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Federal Comments

DHS Must Strengthen Foreign Repair Station Security Rule

By Admin

The Honorable Janet Napolitano Secretary U.S. Department of Homeland Security Washington, D.C. 20528Dear Secretary Napolitano: I am writing in regard to a letter sent to you earlier this week by several aviation industry associations urging timely completion of a final rule on aircraft repair station security.  While we agree that action on new security rules […]

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TTD Fully Supports NTSB Accident Investigation Party Process

By Admin

Mr. David Tochen General Counsel Office of the General Counsel National Transportation Safety Board 490 L’Enfant Plaza Washington, D.C. 20594   RE:     Plan for Retrospective Analysis of Existing Rules            National Transportation Safety Board            Docket No. NTSB-GC-2012-001   Dear Mr. Tochen, On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am writing to […]

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TTD Comments on National Mediation Board Representation Disputes Proposed Rules

By Admin

COMMENTS OF THE TRANSPORTATION TRADES DEPARTMENT, AFL-CIO __________________________ BEFORE THE NATIONAL MEDIATION BOARD ON REPRESENTATION DISPUTES PROPOSED RULES DOCKET NO. C-7034 August 6, 2012              The Transportation Trades Department, AFL-CIO (“TTD”) hereby submits its comments regarding the Notice of Proposed Rulemaking (“NPRM”) issued by the National Mediation Board (“NMB” or “Board”) on May 15, 2012, […]

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TTD Comments on Control of Alcohol and Drug Use: Addition of Post-Accident Toxicological Testing for Non-Controlled Substances

By Admin

Mr. Lamar Allen Alcohol and Drug Program Manager Office of Safety Enforcement Federal Railroad Administration 1200 New Jersey Avenue SE Washington, DC  20590  RE:     Control of Alcohol and Drug Use: Addition of Post-Accident            Toxicological Testing for Non-Controlled Substances            Federal Railroad Administration            Docket No. FRA–2010-0155 Dear Mr. Allen, On behalf of the […]

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TTD Comments on NMB Proposed Rulemaking

By Admin

On behalf of the Transportation Trades Department, AFL-CIO (“TTD”), I want to thank the National Mediation Board (“NMB” or “Board”) for the opportunity to present our views on the Board’s recently proposed rules regarding representation procedures. TTD consists of 32 affiliated unions representing workers in all modes of transportation, including those covered under the Railway […]

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TTD Comments on Lithium Battery Rulemaking

By Admin

VIA ELECTRONIC SUBMISSION Mr. R. Ryan Posten Deputy Associate Administrator Pipeline and Hazardous Materials Safety Administration RE:     Pipeline and Hazardous Materials Safety Administration Docket No. PHMSA–2009–0095 (HM-224F) Hazardous Materials: Transportation of Lithium Batteries Notice of Proposed Rulemaking (NPRM); request for additional comment Dear Mr. Posten: On behalf of the Transportation Trades Department, AFL-CIO (TTD), […]

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TTD Comments on Family and Medical Leave Act Rulemaking

By Admin

VIA ELECTRONIC SUBMISSION Mary Ziegler Director of the Division of Regulations, Legislation and Interpretation Wage and Hour Division US Department of Labor; Room S-3510 200 Constitution Ave., NW Washington DC, 20210 RE: The Family and Medical Leave Act; RIN 1235-AA03 Dear Ms. Ziegler, On behalf of the Transportation Trades Department, AFL-CIO (TTD), we are pleased to […]

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Comments on Passenger Rail Privatization

By Admin

The Honorable Joseph C. Szabo Administrator Federal Railroad Administration U.S. Department of Transportation 1200 New Jersey Avenue, SE Washington, DC  20590 VIA http://www.regulations.gov Re:      Docket No. FRA-2009-0108, Notice No. 1: Alternate Passenger Rail Service Pilot Program Dear Administrator Szabo: On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am writing to comment on the […]

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TTD Supports Hours of Service Change for Passenger Train Operators

By Admin

The Honorable Joseph C. Szabo Administrator Federal Railroad Administration (Attention: Docket Operations, M-30) U.S. Department of Transportation 1200 New Jersey Avenue, SE Rm W-12-140 West Building Ground Floor Washington, DC  20590-0001 Re: Docket No. FRA-2009-0043, Notice No. 1: Hours of Service of Railroad Employees; Substantive Regulations for Train Employees Providing Commuter and Intercity Rail Passenger Transportation; […]

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Strengthening Helicopter Safety

By Admin

The Honorable J. Randolph Babbitt Administrator Federal Aviation Administration (Attention: Docket Operations, M-30) U.S. Department of Transportation 1200 New Jersey Avenue, SE Rm W-12-140 West Building Ground Floor Washington, DC  20590-0001 Re: Docket No. FAA-2010-0982: 14 CFR Parts 1, 91, 120, and 135 Air Ambulance and Commercial Helicopter Operations, Part 91 Helicopter Operations, and Part 135 […]

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