British Columbia Ministry of Transportation and Infrastructure

April 18, 2012

Director General, Rail Safety
Transport Canada
Rail Safety
427 Laurier Avenue West
Ottawa, Ontario  K1R 7Y2
Canada

Dear Sir:

Re: Draft Railway-Roadway Grade Crossings Policy and draft Canadian Railway-Roadway Grade Crossings Standards

The British Columbia Ministry of Transportation and Infrastructure currently is responsible for over 600 railway-roadway grade crossings.  We would like to thank you for the opportunity to present comments on the draft standard and policy.

British Columbia’s geography presents many challenges for road design in mountainous and coastal areas.  Due to this geography railway crossings are often positioned in less than ideal locations while providing vital access for the national and international highway networks, international ports and airports, local communities, industry and to private lands and resources.  In many locations crossings are located on roads that provide sole uninterruptible access to communities.

The Ministry is responsible for a large road inventory and is concerned that inspection costs and time required by the proposed policy and standard at railway crossings that have existed for many years, without an accident history or recorded incidents, will take resources from other indentified safety concerns on our highway system.  We encourage the Federal Government to make grade crossing safety grants a priority for upgrading crossings, which were built to the standards at the time of construction, to meet the new Federal standards when necessary.

The attached pages contain the Ministry’s comments on the proposed policy and standard.

Yours truly,

Gordon R. Eisenhuth
Rail, Navigable Waters Coordinator

(Canadian Railway-Roadway Grade Crossings Standards)
British Columbia Ministry of Transportation Submission

Table 4.3-Grade Crossing Design Vehicle Selection

All crossings intended for vehicular use should be designed to safely accommodate emergency response vehicles at a very minimum.  A WB-12 would allow most emergency response vehicles to access properties and areas.  These emergency crews could then respond without undue risk to themselves and rail operations.  This design vehicle would also cover many delivery vehicles (propane, courier, oil etc.).

4.5-Grade Crossing Clearance Distance
c)  greater than standard spacing between multiple tracks
Definition of standard spacing needs to be identified. While many in the industry would understand this it should be universally understood.

Departure Time – Pedestrians, Cyclists and Persons Using Assistive Devices
4.8 Pedestrians, cyclists and persons using assistive devices travel at an assumed speed of 4.4 km/h or 1.22 m/s.
Crossing Clearance Distance for pedestrians, cyclists and persons using assistive devices is the distance between 5 m from the closest rail where there are no signs or signals, and 2 m in advance of a crossing sign, stop sign or signal, to the point where the person is 2.4 m beyond the farthest rail.

Pedestrian speeds should be reduced to 1.0m/s in areas with elderly, schools and persons using assistive devices.

Clearance distance beyond the tracks should be greater than 2.4m.  While 2.4m is outside the dynamic clearance of the train it can be unsettling for some pedestrians to be that close to a moving train and may cause them to react irrationally.

Gate Arm Clearance Time
4.9 (a) Once the flashing lights of a grade crossing warning system are activated, time is required for the design vehicle to pass by the gate arm of a grade crossing warning system before the gate arm starts its descent once the driver is committed to continue over the crossing.

Gate-vehicle interaction time is often 2 or 3 seconds after gates start descending.  Having the gates starting descent as soon as possible, while allowing time for the longest/slowest design vehicle to pass the gate without conflict, will reduce driver tendency to beat the descending gate.  We should consider any driver past the gate to be committed to continue over the crossing.   The area between the gate and the crossing should be considered the active crossing area (area of train conflict).  Many jurisdictions have driver rules that consider it an infraction to stop closer than 5 metres from a railway crossing.

SECTION 5 – LOCATION OF GRADE CROSSINGS
5.1 When an unrestricted grade crossing, or a road intersection or a property access on the road approach to an unrestricted grade crossing is to be constructed, the location shall be such that no part of the travelled way of the intersecting road or entranceway, or the stop line or position for a traffic control device, shall be closer than 30 m from the nearest rail of the grade crossing, where the maximum railway operating speed exceeds 15 mph. Railway service roads are excluded from this restriction (see Figure 5-1).

