Responses to consultation on new ORR guidance on Principles of Level Crossing Safety – Published June 2021 Aberdeen City Council Amey Rail Ltd ASLEF Association of Directors of Environment, Economy, Planning and Transport (ADEPT) Atkins British Horse Society (The) Central Bedfordshire Council Costain Dartford Borough Council Denbighshire County Council Dumfries and Galloway Council Ed Rollings Associates Ltd Essex County Council Friends of the Far North Line Furrer+Frey Overhead Contact Lines Gloucestershire County Council Individual number 1 Individual number 2 Individual number 3 Individual number 4 Individual number 5 Individual number 6 Individual number 7 Individual number 8 IOHS Kilnside Farm Network Rail North Yorkshire Moors Railway Parliamentary Advisory Council for Transport Safety (PACTS) Peak and Northern Footpaths Society Rail Crossing Safety Consultants Limited Rail Delivery Group Ricardo Rail Limited RSSB Shropshire County Council Sotera Risk Solutions South Lanarkshire Council Suffolk County Council Surrey County Council Systra The Ramblers The Ramblers – Dorset Area The Ramblers – Swindon and North East Wiltshire Group Transport for London (TfL) UKTram Victa Railfreight Warwickshire County Council West Somerset Railway PLC From: Graeme McKenzie (Aberdeen City Council) Sent: 26 February 2021 18:15 To: Level Crossing Principles <[email protected]> Subject: ORR Consultation - "Principles for managing level crossing safety" Please find a response on behalf of Aberdeen City Council with respect to the ORR consultation on the proposed guidance "PRINCIPLES FOR MANAGING LEVEL CROSSING SAFETY". 1. Who are you responding as (an individual/for an organisation) and what is your role? Operations and Protective Services, Aberdeen City Council – Technical Officer, Traffic Management and Road Safety 2. Who would use this guidance in your organisation? When and how would it be used? This guidance would have potential to be used by a multitude of teams in terms of the Local Roads Authority function; Traffic Management & Road Safety, Roads Design, Roads Construction Consent, Roads Development, Structures, Roadworks Coordination and Roads Services (maintenance). It would also be of possible interest to environmental planning colleagues when considering core paths, rights of way etc. The document would be a valuable point of initial reference when considering the possibility of any new level crossing, while it would be equally applicable in terms of monitoring existing crossings, or where circumstances could warrant a review of a crossing so that it continues to operate safely and efficiently in terms of the surrounding road network. 3. Are the risks associated with all types of level crossings sufficiently and clearly covered? Are there gaps in the document that you think need to be addressed? As a document that acts as a base reference it does appear to provide very good coverage of the potential risks and identify the multitude of user types. In terms of the Local Roads Authority function, it is specifying the many factors that have to be taken into account, thus road layout, surface, visibility, the use of signs, traffic movement in the vicinity, environmental factors etc. I do not consider there to be any gaps from a roads perspective, as it is a prompt to ensure design guidance / regulations from other documents, legislation, Statutory Instruments etc. is used appropriately to deal with the risk factors highlighted. Albeit, while I note the guidance states, “You will also need to take account of other health and safety guidance and legislation relevant to the railways and public highways. Equally, you will need to comply with relevant equality legislation and consider other relevant standards and guidance. Further information is available on our website.”, I did ponder whether it would be worthwhile including specific references to relevant information such as DfT Traffic Signs Manuals, legislation etc. At the same time I appreciate those reading this document should be practitioners that are alert to the relevant guidance and there is also the issue of specific references being superseded over time. 4. If you carry out level crossing risk assessments, would you find this guidance helpful? Please explain your answer Within the Aberdeen City Council area, I believe the last level crossing was removed circa 2018/19. Nonetheless, this guidance would be of help should any new level crossing be established in the future. 5. ORR has published a number of principles-based guidance on various topics. How do the principles in this level crossings guidance fit with other railway safety guidance that you use? N/A 6. What other information from ORR on level crossings would you find helpful? As indicated in the text accompanying the draft document, the possible website publication of case studies could be of value. 