Get Updates


Mailing List Options

Federal Comments

TTD Responds to Autonomous Vehicle Technology Proposal

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write to comment on NHTSA’s Notice of Proposed Rulemaking (NPRM) concerning vehicle-to-vehicle communications. By way of background, TTD consists of 32 affiliate unions that represent workers in all modes of transportation who will be impacted by the development and deployment of automated transportation. We therefore have a vested interested in the rulemaking.

Through this NPRM, NHTSA proposes to require that all light duty vehicles be equipped with vehicle-to-vehicle communications (V2V) systems. As proposed, these systems would transmit information including a vehicle’s speed, heading, and brake status from vehicle to vehicle in order to warn drivers of potential hazards. Critically, NHTSA states that the fusion of V2V and other technologies will “advance the further development of vehicle automation systems, including the potential for truly self-driving vehicles.”

Read More

TTD Comments on Expansion of DOT Drug Testing Panel

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write to comment on DOT’s Notice of Proposed Rulemaking (NPRM) concerning changes to DOT’s drug and alcohol testing regulations. By way of background, TTD consists of 32 affiliate unions that represents workers in all modes of transportation, many of whom are required to undergo DOT drug and alcohol testing. We therefore have a vested interested in the rulemaking.

Through this NPRM, DOT proposes to add four semi-synthetic opioids, (hydrocodone, hydromorphone, oxymorphone, and oxycodone), which are commonly prescribed painkillers to its testing panel. DOT also proposes several other changes to Part 40, including expanded fatal flaws in sample collection, the elimination of blind specimen testing, and changes to regulations concerning Medical Review Officer (MRO) verification.

Read More

TTD Responds to Proposed Security Training for Surface Transportation Employees

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write to comment on TSA’s Notice of Proposed Rulemaking (NPRM) implementing frontline transportation worker security training provisions mandated by Implementing Recommendations of the 9/11 Commission Act of 2007 (9/11 Act). By way of background, TTD consists of 32 affiliate unions that represents workers in all modes of transportation, including frontline employees in freight and passenger rail, public transportation agencies, and over-the-road bus (OTRB) service who would be subject to this training. We therefore have a vested interested in the rulemaking and can offer some unique perspectives as TSA seeks to implement this important and overdue requirement.

Read More

TTD Supports Expanded America’s Marine Highway Program (AMHP)

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write to comment on MARAD’s Notice of Proposed Rulemaking (NPRM) concerning revisions to the American’s Marine Highway Program (AMHP). By way of background, TTD consists of 32 affiliate unions that represents workers in all modes of transportation, including employees in the maritime shipping industry. We therefore have a vested interested in the rulemaking.

Read More

TTD Supports Descriptive Identification Numbers on Oil Cargo Tanks

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write to comment on PHMSA’s Advance Notice of Proposed Rulemaking (ANPRM) concerning identification numbers on oil cargo tanks. By way of background, TTD consists of 32 affiliate unions that represents workers in all modes of transportation, including rail employees who transport oil and emergency personnel who respond in the case of an accident.

In PHMSA’s ANPRM, the Administration seeks comments on regulations regarding the marking of identification numbers on cargo tanks carrying petroleum products. In issuing this ANPRM, PHMSA is fulfilling a requirement of the Protecting our Infrastructure of Pipelines and Enhancing Safety (PIPES) Act of 2016, which directed the Administration to respond to a petition for rulemaking filed by the Commercial Vehicle Safety Alliance (CVSA), which proposed amendments to the Hazardous Materials Regulations (HMR). The notice also addresses a petition filed by the American Trucking Associations (ATA), which also proposes HMR amendments. In addition to the petitions, PHMSA requests comments on several other items relating to identification numbers.

Read More

TTD Opposes Voice Calls on Airplanes

On behalf of the Transportation Trades Department, AFL-CIO (TTD) I write in response to the Department of Transportation’s (DOT) Notice of Proposed Rulemaking (NPRM) concerning the use of mobile devices to make voice calls while onboard a flight traveling within, to or from the United States. By way of background, TTD consists of 32 affiliated unions that represent workers in all modes of transportation, including several with aviation members who would be directly impacted by this proceeding.

Read More

Answer of Labor Parties to Norwegian Air UK Limited’s Application for an Exemption

The undersigned labor organizations (“the Labor Parties”) oppose the contingent application of Norwegian Air UK Limited (“NAUK”) for exemption authority. Any exemption from the requirement that a foreign air carrier hold a foreign air carrier permit must be consistent with the public interest. Six months ago, DOT denied a previous request for an exemption by NAUK, finding that a grant of the carrier’s application would not be consistent with the public interest. Order 2016-6-22 at 2. For the reasons set out below, the Department should deny NAUK’s current request as well.

Read More

Answer of Labor Parties to Norwegian Air UK Limited’s Request for Expedited Processing

BEFORE THE U.S. DEPARTMENT OF TRANSPORTATION WASHINGTON, DC Application of NORWEGIAN AIR UK LIMITED for an exemption under 49 U.S.C. § 40109 and a foreign air carrier permit pursuant to 49 U.S.C. § 41301 Docket No. OST-2015-0261 ANSWER OF LABOR PARTIES TO NORWEGIAN AIR UK LIMITED’S REQUEST FOR EXPEDITED PROCESSING Edward Wytkind, President Transportation Trades Department, […]

Read More

TTD Comments on Competitive Passenger Rail Service Pilot Program

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write to comment on FRA’s Notice of Proposed Rulemaking (NPRM) which seeks to implement the Competitive Passenger Rail Service Pilot Program. As the FRA notes, Section 11307 of the FAST Act (codified at 49 USC 24711) has directed the agency to solicit bids from non-Amtrak entities to replace current Amtrak service on up to three long-distance routes and that this NPRM is a result of that mandate. By way of background, TTD consists of 32 affiliated unions representing workers in all modes of transportation, including employees working on and in conjunction with existing passenger rail routes, who would be impacted by this proceeding.

Read More

TTD Urges that Port Metrics Not be Used to Undermine Collective Bargaining

As the Department of Transportation (DOT) convenes its Port Performance Freight Statistics Working Group today, I urge you to implement the statute creating this group and the broader port statistics program as directed by Congress in Section 6018 of the FAST Act. Attempts by some to broaden the scope of the Port Performance program to include the collection of worker productivity measurements should be dismissed by the DOT. As you know, the collection of these worker productivity metrics was debated and ultimately rejected by Congress during consideration of the FAST Act. Now certain interests are promoting this data collection in a deliberate and poorly veiled attempt to undermine the collective bargaining process in the seaport sector, even though it contradicts the views of this Administration and goes beyond the scope and mission of DOT and its Bureau of Transportation Statistics (BTS).

Read More

Sign Up for Updates