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Federal Comments

TTD Endorses Better Oversight of Curbside Bus Operators

Through this notice, FMCSA is seeking to define a “curbside bus operator” for the purpose of implementing section 32707 of MAP-21, which requires an annual safety fitness assessment of certain motor carriers of passengers that serve primarily urban areas with high passenger loads. The Agency has specifically identified curbside operators as the intended subject of that requirement, and proposes that these carriers should be defined as those that use 25% or more of their motorcoaches for operations involving pick-ups and drop-offs at curbside locations or parking lots.

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STB Should Reject Canadian Pacific’s Voting Trust Proposal

In its March 2, 2016 filing, CPRL requests the STB to provide a declaratory order on whether it would be potentially permissible for CPRL to hold its own subsidiaries in trust while it acquires ownership and control of NS and seeks regulatory approval of a CP-NS merger. CPRL has not submitted an actual voting trust proposal for STB’s review but rather requests the agency’s opinion on a theoretical trust. CPRL’s petition also requests a ruling on whether it would be permissible for CP’s chief executive officer (CEO) to divest from CP and assume a comparable position at NS where he would implement various substantial operational and structural changes.

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TTD, Transit Unions Urge DOT to Issue Rule to Protect Transit Workers

As labor organizations representing transit workers throughout the country, we urge the Department of Transportation (DOT) and your Federal Transit Administration (FTA) to issue a rule to protect bus drivers and other transit operators from the physical assaults that are plaguing this industry. As you know, Section 3022 of the Fixing America’s Surface Transportation (FAST) Act, builds upon FTA’s authority to regulate the safety of public transportation and requires the agency to issue a rulemaking on transit operator assaults. We believe that given the gravity of the problem, the clear Congressional directive, and DOT’s own engagement on this issue, that a rule to mitigate assaults should be finalized this calendar year.

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TTD Comments on Proposed Training Rule for Commercial Drivers

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) on Minimum Training Requirements for Entry-Level Commercial Motor Vehicle Operators. By way of background, TTD consists of 32 affiliated unions that represent workers in all modes of transportation, including those whose members maintain a commercial driver’s license (CDL) for employment. We therefore have a vested interest in this rulemaking.

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TTD Responds to Proposed Public Transportation Agency Safety Plans

In this NPRM, FTA requires that transit agencies receiving funds under 49 U.S.C. Chapter 53 and not regulated by another agency, develop and implement a Public Transportation Agency Safety Plan (Safety Plan). This NPRM establishes the core components that Safety Plans must contain, including methods to identify, evaluate, and minimize safety risk. Among other minimum components, Safety Plans must include training programs for personnel responsible for safety, and in certain cases, emergency preparedness and response plans. FTA requires that covered transit agencies develop their Safety Plans using a four-pillared Safety Management System (SMS) approach to ensure agencies’ unique needs are met.

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Joint Comments Opposing the Application of Norwegian Air UK Limited for a Foreign Air Carrier Permit

The record in the NAI proceeding shows that NAI is staffing its long-haul flights with flight crew based in Thailand and employed by non-European crew supply companies on employment contracts governed by Asia law: Singapore law in the case of pilots and Thailand law in the case of flight attendants. The record in that case further shows the terms and conditions of employment for those pilots and flight attendants are substantially inferior to those that apply to pilots and flight attendants employed directly by Norwegian or its subsidiaries. The Labor Parties showed that granting NAI either an exemption or a foreign air carrier permit would be inconsistent with the public interest standards set out in the aviation statutes and the provisions of the ATA, in particular, Article 17 bis.

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TTD Responds to Public-Private Partnership Model Contract Guide

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to comment on the Federal Highway Administration’s (FHWA) Draft Availability Payment Concessions Public-Private Partnership Model Contract Guide as well as on the Labor Best Practices chapter. By way of background, TTD consists of 32 affiliated unions in the transportation sector, including those who may be affected by a Public Private Partnerships (PPP or P3) concession agreement.

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EU Proposal to Include Aviation and Maritime Transport Services in TTIP Should be Rejected

Dear Mr. President,

As the elected leaders of unions representing American aviation and maritime workers, we are extremely concerned by elements in the proposal for the services, investment and e-commerce chapter of the Transatlantic Trade and Investment Partnership (TTIP) recently released by the European Union (EU). On May 10, 2013 the Transportation Trades Department, AFL-CIO (TTD) submitted comments to USTR (attached) on behalf of the undersigned unions which urged trade negotiators to resist efforts by the EU to include air and maritime transport services in the TTIP negotiations. The proposal released by the EU on July 31, 2015 confirmed that the EU is seeking to use the TTIP process as a means to undermine and dismantle many critical U.S. aviation and maritime laws and regulations at the expense of U.S. workers.

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TTD Endorses Transit Safety Improvements

With the passage of MAP-21, Congress provided FTA the much needed authority to regulate safety across our nation’s transit systems. Codified at 49 USC 5329, the mandate requires FTA to develop a comprehensive Public Transportation Safety Program intended to improve the safety performance of transit systems. This NPRM seeks to implement several components of that Program by formally adopting Safety Management Systems (SMS) as the foundation of FTA’s safety oversight and regulations; establishing procedures for FTA to conduct inspections and audits of equipment, facilities, and operations; creating procedures for the agency to make enforcement actions against noncomplying transit agencies; and setting the framework for the National Public Transportation Safety Plan (National Safety Plan).

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TTD Calls for Increased MSP Funding

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to comment on the Maritime Administration’s (MARAD) Notice of Proposed Rulemaking (NPRM) on the Maritime Security Program (MSP). By way of background, TTD consists of 32 affiliated unions that represent workers in all modes of transportation, including those who work on vessels providing sealift support under MSP.[1] We therefore have a vested interest in this rulemaking. In addition, we endorse the comments that USA Maritime filed on behalf of several TTD member unions and others, including the International Organization of Masters, Mates & Pilots, ILA (MM&P), the Marine Engineers’ Beneficial Association (MEBA) and the Sailors’ Union of the Pacific (SUP).

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