Policy

The undersigned labor organizations are pleased to respond to the Federal Railroad Administration’s (FRA) notice regarding BNSF Railway Company’s (BNSF) petition to extend its waiver allowing Class I brake tests and other mechanical inspections associated with a train entering the United States at Eagle Pass, Texas, to be performed at alternate locations rather than immediately at the border as required by federal regulations. Our unions represent BNSF freight rail workers across various crafts and therefore have a vested interest in this matter. For the reasons outlined below, we ask that the FRA deny BNSF’s petition to extend its waiver.

Specifically, BNSF is requesting a waiver extension from 49 CFR 232.205 and certain provisions of part 215 relative to the inspection of trains entering the United States from Mexico. BNSF seeks to continue to move trains received in interchange from Ferrocarril Mexicano, S.A. (FXE), approximately 12 miles outside of the community of Eagle Pass, Texas, to facilities at Ryan’s Ruin, Texas, or Horan Siding, where the required inspections will be performed.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Railroad Administration’s (FRA) notice regarding the Northeast Illinois Regional Commuter Railroad Corporation’s (Metra) petition to extend its waiver of compliance from the provisions of §236.377, Approach locking; §236.378, Time locking; §236.379, Route locking; §236.380, Indication locking; and §236.281, Traffic locking, to extend the periodic testing schedules from at least once every two years to at least once every four years. TTD consists of 37 affiliated unions representing the totality of rail labor. For the reasons outlined below, we respectfully request that the FRA deny Metra’s petition. Additionally, TTD endorses the comments of our affiliate, the Brotherhood of Railroad Signalmen (BRS).

In its petition, Metra is requesting an extension of its initial waiver, first granted in 2012 and most recently extended in 2018, that allows for the verification and testing of signal locking systems controlled by microprocessor-based equipment through the use of alternative procedures every four years. As BRS notes in its comments, continuing to grant this request bypasses several safety checks that validate signal control systems. First, the alternative methods of verification currently in place under this waiver, using the Cyclic Redundancy Check (CRC)/Checksum/Universal Control Number (UCN), are not an adequate substitute for required field verification testing. These methods cannot reliably discover errors that would otherwise be identified through the required means of testing and verification as established under federal regulations.

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 safety performance measures set forth in the National Safety Plan will adequately address growing safety concerns in the public transportation sector.

As the agency explains, 49 USC § 5329(d)(1) requires transit agencies receiving § 5307 Urbanized Area Formula funds or § 5311 Rural Area Formula funds to certify that they have in place a Public Transportation Agency Safety Plan (PTASP). The Infrastructure Investment and Jobs Act (IIJA) adds new requirements for safety performance measures related to the PTASP safety risk reduction program, precautionary and reactive actions in emergency situations, and consideration of performance-based and risk-based methodologies.

July 31, 2023 The Honorable Patty Murray Chair Committee on Appropriations United States Senate Washington DC 20510 The Honorable Susan Collins Vice Chair Committee on Appropriations United States Senate Washington DC 20510 The Honorable Kay Granger Chairwoman Committee on Appropriations United States Senate Washington DC 20510 The Honorable Rosa DeLauro Ranking Member Committee on Appropriations […]

July 26, 2023 The Honorable Cathy McMorris Rodgers, Chair House Committee on Energy and Commerce The Honorable Frank Pallone, Jr., Ranking Member House Committee on Energy and Commerce The Honorable Gus Bilirakis, Chair Subcommittee on Innovation, Data, and Commerce The Honorable Jan Schakowsky, Ranking Member Subcommittee on Innovation, Data and Commerce Dear Chair McMorris Rodgers, Ranking Member […]

July 19, 2023 Dear Representative: As the Securing Growth and Robust Leadership in Aviation Act moves to the House floor, the Transportation Trades Department, AFL-CIO (TTD) outlines our positions on pending amendments below. Please note that the amendment number is listed first as it appeared in the Rules Committee and second as it appears for […]

July 18, 2023 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) […]

July 17, 2023 Dear Senator,  On behalf of the Transportation Trades Department, AFL-CIO (TTD), representing 37 labor unions across all modes of transportation, we urge you to oppose Senate Amendment 265, led by Senator Risch, that would eliminate Ship American “cargo preference” rules that are essential to our U.S. Merchant Marine and U.S.-flag shipping industry. […]

The Honorable Kevin McCarthy Speaker U.S. House of Representatives H-232, the Capitol Washington, DC 20515 The Honorable Hakeem Jeffries Democratic Leader U.S. House of Representatives H-204, the Capitol Washington, DC 20515 July 14, 2023 Dear Speaker McCarthy and Leader Jeffries, The undersigned labor organizations representing airline workers write to urge that you allow for a […]

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 […]