian banned from UK-USA?

Wed Apr 03, 2019 8:30 am

adamblang wrote:
sonicruiser wrote:
Amazing to see just how far ahead of the curve they really were. They were ready for Brexit way before anyone else.

Eh, that's more of a happy coincidence. Their interest with all these AOCs is more in making sure their labor groups can't possibly organize.


Not true. I can tell you that most employees in the airline are already organized in the respective countries they're based in.

The reason behind all these AOCs are to get permits to operate in various parts of the world.

For example to operate in Argentina, it has to be an Argentinian AOC and only Argentinian employees. Norwegian Air Sweden should be used to try and get overflight permits over Siberia. At least that's the plan.

And so on..
 
Stickpusher
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Re: BREXIT: Norwegian banned from UK-USA?

Wed Apr 03, 2019 8:58 am

scbriml wrote:
ELBOB wrote:
YIMBY wrote:
It still is quite conditional. The Kingdom intends to abolish ownership rules, but apparently has not yet done it, as it expects reciprocity.


And I am glad the UK plans to do so as it was one of the most blatently protectionist laws in the EU. What does it matter who owns an airline, so long as it adheres to local regulatory requirements?

The second most blatent piece of protectionism was the requirement to seek wet-leases from with the EU before looking elsewhere.


Isn't that the same as the USA?


It is, and the EU would not want to grant access to European carriers without (that word again) reciprocity from the US and other administrations. It's the EU keeping a level playing field, nothing much more than that. I don't think a bilateral with the UK would be feasible, if EZY, RYR, WZZ etc creating cross-border entities are anything to go by (they must surely have looked into that). I think that kind of arrangement would impinge on the aspects surrounding market access that are the main bone of contention in this entire debacle. We should also remember that the UK and the EU cannot negotiate a future trading relationship until severance happens, so those carriers are hedging their bets in the least costly ways they can until some relationship is negotiated down the line - which could take 10 years of WTO if the UK's damage assessment is any guide. https://assets.publishing.service.gov.u ... ssible.pdf

I should add that in a trade-driven society of nations with domestic societies of people there will always be a degree of protectionism when global market forces could materially harm people in other countries. Not every nation has an absolute "comparative advantage" in making stuff to trade, and no nation wants to suborn itself to others, for the sake of its people. Protectionism (tariffs etc) are a balancing mechanism if properly used, larger trading entities might decide to weaponise them if they feel they can - but for local populations, keeping people employed and putting a brake on potential harm to a society protectionism is the tool of choice. It happens everywhere. "Free markets" are called for only by those least likely to be harmed by them, the EU created a large domestic free market on the understanding that members would be shielded from the consequences by oversight from higher up to ease imbalances.

I'm as big a fan of protectionism as I am of engine oil. They're both messy and horrible in the wrong place but essential in the right one. I feel obliged to point out that French and German engineering and car firms were extremely concerned about the expansion of the EU back in the day, because they felt they had everything to lose when their own governments were exposing themselves to other major industrialised countries such as the UK, when until then they had a dominant market position domestically. Nothing much seemed to come of it, but their concerns were real. But this is o/t.

One final note, though. I've spoken to a few people that think the UK will be trading with the EU on WTO rules but nowhere else. That's not true. Our basic trade agreements globally have been negotiated as a unified EU bloc (with EU clout behind it thanks to a huge domestic market of getting-on-for 580M souls) and individual states have been allowed to make bilaterals on top of that provided they don't harm the basic trade agreement (such as a unilateral lowering of tariffs that are in place) and only add nuances. This matters to air carriers because the underpinning EU trade agreements (e.g. with the US) will go overnight, and new trade arrangements will take time to shake out, which I think means that EZY/RYR/WZZ have seen this period of uncertainty lasting a lot longer than some of us believe it might. This is why the UK government is in such disarray, they're trying to accomodate the will of about half the population knowing what the consequences actually involve, and they're factionalising because they're torn between public opinion and economic reality. As a result nobody thinks they're competent. They're facing either a constitutional crisis or an economic one.
 
yoni
Posts: 221
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Re: BREXIT: Norwegian banned from UK-USA?

Wed Apr 03, 2019 9:06 am

Dieuwer wrote:
In the case of a hard Brexit, will Norwegian (as an European company) be banned from flying UK-USA?


