Federal Comments

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write to comment on the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) Advanced Notice of Proposed Rulemaking (ANPRM) on Hazardous Materials, Oil Spill Response Plans (OSRPs) for High-Hazard Flammable Trains (HHFTs). By way of background, TTD consists of 32 affiliate unions representing workers across the transportation spectrum, including the International Association of Fire Fighters (IAFF) whose members answer the call when transportation-related emergencies occur. We therefore have a vested interest in this proceeding.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write to comment on the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) Notice of Proposed Rulemaking (NPRM) on Hazardous Materials, Enhanced Tank Car Standards and Operational Controls for High-Hazard Flammable Trains (HHFTs). By way of background, TTD consists of 32 affiliate unions including those that represent workers employed in the railroad industry and the first responders who answer the call when rail accidents occur.[1] We also note that two of our affiliates, the Brotherhood of Railroad Signalmen (BRS) and the Sheet Metal, Air, Rail and Transportation Workers (SMART) Transportation Division, have each filed comments in this proceeding.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write to comment on the Federal Motor Carrier Safety Administration’s (FMCSA) Notice of Intent to pursue a Negotiated Rulemaking to implement section 32304 of MAP-21. This mandate calls on the Secretary to establish minimum entry-level driver training (ELDT) requirements for individuals who operate commercial motor vehicles (CMVs). By way of background, TTD consists of 32 affiliate unions that represent workers in all modes of transportation, including a wide range of workers of who hold commercial driver’s licenses (CDLs) and operate a variety of CMVs.[1] We therefore have a vested interest in this rulemaking. In addition to this filing, some of our affiliate unions have commented as well, and we express support for those submissions.

The Labor Parties hereby reply to the comments filed in response to DOT’s August 4 Notice (“Notice”) requesting comments on the views expressed by DG MOVE on the meaning and applicability of Article 17 bis of the U.S.‐EU Air Transport Agreement (“ATA” or “Agreement”) as it pertains to consideration of a foreign air carrier’s application for operating authority. For the reasons set forth below, the Labor Parties believe that DOT should reject the narrow view of Article 17 bis advanced by DG MOVE and deny NAI’s application for an exemption on the ground that the application does not meet the standards set out in 49 U.S.C. § 40109, and should issue a show cause order stating that it proposes to deny NAI’s application for a foreign air carrier permit on the ground that approval would be inconsistent with Article 17 bis.

The Association of Flight Attendants-CWA (AFA), the International Association of Machinists and Aerospace Workers (IAM), the Transport Workers Union (TWU), and the Transportation Trades Department, AFL-CIO (TTD) submit this reply to comments filed in response to DOT’s August 4 Notice (“Notice”) requesting comments on the views expressed by DG MOVE on the meaning and applicability of Article 17 bis of the U.S.-EU Air Transport Agreement (ATA).

The AFA, IAM and TWU submit this joint statement to articulate our unions’ shared opposition to the application of Norwegian Air International (NAI) for a foreign air carrier permit and exemption (Docket: DOT-OST-2013-0204). We call on the U.S. Department of Transportation (DOT) to deny NAI’s application for an exemption so that the proper evaluation and adjudication processes can be completed.

The AFA, IAM and TWU submit this joint statement to articulate our unions’ shared opposition to the application of Norwegian Air International (NAI) for a foreign air carrier permit and exemption (Docket: DOT-OST-2013-0204). We call on the U.S. Department of Transportation (DOT) to deny NAI’s application for an exemption so that the proper evaluation and adjudication processes can be completed.

The ETF and TTD join in this submission to express our serious objections and concerns outlined below. As indicated, in addition to the submissions we have made separately regarding the severe negative impacts that this matter will have on fair competition, jobs and labor rights, we have deep and profound concerns that the business model being pursued by Norwegian Air International (NAI) raises significant security concerns. Among other things, we believe that critical policies and regulations adopted following the terrorist attacks of September 11, 2001, by the U.S. and EU to ensure the safety of its citizens could be at risk.

The Air Line Pilots Association, the Transportation Trades Department, AFL-CIO, and the European Cockpit Association hereby submit the following comments in response to DOT’s August 4 Notice regarding the views voiced by the Director of Aviation of the European Commission’s Directorate of General Mobility and Transport (“DG MOVE”) on the applicability of Article 17 bis of the U.S.-EU Air Transport Agreement (“ATA” or “Agreement”) to NAI’s application. For the reasons set out below, the Labor Parties believe that DOT should reject DG MOVE’s interpretation of Article 17 bis and promptly deny NAI’s application for an exemption on the grounds that approval would be inconsistent with the public interest and with Article 17 bis.

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) to Prohibit the Coercion of Commercial Motor Vehicle Drivers. By way of background, TTD consists of 32 affiliated unions that represent workers in all modes of transportation, including those who operate over-the-road buses and other commercial motor vehicles, and therefore have an interest in this rulemaking.