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Federal Comments

TTD Calls for Additional Investigation on Proposed Rail Safety Measures

By Admin

June 18, 2024 Mr. Karl Alexy Associate Administrator for Railroad Safety & Chief Safety Officer Federal Railroad Administration 1200 New Jersey Avenue SE Washington DC,  20590       RE:     Amtrak Petition for Waiver of Compliance, Shunt Enhancer Equipment                   Docket No. FRA-2023-0095  Dear Mr. Alexy: On […]

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Transportation Labor Supports Safety Standards for Transit Roadway Workers

By Admin

May 24, 2024 The Honorable Veronica Vanderpool Acting Administrator Federal Transit Administration U.S. Department of Transportation 1200 New Jersey Avenue, SE Washington, DC  20590 Re:      NPRM re: Rail Transit Roadway Worker Protection              Docket No. FTA-2023-0024 Dear Acting Administrator Vanderpool: On behalf of the Transportation Trades Department, AFL-CIO (TTD), I […]

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TTD Continues to Support Strong Buy America Requirements

By Admin

May 13, 2024 Shailen P. Bhatt Administrator Federal Highway Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590      RE:     Notice of Proposed Rulemaking on Buy America Requirements for Manufactured Products      Docket No. FHWA-2023-0037 Dear Administrator Bhatt: On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to […]

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Buy America Waiver Would Come at the Expense of Union Workers

By Admin

April 15, 2024 Michael Regan Administrator Environmental Protection Agency 1200 Pennsylvania Avenue N.W. Washington, DC 20004 RE:    Proposed General Applicability Public Interest Waiver of Section 70914(a) of P. L. 117-58, Build America, Buy America Act, 2021 for U.S. Environmental Protection Agency Financial Assistance Awards under the Clean Ports Program Administrator Regan: On behalf of […]

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TTD Supports Drug & Alcohol Testing Standards For Foreign Air Repair Station Workers

By Admin

April 5, 2024   The Honorable Michael Whitaker Administrator Federal Aviation Administration 800 Independence Avenue, SW Washington, DC  20591       RE:   Drug and Alcohol Testing of Certificated Repair Station Employees Located Outside of the United States                 Docket No. FAA-2012-1058 Dear Administrator Whitaker: On behalf of […]

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TTD Urges FRA To Consider Labor’s Concerns When Evaluating Autonomous Railcar Testing

By Admin

April 1, 2024 Mr. Karl Alexy Associate Administrator for Railroad Safety & Chief Safety Officer Federal Railroad Administration 1200 New Jersey Avenue SE Washington DC, 20590      RE:     Petition for Waiver of Compliance, Georgia Central Railway, L.P. and Heart of Georgia Railroad, Inc.      Docket No. FRA-2023-0066 Dear Mr. Alexy: On behalf of […]

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Reject BNSF’s Request for Permanent Waiver from Safety Measures

By Admin

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Railroad Administration’s (FRA) notice regarding BNSF Railway Company’s petition to make permanent its existing waiver from certain provisions of the Federal railroad safety regulations contained at 49 CFR parts 232 (Brake System Safety Standards for Freight and Other Non-Passenger Trains and Equipment; End-Of-Train Devices), and 229 (Railroad Locomotive Safety Standards). Canadian National Railway Company (CN) and Union Pacific Railroad (UP) are also requesting relief under the existing waiver. TTD consists of 37 affiliated unions representing the totality of rail labor, including freight rail employees.[1] For the reasons outlined below, we ask that the FRA deny this petition. In addition, we endorse the comments filed in this docket by our affiliates, the Brotherhood of Locomotive Engineers and Trainmen (BLET) and the Transportation Division of the International Association of Sheet Metal, Air, Rail, and Transportation Workers (SMART-TD).

The existing waiver allows BNSF, CPKC, and CSX to test extending the air flow method (AFM) test intervals from 92 days to 184 days on locomotives equipped with the New York Air Brake (NYAB) CCB–II and Fastbrake air brake systems. The most recent petition requests that the relief granted under the existing waiver be extended to CN and UP. In addition, BNSF is requesting that this relief be made permanent.

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Workers Must Be Front and Center in Clean Energy Transition

By Admin

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Department of Energy’s (DOE) request for information (RFI) on the progression to net-zero emission propulsion technologies for the rail sector. TTD consists of 37 affiliated unions representing the totality of rail labor, including both passenger and freight rail workers.[1] We therefore have a vested interest in this RFI and encourage the DOE to take our input into consideration.

Our affiliate unions represent the vast majority of railroad industry workers engaged in train operations, train dispatching, signal, maintenance of way and mechanical maintenance, inspection, testing, and repair on passenger and freight railroads throughout the United States. Each of these crafts will be impacted in some way by the transition to net-zero rail propulsion technology. Workers in the mechanical crafts, who are responsible for the maintenance, inspection, testing, and repair of locomotives and rail cars, will likely experience the most significant changes to their day-to-day jobs as the rail sector begins to transition to net-zero technology and the technology used in locomotives changes from the current diesel based setup.

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FTA Must Empower Workers to Make Decisions About Fatigue

By Admin

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Transit Administration’s (FTA) advanced notice of proposed rulemaking (ANPRM) regarding potential standards for hours of service and fatigue risk management programs for transit workers. TTD consists of 37 affiliated unions, including those representing the majority of public transportation workers in the United States, whose safety and livelihoods will be impacted by potential regulations governing hours of service and fatigue risk management for transit employees.[1] In addition, we endorse the comments submitted by our affiliates, the Transport Workers Union of America (TWU) and the Amalgamated Transit Union (ATU).

Background

Prior to responding to the substance of this ANPRM, we’d like to first express our strong disapproval of the FTA’s handling of this proceeding. From the beginning of this rulemaking process, the FTA’s noticeable partiality toward the American Public Transportation Association (APTA) has been an affront to our members. The FTA has made feeble attempts to engage with the labor organizations whose members will be directly affected by the establishment of hours of service requirements, all the while holding listening sessions that have served as sounding boards for anti-worker and anti-union sentiments. The FTA must consider the perspectives and expertise of those directly involved in providing this essential service to our communities. We urge the FTA to work with labor stakeholders in an open and meaningful way going forward.

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TTD Urges FRA to Consider Labor’s Input for Brightline West “Buy America” Waiver

By Admin

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Railroad Administration’s (FRA) request for comments on a proposed non-availability waiver of Buy America requirements for certain components necessary to complete a high-speed passenger train project between Las Vegas, NV and Rancho Cucamonga, CA. TTD consists of 37 affiliated unions, including those representing the totality of rail labor and workers in construction and manufacturing who will be directly impacted by this potential waiver.[1] We therefore respectfully request that the FRA take our input on this matter into serious consideration.

At the request of the Nevada Department of Transportation (NVDOT) and Brightline West, the FRA seeks to waive its Buy America requirements for the domestic production of the trainset, signal systems, high-speed rail turnout and fire alarm systems required for the high-speed passenger rail project between Las Vegas and Rancho Cucamonga. According to the FRA’s notice, two potential suppliers, Siemens and Alstom, represented they could provide the necessary high-speed rail components that meet Brightline West’s specifications and the applicable FRA safety requirements but could not domestically produce certain components that would be required to meet the specifications.

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