&
Vehicles

11.1 Unrestricted grade crossings for vehicular use shall have a grade crossing warning system if:

(g) the maximum railway operating speed exceeds 15 mph and there is any situation causing vehicles routinely to stop and to queue closer than 2.4 m to the nearest rail in the crossing, for example, as a result of a Yield sign, a roundabout, a pedestrian crosswalk, a bikeway, or a stopped vehicle waiting to make a left turn.

Sidewalks and trail/cyclist crossings of road approaches to railway crossings can cause queuing back to tracks when in use and should be included in the list for these criteria.  Many of these road crossings now have pedestrian signals to give notice to drivers of the use of the crossing.  Section 5.1 should include wording similar to Section 11.1.

Figure 6-1 Grade Crossing Surface Dimensions
NOTES:

1 The minimum width of the grade crossing surface for a sidewalk, path, trail, or any other route for a person for regular use by a person using an assistive device or a bicycle is 1.5 m measured at right angles to the centreline of the sidewalk, path, trail, or route.

Grade crossing surfaces should be at least 2.8m wide.  If you provide 0.5m each side additional crossing width for safety that would allow a walkway/trail 1.8m wide to allow marginal un-constricted width in the area of the crossing.  A constriction at the tracks could cause cyclists, dog walkers, baby carriages, etc. to leave the path/crossing surface to navigate around each other and delay their departure from the crossing area.

SECTION 7 – ROAD GEOMETRY (GRADE CROSSING AND ROAD APPROACHES)
7.1
(a) The horizontal and vertical alignment of the road approach and the road over the grade crossing shall be smooth and continuous within the safe stopping sight distance.
(b) The horizontal alignment of the road approaches to a grade crossing where train speeds exceed 15 mph shall be straight extending beyond the outside rails for a distance equal to 5 m to the nearest rail plus the length of the grade crossing design vehicle.

The definition of straight could mean that it is not possible to build a crossing in difficult geography or when properties are constricting rights-of-way.  This could lead to steeper grades or make it more difficult to carry out safety related crossing improvements unnecessarily deferring or cancelling projects.  If curves have large radii and do not distract the driver and allow all signals, signs and sightlines to be effective for the road speed then modest curves should be allowed.

7.2 Subject to the conditions in subsection 7.1 and except to provide for vehicular grade crossings of super-elevated track as required in subsection 7.4, the maximum gradients for road approaches to a grade crossing shall not exceed the following:
(a) ratio of 1:50 (2 per cent) within 8 m of the nearest rail and 1:20 (5 per cent) for 10 m beyond, at unrestricted grade crossings for vehicular use;

At many sites the super elevation (cross fall) between the rails is greater than 2%.  The differential grade between track super elevation and road grade should be suitable for the road speed.  This would allow driver safety at road speed and reduce the like hood of low clearance vehicles contacting the crossing surface or rails.  Our province has the following wording;

Pedestrian/Cyclist crossing approaches shall have:

  • Grades less than 2% within 5 metres of nearest track (less than 1% for crossings with persons depending on mobility assistive devices);
  • Grades of less than 10% beyond 5 metres and within 10 meters.

Road grade through crossing and within 10 m of track shall have a maximum grade differential between road grade and railway super elevation (Cross-slope between top of rails):

  • 0% for ≥ 60 km/h (road speed)
  • 1% for 40-60 km/h (road speed)
  • 2% for < 40 km/h (road speed);
  • Zero grade differential is preferred.

Road cross fall on tangent approaches shall be transitioned at a maximum rate of 2% per 30 metres to match the track grade at the crossing.  Road super elevation on curved approaches shall be transitioned over the appropriate length of spiral and tangent run out (refer to Section 330 of the BC MoT Supplement to TAC Geometric Design Guide).

7.6  A grade crossing where the maximum railway operating speed exceeds 15 mph shall be  constructed as specified in Figure 7-1, with the angle of intersection between the road and the track of:
(a) not less than 70 nor greater than 110 degrees without a grade crossing warning system; or
(b) not less than 45 nor greater than 135 degrees with a grade crossing warning system.

Why not more than 45 degrees if the crossing is protected with gates and is not in an area with high pedestrian use?  If the crossing receives some use by cyclists ‘swing outs’ could be incorporated in the shoulders to allow cyclists to cross at 70 degrees or better.

