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Federal Comments

FRA Must Reject Unjustified Training Waiver

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Railroad Administration’s request for comment on its notice entitled Petition for Waiver of Compliance from Long Island Rail Road (LIRR). TTD consists of 33 affiliate unions representing workers in all modes of transportation, including impacted employees at Long Island Railroad. We therefore have a vested interest in this petition.[1] We also strongly endorse the comments of the Transport Workers Union of America, a TTD-affiliated union.

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TTD Petitions DOT for Passenger Face Mask Mandate

Dear Secretary Chao:   On behalf of the Transportation Trades Department, AFL-CIO (TTD) and our 33 affiliated unions across the transportation industry[1], I write today to petition the Department of Transportation (DOT) to expeditiously promulgate regulation to mandate the usage of masks or face coverings for passengers travelling with DOT-regulated commercial transportation providers during the course of the Presidential Declaration of Emergency for COVID-19.

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TTD: Increasing Railroad Classification Thresholds is Unwarranted

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on Montana Rail Link Inc.’s petition concerning changes to revenue thresholds for the classification of rail carriers. By way of background, TTD consists of 33 affiliate unions, including unions representing freight rail workers who may be impacted by the granting of this petition.

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FMCSA Must Not Modify Hours of Service Standards for Unproven Automated Technology

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to FMCSA’s request for comment on its notice Hours of Service of Drivers: Pronto.ai, Inc. (Pronto); Application for Exemption. TTD consists of 33 affiliate unions representing workers in all modes of transportation, including drivers of commercial motor vehicles.[1] We therefore have a vested interest in this policy.

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To Protect Workers from COVID-19, DOT Must Pause Testing

Dear Ms. Kelly: On behalf of the Transportation Trades Department, AFL-CIO (TTD), I call on the Department of Transportation to take immediate action to eliminate risks of COVID-19 contagion from continued random drug and alcohol testing of essential transportation workers. TTD consists of 33 affiliate unions representing workers in all modes of transportation covered by DOT’s drug and alcohol testing requirements, including those administered by FAA, FMCSA, FTA, FRA, PHMSA and USCG

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TTD Demands Immediate Federal Protective Measures for Frontline Transportation Workers

Dear Secretaries Chao and Scalia: It has now been over a month since the World Health Organization (WHO) declared the COVID-19 outbreak to be a pandemic. The United States alone has had over 670,000 confirmed cases and, tragically, over 34,000 deaths. Since this public health crisis began, TTD and our unions have consistently urged the federal government to take specific steps to protect frontline transportation workers and their families from exposure to this virus.

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Rail Labor to FRA: Recalling Furloughed Employees Must Come Before Safety Waivers

Dear Administrator Batory: On March 13th, the FRA opened the Emergency Relief Docket (FRA-2020-0002) for Novel Coronavirus (COVID-19), activating the provisions of 49 CFR § 211.45. These provisions grant the FRA wide latitude to expeditiously waive its regulations, including those that concern rail safety and the wellbeing and fair treatment of employees. For these reasons, we are carefully monitoring requests for relief made to the docket and may file additional comments on present or future petitions.

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Union Leaders Call on FTA to Set Mandatory Safety Standards, Ensure Pay for Frontline Transit Workers

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:

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DOT’s AV 4.0 is More of the Same

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.

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TTD to FRA: Hands on Training is Not Replaceable

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

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