Federal Comments

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Federal Motor Carrier Safety Administration (FMCSA)’s solicitations for information on how its regulations may be affected by autonomous technology. By way of background, TTD consists of 32 affiliate unions representing workers in all modes of transportation, including those who will be impacted by the development and deployment of automated driving systems.[1] We therefore have a vested interest in the notice.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Federal Railroad Administration (FRA)’s solicitations for information related to the future of automation in the railroad industry. By way of background, TTD consists of 32 affiliate unions representing workers in all modes of transportation, including workers across all crafts in the railroad industry who will be impacted by automation. We therefore have a vested interested in the notice. [1] TTD also endorses the comments of the International Association of Sheet Metal, Air, Rail and Transportation Workers, Transportation Division (SMART-TD), a TTD affiliated union.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Pipeline and Hazardous Materials Safety Administration (PHMSA)’s solicitations for information on autonomous surface transportation of hazardous materials. By way of background, TTD consists of 32 affiliate unions representing workers in all modes of transportation, including those who will be impacted by the development and deployment of automated driving systems, workers who transport hazardous materials, and first responders tasked with responding to incidents involving hazmat. We therefore have a vested interest in the notice.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the FAA’s Draft Advisory Circular AC 120-66C, Aviation Safety Action Program (ASAP). By way of background, TTD consists of 32 affiliate unions representing workers in all modes of transportation, including several unions in the aviation sector who have members that participate in ASAPs at their place of employment. We therefore have a vested interest in the circular.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Federal Transit Administration (FTA) and National Highway Traffic Safety Administration’s (NHTSA) solicitations for information on autonomous transit buses and autonomous vehicle design. By way of background, TTD consists of 32 affiliate unions representing workers in all modes of transportation, including those who will be impacted by the development and deployment of automated driving systems. We therefore have a vested interested in the rulemaking.[1]

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the National Highway Traffic Safety Administration’s (NHTSA) A Vision for Safety 2.0 guidance regarding autonomous vehicles. By way of background, TTD consists of 32 affiliate unions representing workers in all modes of transportation, including those who will be impacted by the development and deployment of automated driving systems. We therefore have a vested interested in the guidance.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the National Tank Truck Carriers, Inc. (NTTC) application for exemption from rest break regulations. By way of background, TTD consists of 32 affiliate unions across all modes of transportation, including both commercial motor vehicle drivers subject to FMCSA’s hours-of-service (HOS) regulations, and emergency personnel who respond in the event of an accident involving a CMV. We therefore have a vested interested in the rulemaking.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Federal Motor Carrier Safety Administration’s (FMCSA) Notice of Proposed Rulemaking (NPRM) regarding FMCSA’s rulemaking procedures. By way of background, TTD consists of 32 affiliate unions across all modes of transportation, many of whom operate commercial motor vehicles and are therefore subject to FMCSA’s regulations.[1] We therefore have a vested interested in the rulemaking.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to comment on the Federal Transit Administration’s (FTA) notice of proposed rulemaking (NPRM) encouraging private sector participation and investment in transit capital projects. By way of Background, TTD consists of 32 affiliate unions in the transportation sector, including those who may be affected by increased private participation in the public transportation space.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the National Highway Traffic Safety Administration’s (NHTSA) information collection request (ICR) regarding the use of seat belts on school buses. By way of background, TTD consists of 32 affiliate unions, several of whom represent school bus drivers and bus aides. [1] We therefore have a vested interested in the collection request.

Through this ICR, NHTSA plans on collecting information in order to understand the factors considered by state and local agencies when deciding whether to require seat belts on school buses, how these requirements are funded, and challenges that may occur. NHTSA states that it will collect this data through interviews, discussions, and a web-based survey.