Federal Comments Archives - Page 19 of 31

July 8, 2016

Federal Comments, Policy

TTD Comments on Sleep Apnea Notice

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write to comment on FRA and FMCSA’s joint Advanced Notice of Proposed Rulemaking (ANPRM) on evaluating certain safety-sensitive transportation workers for obstructive sleep apnea (OSA). By way of background, TTD consists of 32 affiliated unions representing workers in all modes of transportation, including those who…
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June 15, 2016

Federal Comments, Policy

TTD Urges FRA to Issue a Strong Final Rule on Minimum Crew Size

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Federal Railroad Administration’s (FRA) Notice of Proposed Rulemaking (NPRM) on Train Crew Staffing. By way of background, TTD consists of 32 affiliate unions representing workers in all modes of transportation including those employed in the passenger and freight…
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May 31, 2016

Federal Comments, Policy

TTD Responds to RRB Occupational Disability Form Revision

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write to comment on the Railroad Retirement Board’s (RRB) proposed renewal and revision of its G-251 form. By way of background, TTD consists of 32 affiliated unions that represent workers in all modes of transportation, including those employed in the railroad industry. We therefore have…
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April 11, 2016

Federal Comments, Policy

TTD Endorses Better Oversight of Curbside Bus Operators

Through this notice, FMCSA is seeking to define a “curbside bus operator” for the purpose of implementing section 32707 of MAP-21, which requires an annual safety fitness assessment of certain motor carriers of passengers that serve primarily urban areas with high passenger loads. The Agency has specifically identified curbside operators as the intended subject of…
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April 8, 2016

Federal Comments, Policy

STB Should Reject Canadian Pacific’s Voting Trust Proposal

In its March 2, 2016 filing, CPRL requests the STB to provide a declaratory order on whether it would be potentially permissible for CPRL to hold its own subsidiaries in trust while it acquires ownership and control of NS and seeks regulatory approval of a CP-NS merger. CPRL has not submitted an actual voting trust…
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April 7, 2016

Federal Comments, Policy

TTD, Transit Unions Urge DOT to Issue Rule to Protect Transit Workers

As labor organizations representing transit workers throughout the country, we urge the Department of Transportation (DOT) and your Federal Transit Administration (FTA) to issue a rule to protect bus drivers and other transit operators from the physical assaults that are plaguing this industry. As you know, Section 3022 of the Fixing America’s Surface Transportation (FAST)…
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April 6, 2016

Federal Comments, Policy

TTD Comments on Proposed Training Rule for Commercial Drivers

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to comment on the Federal Motor Carrier Safety Administration’s (FMCSA) Notice of Proposed Rulemaking (NPRM) on Minimum Training Requirements for Entry-Level Commercial Motor Vehicle Operators. By way of background, TTD consists of 32 affiliated unions that represent workers in all modes of transportation,…
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April 5, 2016

Federal Comments, Policy

TTD Responds to Proposed Public Transportation Agency Safety Plans

In this NPRM, FTA requires that transit agencies receiving funds under 49 U.S.C. Chapter 53 and not regulated by another agency, develop and implement a Public Transportation Agency Safety Plan (Safety Plan). This NPRM establishes the core components that Safety Plans must contain, including methods to identify, evaluate, and minimize safety risk. Among other minimum…
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January 4, 2016

Federal Comments

Joint Comments Opposing the Application of Norwegian Air UK Limited for a Foreign Air Carrier Permit

The record in the NAI proceeding shows that NAI is staffing its long-haul flights with flight crew based in Thailand and employed by non-European crew supply companies on employment contracts governed by Asia law: Singapore law in the case of pilots and Thailand law in the case of flight attendants. The record in that case…
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October 30, 2015

Federal Comments, Policy

TTD Responds to Public-Private Partnership Model Contract Guide

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to comment on the Federal Highway Administration’s (FHWA) Draft Availability Payment Concessions Public-Private Partnership Model Contract Guide as well as on the Labor Best Practices chapter. By way of background, TTD consists of 32 affiliated unions in the transportation sector, including those who…
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