Dear Minister Hauglie:

I am writing on behalf of the Associations of Star Alliance Pilots (“ASAP”) Executive Board. As you may know, the Star Alliance is an airline marketing consortium consisting of 28 member airlines. ASAP consists of the leadership of the pilot unions and associations of those carriers and represents approximately 30,000 pilots worldwide.

In connection with the International Federation of Air Line Pilots’ Associations (“IFALPA”) 71st Annual Conference in New Orleans, the ASAP leadership was briefed on the Norwegian Ministry of Labour and Social Affairs (ASD) proposal to change the Immigration Regulations for workers in international civil aviation. We understand that the current regulation requires that foreign aviation staff, not being EEA nationals, must have a residence permit when they work on Norwegian aircraft engaged in international traffic. We would like to stress that this is also the case in many nations globally to protect jobs and national competence.

We understand that the Ministry`s justification to amend the Norwegian regulations is the desire to harmonize them with the Schengen border Regulation. In this context it is important to emphasise that several EU nations do have national legislation to protect flying jobs for their citizens. We strongly believe that a change in Norwegian regulations could have major negative employment effects, as this could encourage social dumping practices resulting in a loss of good jobs on a large scale even globally.

535 Herndon Parkway Herndon, Virginia USA, 20170 Alliancepilot.org

An important core value in aviation is safety. Many Low Cost Carriers that were started in recent years have employee models largely based on temporary employment contracts, The individual employee often is acting as self-employed through an employment agency in a tax haven which is problematic in many aspects. In addition to setting the traditional employment model aside, this practice also poses a significant challenge to flight safety through a far more complex and less transparent structure which complicates oversight of the operations.

The use of alternative models of employment and flags of convenience is in ASAP ́s view a serious threat to both good flying jobs globally and flight safety. It is our strong belief that a change in the Norwegian regulations will degrade the quality of aircrew jobs and is a step in the wrong direction towards the international shipping model.

With such potentially damaging effects the Associations of Star Alliance Pilots strongly urges the Norwegian Government not to change its Immigration Regulation.

I appreciate your attention to this matter. Yours sincerely,

Captain Ron Pellatt
Chairman, ASAP Executive Board Rpellatt@acpa.ca