Federal Comments

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to FMCSA’s request for comment on its Notice of Proposed Rulemaking (NPRM) regarding changes to the agency’s hours of service regulations. TTD consists of 33 affiliate unions representing workers in all modes of transportation, including thousands of commercial motor vehicle drivers who will be impacted by these proposed changes. We therefore have a vested interest in this rulemaking.[1]

In the NPRM, FMCSA proposes five major changes to its current HOS regulations. This includes modifications to current requirements concerning the short haul exemption, drive time limits during adverse driving conditions, the 30-minute rest break, the use of sleeper berths, and a new proposal on split duty.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on Norfolk Southern Railway Company’s (NS) waiver of compliance regarding the operation of RoadRailer units. By way of background, TTD consists of 33 affiliate unions representing workers in all modes of transportation, including rail workers who operate and inspect the equipment discussed in NS’ request

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Maritime Administration’s (MARAD) notice seeking information on port automation. By way of background, TTD consists of 33 affiliate unions representing workers in all modes of transportation, including the International Longshoremen’s Association, who are employed at and around ports and harbors. We therefore have a vested interested in the request.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to FMCSA’s request for comment on its Advanced Notice of Proposed Rulemaking (ANPRM) regarding the deployment of automated commercial motor vehicle technologies. TTD consists of 33 affiliate unions representing workers in all modes of transportation, including commercial motor vehicle drivers who may operate vehicles with some level of automated driving systems (ADS) and will be impacted by the deployment of ADS with high levels of autonomy.[1]

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to DOL’s Notice of Proposed Rulemaking (NPRM) on apprenticeship programs. TTD consists of 33 affiliate unions representing workers in both sectors with substantial apprenticeship density and in sectors where greater application of apprenticeship programs could prove beneficial[1]. 

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.

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.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Federal Transit Administration’s (FTA) notice providing information on proposed changes and clarifications to the National Transit Database (NTD) reporting requirements. By way of background, TTD consists of 33 affiliate unions representing workers in all modes of transportation including those in the transit sector.[1] We therefore have a vested interested in the proposal

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.

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.