Railway Crossing Ahead Sign
9.3 (a) Railway Crossing Ahead Signs as specified in the Traffic Control Devices Manual shall be installed on all road approaches for vehicles leading to public grade crossings with an average annual daily traffic (AADT) exceeding 100, including on intersecting roads within 30 m of the nearest rail of the grade crossing.

Should this standard be restricted to roads with over 100 AADT?  Does not everyone deserve the same information, regardless of volume?

9.8 (c) When a Stop Ahead Sign is to be installed, it shall be installed as per the Traffic Control Devices Manual, and a supplementary tab sign indicating the presence of the grade crossing shall be used to supplement the sign, as illustrated in Figure 9-4 and located so as to be clearly seen by persons approaching the grade crossing.

Is this sign meant to replace the Advance Warning Sign?  We believe the supplementary tab is redundant with the Advance Warning Sign installed at each crossing approach.

Pavement Markings
9.6 Pavement markings as specified in the Traffic Control Devices Manual shall be applied at unrestricted grade crossings with paved road approaches.
9.7 Lines shall be applied within 8 m of the nearest rail to delineate the edges of the travelled surface of sidewalks and pedestrian paths with paved surfaces (i.e. asphalt, concrete, etc.), specifically identified as a route for persons using assistive devices.

When there are raised sidewalks why is it necessary to paint?  The definition is the curb and edge of the raised sidewalk.

SECTION 11 – GRADE CROSSING WARNING SYSTEMS
Vehicles
11.1 Unrestricted grade crossings for vehicular use shall have a grade crossing warning system if:
(a) the forecast cross-product is 1,000 or more and the maximum railway operating speed exceeds 15 mph; or
(d) there are two or more tracks and trains may be passing one another and the maximum railway operating speed exceeds 15 mph; or

Should this be related to train speed?  What are the train operating instructions that govern safety at the crossing?  I have concern that in areas with pedestrians, slow moving large vehicles or where there is a potential to pass stopped vehicles waiting for a train that the train may be not observed or may not be perceived as a threat.  Trains are often perceived as being much slower than they are.

Pedestrian or Cyclist Paths
11.2 Unrestricted grade crossings for pedestrian or cyclist use only, shall have a grade crossing
warning system where:
(a) the maximum railway operating speed exceeds 60 mph; or
(b) the maximum railway operating speed exceeds 15 mph and there are two or more tracks at the grade crossing where trains may be passing one another.

Pedestrian or cyclist crossing warrants for signals should also be based on safe sightlines. Regardless of train speed or number of tracks if the person crossing is unable to see a train in time to determine if it safe to cross other measures need to be employed.  Signals would be warranted if sightlines are inadequate for safe passage.

“Walk Light” Grade Crossing Warning Systems Used at Grade Crossings Other Than Unrestricted Grade Crossings
11.5 The standards provided in Appendix C, Standards for “Walk Light” Grade Crossing Warning Systems give the design requirements for “Walk Light” grade crossing warning systems when used at grade crossings other than unrestricted grade crossings.

11.6 “Walk Light” grade crossing warning system installations will only be used at grade crossings other than unrestricted grade crossings where there is control over the actual crossing users. A crossing assessment will be used to identify these conditions.

11.7 All of the elements associated with the “Walk Light” grade crossing warning systems installation prescribed in Appendix C shall be designed in accordance with the CRRGCS and the AREMA Communications & Signals Manual requirements for Highway Rail Grade Crossing Warning Systems except when in conflict with Appendix C, in which case Appendix C will take precedence.

A walk light would be on all the time except when a train is approaching or occupying the crossing.  Would a “DON’T WALK” sign be more effective?  It would standout and only illuminate when a train is approaching.  Also why restrict these ancillary signals to all crossings except unrestricted grade crossings?  We have been investigating their use at multi-track crossings where signals are well oriented for road traffic but bi-directional pedestrian traffic does not necessarily have to pass a typical railway signal to enter the crossing.  This situation (“dark quadrant”) is even more pronounced on multi-lane roads.

