Letters to the Administration

We write to express concern that a previously rare and limited business model for air service, once confined to private jet charters, is expanding so rapidly that it threatens to take over a large part of the air services in the United States.  Airlines selling passenger tickets on flights that are scheduled in all but name are operating under a combination of rules: the safety rules of 14 CFR Part 135, the economic rules of 14 CFR Part 298 for commuter air carriers, and 14 CFR Part 380 for public charters.  Because of a loophole created by that combination of rules, these airlines are able to skirt safety and security regulations that your departments and agencies enforce.  A pending application before DOT by a unit of SkyWest Airlines implicates this business model, as we will describe.

One such air carrier is branded as “JSX.”  The operator is Delux Public Charter, LLC, d/b/a JSX Air, and the charterer and re-seller of seats is JetSuiteX, Inc. (collectively, JSX).  Through this complex structure, JSX is providing scheduled passenger service between major airports available for purchase in a manner that — to the ordinary consumer — looks identical to buying a seat on a regular scheduled airline.  This arrangement enables JSX to fly a self-described “hop-on jet service” with scheduled operations on aircraft limited to 30 passengers under Part 135, asserting a speedy path to the plane using “private terminals,” and “non-invasive security procedures.”

March 14, 2023 The Honorable Pete Buttigieg Secretary U.S. Department of Transportation 1200 New Jersey Avenue, S.E. Washington, DC 20590 Dear Secretary Buttigieg, The hazardous materials rail spill in East Palestine, OH has seriously jeopardized public health and safety, caused significant environmental damage, and imposed enormous economic costs for clean-up and restoration. In the aftermath […]

Technological change has always been a hallmark of the transportation sector. But with recent advancements in automation, robotics and artificial intelligence, and other emerging technologies, the pace of and impact of technological change has been more rapid and significant than at any other time in the history of human mobility.

While our organizations represent different stakeholder communities with diverse perspectives, we are firmly aligned in our belief that the pace of technological change necessitates a more responsive federal apparatus that brings together the voice of leaders in innovation, employers, unions, and other key stakeholders to better understand and manage the broad impacts of new technologies on the workforce.

February 9, 2023 Administrator Amit Bose Federal Railroad Administration 1200 New Jersey Ave, SE Washington, DC 20590 Dear Administrator Bose: On behalf of the Transportation Trades Department (TTD) of the AFL-CIO, we are writing to express our concerns about the safety of freight rail operations in the United States and to urge greater federal oversight […]

The Honorable Pete Buttigieg Secretary U.S. Department of Transportation 1200 New Jersey Avenue, SE Washington, DC 20590 Dear Secretary Buttigieg: On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am writing to express deep concern about the U.S. Department of Transportation’s (DOT) approach toward the deployment of poorly regulated and potentially disruptive new technologies […]

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I offer my strong support for Captain Donald L. Moak to serve another term on the Board of Governors of the United States Postal Service (USPS).

The USPS Board of Governors was established by Congress more than 50 years ago to direct the powers of the Postal Service, and to oversee its expenditures, practices, and long-range planning, and to set policies on all postal matters. As a labor federation representing workers in all modes of transportation, including the National Association of Letter Carriers (NALC), whose members drive the country’s largest federal fleet, TTD has a vested interest in ensuring the Board promotes the safety, security, and welfare of the Postal Service’s workers. Given Captain Moak’s current service on the Board and his long and distinguished career in union labor, we know he is more than qualified to be reappointed to serve a second term.

On behalf of the Transportation Trades Department, AFL-CIO (TTD) and the totality of rail labor as represented by our affiliated unions, I write in support of the sentiments raised by the National Grain and Feed Association’s (NGFA) March 24th letter to the Board. NGFA describes service disruptions its members are facing on the Union Pacific (UP), Burlington Northern Santa Fe (BNSF) and Norfolk Southern (NS), in both picking up and delivering grain and feed products. As NGFA discusses, this presents not only financial challenges for its members, but ultimately threatens the ability of the nation’s farmers to feed their livestock. The notion that our nation’s food supply chain is threatened by the continued negligence and intransigence of the railroad industry is both stunning and unacceptable. 

On behalf of U.S. transportation workers — including the vast majority of public transportation employees — who are collectively represented by the undersigned unions, we are writing to ensure you are aware of the increasingly dangerous atmosphere in our public transportation systems and to urge you to protect workers and riders by immediately implementing the safety provisions of the Bipartisan Infrastructure Law (BIL). Our members include bus and rail transit operators, station agents, car cleaners, mechanics, and other frontline workers, all of whom are at risk of assault and worse each day they arrive at work. President Biden committed to protecting these workers and that promise was enshrined into law as part of the BIL. Before, and particularly during the COVID-19 pandemic, these workers have laid their lives on the line every day to ensure Americans have access to safe, reliable transportation, and we must not turn our backs on them another day.

On February 1, 2022, BNSF Railway implemented a new “Hi-Viz” attendance policy that betrays its obligation to protect the safety and health of its workers and the public. This draconian new policy will reduce the safety of the rail network and exacerbate existing supply chain challenges. We concur with the letter sent on January 31, 2022 by the BLET and SMART-TD, TTD affiliate unions, and hope you will examine this matter and its effects on impacted BNSF employees.

Most railroad engineers and trainmen do not work predictable schedules. They are expected to remain in on-call status continuously, without pause for weekends and holidays. This often means that a rail worker can learn at any time, with as little as 90 minutes of notice, that they are called to report to work for a shift lasting anywhere from 12 to 60 hours. The only mechanism that provided some degree of predictability to this arrangement was train line-ups, which indicated a loose likelihood of being called to duty, and were solely managed by the railroad. BNSF has admitted that this system was inadequate and poorly predicted workers’ schedules.