INDEPENDENCE, Ohio, May 11 — The Brotherhood of Locomotive Engineers and Trainmen (BLET) was one of five rail Brotherhoods to file joint comments on May 7 in response to the Federal Railroad Administration’s (FRA) March 29 Request For Information (RFI) regarding automation in the railroad industry.
In general, the unions asserted that public and worker safety is their top priority, and also stressed that any roll-out of new technologies and/or automation should only be done cautiously under well-defined government safety regulations.
Signatories to the 26-page joint submission were: National President Dennis R. Pierce, Brotherhood of Locomotive Engineers and Trainmen (BLET); President John Previsich, SMART Transportation Division; President W. Dan Pickett, Brotherhood of Railroad Signalmen (BRS); President F. Leo McCann, American Train Dispatchers Association (ATDA); and General President Richard A. Johnson, Carmen Division/TCU.
The unions noted that safety should be the top goal of all involved stakeholders — especially the FRA — when considering the future of rail automation. The unions reminded the FRA of its mandate from Congress, which reads in part: “[i]n carrying out its duties, the Administration shall consider the assignment and maintenance of safety as the highest priority, recognizing the clear intent, encouragement, and dedication of Congress to the furtherance of the highest degree of safety in railroad transportation.”
“As such, safety must be first and foremost when discussing the future of automation of our nation’s railroads,” the unions wrote. “It would be unethical and would violate the mandate of Congress to sacrifice safety for potential profits.”
The unions also noted that their duty to protect the jobs and incomes of their members should not be used to discount their arguments on behalf of safety.
“Discounting our safety concerns because we fight to preserve jobs and earnings is the most extreme form of double standard, given the profit-seeking goal of the industry underlying its support of automation it may advocate,” the unions wrote.
Another major assertion from the unions is that a tight regulatory framework with clearly defined terminologies is a must when exploring the future of automation.
“New technology does not always mean automated and it is important to make distinctions when and where they exist. Automation does not always mean fully autonomous operation, which is why FRA needs to provide clear definitions when it reduces the real world adoption of automation to written regulations. FRA’s power to define cannot be overstated in any instance, but when dealing with automation the agency must take care to understand what is being explained and defined, as do all the stakeholders in the industry, in this complex arena…. We also believe there is no appetite on the part of the public, regulators, employees or railroads to have a fully automated system,” the unions wrote.
The unions also warned that what widespread replacement of human labor by autonomous technology could create severe societal disadvantages. They pointed out that hourly inflation-adjusted wages received by the typical worker have barely risen, growing only 0.2% per year since the 1970s, and that the percentage of private-sector workers participating in an employment-based defined benefit retirement plan plummeted from 28% in 1979 to just 2% in 2014, a period during which increases in productivity far outstripped increases in worker compensation.
The unions predicted that automating a significant sector of the American economy will exacerbate these negative trends, because incomes from that sector are likely to decline precipitously. Further, that automating a high-wage sector or industry like the railroad industry would produce an outsized effect on the national economy, and that the railroads would suffer declines in traffic as the purchasing power of workers whose jobs are automated out of existence disappears.
As a part of its March 29 RFI, the FRA also sought comment on a list of 25 specific questions regarding automation. The unions noted that many of those questions because they could only be answered by the rail carriers, and they reserved the right to request an extension of the May 7 deadline in order to have reasonable time to review and comment on the rail industry responses.
A copy of the 26-page submission is available at:
Friday, May 11, 2018