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ASLRRA files opposition to two-person crews with the FRA

The American Short Line and Regional Railroad Association (ASLRRA) has urged the Federal Railroad Administration (FRA) to abandon its call to require two-person crews in many types of service, citing lack of consideration for economic impact to its small business members in the implementation of a rule with no proven safety benefit.

“We are aligned with the FRA in the commitment to the safe operation of America’s freight rail network,” said Linda Bauer Darr, President of ASLRRA. “However, there is no evidence that the proposed Train Crew Staffing Rule will address safety challenges in a way that is meaningful and operationally sustainable for our small businesses.”

In comments submitted to the FRA on June 15, ASLRRA stated that the rulemaking was flawed in its analysis of the economic impact to small railroads. The economic impact anticipated for small railroads is much more significant than the assumptions made, and Darr contends should have been evaluated by the Small Business Administration’s Office of Advocacy prior to the rulemaking, pursuant to the Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA). Class III railroads, tourist and scenic railroads meet the economic criteria for consideration.

Darr also outlined that the cost impact to short lines was based on inaccurate assessments of operations, including reliance on the Class I railroad average speed, which for a variety of reasons, is much higher than the average short line speed.

“We are concerned that the burden of additional regulated labor cost, without an offset of improved safety, will lead to the diversion of scarce financial resources in our small businesses away from capital investments with a proven link to safety, such as infrastructure and track upgrades, ultimately making rail transport less competitive than other competing methods,” said Darr.

Results from a member study conducted by ASLRRA last month showed that short lines have operated with one person in the cab under every proposal where FRA considers requiring two, and have done so safely for decades. FRA has not presented any contrary data.

“An example of a cooperative approach to rail safety is the Short Line Safety Institute, a partnership between FRA and ASLRRA. As opposed to new regulations unsupported by specific facts, this effort addressing short line railroads.

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