Federal Comments Archives - Page 16 of 33

September 3, 2019

Federal Comments

TTD Responds to MARAD on Port Automation

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…
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August 28, 2019

Policy, Federal Comments

TTD Responds to FMCSA on Automation

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…
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August 26, 2019

Policy, Federal Comments

DOL’s Apprenticeship Proposal is Not the Way Forward

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].
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July 22, 2019

Policy, 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…
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June 10, 2019

Policy, Federal Comments

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…
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June 10, 2019

Policy, Federal Comments

TTD urges Federal Transit Administration not to include private ride-hailing companies in definition of transit

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…
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May 8, 2019

Policy, Federal Comments

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…
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April 1, 2019

Policy, Federal Comments

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…
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March 28, 2019

Policy, Federal Comments

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…
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January 17, 2019

Policy, Federal Comments

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…
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