Federal Comments

Under this NPRM, FAA creates new 14 CFR part 107 to regulate the operation of non-recreational small unmanned aircraft systems (sUAS) in the NAS; the certification of sUAS operators; and the requirements of the small unmanned aircrafts. Finding that sUAS are capable of safely operating in the NAS, FAA proposes this rulemaking in accordance with the FAA Modernization and Reform Act of 2012 and begins the integration of small commercial UAS into our nation’s airspace.

At the outset, we express support for FMCSA’s consideration of updating its existing standard that requires motor carriers to maintain a specified minimum level of financial responsibility to provide coverage for public liability and property damage resulting from a commercial bus accident. TTD and our affiliates have a long history of advocating for strengthening market entry standards to help ensure only upstanding motor carriers are granted operating authority. Just last week, TTD’s Executive Committee renewed the call for improving these standards, urging FMCSA to increase the current minimum level of financial responsibility.

TTD and our affiliates strongly oppose efforts to overturn the decades-old policy that prohibits passengers from using mobile wireless devices to make voice calls while in-flight. As thoroughly explained in our filings to proceedings promulgated by the Federal Communications Commission (FCC) and Department of Transportation (DOT), we believe the introduction of in-flight voice calls pose unnecessary safety issues and security risks to passengers and flight crews, including flight attendants and pilots.[2] Overturning this longstanding policy also creates another unnecessary distraction in an inherently disruptive cabin environment that could create adversarial interactions between passengers.

At the request of Amtrak and CAHSRA, FRA seeks to waive its Buy America standard in order to allow the final assembly of up to four HSR trainset prototypes to take place outside the U.S.  Given the limitations on the domestic production and testing of HSR trainset prototypes as identified in the notice, we will not oppose this narrow waiver to help expand HSR in the U.S. while simultaneously developing domestic production facilities.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write in response to the Federal Motor Carrier Safety Administration’s (FMCSA) notice of a new Information Collection Request (ICR), “The Impact of Driver Compensation on Commercial Motor Vehicle (CMV) Safety.” By way of background, TTD consists of 32 affiliate unions that represent workers in every mode of transportation, including those employed in the CMV industry. We therefore have a vested interested in this proceeding.[1] We also endorse the comments filed by the Amalgamated Transit Union (ATU).

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).