Norwegian Cruise Line Holdings President and CEO Frank Del Rio filed a declaration in court as part of the company’s lawsuit against the surgeon general of the State of Florida over vaccination requirements.

Over nine pages, Del Rio goes into detail about the company’s restart, operating 100 percent vaccinated voyages, various challenges and the hurdles the State of Florida has put in front of them by fining any business that asks for proof of vaccination. 

Key Takeaways From Del Rio’s Court Declaration:

• Set to sail from Florida on August 15, the Norwegian Gem currently has 1,265 guests booked for her Caribbean itinerary. The ship is reported to have a double occupancy of 2,400 guests at 100 percent, meaning the initial load factor would be approximately 53 percent.
• Norwegian’s voluntary halt in operations due to the pandemic in March 2020 has cost the company to date in excess of $6 billion. Del Rio estimated that employees and businesses in the State of Florida have lost approximately $2 billion in outlays from Norwegian due to the halt of Norwegian’s operations in 2020. Norwegian bolstered its liquidity through multiple historic capital markets transactions, exceeding $7.5 billion.
• Under Florida’s ban, Norwegian will be forced to modify or cancel the itinerary of the Norwegian Gem because its itineraries embark from Miami, Florida, and its passengers are expecting 100 percent vaccination of passengers and crew onboard.
• The cancellation could cost Norwegian approximately $4 million in lost revenues per seven day cruise, and likely cost the broader cruise ecosystem that supports the Norwegian Gem sailing hundreds of thousands of dollars per cruise. These losses will only become greater over time, as Norwegian’s subsidiaries have 15 ships planning to embark guests in Florida this coming fall and winter seasons, he said.
• Norwegian has concluded that the most effective way to ensure the health and safety of passengers and crew is to require full vaccination on cruises by everyone onboard. Various third-party industry surveys also indicate that a vast majority of Norwegian’s target cruise passengers prefer completely vaccinated voyages.
• Del Rio attributed the demand for Norwegian cruises in large part to its plan for 100% vaccination. Del Rio noted that unless Norwegian is able to verify vaccination status, its ability to attract and assure its passengers will be severely undercut. Additionally, requiring full vaccination for 100 percent of passengers and crew is consistent with the vaccination protocols required by many foreign ports where Norwegian ships are scheduled to visit.
• Norwegian has attested to the CDC under the potential threat of criminal penalties that at least 95 percent of passengers and 95 percent of its crew on its upcoming cruise “will be confirmed as fully vaccinated prior to sailing.” Norwegian planned – and continues to plan – to “confirm” passengers’ and the crew’s COVID-19 vaccination status through documentation, which Del Rio said is to be “the only reliable way of confirming vaccination status in this context.”
• Del Rio said it is “irresponsible, counterproductive and damaging to our brand” to deviate from its 100 percent vaccination approach in order to make homeports in Florida viable.
• The Florida Ban, according to Del Rio, may also result in a loss or diminishment of employment for Norwegian’s contract workers at the PortMiami terminal (well over 100 on a turnaround day), as well as the employees working transit and hospitality in the area.
• The crew on its ships, approximately 1,800 per voyage, could also be at risk of unemployment if Norwegian cannot resume and maintain operations as currently planned. The loss of revenue caused by the ban in calendar year 2021 could exceed $100 million and could also result in a loss or diminishment of employment for Norwegian employees in South Florida.