AAR Comments

ASSOCIATION OF
AMERICAN RAILROADS
Sarah G. Yurasko
Assistant General Counsel

October 13, 2017
Via email to: [email protected]
Office of Information and Regulatory Affairs
Office of Management and Budget
725 17th Street NW
Washington, DC 20503
Attention: FRA Desk Officer

Re: FRA Proposed Agency Information Collection Activities; Autonomous Locomotive
Technology; OMB Control Number 2130-XXXX
Dear FRA Desk Officer:
The Association of American Railroads (“AAR”), on behalf of itself and its member railroads,
submits the following comments in response to the Federal Railroad Administration’s (“FRA”)
Information Collection Request (“ICR”) to conduct two studies regarding automated locomotive
technology.1 AAR is a trade association whose membership includes freight railroads who employ
95 percent of the workers of all railroads in the United States and who will therefore be impacted
by this ICR.
FRA proposes with the first study, “Experimental Investigation of Automation-Induced
Human Error in Locomotive Cab,” to identify and evaluate the potential for human error
associated with the operation of systems and automation in the locomotive cab. FRA states that it
will use the research’s results to identify training, operational procedures, or automation design
standards that will improve the safety of automated systems in locomotive cabs.
AAR is interested in studies that advance the development of autonomous locomotive
technology. Autonomous locomotive technology will enhance rail safety and operations by
minimizing, and possibily eliminating, human factors that contribute to accidents. Studies to
develop this new technology are a necessary and appropriate part of FRA’s role in advancing rail
safety. However, this study prematurely focuses on assessing human errors caused by
automation, while the far likelier consequence of implementing such technology is the avoidance
of human error. FRA should instead study human errors that could be avoided by automation.
1

See 82 Fed. Reg. 43,078 (Sept. 13, 2017). FRA Docket No. FRA-2017-0002-N-12.
425 3rd Street SW; Ste 1000 I Washington, DC 20024 I P (202) 639-2504 I [email protected]

October 13, 2017
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Then, FRA should determine what regulations are necessary to promote autonomy technology
development and innovation. Only after the technology itself is fully developed and
implementable should the FRA examine whether there are any human errors caused by
automation. Given the current state of development, it is unlikely that this study will yield
information of present value, and its piecemeal approach may lead to unnecessary roadblocks to
the development of technology that could otherwise greatly benefit safety in the near term. FRA
should also include in the study a control group demonstrating the number of errors that occur in
locomotives absent autonomous technology. AAR supports FRA’s interest in this area but cautions
that the narrow and premature scope of the study may be counterproductive to the development
of safety-enhancing technology. We encourage FRA to develop a path toward autonomy instead.
With the second study, “Design and Evaluation of a Robust Manual Locomotive Operating
Mode,” FRA proposes to design and evaluate a prototype locomotive operating mode that allows
an operator to “manually” control a train by providing the desired speed target while the control
system determines the throttle-notch changes required. The agency states that the information
collected from this research will be used by researchers and equipment designers to evaluate the
merit of a prototype display and control configuration maximizing the use of both automation and
human capabilities. This is more properly focused on the development and advancement of
automation technology. AAR would appreciate more information about this study as it unfolds.
Finally, AAR is going to offer a meeting with FRA staff to provide an informational overview
on some of the developments the industry has been considering in automation. I will be including
these comments to the ICR in a meeting invitation.
Thank you for the opportunity to provide comments on this ICR.

Sincerely,

Sarah Yurasko

425 3rd Street SW; Ste 1000 I Washington, DC 20024 I P (202) 639-2504 I [email protected]