Office of Ports & Waterways Planning
U.S. Department of Transportation
1200 New Jersey Ave., S.E.
Washington, DC 20590
RE: Challenges and Impacts of Automated Transportation in a Port Environment
Dear Mr. Black:
On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Maritime Administration’s (MARAD) notice seeking information on port automation. By way of background, TTD consists of 33 affiliate unions representing workers in all modes of transportation, including the International Longshoremen’s Association, who are employed at and around ports and harbors.  We therefore have a vested interested in the request.
Through the notice, MARAD asks wide-ranging queries on the application of automated technologies at ports and harbors. While we understand MARAD has included a question on workforce impacts and future training needs as it relates to automation decisions, we urge the agency to engage actual frontline workers as they contemplate these questions. Much as MARAD seeks commentary from manufacturers, designers, and the intelligent transportation industry, it would be a mistake to exclude workers and their unions from this outreach.
The ILA, as well as transportation labor broadly, have long been at the forefront of technological developments in their respective sectors. From the rise of containerization to the arrival of Post-Panamax vessels at our nation’s ports, the ILA and its members have championed positive technological advancements when warranted. At the same time, the union has not been afraid to raise the alarm when safety, efficiency, or working conditions are threatened. Over time, longshore workers and port employees have constantly evolved and adapted to meet our domestic maritime needs.
As the sector continues to evolve, the federal government has an obligation to understand how the developments it champions affect working people. In doing so, MARAD and DOT must recognize that working in tandem with affected port and maritime unions is a critical and non-negotiable tenet of the introduction of industry-altering technologies. As an example, last year the ILA signed a new master collective bargaining agreement that included a fair and reasonable framework for the use of new technology at ILA-represented port and harbor terminals. As MARAD and DOT continue to push automation, they must address issues like displacement and training on new technologies in conjunction with the voices of workers.
In regards to the current state of port automation, we note that these technologies differ substantially from automation in other modes of transportation. Whereas DOT and its agencies have and continue to promote or even directly fund the research and development of autonomous technologies, automated port equipment is an existing commercial product. However, the vast majority of terminal operators are not pursuing automation. This is due in large part to the fact that automation technology is extraordinarily costly, and many domestic ports are handling record cargo volumes without a need for automated assistance.
As MARAD and DOT evaluate port automation and administer potentially relevant grant programs, we urge Departments to not provide funding for automated port equipment. By providing funding for technology that operators are not currently purchasing, MARAD and DOT would distort the market by incentivizing procurements that terminal operators would not have made without the government’s intervention. We note that these prospective projects could have the immediate impact of eliminating jobs at ports and harbors. Taking affirmative actions to eliminate jobs in the longshore sector by funding unneeded projects would be a poor programmatic eligibility for MARAD to consider.
This position is reflected in report language to the Consolidated Appropriations Act of 2019, which clarifies that MARAD should not fund automation projects that cause job loss through the Port Infrastructure Development Program. Additionally, a letter to MARAD reiterating this restriction was sent by Chairman David Price of the House Transportation, Housing and Urban Development, and Related Agencies Appropriations Committee. We urge that this position be applied to any grant which funds port infrastructure or equipment.
Finally, regardless of how exactly automated technology is or is not deployed at ports and harbors, we once again call on MARAD and DOT to give consideration to how this may impact these workforces, and the steps that the federal government can take to ensure that these workers are prepared for future developments and changes in the port arena. MARAD must not allow an interest in technological development to result in workers being left behind.
We look forward to continuing to work closely with MARAD and DOT on issues related to autonomous technology, at ports and harbors as well as across the nation’s transportation system.
Larry I. Willis
 Attached is a complete list of TTD’s 33 affiliate unions.
 We have previously raised this issue in comments to automation dockets from other modal agencies including Docket Nos: FMCSA-2018-0037, DOT-OST-2018-0149, DOT–OST–2018–0150, FMCSA–2018–0037, PHMSA-2018-0001, FTA–2017–0024, FTA–2017–0025, NHTSA–2018–0009, NHTSA–2017–0082, FMCSA–2017–0114 , and NHTSA–2016–0126.
 Attached is Chairman Price’s letter to MARAD