Yes, it is a possibility. But it will depend on ownership requirements to be put in place by the UK (I know that the UK wants to remove these requirements). Norwegian Air UK is currently owned by Norwegian Air Shuttle whose shareholders are primarily Norwegian.
I am not sure that they would be able to operate UK-USA flights, even with a UK AOC, if they are not owned primarily by British interests, unless the UK allows them to continue their flights without restriction (as it seems to be the case for airlines licensed before Brexit) and the UK-USA Air Transport Agreement includes airlines owned by a third-party country.

I am quite sure that BA, VS and the American airlines wouldn't mind if strict ownership requirements apply to Norwegian Air UK.
 
Andy33
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Re: BREXIT: Norwegian banned from UK-USA?

Wed Apr 03, 2019 9:29 am

yoni wrote:
Dieuwer wrote:
In the case of a hard Brexit, will Norwegian (as an European company) be banned from flying UK-USA?


Yes, it is a possibility. But it will depend on ownership requirements to be put in place by the UK (I know that the UK wants to remove these requirements). Norwegian Air UK is currently owned by Norwegian Air Shuttle whose shareholders are primarily Norwegian.
I am not sure that they would be able to operate UK-USA flights, even with a UK AOC, if they are not owned primarily by British interests, unless the UK allows them to continue their flights without restriction (as it seems to be the case for airlines licensed before Brexit) and the UK-USA Air Transport Agreement includes airlines owned by a third-party country.

I am quite sure that BA, VS and the American airlines wouldn't mind if strict ownership requirements apply to Norwegian Air UK.

I'm sure they wouldn't as long as the same requirements don't apply to them. BA - subsidiary of Spanish-registered IAG, which has 20% shareholding by QR.
VS - 49% owned by DL, 30% shareholding from AF-KLM.
 
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Aisak
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Re: BREXIT: Norwegian banned from UK-USA?

Wed Apr 03, 2019 9:36 am

yoni wrote:
But it will depend on ownership requirements to be put in place by the UK (I know that the UK wants to remove these requirements). Norwegian Air UK is currently owned by Norwegian Air Shuttle whose shareholders are primarily Norwegian.
I am not sure that they would be able to operate UK-USA flights, even with a UK AOC, if they are not owned primarily by British interests, unless the UK allows them to continue their flights without restriction (as it seems to be the case for airlines licensed before Brexit) and the UK-USA Air Transport Agreement includes airlines owned by a third-party country.

I am quite sure that BA, VS and the American airlines wouldn't mind if strict ownership requirements apply to Norwegian Air UK.

Well, I’m sure they’ll mind as the same laws would apply to them.
Virgin Atlantic is owned by
Delta 49% US
AFKLM 31% EU (you can strip down nationality by looking into their shareholders nationality)
Virgin 20% GB

And BA carrier is owned by Spanish IAG which is not +51% British owned.

Also new-formed Connect Airways is owned by:
Virgin Atlantic 30%: British registered but max 20% British owned
Stobart 30%: Guernsey registered but as it is listed on LSE, there is the need to dig into each shareholder nationality to know
Hedge fund 40%: based in Luxembourg.

Ryanair UK is supposedly wholly owned subsidiary of Ryanair DAC (IE) and only around 20% of shareholders are British.

Wizz UK is supposedly wholly owned subsidiary of Wizz, registered in some country in the EU, and I would be shocked if it has more British interests than any of the above.

So in summary, The UK allowing to go on with current EU ruling of +50% in EU hands is not being done by the purity of their hearts or by any attempt to open their domestic operations to foreign investment. The British aviation industry would collapse on day 1, if thougher rules were to be enforced
 
phollingsworth
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Re: BREXIT: Norwegian banned from UK-USA?

Wed Apr 03, 2019 9:49 am

Unlike HMG which can reserve publication of agreements for quite a while the US is required to publish the agreement in order for it to become effective. The key bit is in Annex 1 of the agreement: https://www.state.gov/e/eb/rls/othr/ata/u/uk/287694.htm

Concerning Additional Matters Related to Ownership and Control of UK Airlines

An airline of the United Kingdom that was authorized by the Department of Transportation as of November 28, 2018, shall be deemed to satisfy the ownership and control standards of Articles 3(a) and 4(1)(b) of the Agreement, provided that:

a. substantial ownership of the airline remains vested in the United Kingdom, one or more States that were party to the European Economic Area Agreement as of November 28, 2018, and continue to be such a party, nationals of one or more of these States, or a combination thereof, provided that any such State is party to a modern liberal air transport agreement with the United States that is being applied;

b. changes in the degree of ownership of the airline by third countries or their nationals do not result in significant third country ownership; and

c. the degree of control of the airline exerted by third countries or their nationals does not increase substantially.


