Policy

Dear Representative: On behalf of the Transportation Trades Department, AFL-CIO (TTD), I’m writing to express our serious concerns about the drastic cuts to transportation programs in the House Appropriations Transportation, Housing and Urban Development and Related Agencies Subcommittee’s FY24 bill. Although TTD commends the inclusion of much-needed investments in FAA’s operations and maintenance budget to […]

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on Amtrak’s petition for a waiver of compliance from the “hands-on” component of periodic refresher trainings required by 49 CFR 232.203(b)(8), 49 CFR 215.11(b), 49 CFR 229.5, and 49 CFR. 238.109. TTD consists of 37 affiliate unions, which include the totality of rail labor, and therefore has a vested interest in this petition. Virtual training is not a sufficient substitute for hands-on training, and as such, we request that the Federal Railroad Administration (FRA) deny Amtrak’s petition for a waiver of compliance from such requirements.

As discussed below, we oppose Amtrak’s waiver request and urge the FRA to reject the request because it jeopardizes the safety of rail labor employees and the public. When protocols are revisited, it is imperative to recognize and retain, not weaken or waive the very requirements that are core to the safety of our system.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), and the totality of rail labor as represented by our affiliated unions, I write to request that Congress provide Amtrak with $3.65 billion in the final Fiscal Year (FY) 2024 appropriations bill. That level is consistent with Congress’ authorized level in the Bipartisan Infrastructure Law (BIL). Providing Amtrak with this level of funding will ensure that our national passenger rail system has the staffing and operating capacity necessary to maintain current service and move forward with the BIL’s generational investments.

Amtrak’s overall financial performance in FY2022 improved significantly, continuing its trend of recovery since the COVID-19 pandemic.[1] Total ridership in the seven-month period ending on April 30th was 84% of 2019 levels and ticket revenues were 95% of 2019 levels.[2] Ridership on certain routes in states like Virginia is at an all-time high.[3] Responding to increased demand, Amtrak hired roughly 3,700 new employees in FY2022 and is working to hire more than 4,000 employees in FY2023 so it can start or expand rail service in many states. Now is the time for Congress to help Amtrak continue to build on this progress, not undermine it.

As representatives of the freight and passenger railroad industry and the highly-trained, hardworking railroad workforce, we urge you to support the swift passage of H.R.2785/S.1274, the Railroad Employee Equity and Fairness Act (REEF Act). This common-sense, bipartisan bill would eliminate sequester cuts to railroad unemployment and sickness benefits that have unfairly short-changed railroad workers and their families for over a decade.

Railroad workers play a critical role in keeping the passenger and freight rail network safe and our economy moving. They deserve to access the full value of the benefits they have earned. Currently, Railroad Unemployment Insurance Act (RUIA) benefits are the only federal unemployment insurance and sickness benefits program subject to sequestration. Every other American’s unemployment, disability, or sickness benefits are not subject to the same cuts.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Transit Administration’s (FTA) Notice of Proposed Rulemaking (NPRM) implementing statutory changes in the Infrastructure Investment and Jobs Act (P.L. 117-58) regarding safety protections for frontline transportation workers. TTD consists of 37 affiliated unions – including those representing the majority of public transportation workers in the United States – who together, fought to ensure the provisions under consideration in this rulemaking were passed into law, and who have a significant interest in ensuring they are correctly implemented.

In addition to our own comments below, we endorse the comments filed by our affiliated unions, the Amalgamated Transit Union (ATU) and the Transport Workers Union of America (TWU), as well as those filed by Majority Leader Schumer, and the comments jointly filed by Senators Brown, Van Hollen, Reed, Warren, and Menendez.

June 22, 2023 Administrator Michael S. Regan Environmental Protection Agency Office of the Administrator, 1101A 1200 Pennsylvania Avenue, N.W. Washington, DC 20460 Dear Administrator Regan, Thanks to unprecedented investments from the Infrastructure Investment and Jobs Act and Inflation Reduction Act in clean energy and mobility, the Environmental Protection Agency is now responsible for managing billions […]

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Railroad Administration’s (FRA) notice of Port-Authority Trans Hudson’s (PATH) petition to extend its waiver of compliance with respect to the timely fixing of door defects under 49 CFR §238.305 and the required Class II brake inspection under 49 CFR §238.317. TTD consists of 37 affiliated unions representing the totality of rail labor, including PATH rail workers. We ask that the FRA deny PATH’s petition on the grounds that eight days is an unacceptable wait time for repairing mechanical door defects and risks the safety of the affected trains, passengers, and crews. Additionally, we endorse the comments of our affiliate, the Transportation Division of the International Association of Sheet Metal, Air, Rail, and Transportation Workers (SMART-TD).

PATH seeks to extend a waiver related to passenger equipment standards under Part 238 of Title 49, Code of Federal Regulations.[1] Specifically, PATH requests to extend its existing waiver relief from 49 CFR §238.305(c)(10) and (d), and 49 CFR §238.317(a)(1). PATH requests continued relief from the requirement that a car must be removed from service on the day after its calendar day interior mechanical inspection. In its petition, PATH seeks permission for a car to remain in service up to eight calendar days following notification of a mechanical door defect. It also seeks relief from the requirement to perform a Class II brake test where terminal dwell time is less than five minutes because of logistical challenges.

The railroad Labor Organizations identified above (“Labor Organizations”) are the collective bargaining representatives for the vast majority of railroad industry workers engaged in train operations, train dispatching, signal, maintenance of way and mechanical maintenance, inspection, testing, and repair on passenger and freight railroads throughout the United States.

The Labor Organizations and their individual and collective memberships have a direct safety interest whenever FRA determines to waive safety regulations. The public also shares this interest, especially when a waiver of regulations regarding the performance of tests that confirm the proper functioning of locomotive and train air brake systems is involved. The classes or crafts of employees represented by the Labor Organizations include those who will be directly affected by the waiver of the safety regulations discussed in these comments. Particularly, we wish to dispel the notion that waiving current air test requirements promotes safety at a time when railroads simultaneously work to avoid any requirement to upgrade their current braking systems.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Railroad Administration’s (FRA) request for comment on an Information Collection Request (ICR) related to amending the current railroad accident/incident reporting regulations (Form FRA F 6180.54) to add (1) the length of the involved trains, in feet, and (2) the number of crew members who were aboard a controlling locomotive involved in an accident at the time of such accident. TTD consists of 37 affiliated unions representing the totality of rail labor, including both passenger and freight rail workers. We therefore have a vested interest in this ICR.

These changes would bring the FRA into compliance with a congressional mandate in the Bipartisan Infrastructure Law to add (1) the number of cars and length of the involved trains; and (2) the number of crew members who were aboard a controlling locomotive involved in an accident at the time of such accident to Form FRA F 6180.54 (“the Form”) for a five-year period.

June 14, 2023 Dear Senator:  On behalf of the undersigned labor organizations representing tens of thousands of aviation employees, we write to urge you to vote in favor of the amendment Klobuchar 1 during the  Commerce, Science, & Transportation Executive Committee mark up tomorrow.   Transportation workers know all too well the consequences of predatory business […]