By: Ian Jefferies, AAR President & CEO
Date: May 28, 2019

The rail industry applauds the inclusion of rail in the U.S. Department of Transportation’s (DOT’s) guidance for automation in the transportation sector. Although we agree with the DOT’s call on government and agencies to “explore the interaction between automated vehicles and highway-rail grade crossings,” we also see an opportunity to further improve safety beyond grade crossings by expanding freight rail’s place in the automation discussion.

Doing so could help federal policy keep pace with innovation within the sector and ensure that railroads are on equal footing with their transportation peers, like commercial trucking. Unbeknownst to many, freight railroads — which operate across a 140,000-mile, privately-financed network responsible for moving virtually every sector of the economy — use myriad technologies that improve both the efficiency and effectiveness of incident prevention and mitigation.

Recent government data show that recent years have been the safest on record for the rail sector, including a 10% reduction in train accidents since 2009.

Observers rightly credit investment — averaging $25 billion in recent years – for this success, much of which has gone towards technological solutions such as Positive Train Control (PTC), wayside detectors along track to assess equipment in real-time and ground-penetrating radar that similarly allows railroads to evaluate infrastructure conditions.

Each day, the freight railroads expand PTC operations, further reducing the risk of accidents on the nation’s rail network. By the end of 2018, the Class I railroads had installed and were operating PTC on the vast majority of their required networks, met all other statutory PTC requirements and remained on track to fully implement this critical safety technology by the final 2020 deadline. The railroads’ commitment to safety is unwavering, and this industry is proud of its accomplishments in this immense undertaking

Although the public should be thankful for clear leadership from the DOT, we hope for even more progress in the future. Modernizing the approach at the Federal Railroad Administration to regulate in a way to achieve desirable outcomes, not mandating narrow prescriptions, will generate further gains. The current paradigm, which sometimes fails to define the problem at hand, increases compliance costs and chills innovation. Ideal policymaking would center on demonstrated outcomes — such as improving safety in a specific area — and be rooted in complete and sound science.

Takeaways from AAR’s Filing

  • Increased automation will result in meaningful safety improvement.
    Over one-third of train accidents are caused by human error. A transition to greater reliance on technology can help compensate for the limitations inherent in human eyes, minds and hands, resulting in continued safety improvement in the coming years.
  • Federal transportation policy should be mode-neutral.
    Railroads are an essential component of our national transportation network, delivering cost-effective and environmentally-friendly freight transportation that reduces highway congestion. For railroads to remain a viable, competitive alternative to other transportation modes, DOT must support automation in all modes of transportation, including rail. Without equal application across modes, federal policies have the potential to inadvertently shift freight from one mode to another.
  • Greater regulatory certainty is essential.
    Today, many proven safety-enhancing technologies may only be used in conjunction with redundant manual inspections required by regulation, unless approved by the Federal Railroad Administration (FRA) for an alternative process through a cumbersome and uncertain waiver process. Greater regulatory certainty would incentivize rail investment in innovation. For example, ongoing regulatory uncertainty has delayed investment in continuous rail inspection technology, which has been proven to reduce rail service failures by 50% over traditional methods.
  • Guidelines for automation of highway vehicles must consider highway-rail grade crossings.
    Grade crossing accidents are a critical safety problem that can be meaningfully addressed through the development and deployment of automated vehicles. As the FRA noted in a recent study, nearly all deaths at rail-highway crossings are preventable, as “94% of train-vehicle collisions can be attributed to driver behavior or poor judgment.” Designing motor vehicles to recognize and respond appropriately to warning devices and approaching trains has the potential to save hundreds of lives each year.