SECTION 14 – PREPARE TO STOP AT RAILWAY CROSSING SIGN
14.2 The Prepare to Stop at Railway Crossing Sign shall provide warning:
(c) following completion of the operation of the flashing lights of a grade crossing warning system for the time required for vehicles queued for the grade crossing to resume the maximum road operating speed on all roads that meet the criteria for a “freeway” or “expressway” classification in the Geometric Design Guide and on any other road approach where visibility at a safe stopping sight distance of vehicles queued for the grade crossing is restricted.

Post operation of the AAWS would be out of step with all AAWS installations in BC.  Post operation will lead to confusion asking drivers to prepare to stop even though the crossing signal ahead will not go into flash when the train has already departed from the crossing.  Some people will stop and others will try to carry on.  Some drivers will think this is a malfunction and driver apathy will potentially affect the viability of all AAWS systems whether at railway crossings or not.  In BC most AAWS systems are locate at highway intersections.  AAWS installations at railway crossings account for less than 1% of the total installations.

Since vehicles queued back on the road approach from a railway crossing will have their brake taillights on and be visible from as far back as the AAWS is visible on the highway approach the advantage of AAWS post operation is negligible.  In fact most railway crossings will not meet the warrants for AAWS installations and where vehicle queuing is common it is the traffic engineer’s responsibility to ensure roadway safety at these sites.  These are “ACTIVE ADVANCE WARNING SIGNS”, not signals.  Many similar warning signs do not have an active component and still provide warning information to drivers of a changed condition ahead.

SECTION 16 – AREAS WITHOUT TRAIN WHISTLING AT GRADE CROSSINGS
16.3 The operating control circuits of all grade crossing warning systems shall meet the criteria of section 20 of the CRRGCS.

Section 20 of the Regulation is “reserved” and has no information.  Should this be making reference to Section 19?

SECTION 19 – BELLS, GATES AND FLASHING LIGHT UNITS
Consistency of Warning Times

(b) Where the maximum railway operating speed has been reduced, other than for a temporary slow order, the approach warning times for trains routinely operating over the grade crossing, including trains operating at the maximum permitted speed, may be up to 13 seconds longer than the Design Approach Warning Time, but shall not exceed the limits in section 20.4(c).

Section 20.4(c) of the Regulation is “reserved” and has no information.  Should this be making reference to Section 19.12(c)?

APPENDIX D
Sharing Requirements

Factors that must be shared in accordance with the Draft Railway-Roadway Grade Crossings Policy must include, but are not limited to, the following:
Table D-1: Location Data
Maximum Gradient under design vehicle stopped 2m in advance of crossing sign or warning signal mast

Section 7 indicates that except for vehicular crossings of super-elevated track the road grade (7.2 (a)) should be 2% within 8m of the nearest rail and 5% for a further 10m.  In Table D-1 we are asked to measure the Maximum Gradient under design vehicle stopped 2m in advance of crossing sign or warning signal mast.  Were Section 7 and Table D-1 meant to be correlated?

Table 4-6 Ratios of Acceleration Times on Grades
K = the additional time required for the grade crossing design vehicle’s acceleration through the clearance distance due to the grade crossing conditions.
Table D-1: Location Data
Grade crossing road approach conditions ("K")

Please note that “K” factors in road design relate to other parameters.  This could be confusing without a more complete reference or revision.

Appendix E – Grade Crossing Standards to be met at [CIF]
Grade Crossing Surface

1. (a) The grade crossing surface shall be in accordance with the diagrams set out in Figure 1 and shall have a width of
(i) 8m; or

I could not find “Figure 1”.  Is it reference to Figure E-1?   Figure E-1 – Crossing Surface depicts a two way road crossing of the tracks.  What would be the safe width for a single lane road?  Nominal road width of 4.8m plus 0.5m each side would be 5.8m.

Appendix E – Grade Crossing Standards to be met at [CIF]
Flashing Light Type and Gates

13. When gates are required, they shall be installed as adjuncts to signals of the flashing light type and shall comply with the following additional requirements for this type of protective device:
(l) circuits for operation of the gate shall be arranged so that the gate arms

(i) start their downward motion not less than three seconds after the signal lights start to operate,
(ii) reach full horizontal position before any train on a main track reaches the grade crossing, and
(iii) remain down until the train has cleared the grade crossing.

