Public policy is notorious for intersecting with various other policies, market forces, and public and private actions. It is one reason unintended consequences can be so prolific, and why ‘the path to hell is paved with good intentions’ rings so true. One such intersection involves rail roads, roadways, and the environmental impacts implicated by them.
The issue starts with safety. That is a goal that everyone agrees should remain high, if not the top priority of public policy in the transportation space. Avoiding train derailments, traffic accidents, and collisions is critical not only to human life, but to the environment as well. Rail and traffic incidents often lead to additional tailpipe emissions, smoke and pollutant emissions, leaked hazardous material, and other environmental and ecological impacts.
Under the banner of safety, however, one policy may not actually achieve its intended safety impact, while inadvertently leading to greater environmental impacts as well as market disruptions. That issue is mandated crew sizes in locomotives.
The proposal boils down to a requirement that trains be operated by no fewer than two people. While this sounds like it should achieve safety results, little or no data actually supports it. A 2016 proposed rule from the Federal Railroad Administration stated, “FRA does not currently collect sufficient data related to the size of a train crew nor do accident reports and investigations generally address the size of a crew in order for FRA or any entity to definitively compare one-person operations to multiple person operations.” A subsequent study did find undocumented, informal gains in safety and efficiency from teamwork, although the empirical effect on safety is not stated.
Since the initial proposal and the more recent teamwork study, the FRA withdrew the proposal and Positive Train Control (PTC) technology has been incorporated in the entire rail fleet that meets minimum size, load, and operation thresholds. Full compliance with PTC means that now, trains are loaded with computers and software that continuously communicate with satellites, other trains, smart infrastructure, and more. It is even capable of stopping a train in the case of overspeeding, anticipated collision, or other event when the human crew fails to act. It does work humans cannot do, or does it with greater speed and precision, in order to assist humans – not to replace them. The question though is how PTC can effectively assist a single person or crew while maintaining safety.
PTC has been an enormous leap toward safer train operation. That means safeguarding crew lives, local communities, vehicles, and environments as well. Fewer derailments means fewer spills and leaks of hazardous material and environmental impact. Whether additional crew members also achieve this – or are required to achieve it – is inconclusive. That is because there is not good data showing two-member crews having reduced human error derailments or incidents, or one-person crews causing avoidable incidents.
Importantly, the question of crew sizes is limited to crews within a locomotive. If a carrier does reduce personnel down to one person, it may shift others to supportive roles or elsewhere in the network of safe train management or from elemental to distributed teams, which may actually serve higher safety purposes than inside the locomotive, given the sophistication of PTC and a well-trained engineer inside.
In either case, the PTC conversation is not about replacing engineers or conductors or necessarily reducing crew sizes, it is a question about the data and safety impact. Unless or until data shows that it is necessary to have multi-person crews, the entire federal crew size mandate is about employment. That employment decision is worth discussion, especially with the known positive impacts and social enhancements of teamwork, but with PTC and other technological innovations, the overall safety impact of multi-person crews is unsettled. Rail carriers may choose to – and in many cases should – maintain multi-person crews. In other cases, they do and should allow collective bargaining to settle the matter, where teamwork and anecdotal safety data can feature prominently in negotiations.
As a matter of public policy, it is important to pull the curtain back on several implications from this decision. Holding aside the rail safety impact altogether, we should explore what is likely to happen elsewhere as a result of a federal crew size mandate. This safety/employment policy would also have other impacts on the movement of freight and, perhaps counterintuitively, on safety.
PTC represents a capital investment by rail carriers. In order to achieve better safety outcomes through this technological innovation, the rail industry spent great resources. Mandating crew minimums is an economic limitation placed on rail carriers, which will inadvertently limit the ability and resources to invest in additional technology and safety innovations. Moreover, the added economic impact of mandated employment will be incorporated into the cost of goods being transported. This will likely result in a marginal shift from rail to trucks.
Trucks already enjoy a policy-generated competitive advantage over freight in the financing of their infrastructure. The 140,000-mile rail network is largely funded by private investment, while the Interstate Highway System and other public roads are funded through user fees and public tax dollars. On top of this, commercial vehicles are known to make a disproportionate impact on road condition relative to the user fees and taxes they pay. This results in commercial vehicles receiving a double benefit by using publicly funded roads and paying less than their impact-proportionate share for wear and tear.
This creates another safety and environmental impact. The nation’s roads and bridges are already in unprecedented disrepair. Shifting the margin of freight movement from rail to roads would result in marginally greater wear and tear, traffic, economic losses, fatalities, and environmental impacts.
More traffic and heavy payloads cause a greater amount of wear and tear. In turn, the degraded surface leads to slow downs, accidents, fatalities, and more. These represent economic losses due to delays and lost productivity, as well as wasted fuel, vehicle maintenance and repairs, and commercial products stuck in traffic. Moreover, road fatalities are correlated with greater traffic and degraded roadways. A high level of traffic also means tailpipe emissions and potential unnecessary idling.
Added to this, on average railroads can move a ton of freight 480 miles on one gallon of diesel. This is in contrast to a commercial vehicle, with much lower fuel efficiency, potentially achieving only a third the efficiency of rail. While burning fuel is required to transport goods, doing so with the most efficient method is best for the environment.
A federal mandate on railroad crew sizes is an early policy domino, which by itself seems like a minimal impact. When considering that there is little or no data to support crew size mandates under the rationale of safety, it becomes clear that it is an employment decision. That has the potential to decrease innovation and safety investments by rail carriers, while also shifting the marginal freight load to another mode of transportation.
Moving cargo by truck instead of rail means additional wear and tear on already degraded surface infrastructure, reinforcing a policy-generated competitive advantage, compounding unsafe road conditions, and leading to greater climate impacts. These impacts are important to know, because they will likely accrue whether or not a crew size mandate achieves its intended safety objective.
The data on single and multi-person crews alongside PTC is unsettled. The U.S. is far away from autonomous trains, and still far from single-crew trains being the norm. Presently, a federal mandate on crew sizes is not supported by robust data. Further study is important, not only to understand the safety impact of crew sizes, but to better hone the technology we use to assist conductors and engineers to further improve safety. Jeopardizing safety in the name of economics is irresponsible, and rail carriers decreasing personnel must only do so when data bears out that it is safe to do so. Those utilizing employment arguments should fully embrace the value of teamwork and importance of collaboration in rail safety, but they need to collect more data before a federal minimum crew size can be set in the name of safety.
Written by Benjamin Dierker, Director of Public Policy
The Alliance for Innovation and Infrastructure (Aii) is an independent, national research and educational organization. An innovative think tank, Aii explores the intersection of economics, law, and public policy in the areas of climate, damage prevention, energy, infrastructure, innovation, technology, and transportation.