Federal Comments

Stories of frontline public transportation workers contracting COVID-19 and tragically dying from the virus are already emerging around the country, and it will only get worse in the coming weeks and months. To ensure the best use of the emergency funding provided by the CARES Act and to protect the health and safety of the frontline workforce and traveling public, we request the following:

Dear Mr. Fulton: On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to DOT’s request for comment on its document entitled “Ensuring American Leadership in Automated Vehicle Technologies: Automated Vehicles 4.0 (AV 4.0).”  TTD consists of 33 affiliate unions representing workers in all modes of transportation, including those who will be impacted by the development and deployment of automated vehicles. We therefore have a vested interest in this policy.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Canadian Pacific Railway’s (CP) petition for a waiver of compliance from the “hands-on” component of periodic refresher training required by 49 CFR 232.203(b)(8). By way of background, TTD consists of 33 affiliate unions, including unions representing freight rail workers.[1] In responding to this notice, TTD strongly endorses the comments filed by the Transport Workers Union of America and the Brotherhood of Railway Carmen Division of the Transportation Communications Union/IAM

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) Notice of Proposed Rulemaking (NPRM) concerning the transportation of liquefied natural gas (LNG) by rail. By way of background, TTD consists of 33 affiliate unions, including unions representing freight rail workers and first responders.[1] In responding to this notice, TTD strongly endorses the comments filed by the International Association of Fire Fighters (IAFF) and the International Association of Sheet Metal, Air, Rail and Transportation Workers, Transportation Division (SMART-TD).

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Federal Railroad Administration’s (FRA) Notice of Proposed Rulemaking (NPRM) concerning Grade Crossing Action Plans. TTD consists of 33 affiliate unions, including unions representing railroad operating crews, workers who install and maintain crossing-grade signal systems, and first responders.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Federal Aviation Administration’s (FAA) Advance Notice of Proposed Rulemaking (ANPRM) concerning Flight Attendant Duty Period Limitations and Rest Requirements. By way of background, TTD consists of 33 affiliate unions, including unions representing flight attendants, and unions whose members work cooperatively with flight attendants to maintain safety aboard commercial aircraft.[1] In responding to this notice, TTD strongly endorses the comments filed by the Association of Flight Attendants-CWA, the International Association of Machinists and Aerospace Workers, and the Transport Workers Union.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to FRA’s request for comment on Norfolk Southern’s (NS) petition for a waiver of compliance concerning employee injury/illness forms. TTD consists of 33 affiliate unions representing workers in all modes of transportation, including freight rail employees whose workplace injuries and illness are reported and documented via the regulation NS seeks relief from.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to FMCSA’s request for comment on its Notice of Proposed Rulemaking (NPRM) regarding changes to the agency’s hours of service regulations. TTD consists of 33 affiliate unions representing workers in all modes of transportation, including thousands of commercial motor vehicle drivers who will be impacted by these proposed changes. We therefore have a vested interest in this rulemaking.[1]

In the NPRM, FMCSA proposes five major changes to its current HOS regulations. This includes modifications to current requirements concerning the short haul exemption, drive time limits during adverse driving conditions, the 30-minute rest break, the use of sleeper berths, and a new proposal on split duty.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on Norfolk Southern Railway Company’s (NS) waiver of compliance regarding the operation of RoadRailer units. By way of background, TTD consists of 33 affiliate unions representing workers in all modes of transportation, including rail workers who operate and inspect the equipment discussed in NS’ request

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Maritime Administration’s (MARAD) notice seeking information on port automation. By way of background, TTD consists of 33 affiliate unions representing workers in all modes of transportation, including the International Longshoremen’s Association, who are employed at and around ports and harbors. We therefore have a vested interested in the request.