This should be reviewed as I believe the AREMA and other manuals of practice require a gate to be in the horizontal position at least 5 seconds before the train enters the crossing.  Also the gate should be down for at least 5 seconds before the train enters the crossing on a siding, spur, or other non-main tracks.

Table 1. Item 3. Of the Draft Railway-Roadway Grade Crossings Policy.  Condition of the road approaches.

Referenced section of the CRRGCS section 7.8 cannot be found.

(Canadian Railway-Roadway Grade Crossings Policy)
British Columbia Ministry of Transportation Submission

5. (1) With respect to a public grade crossing, the railway company is responsible for
(a) the standard of construction and maintenance of
(i) the crossing surface;

There needs to be some checks and balances in place.  If the road authority or Municipality is aware of the need to minimise flange way cross-section at specific crossings or require a specific crossing surface due to vehicle speed, the railway, when developing a standard of construction and maintenance for a specific crossing, should get agreement with the other party.  In the RCCGCS Table D-2, Technical Data, the Road Authority is responsible for data/classification of Road Classification, if regularly used by pedestrians, cyclists, and persons using assistive devices, AADT, road operating speed and design vehicle.  The Road Authority should, at the very least, provide agreement to the type of crossing, the standard of crossing surface materials and flange way dimensions.

5. (1) With respect to a public grade crossing, the railway company is responsible for
(b) sightlines along the railway right-of-way;
(c) the removal of snow from the crossing surface for the safe passage of road and rail traffic at the grade crossing; and
(d) the removal from the railway right-of-way of snow that obstructs the sightlines.

The Ministry agrees with the requirement to have snow removed from the crossing surface.  We have had incidents with very deep ruts forming across the road at each rail.  These ruts have caused vehicles with small radius wheels to become stuck on the crossing.  Various railway maintenance manuals and documents ask the road crews to lift their blades at least an inch above the track/crossing surface.  Therefore the road crews are unable to effectively clear the crossing from the ever deepening snow.  This clause should also include ice and debris.

8.
(2) A responsible authority for a grade crossing must ensure that the information referred to in subsection (1) is updated and shared as soon as practicable if any of the following events occur:
(d) there is a change of more than 16 km/h (10 mph) in the maximum operating speed of rail or road traffic approaching the grade crossing;

I have concern with pre-emption timing (rail and road) and sightline issues even when changes are less than proposed 16km/h.  Pre-emption designs must be designed to accurately time various phases so when a train is approaching it does not leave drivers trapped on the crossing.   A change of more than 5km/h should be reported to each party to review sightline and advance pre-emption requirements.

14. (1) The railway company must, within three years after the [CIF] document and notify the road authority or beneficiary of the conditions necessary for adequate warning of the approach of railway equipment at all grade crossings.

The railway should not have soul authority in determining “adequate warning” but that a consensus should be reached with the effected parties.  Adequate warning requires a basic understanding of road vehicles and road design.  Appendix “D” of the Draft CRRGCS specifies the information responsibilities in this regard.

18. Before a railway company ceases the use of the whistle on railway equipment at or in the vicinity of a grade crossing in response to a resolution of the government of a municipality declaring that it agrees that the whistle should not be used in that area, the railway company must determine whether the area meets the requirements set out in section 35. The railway company must document and notify the road authority of the conditions necessary for adequate warning of the approach of railway equipment and confirm that these conditions have been met.

Railway should also notify and coordinate with the Municipality if different than the road authority.  The responsibilities in different jurisdictions may require mitigation or ancillary work by the Municipality or similar jurisdiction and not the Road Authority.
Railway Company must determine whether the area meets the requirements????  It would be reasonable that the railway not have the final determination but that a consensus should be reached with the effected parties.

22. The conditions documented in subsections 14 to 21 must take into account those factors set out in section 3.1 of the CRRGCS.

My copy of the CRRGCS has section 3.2.1, not 3.1.

Table 1. Item 3. Of the Draft Railway-Roadway Grade Crossings Policy.  Condition of the road approaches.

Referenced section of the CRRGCS section 7.8 cannot be found.

