The BLET filed extensive comments with the FRA on March 17 raising questions about CSXT’s use and implementation of Trip Optimizer/Air Brake Control (TO/ABC, or “zero-to-zero”) technology.
If fully approved, CSXT’s Product Safety Plan (PSP) would, for the first time, allow software to completely control a train’s air, independent, and dynamic braking systems. In other words, software would operate and control the train’s movements — not a certified locomotive engineer. If approved, zero-to-zero would almost completely automate the movement of a train from the beginning to the end of a run, moving at full speed and adjusting speed throughout the trip.
Zero-to-zero (an extension of Trip Optimizer) and similar systems at other railroads (such as LEADER at Norfolk Southern) were conceived as a way to assist engineers in obtaining greater fuel efficiency when operating locomotives. Over time, some carriers have mandated that this guidance tool should supersede the skill-based judgment of locomotive engineers, making technology the primary method of train operation and the engineer the backup.
BLET’s extensive comments included 23 specific reasons why CSXT’s request should be denied. For example, while engineers are required to follow all operating and train handling rules, the BLET has identified multiple rules that would be violated while zero-to-zero has control of a train. BLET is adamant that an overreliance on this system would result in the “deskilling” of locomotive engineers. BLET is also concerned that CSX has not demonstrated that the software can respond to less than optimal conditions, such as wet weather, or that it can handle trains safely in all operational environments or during unplanned events.
A PDF of the BLET’s comments can be found here on the National Division website.