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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 railroad and airline employees covered by the Railway Labor Act (“RLA”).[1]  TTD welcomes the opportunity to submit comments to the NMB regarding its recent proposed decertification procedure rule-making.   TTD strongly opposes the Board’s proposed rulemaking.  The NPRM is inconsistent with the RLA.  The proposed rules changes exceed the scope of the Board’s narrow jurisdiction under Section 2, Ninth and unreasonably restrict employees’ exercise of the right to choose representation under the statute.  For all the reasons discussed below, the NMB should reconsider its proposed rulemaking and rescind the NPRM.

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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 work in the aviation and rail sectors, are covered by the Railway Labor Act (RLA), and thus are directly affected by this rulemaking.[1] I should note that Carmen Parcelli, outside counsel representing TTD in this matter, also will appear today. Carmen will focus on the legal arguments and procedural deficiencies of this proposal while I will touch on some of the broader policy concerns and emphasize key arguments. In addition, TTD will be filing more extensive comments by the April 1 deadline.

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Cosponsor H.R. 1139 – the Transit Worker and Pedestrian Protection Act of 2019

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I urge you to cosponsor H.R. 1139, the Transit Worker and Pedestrian Protection Act. This bipartisan, common-sense legislation will help address the ever-growing epidemic of assaults committed against transit workers, enhance pedestrian safety, and facilitate needed improvements to the bus operator work station.

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Cosponsor S. 436 – the Transit Worker and Pedestrian Protection Act of 2019

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I urge you to cosponsor S. 436, the Transit Worker and Pedestrian Protection Act. This common-sense legislation will help address the ever-growing epidemic of assaults committed against transit workers, enhance pedestrian safety, and facilitate needed improvements to the bus operator work station.

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TTD to Representatives: Fully Fund the Maritime Security Program in FY’20

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I ask you to sign the bipartisan letter being circulated by Representatives Joe Courtney (D-CT) and Robert Wittman (R-VA) requesting the fully authorized level of $300,000,000 for the Maritime Security Program (MSP) in the FY 2020 Transportation, Housing, and Urban Development appropriations bill.

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TTD to Senators: Fully Fund the Maritime Security Program in FY’20

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I ask you to sign the bipartisan letter being circulated by Senators Mazie Hirono (D-HI) and Roger Wicker (R-MS) requesting the fully authorized level of $300,000,000 for the Maritime Security Program (MSP) in the FY 2020 Transportation, Housing, and Urban Development appropriations bill.

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Improving Drug and Alcohol Testing and Treatment for the Transportation Workforce

The United States is in the midst of an opioid epidemic, affecting hundreds of thousands of Americans across race, gender and socio-economic status, and the devastation to our communities has been profound. Transportation workers are not immune from drug and alcohol abuse and are rightfully held to higher standards through federal testing requirements because of […]

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Fatigued Driving is Dangerous Driving

Driver fatigue presents one of the greatest safety threats to commercial bus and truck drivers, their passengers, and the people with whom they share the roads. This problem will not go away without further action by the federal government and the rethinking of the current deregulatory approach. In fact, the number of people killed in […]

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Attacks on the Postal Service: Please Return to Sender

The United States Postal Service (USPS) and its hundreds of thousands of hard working employees provide an integral and irreplaceable service, delivering mail via almost every mode of transportation to every community in the nation, and helping to keep our economy running. It does so without the use of taxpayer funding, and despite Washington’s unceasing […]

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Principles for the Transit Workforce in Automated Vehicle Legislation and Regulations

Automation is certain to impact every sector of transportation and its workforce. From automated vehicles on the ground and ships at sea, to unmanned aerial vehicles and the myriad applications of robotics, the pace and complexity of new technologies under development are significant.

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