April 27, 2015
The Honorable Anthony Foxx
U.S. Department of Transportation
1200 New Jersey Ave. SE.
Washington, DC 20590
Re: Comments on Notice of Proposed Rulemaking,
ID Number DOT ST-2015-0013
I write today in opposition to the inclusion of rolling stock within the Department of Transportation’s (DOT) Notice of Proposed Rulemaking on Geographic-Based Hiring Preferences in Administering Federal Awards and associated pilot program. This proposal is well intentioned, but its harmful impact on businesses and communities across the country cannot be overlooked.
Rolling stock manufacturers employ thousands of American workers across the United States in large, permanent facilities. The cutting-edge work done at these locations is labor intensive and requires a well-trained workforce.
Years of skill-building and training is invested in these employees and the equipment the companies use. It is for this reason that these manufacturers do not often move and re-locate.
These manufacturing facilities are a focal point and critical component of the local economy in the towns where they have been built over generations. The transit agencies see a large return on capital investment in the towns in which they are located and this proposed rule would erode this beneficial economic model. This impractical proposal would incentivize companies to mothball existing facilities in order to build temporary, makeshift plants and facilities across the country only to uproot when the contract is over and leave the country littered with
abandoned facilities. This structure is not a sound economic-business model. Rolling stock manufacturers would have little to no incentive to invest in the communities and the workforce in which they hire.
This proposal would also negatively impact those currently employed in transit manufacturing and drive up the price of-contracts. This cost, in turn, would be put on the shoulders of hard-working American citizens. We can all agree that this is neither fair nor in our best interest.
It is with these concerns in mind that I respectfully ask that you remove rolling stock companies from the aforementioned DOT Notice of Proposed Rulemaking. We both wish to help grow our nation’s manufacturing sector, but this proposal would have damaging effects on communities and labor workforces across this great country.
Member of Congress