Federal Comments

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the U.S. Department of Transportation’s (DOT) Proposed Temporary Waiver of Buy America Requirements for Construction Materials. TTD consists of 37 affiliate unions representing workers in construction and manufacturing who are directly impacted by Buy America policies.[1]

The waiver would provide relief from Buy America requirements for 180 days, beginning May 14, 2022. During this time, DOT expects states, industry, and other partners to begin the compliance process in conjunction with the new Made in America standards that were included in the Build America, Buy America (BABA) title of the Infrastructure Investment and Jobs Act (IIJA). These requirements include that all of the iron, steel, manufactured products, and construction materials used in federally-assisted infrastructure projects are produced in the United States.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the U.S. Department of Transportation’s (DOT) proposed rule regarding the Addition of Oral Fluid Specimen Testing for Drugs. TTD consists of 37 affiliate unions representing workers across all modes of transportation.[1]

The proposed rule would allow the use of oral fluid specimens to be used for drug testing programs. In 2019, the Department of Health and Human Services (HHS) approved the use of oral fluid drug testing, and this proposed rule would align DOT’s regulations with the new Mandatory Guidelines for Federal Workplace Drug Testing Programs using Oral Fluid already finalized by HHS. In addition to the establishment of oral fluids as an accepted specimen, DOT also proposes to make a number of changes to its drug testing regulations beyond the scope of the addition of a new specimen.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the U.S. Department of Transportation’s (DOT) notice regarding the Non-Traditional and Emerging Transportation Technology (NETT) Council’s request for comments. TTD consists of 37 affiliate unions representing workers across all modes of transportation. Those unions, and the millions of workers they represent, bring a critical perspective to the questions put forward in this notice.

As you know, the Infrastructure Investment and Jobs Act (IIJA) tasked the NETT Council with resolving jurisdictional and regulatory gaps or inconsistencies associated with nontraditional and emerging transportation technologies and coordinating DOT’s response to nontraditional and emerging transportation technology projects. While TTD supports an agency-wide approach to evaluating the regulatory challenges presented by new and emerging technologies, the agency’s success in meeting these challenges will hinge squarely on the direct involvement of labor unions. History has proven that strong unions and worker engagement are essential to mitigate the harms inherent in rapid technological changes to industries, and this is particularly true in the transportation sector, which has enjoyed relatively strong union density over the past century.

The Transportation Trades Department, AFL‐CIO (“TTD”), AFL-CIO, the International Association of Machinists and Aerospace Workers (IAM) and the Transport Workers Union of America (TWU), hereby submit this Answer to the Consolidated Reply of Wizz Air Hungary, Ltd. (Wizz), including its motion for an exemption, and supports the Response of the Air Line Pilots Association, International (ALPA) and Association of Flight Attendants, CWA.   As we will show, the Consolidated Reply fails to address the concerns raised by ALPA, the European Cockpit Association (ECA), the Allied Pilots Association (APA), the Independent Pilots Association (IPA), and the Southwest Airlines Pilots Association (SWAPA).  Collectively, we support the request of these pilot unions and associations for consultations among the Department and its European counterparts. 

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Railroad Administration’s notice regarding Union Pacific’s petition for extension of a waiver of compliance. TTD consists of 36 affiliate unions representing workers in all modes of transportation, including carmen and other rail workers who work on lines covered by this waiver.[1]

In its petition, UP requests to extend a 2017 waiver of compliance to continue using wheel temperature detectors (WTD) on a segment of UP track to measure potential safety improvements and cost reductions on brake testing and maintenance. This waiver differs from current rules that state that extended haul trains are permitted to move a train up to, but not exceeding, 1,500 miles between brake tests and inspections. 49 CFR 232.213(a). In addition, current rules require that equipment with defective or insecure power brakes only be moved from the place at which the defect or insecurity was first discovered to the nearest available place at which the repairs can be made (49 CFR 232.15 and 49 U.S.C. 20303), and each car in a train must have the air brakes in effective operating conditions unless the car is being moved for repairs in accordance with 49 CFR 232.15 (49 CFR 232.1 03(f)).

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the U.S. Department of Transportation’s (DOT) request for information on its (FY) 2022-2026 Research, Development, and Technology (RD&T) Strategic Plan. TTD consists of 36 affiliate unions representing workers in all modes of transportation, including those directly affected by the DOT’s policies and programs. Specifically, the next wave of research initiatives funded by the agency as a result of the RD&T Strategic Plan will have a profound effect on the future of mobility, work and jobs in this industry. We therefore have a vested interest in the results from this important proceeding.[1] We also want to concur with the separate comments submitted by the Transport Workers Union, a TTD member union.

Dear Administrator Fernandez, On behalf of the Transportation Trades Department, AFL-CIO (TTD), I urge you to ensure that the transformative investments in Zero-Emission Buses (ZEBs) included in the Infrastructure Investment and Jobs Act (IIJA) promote good union jobs among the incumbent and future workforces who will be tasked with maintaining the next generation of transit […]

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the U.S. Department of Transportation’s (DOT) request for comment on its 2022-2026 Strategic Plan. TTD consists of 33 affiliate unions representing workers in all modes of transportation, including workers directly affected by the DOT’s policies and programs.[1] We must be clear that the goals outlined by the DOT for the 2022-2026 Strategic Plan—creating good jobs, improving equity and environmental outcomes, and making the DOT more effective and accountable to the American people—can, and will, only be successfully achieved when the voice of working people is integral to the formulation and implementation of those policies.

While these comments aim to be comprehensive, we also recognize that they may not be fully inclusive in representing the needs and positions of transportation labor. We therefore strongly urge your full consideration of individual comments filed by our affiliated unions, and encourage further ongoing dialogue with those who represent working people to ensure the 2022-2026 Strategic Plan gives due consideration to the needs of all working people.

On behalf of the Transportation Trades Department, AFL-CIO (TTD) and our 33 affiliated unions, we thank you for taking this important step to begin examining the serious safety issues facing transit workers across this country every single day.

TTD’s affiliated unions collectively represent most transit workers in this country, including rail transit, bus, roadway, construction, and maintenance workers[1]. Most of these workers interface directly with the public, and all are exposed to the risks of assault. We have long-called for both legislative and regulatory solutions to increase worker safety, including putting a stop to the scourge of assaults on transit workers.

August 16, 2021   Nuria Fernandez Federal Transit Administration East Building 1200 New Jersey Avenue, SE Washington, DC 20590 RE: Transit Safety Concerns Docket No. FTA-2021-0011 On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Transit Administration’s (FTA) Request for Information on Transit Safety Concerns. TTD consists […]