This basically means that all of the existing EU control UK AOCs can continue to operate, but any new ones require approval.
 
Bhoy
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Re: BREXIT: Norwegian banned from UK-USA?

Wed Apr 03, 2019 10:42 am

FlapsOne wrote:
Dieuwer wrote:
Do other European LLCs do this as well? EasyJet-UK, EasyJet-France, Easyjet-Germany?


easyJet was always two airlines: easyJet Airline Co. Ltd and easyjet Switzerland. Now its easyJet UK, easyJet Europe and easyJet Switzerland.

Just to elaborate on easyJet Switzerland (EZS/DS) - when easyJet first started operating from Geneva in the late 1990s, before open skies, to operate to non-UK destinations, as Switzerland is outside the EU, they needed a Swiss AOC. So they bought a 49% stake in charter airline TEA (the highest amount they could as non-nationals), and turned it into an easyJet Franchisee. All current EZS Aircraft were originally delivered to easyJet UK (the original group), and transferred to the HB- registry. Some have subsequently been returned to the G- registry.

easyJet Europe is a virtual Airline set up at the end of 2017 to counteract Brexit, whereby half the G- fleet has now been transferred to the Austrian (OE-) registry, thereby keeping a foot in the EU should there be any issue operating domestic flights in other EU Countries (easyJet have domestic routes in France, Italy, Germany and Spain, if not more countries)
 
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Aisak
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Re: BREXIT: Norwegian banned from UK-USA?

Wed Apr 03, 2019 12:56 pm

Bhoy wrote:
easyJet Europe is a virtual Airline set up at the end of 2017 to counteract Brexit, whereby half the G- fleet has now been transferred to the Austrian (OE-) registry, thereby keeping a foot in the EU should there be any issue operating domestic flights in other EU Countries (easyJet have domestic routes in France, Italy, Germany and Spain, if not more countries)


No more virtual than easyjet Switzerland.
easyJet Europe Airline GmbH is an Austrian company and did apply for an AOC to the Austrian authorities.

Staff employed by easyjet (UK) but based around continental Europe under local laws are transferred to the new entity also under local laws and half the easyjet (UK) fleet, which was already based in continental Europe airports have transferred to the OE- reg from the previous G- ones.

Thomas Haagensen (EU citizen) has been appointed as Managing Director at its HQ in Vienna, so control is easy (no pun intended) to prove it to be under EU hands. Being wholly owned subsidiary of Easyjet plc (listed on LSE) is way more problematic but there are ways to circumvent ownership rules.

Switzerland was purchased and Austria was built up from scratch. Switzerland is 51% owned by a local entity while Austria (for now) is not as it is not needed ( again, for now). That’s where differences end.

Hint: easyjet EU is not only needed for domestic flights wholly within member states. Rights on Spain-France or Germany-Italy were also at risk and that’s why the Austrian entity holds them now
 
yoni
Posts: 221
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Re: BREXIT: Norwegian banned from UK-USA?

Wed Apr 03, 2019 2:18 pm

Aisak wrote:
Well, I’m sure they’ll mind as the same laws would apply to them.
Virgin Atlantic is owned by
Delta 49% US
AFKLM 31% EU (you can strip down nationality by looking into their shareholders nationality)
Virgin 20% GB

And BA carrier is owned by Spanish IAG which is not +51% British owned.

Also new-formed Connect Airways is owned by:
Virgin Atlantic 30%: British registered but max 20% British owned
Stobart 30%: Guernsey registered but as it is listed on LSE, there is the need to dig into each shareholder nationality to know
Hedge fund 40%: based in Luxembourg.

Ryanair UK is supposedly wholly owned subsidiary of Ryanair DAC (IE) and only around 20% of shareholders are British.

Wizz UK is supposedly wholly owned subsidiary of Wizz, registered in some country in the EU, and I would be shocked if it has more British interests than any of the above.

So in summary, The UK allowing to go on with current EU ruling of +50% in EU hands is not being done by the purity of their hearts or by any attempt to open their domestic operations to foreign investment. The British aviation industry would collapse on day 1, if thougher rules were to be enforced


Good points. But both VS and IAG are owned in majority by British and American interests. I think that British and American airlines (especially Delta Airlines) will seize any opportunities to block Norwegian's expansion into this lucrative UK-US market either through the new Air Transport agreement between the 2 countries or other regulations.

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