Government policy needs to encourage innovation across all modes of transportation.

That’s the message the private freight rail industry delivered to the U.S. Department of Transportation (USDOT) this week as it works to develop guidance and principles for the deployment of autonomous-vehicle technology on our nation’s highways.

Technology, AAR noted in its filing, has the potential to create breakthrough gains in safety performance, just as it does for other transportation modes. Automated technologies can detect more, respond faster and provide a larger window for action than a safety system that is subject to the limitations inherent in human eyes, minds and hands.

“Safety is at the center of all that the industry does, and by ensuring that federal policy enables innovation in the rail sector, we will make a safe network safer,” said AAR President and CEO Edward R. Hamberger. “As our filing states, ‘safety is good business, and good business is good for safety.’ We applaud the USDOT for seeking thorough input from the full array of transportation stakeholders and welcome their effort to develop a paradigm most conducive to innovation and growth.”

Here are some of the key takeaways from AAR’s filing:

Increased automation will result in meaningful safety improvement.

U.S. railroads have worked diligently to improve the safety of their operations, with great success; recent years have been among the safest on record for the rail sector. Today, however, 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, USDOT 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.

Read AAR’s Full Comments