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Federal Comments

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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TTD Supports the Gold Standard in Drug Testing, Opposes Unsubstantiated Hair Specimen Testing

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write to comment on the Substance Abuse and Mental Health Services Administration (SAMHSA) Request for Information Regarding the Use of the Hair Specimen for Drug Testing. By way of background, TTD consists of 32 affiliate unions that represent workers in all modes of transportation including those who would be directly impacted by any changes made to the current Mandatory Guidelines for Federal Workplace Drug Testing Programs. We therefore have a vested interest in this notice. In addition to the comments that follow, we endorse those submitted independently by TTD affiliates, the Air Line Pilots Association (ALPA), International Association of Sheet Metal, Air, Rail and Transportation Workers-Transportation Division (SMART-TD), and the Transport Workers Union of America (TWU).

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TTD Supports Proposal to Medically Certify Drivers with Diabetes

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write in support of the Notice of Proposed Rulemaking (NPRM) on Qualifications for Commercial Motor Vehicle (CMV) Drivers; Diabetes Standard. By way of background, TTD consists of 32 affiliate unions representing workers in all modes of transportation, including those who are medically certified to operate a CMV. We therefore have a vested interest in this rulemaking. In addition to the comments that follow, we endorse those separately filed by TTD affiliates, the Amalgamated Transit Union (ATU) and the Sheet Metal, Air, Rail Transportation Union – Transportation Division (SMART-TD).

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U.S., European Unions Agree: Ground NAI Scheme


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TTD Calls for Strong Safety Standards for Drone Integration

Under this NPRM, FAA creates new 14 CFR part 107 to regulate the operation of non-recreational small unmanned aircraft systems (sUAS) in the NAS; the certification of sUAS operators; and the requirements of the small unmanned aircrafts. Finding that sUAS are capable of safely operating in the NAS, FAA proposes this rulemaking in accordance with the FAA Modernization and Reform Act of 2012 and begins the integration of small commercial UAS into our nation’s airspace.

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TTD Supports Increasing the Motorcoach Insurance Requirement

At the outset, we express support for FMCSA’s consideration of updating its existing standard that requires motor carriers to maintain a specified minimum level of financial responsibility to provide coverage for public liability and property damage resulting from a commercial bus accident. TTD and our affiliates have a long history of advocating for strengthening market entry standards to help ensure only upstanding motor carriers are granted operating authority. Just last week, TTD’s Executive Committee renewed the call for improving these standards, urging FMCSA to increase the current minimum level of financial responsibility.

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TTD Steps Up Fight to Ban Voice Calls on Commercial Flights

TTD and our affiliates strongly oppose efforts to overturn the decades-old policy that prohibits passengers from using mobile wireless devices to make voice calls while in-flight. As thoroughly explained in our filings to proceedings promulgated by the Federal Communications Commission (FCC) and Department of Transportation (DOT), we believe the introduction of in-flight voice calls pose unnecessary safety issues and security risks to passengers and flight crews, including flight attendants and pilots.[2] Overturning this longstanding policy also creates another unnecessary distraction in an inherently disruptive cabin environment that could create adversarial interactions between passengers.

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TTD Advocates for Strong Buy America Standards

At the request of Amtrak and CAHSRA, FRA seeks to waive its Buy America standard in order to allow the final assembly of up to four HSR trainset prototypes to take place outside the U.S.  Given the limitations on the domestic production and testing of HSR trainset prototypes as identified in the notice, we will not oppose this narrow waiver to help expand HSR in the U.S. while simultaneously developing domestic production facilities.

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