Federal Comments

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.

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) on Train Crew Staffing. By way of background, TTD consists of 32 affiliate unions representing workers in all modes of transportation including those employed in the passenger and freight rail industries. We therefore have a vested interest in this proceeding. In addition, we endorse the comments filed by a TTD affiliate, 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 write to comment on the Railroad Retirement Board’s (RRB) proposed renewal and revision of its G-251 form. By way of background, TTD consists of 32 affiliated unions that represent workers in all modes of transportation, including those employed in the railroad industry. We therefore have a vested interest in this proceeding.

Through this notice, FMCSA is seeking to define a “curbside bus operator” for the purpose of implementing section 32707 of MAP-21, which requires an annual safety fitness assessment of certain motor carriers of passengers that serve primarily urban areas with high passenger loads. The Agency has specifically identified curbside operators as the intended subject of that requirement, and proposes that these carriers should be defined as those that use 25% or more of their motorcoaches for operations involving pick-ups and drop-offs at curbside locations or parking lots.

In its March 2, 2016 filing, CPRL requests the STB to provide a declaratory order on whether it would be potentially permissible for CPRL to hold its own subsidiaries in trust while it acquires ownership and control of NS and seeks regulatory approval of a CP-NS merger. CPRL has not submitted an actual voting trust proposal for STB’s review but rather requests the agency’s opinion on a theoretical trust. CPRL’s petition also requests a ruling on whether it would be permissible for CP’s chief executive officer (CEO) to divest from CP and assume a comparable position at NS where he would implement various substantial operational and structural changes.