Due to the importance of the issue and the record response, the Federal Railroad Administration (FRA) has extended the comment period for the Noticed of Proposed Rulemaking (NPRM) on a two-person minimum freight crew size rule, the SMART Transportation Division National Legislative Department reports.

The new deadline for SMART-TD members, rail labor and the public to let their voices be heard in this pivotal conversation about the safety of U.S. railroad operations is now Dec. 21st, 2022.

“Please keep the pressure on and the pedal down as we fight together for our safety and our jobs,” said National Legislative Director Greg Hynes. “We’ve blown well past the level of comments that the prior NPRM received after it was introduced in 2016, getting almost 10 times the number of comments it received.

“There are a lot of things going on, but we need to keep spreading the word about the Rule of 2 and how it is essential to rail safety. If you have not commented on how important it is to maintain rail staffing at the current safe level, you still have time to do so!”

Members who have not yet posted a comment to the FRA in support of the Rule of 2, or who have a spouse or family member who would like to do so should please follow this link.

An instructional video about how to file a comment is available here.

The Federal Railroad Administration (FRA) announced Sept. 22 that the public comment period for the two-person crew size Notice of Proposed Rulemaking (NPRM) has been extended.

Stakeholders now have an additional 60 days to show their support for the minimum crew size of two in the cab of trains nationwide. The previous deadline was Sept. 26.

“This extension was requested by congressional Republicans on the Transportation and Infrastructure Committee and was granted by the FRA,” National Legislative Director Greg Hynes said.

He also pointed out that extensions are normal under rules of this magnitude: “It allows concerned members of the public and railroad workers alike to continue to support the truth — that safe train operations in this country are best maintained by following the Rule of Two.”

A public hearing on the matter also will be scheduled in the near future, FRA said in its Federal Register notice.

The deadline for the public to comment is now Dec. 2, according to the notice published.

As of midday Sept. 22, the NPRM had nearly 10,500 comments.

SMART Transportation Division President John Previsich and leaders from four other unions — the ATDA, BLET, BRS and TCU — submitted a 26-page document May 7 in response to the Federal Railroad Administration’s request for comment on autonomous trains.
In it, Previsich and union leaders Leo McCann, Dennis Pierce, W. Dan Pickett and Richard Johnson outline the approach they believe the industry should take in adopting new technologies in the rail industry in addition to the continuing role labor will play as these technologies advance.
To read a PDF of their submission, visit this link.
Previsich also submitted a second set of comments to FRA outlining SMART TD’s position on automation.
“Safety must be first and foremost when discussing the future of automation of our nation’s railroads,” Previsich wrote. “It would be unethical and would violate the mandate of Congress to sacrifice safety for potential profits.”
SMART TD’s comments:
1. Safety and security must be our No. 1 priority
2. Essential job functions of human railroad employees cannot be automated
In addition, the condition of America’s infrastructure, the risk of cyberattacks and the elimination of the human element of being able to watch and respond to possible safety threats also should be weighed as autonomous technology is considered, Previsich said.
“The functions of human crewmembers can never be fully automated in a way that maintains safety at its current level, let alone increases safety,” Previsich wrote. “In this industry, we are beset by challenges from all sides, and it is critical that at this juncture we take all of these challenges into consideration when it comes to automation, so as to keep railroads moving efficiently, profitably, and most importantly, safely.”
To read SMART TD’s full comments, follow this link.

A pair of BNSF conductors out of Winslow, Ariz., were recently featured in an article by the Arizona Daily Sun talking about their concerns about automating trains.
Legislative Representative Ellis Laird and Wade Carlisle, both of Local 113, talked to reporter Corina Vanek about the dangers an unmanned freight train hurtling through our neighborhoods can pose to the general public.
“It’s a horrible idea for a lot of different reasons,” Laird told Vanek. “Right now, we have two sets of eyes on each train. Humans can react to different situations, I don’t think they will ever be able to program a computer for every different situation.”
Read the whole article here.
Brothers Laird and Carlisle did their part to let the public and the FRA know why automated trains are a bad idea by getting in touch with their local newspaper. Have you done your part?
Click on the link below and tell the FRA why you think autonomous trains are WRONG! Then, forward the link to your family and friends and encourage them to do the same.
You only have until May 7 to make your voice heard!

The FRA needs to hear from YOU to STOP Self-Driving Trains!
The Federal Railroad Administration has released a request for information (RFI) about autonomous (aka self-driving/zero-person crew) trains.
“FRA requests information and comment on the future of automation in the railroad industry. FRA is interested in hearing from industry stakeholders, the public, local and State governments, and any other interested parties on the potential benefits, costs, risks, and challenges to implementing automated railroad operations. FRA also seeks comment on how the agency can best support the railroad industry’s development and implementation of new and emerging technologies in automation that could lead to safety improvements or increased efficiencies in railroad operations.”
As professionals in this industry, and as concerned citizens about public safety, we need to voice our concerns. The FRA has given us a chance to speak up and we need to take it!
Tell them why autonomous trains are a threat to public safety. You can also remind them of the critical duties of Conductors and Locomotive Engineers.
Speak your mind.
SMART members, now is the time to use our voices to make an impression and weigh in BIG on this issue. Your response is needed!
It only takes a minute. Click on the the link below and tell the FRA why you think autonomous trains are WRONG! Then, forward the link to your family and friends and encourage them to do the same.
You only have until May 7 to make your voice heard!

In comments to the Federal Railroad Administration (FRA), SMART TD’s National Legislative Director John Risch wrote in support of allowing train crews to sound train horns at their discretion when traveling through rural America.
The comments were written in response to the Strasburg Railroad Company’s (SRC) request that their train crews be allowed to sound horns at their discretion due to livestock often grazing on farmsteads bordering tracks in Amish country.
“SRC’s request is not only reasonable, this is the way train crew members have conducted themselves for the past 140 years prior to the enactment of mandatory whistle rules,” Risch wrote. “This isn’t just an issue for Amish country – it’s an issue for all of rural America where farmers oftentimes herd livestock near a crossing and where people ride horses near the railroad track. Our nation’s operating crews should all be allowed the discretion in sounding or not sounding a locomotive horn when these situations arise.”
Risch went further in his letter to not only support SRC’s request but to also request that the FRA extend the waiver request to all railroads with the caveat that carriers be prohibited from disciplining crews from using their discretion.
Click here to read the full letter.