I am writing to express my deep concern about the provisions of Bill C-49 (An Act to amend the Canada Transportation Act and other Acts respecting transportation and to make related and consequential amendments to other Acts) that require all railway operators to install and utilize Locomotive Voice and Video Recorders (LVVRs).
I am supportive of government efforts reduce railway incidents and I support the sophisticated “Black Box” technology already installed on locomotives that records the speed of the train, the use of air breaks, and every other operative action taken by the locomotive engineer.
With this in mind, I believe that the government has seriously erred in its drafting of C-49.
Most importantly, the installation of LVVRs violates the privacy rights of rail workers and will increase the stress-level of those being monitored (which may even reduce safety).
Since LVVRs were heavily lobbied for by employers, there is good reason to believe that they will use this technology as a disciplinary tool. This is not acceptable and has no impact on public safety.
Finally, there are very serious unintended consequences of Bill C-49. There has been no discussion or plan for how the Transportation Safety Board plans to maintain the integrity of the LVVR data once locomotives enter U.S. territory. Furthermore, Bill C-49 will open the door to other transportation employers to adopt LVVRs, making privacy violations the government-sanctioned standard.
I strongly urge you to amend C-49 to eliminate any requirement for Locomotive Voice and Video Recorders.