Federal Comments

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.

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.

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.

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.

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.

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, […]

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.

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).

On behalf of the Transportation Trades Department, AFL-CIO (TTD), we are pleased to comment on the U.S. Department of Commerce’s 21st Century U.S. Port Competitiveness Initiative and hope to better inform the agency’s report on best practices at seaports. By way of background, TTD consists of 32 affiliated unions in the transportation sector, including longshore, maritime and rail unions employed at or otherwise directly affected by U.S. ports. We therefore have a vested interest in this rulemaking.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write to comment on FRA and FMCSA’s joint Advanced Notice of Proposed Rulemaking (ANPRM) on evaluating certain safety-sensitive transportation workers for obstructive sleep apnea (OSA). By way of background, TTD consists of 32 affiliated unions representing workers in all modes of transportation, including those who FMCSA and FRA may consider safety-sensitive and would be impacted by this proceeding.[1] We therefore have a vested interest in this rulemaking.