WRITTEN STATEMENT OF GREG REGAN, PRESIDENT
TRANSPORTATION TRADES DEPARTMENT, AFL-CIO
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FEDERAL RAILROAD ADMINISTRATION PUBLIC HEARING ON PARALLEL SYSTEMS TEST PROGRAM
March 12, 2024
On behalf of the Transportation Trades Department, AFL-CIO (TTD) and our 37 affiliated unions, I want to thank the FRA for scheduling today’s public hearing. The members represented by TTD-affiliated unions have long led the fight for safety improvements in the rail industry, and their combined skill and expertise prevent accidents and save lives on a daily basis. It is therefore imperative that rail workers are considered equal partners in promoting safety as new technologies, like that developed by Parallel Systems and the subject of this petition, become more prevalent. Workers face a future of technology-enabled change and their voices must be a part of any debate over the deployment of automated rail technologies.
And as we know, on August 10, 2023, Georgia Central Railway and Heart of Georgia Railroad submitted a request to the FRA for approval of a test program for a “novel, self-propelled, zero-emission, battery-electric rail vehicle” manufactured by Parallel Systems. This new technology presents workforce challenges and safety concerns that the FRA must take into consideration.
While the testing of this new technology would be initially limited to two rail properties in Georgia, we have to consider that this type of automation could one day interact with the broader rail network, may ultimately be widely deployed, and could interact with other elements of our transportation system, including ports. We strongly encourage the FRA to carefully consider the potential long-term impacts of this type of automated technology, and to broaden its lens beyond the specific parameters of this request as it evaluates this petition.
Workers must have a voice in the adoption of new technology
Too often, the railroads instinctively look to technology as a replacement for existing workers. This petition could very well be the first step toward the eventual widespread integration of automated rail technology into our rail system, and workers must have a voice in this process from the outset.
Strong union and worker engagement are essential to mitigate the harms inherent in rapid changes to industries. Furthermore, the FRA must ensure comprehensive employee protections providing for job guarantees, training and retraining programs, and the continuation of collective bargaining rights and terms and conditions of employment extend throughout any shift, large or small, toward automated rail technology. The preservation of collective bargaining rights and agreements is particularly important with regard to managing technological change and its impact on working people. Any transition toward automated rail technology must also include career ladder and apprenticeship programs for rail workers, ensure the manufacture and development of new technologies is done within the United States, and that any new jobs created come with union protections.
Safety is of the utmost importance
The safety of the rail workforce and the public must be of the highest concern. The FRA must monitor and understand the ways in which this technology interacts with every facet of the existing rail system, including rail workers, traditional locomotives, rail cars, and grade crossings. This can only be accomplished through thorough testing and strict federal oversight.
The FRA must be certain that the vehicle can navigate unforeseen challenges and operate with reliability and precision under a myriad of circumstances. How will the technology communicate and interact with first responders? How will it stop safely when a problem occurs? How will such problems even be identified? These are critically important issues with which other automated vehicles continue to struggle. We need to be sure that the introduction of this technology will not compromise safety in favor of technological advancement, as we have seen play out with the testing of autonomous vehicles on our roads.
Furthermore, we strongly urge the FRA and Parallel Systems to adopt proximity sensors or other human-detection devices to avoid tragic incidents on the rails, in yards, and in ports. Rail labor has seen far too many of its members killed or maimed by technologies without proper safety protocols, precautions and redundancies. Indeed, similar technologies like remote control locomotives have been deployed across the network that have led to senseless deaths of yard personnel. This is why the technology being developed by Parallel Systems – and others in this space – must prioritize human safety above all else.
Transparency, data collection, and public input must be a priority
Workers and the public deserve to know whether the technology Parallel Systems aims to test is safe, and as such, we urge the FRA to require that safety data collected through previous testing be made public. This data should not be limited to crashes and derailments, but should expand to instances where the technology did not behave as predicted. We have made similar requests with regard to the development of other autonomous vehicles, and Parallel Systems’ technology should be no different.
Additionally, we have serious concerns regarding the proposed process for the multi-phase testing program. While we appreciate that Parallel Systems plans to share safety data relevant to each phase with the FRA and request its written approval prior to moving on to the subsequent phase, the public must also have the opportunity to evaluate this data and provide public comment. The public deserves to know exactly how this technology performs at each phase of testing and share any concerns that may arise. Moreover, in order to allow for full transparency and comprehensive evaluation, this data must not be redacted. Safety is not proprietary and any data related to the performance of the technology should not be treated as such.
The FRA needs to consider the far-reaching impacts of automated rail technology
As noted earlier, this petition raises serious concerns about the impact of autonomous rail vehicles on the broader transportation system. For example, Parallel Systems includes graphics on its website illustrating a modular, automated shipping terminal working in conjunction with the technology it aims to test through this petition. We are strongly against the automation of intra-port vehicle traffic, cargo handling, and other port operations as it could have the immediate impact of eliminating jobs at ports and harbors. The FRA must not allow an interest in technological development to result in these workers being left behind.
The FRA should minimize the use of waivers
The FRA should minimize the amount of waivers granted for any technological request, including this one. Until regulations fully account for developing technologies, waivers should be granted sparingly and should be viewed as extraordinary measures. Regulations exist for a reason, and a patchwork system of waivers degrades safety for rail workers and the public, especially when utilized to facilitate the adoption of developing technologies. Regulations should evolve in tandem with technological progress, ensuring that safety standards remain robust and resilient.
Conclusion
No one understands the realities of rail operations on the ground as well as frontline workers. Whether it be the deployment of new technologies, the crafting of new work rules, or the promulgation of new regulations, the meaningful inclusion of rail workers in these conversations and consideration of workers’ input is the only way to maintain and promote safety now and in the future. In moving forward, we emphasize the importance of a comprehensive and inclusive approach to technological integration, prioritizing the safety and well-being of both the rail workforce and the public. TTD and our affiliated unions stand ready to collaborate with the FRA to ensure that safety remains paramount in the ever-evolving landscape of rail technology.