7. (For businesses only, not including public bodies) We are required to review the impact of any regulatory changes, including guidance, on businesses. How would the proposed guidance impact on your business in terms of familiarisation and any changes to your processes? N/A Thanks for providing us with the opportunity to review the proposed guidance, and should you have any questions over our responses, please do not hesitate to get in touch. Kind regards Graeme McKenzie | Technical Officer Aberdeen City Council | Traffic Management and Road Safety | Operations and Protective Services | Operations Marischal College | 2nd Floor West | Broad Street | Aberdeen | AB10 1AB www.aberdeencity.gov.uk | Twitter: @AberdeenCC | Facebook.com/AberdeenCC From: Bolt, Ben (Amey Rail Ltd) Sent: 24 February 2021 12:58 To: Level Crossing Principles <[email protected]> Subject: Consultation on ‘Principles for managing level crossing safety’ guidance Hello, Thank you for the opportunity to respond to the ORR’s consultation on ‘Principles for managing level crossing safety’ guidance. Please see input below, on behalf of Amey Rail Ltd. If you have any queries on the content of this email, please get back to me. Kind regards, Ben Ben Bolt Deputy Professional Head of Design Management | Rail | Transport Infrastructure From: Una Byrne (ASLEF) Sent: 26 February 2021 11:54 To: Level Crossing Principles <[email protected]> Subject: ORR Level Crossings Principles consultation I am emailing on behalf of ASLEF in relation to the Consultation on the draft ‘Principles for managing level crossing safety’ guidance. ASLEFs submission to the consultation is: ASLEF reserve comment until final draft is available. Please note this submission has been sent by email only. Kind regards, Una Byrne Una Byrne Health and Safety Advisor ASLEF Formal response to the Office of Road and Rail consultation on ‘Principles for managing level crossing safety’ guidance PART A: RESPONSES TO QUESTIONS RAISED 1. Who are you responding as (an individual/for an organisation) and what is your role? The Association of Directors of Environment, Economy, Planning and Transport (ADEPT) is responsible for providing day-to-day services including local highways, recycling, waste and planning. ADEPT members are at the very heart of delivering clean sustainable growth, tackling climate change at a local level. We manage the projects that are fundamental to creating more resilient, inclusive and safe communities, economies and infrastructure. ADEPT represents place directors from county, unitary and combined authorities, along with Local Enterprise Partnerships (LEPs), sub-national transport boards and corporate partners drawn from key service sectors throughout England. ADEPT is a membership based, voluntary organisation with: • 85+ county, unitary and combined authority members, • 3 sub-national transport bodies, • 12 local enterprise partnerships (LEPs) and • 20 Corporate Partner members across England. This response to the consultation draws together the views of ADEPT members on its Engineering Board and its Transport and Connectivity Board, including the Rights of Way Managers Group. For clarity on any issues, please contact Mark Stevens, Chair of the ADEPT Engineering Board, at [email protected] or call 07971 837620. 2. Who would use this guidance in your organisation? When and how would it be used? Not all ADEPT members have level crossings within their administrative areas but, for those that do, it would be an important reference document. The guidance document would be used in the day-to-day management of the local highway network (for road level crossings) and the local public rights of way network (especially where there is engagement over restrictive structures and barriers that need improving). This would be in respect of both maintenance and in consideration of any planned improvements to either the highway or rights of way network for which there is a level crossing interface. Consideration by ADEPT members with level crossings in their administrative areas would be given to including the guidance and the expectation that its principles are followed in any contract documents that it issues for the maintenance and improvement of highway or rights of way assets. 1 3. Are the risks associated with all types of level crossings sufficiently and clearly covered? Are there gaps in the document that you think need to be addressed? The Equality Act 2010 is mentioned in User Principles no1. BS5709 could also be mentioned in that paragraph as an example of increasing equality and a least restrictive option. However, there is