Policy

January 31, 2024 Dear Representative: On behalf of our affiliated unions representing hundreds of thousands of airline workers, the Transportation Trades Department, AFL-CIO (TTD) urges you to join Congressional Labor Caucus co-chairs Mark Pocan (D-WI), Debbie Dingell (D-MI) and Donald Norcross (D-NJ), along with Caucus member Jan Schakowsky (D-IL), in a letter (below) to support […]

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Transit Administration’s (FTA) advanced notice of proposed rulemaking (ANPRM) regarding potential standards for hours of service and fatigue risk management programs for transit workers. TTD consists of 37 affiliated unions, including those representing the majority of public transportation workers in the United States, whose safety and livelihoods will be impacted by potential regulations governing hours of service and fatigue risk management for transit employees.[1] In addition, we endorse the comments submitted by our affiliates, the Transport Workers Union of America (TWU) and the Amalgamated Transit Union (ATU).

Background

Prior to responding to the substance of this ANPRM, we’d like to first express our strong disapproval of the FTA’s handling of this proceeding. From the beginning of this rulemaking process, the FTA’s noticeable partiality toward the American Public Transportation Association (APTA) has been an affront to our members. The FTA has made feeble attempts to engage with the labor organizations whose members will be directly affected by the establishment of hours of service requirements, all the while holding listening sessions that have served as sounding boards for anti-worker and anti-union sentiments. The FTA must consider the perspectives and expertise of those directly involved in providing this essential service to our communities. We urge the FTA to work with labor stakeholders in an open and meaningful way going forward.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Railroad Administration’s (FRA) request for comments on a proposed non-availability waiver of Buy America requirements for certain components necessary to complete a high-speed passenger train project between Las Vegas, NV and Rancho Cucamonga, CA. TTD consists of 37 affiliated unions, including those representing the totality of rail labor and workers in construction and manufacturing who will be directly impacted by this potential waiver.[1] We therefore respectfully request that the FRA take our input on this matter into serious consideration.

At the request of the Nevada Department of Transportation (NVDOT) and Brightline West, the FRA seeks to waive its Buy America requirements for the domestic production of the trainset, signal systems, high-speed rail turnout and fire alarm systems required for the high-speed passenger rail project between Las Vegas and Rancho Cucamonga. According to the FRA’s notice, two potential suppliers, Siemens and Alstom, represented they could provide the necessary high-speed rail components that meet Brightline West’s specifications and the applicable FRA safety requirements but could not domestically produce certain components that would be required to meet the specifications.

January 19, 2024 General Jacqueline D. Van Ovost, USAF United States Transportation Command Dear General Van Ovost: On behalf of the undersigned American maritime labor unions who serve aboard MSP vessels, we are writing in regard to the ongoing attacks from the Houthi rebels of Yemen on international and U.S.-flag shipping in the Bab el-Mandeb […]

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Association of American Railroads (AAR)’s request to the Federal Railroad Administration to open an emergency docket under 49 CFR 211.45 to provide relief from its waiver from certain provisions contained in 49 CFR 229 and 49 CFR 232.15 for upwards of 14 days. TTD consists of 37 affiliated unions representing the totality of rail labor, including employees on all the Class I railroads covered by the AAR’s request. For the reasons outlined below, we ask that the FRA deny the AAR’s request.

Current weather conditions do not rise to the level of an “emergency event” or “emergency situation” as required under 49 CFR 211.45. Unsurprisingly, in the middle of January, several parts of the country are experiencing very low temperatures and snow. Such conditions occur regularly and railroads should be prepared. Furthermore, this ongoing winter weather event is not as severe as other winter storms that have occurred  in just the last five years.

January 11, 2024 Dear Senator, The undersigned labor organizations representing workers write to urge that you oppose any change to the statutory pilot retirement age as the Senate Committee on Commerce, Science, and Transportation considers deliberation of an FAA reauthorization bill.  Raising the retirement age to be in noncompliance with International Civil Aviation Organization (ICAO) […]

January 9, 2024 Dear Representative: On behalf of the Transportation Trades Department, AFL-CIO (TTD), and the thousands of workers we represent in manufacturing and electrification, we urge you to oppose the Congressional Review Act Joint Resolution 38 (S.J.Res 38) when it comes to a vote on the House floor. If enacted, this legislation would undermine […]

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Railroad Administration’s (FRA) notice regarding Union Pacific Railroad Company’s (UP) petition to extend its waiver from certain provisions contained in 49 CFR 232.213. The current waiver allows UP to operate designated extended-haul trains for distances of up to 1,680 miles, beyond the limit of 1,500 miles stipulated in the regulation. TTD consists of 37 affiliated unions, representing the totality of rail labor, including UP employees.[1] For the reasons outlined below, we ask that the FRA deny Union Pacific’s petition to extend its waiver.

In support of its request, UP states that it reviews with the FRA “the list of trains associated with this waiver at a frequency of no less than once per quarter” and “adjustments are made accordingly.” UP further explains that “over a 56-month period, the incident rate has been no more than .055%, [which were] four events comprised of wheelset, axle, and journal bearing defects.” Per the federal statute governing the Secretary’s ability to grant safety waivers, the Secretary may grant waivers only “if such waiver or suspension is in the public interest and consistent with railroad safety.”[2] UP acknowledges in its waiver extension request that the trains covered by the existing waiver had a higher incident rate, .055%, than extended-haul trains that undergo inspections of 1,500 miles. These trains had a lower incident rate of .036%. While UP claims the difference is “negligible,” it is unwise to claim that additional accidents are negligible, as evident by the East Palestine, Ohio derailment. Delaying required mechanical testing and inspection unequivocally exposes workers and the communities along UP’s rail lines to unnecessary risk and lacks consistency with railroad safety.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Transit Administration’s (FTA) notice of availability of proposed updates to its National Public Transportation Safety Plan. TTD consists of 37 affiliated unions, including those representing the majority of public transportation workers in the United States, who have a significant interest in ensuring the Public Transportation Safety Certification Training Program (PTSCTP) adequately addresses safety training needs.[1] Additionally, we endorse the comments filed by our affiliates, the Transport Workers Union of America (TWU) and the Transportation Division of the International Association of Sheet Metal, Air, Rail, and Transportation Workers (SMART-TD).

As the FTA explains, this NPRM proposes to amend the PTSCTP regulation at 49 CFR part 672. Specifically, the proposed rule adds administrative requirements for recipients that are subject to the requirements of the rule, in addition to maintaining the existing minimum training requirements for State Safety Oversight Agency (SSOA) employees and contractors who conduct reviews, inspections, examinations, and other safety oversight activities of public transportation systems, and employees and contractors who are directly responsible for the safety oversight of a rail fixed guideway public transportation system.

December 6, 2023 The Honorable Mark Green Chairman Committee on Homeland Security U.S. House of Representatives 176 Ford House Office Building Washington, DC 20515 The Honorable Bennie Thompson Ranking Member Committee on Homeland Security U.S. House of Representatives H2-117 Ford House Office Building Washington, DC 20515 Dear Chairman Green and Ranking Member Thompson, We, the […]