Federal Comments Archives - Page 19 of 31

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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October 28, 2015

Federal Comments, Policy

EU Proposal to Include Aviation and Maritime Transport Services in TTIP Should be Rejected

Dear Mr. President, As the elected leaders of unions representing American aviation and maritime workers, we are extremely concerned by elements in the proposal for the services, investment and e-commerce chapter of the Transatlantic Trade and Investment Partnership (TTIP) recently released by the European Union (EU). On May 10, 2013 the Transportation Trades Department, AFL-CIO…
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October 14, 2015

Federal Comments, Policy

TTD Endorses Transit Safety Improvements

With the passage of MAP-21, Congress provided FTA the much needed authority to regulate safety across our nation’s transit systems. Codified at 49 USC 5329, the mandate requires FTA to develop a comprehensive Public Transportation Safety Program intended to improve the safety performance of transit systems. This NPRM seeks to implement several components of that…
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October 5, 2015

Federal Comments, Policy

TTD Calls for Increased MSP Funding

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to comment on the Maritime Administration’s (MARAD) Notice of Proposed Rulemaking (NPRM) on the Maritime Security Program (MSP). By way of background, TTD consists of 32 affiliated unions that represent workers in all modes of transportation, including those who work on vessels providing…
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