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Federal Comments

FMCSA Must Not Dilute Entry Level Driver Training Requirements

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the United Parcel Service’s (UPS) application for exemption from elements of the Entry Level Driver Training (ELDT) final rule. TTD consists of 33 affiliate unions representing workers in all modes of transportation, including commercial motor vehicle drivers who are subject to the FMCSA’s CMV and CDL requirements.

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FMCSA Must Not Interfere With California Labor and Safety Protections

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to FMCSA’s request for comments on the American Bus Associations’ (ABA) petition for federal preemption of California’s Meal and Rest Break rules. TTD consists of 33 affiliate unions representing workers in all modes of transportation, including those covered by FMCSA’s HOS regulations and California’s rules.[1] For reasons discussed below, we urge FMCSA to reject ABA’s petition.

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TTD Responds to DOT’s Review of Guidance

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Department of Transportation’s (DOT) notice seeking information on guidance documents that it should consider repealing or revising. By way of background, TTD consists of 33 affiliate unions representing workers in all modes of transportation who are impacted by DOT regulations and guidance. [1] We therefore have a vested interested in the request.

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TTD’s Comments on Decertification of Representatives before the NMB

The Unions that comprise the Transportation Trades Department of the AFL-CIO (“TTD”) hereby submit these comments regarding the Notice of Proposed Rulemaking (“NPRM”) issued by the National Mediation Board (“NMB” or “Board”) on January 31, 2019.   84 Fed. Reg. 612 (Jan. 31, 2019).   These 32 affiliated unions represent employees in all modes of transportation, including railroad and airline employees covered by the Railway Labor Act (“RLA”).[1]  TTD welcomes the opportunity to submit comments to the NMB regarding its recent proposed decertification procedure rule-making.   TTD strongly opposes the Board’s proposed rulemaking.  The NPRM is inconsistent with the RLA.  The proposed rules changes exceed the scope of the Board’s narrow jurisdiction under Section 2, Ninth and unreasonably restrict employees’ exercise of the right to choose representation under the statute.  For all the reasons discussed below, the NMB should reconsider its proposed rulemaking and rescind the NPRM.

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Proposed Decertification Rule Undermines Rights of Aviation and Rail Workers

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I thank you for the opportunity to testify today before the National Mediation Board (NMB or Board) on the Decertification of Representatives proposed rule. By way of background, TTD represents 32 affiliated unions in all modes of transportation. This includes a number of unions whose members work in the aviation and rail sectors, are covered by the Railway Labor Act (RLA), and thus are directly affected by this rulemaking.[1] I should note that Carmen Parcelli, outside counsel representing TTD in this matter, also will appear today. Carmen will focus on the legal arguments and procedural deficiencies of this proposal while I will touch on some of the broader policy concerns and emphasize key arguments. In addition, TTD will be filing more extensive comments by the April 1 deadline.

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24-Hour Shifts For Railroad CMV Drivers are Unsafe and Unreasonable

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the exemption filed by the Association of American Railroads (AAR) and American Short Line and Regional Railroad Association (ASLRRA). TTD consists of 32 affiliate unions representing workers in all modes of transportation, including commercial motor vehicle operators in the railroad industry covered by FMCSA hours of service requirements.[1] We therefore have a vested interest in this exemption.

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FRA Must Reject CSX’s Unsafe Inspection Waiver and Attack on Carmen

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to CSX’s petition for a waiver compliance. TTD consists of 32 affiliate unions representing workers in all modes of transportation, including railroad workers in both operating and inspection crafts who would be impacted by the granting of this waiver[1]. We therefore have a vested interest in this proceeding.

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ASLRRA Pilot Program Puts Workers and Rail Safety at Risk

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the American Short Line Railroad Association’s Petition for Waiver of Compliance regarding hours of service requirements (HOS). TTD consists of 32 affiliate unions representing workers in all modes of transportation, including those covered by FRA’s HOS regulations.[1] For this reason, we have a vested interest in this waiver.

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FRA Must Add Conductors to Promising Fatigue Study

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the FRA’s new information collection request (ICR) entitled “The Impact of Commute Times on the Fatigue and Safety of Locomotive Engineers”. TTD consists of 32 affiliate unions representing workers in all modes of transportation, including train crews covered by FRA hours of service and fatigue regulations.[1] For reasons explained below, we support the intent of this ICR but urge changes to its scope to ensure fatigue issue affecting all train crews are being considered. 

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USMCA Must Protect U.S. Rail Workers

Under NAFTA, USMCA’s predecessor, U.S. workers saw their industries decimated and their wages undercut. Americans are still today feeling the impacts of a trade agreement that did not work in their favor, and this country cannot afford to repeat this mistake. We understand that a number of TTD unions and the AFL-CIO have filed comments in this docket focused on broad labor concerns – we are therefore focusing our comments on the failure of the agreement to protect rail workers from unfair competition from Mexico.

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