35. For the purposes of section 23.1 of the Act in respect of the use of the whistle on railway equipment, the following requirements for the area are prescribed:
(a) the grade crossings in the area and their road approaches must meet the requirements of section 16 of the CRRGCS;
(b) whistling in the area is not required for a grade crossing that is outside the area;
(c) there is no recurrent failure by drivers, pedestrians, cyclists, and persons using an assistive device to observe the grade crossing warning systems in the area; and
(d) there is no recurrent unauthorized access to the line of railway in the area.

35. (b) The wording is confusing.  It appears to imply railway crossings just outside of the study area for whistling cessation do not require a train whistling on an approach within the study area limits.   Since whistling is normally required 1320’ (402m) from each crossing if a crossing outside of the study area is less than 2640’ from a crossing in the study area it does not require whistling on that approach within the area?   The purpose of the study for whistling cessation is to review each crossing and area.  Why would a crossing outside that area be eligible for reduced whistling?

38. (1) When a driver, a pedestrian, a cyclist, or a person using an assistive device requires passage over a public grade crossing, it is prohibited for a train, engine or other railway equipment, or any part of it,
(a) to stand or switch on any part of the public grade crossing for a period longer than five minutes;
(b) to obstruct the public grade crossing, or cause it to be obstructed, for a period longer than ten minutes;
(c) to stand so as to cause the unnecessary operation of a grade crossing warning device;
(d) to stand so as to unnecessarily interfere with the sightlines of a train approaching the public grade crossing on another track, notwithstanding CRRGCS section 8.6; and
(e) to be left unattended while interfering with the sightlines of a train approaching the public grade crossing on another track.
(2) Employees of the railway company must clear any grade crossing when an emergency vehicle requires passage.

Ten minutes is an extremely long time!  Many emergency responders in North America adhere to the guideline of responding to an emergency in 8 minutes or less 90% of the time.  There is a great deal of data related to heart attack and stroke victim’s survival rate diminishing significantly after 4 – 6 minutes.  To break a train to allow passage of emergency vehicles may take several minutes after communication is established.  Train crews may not be at the crossing and the emergency vehicle may not be aware of the reason for congestion all of which adds to response times.  Also if a busy road is blocked by a train for 10 minutes one could expect the queue of vehicles to be over 7,000’ long (2,133m) in each lane.  (1800 vehicles per hour each lane is not an extraordinarily busy road).  It is understood that a long train starting to move near the crossing may require several minutes to clear the crossing but if it is a continuous movement there is little anyone can do.

47. When work is carried out within the limits of a crossing surface or an activity related to work on the line of railway is carried out within the limits of a crossing surface, the responsible authority must follow the technical guidelines and standards in respect of the control of traffic in a work zone that are
(a) set out in Part D of the Uniform Traffic Control Devices Manual;
(b) established by the department of transportation of the province where the grade crossing is located; or
(c) established by the government of the municipality where the grade crossing is located.

Often work outside the limit of the crossing surface may impact the safety of the crossing users.  It may be within a safe clear zone of traffic, equipment or materials blocking sightlines, track equipment interfering with normal signal operations and drainage being temporarily blocked etc.

48. The railway company must ensure that a sufficient number of persons with appropriate training and equipment are stationed at the grade crossing to advise drivers, pedestrians, cyclists, and persons using an assistive device whether it is safe to cross the tracks when work is carried out on a line of railway within the activating limits of a grade crossing warning system and the work might result in
(a) the activation of the system; or
(b) the failure of the system to operate when a train or engine is approaching.

Should add reference to blocked sightlines on tracks or to crossing signals and if a temporary adjacent crossing is being utilized.

Should also add a note that all detours, road/trail closures and must be approved by the responsible authority.  Public Road/Trail traffic is the duty of the responsible authority and work impacting that traffic must be coordinated.

49. (1) In addition to section 48, when work is carried out on a line of railway within the activating limits of a grade crossing warning system interconnected with a traffic signal and the work might result in the activation of the system, the railway company must
(a) before carrying out that work, notify
(i) in the case of a public grade crossing, the road authority that is a responsible authority, or
(ii) in the case of a private grade crossing, the beneficiary, and, where applicable, the road authority in respect of a public road that intersects with the road approach to the private grade crossing;
(2) When work is carried out on a line of railway within the activating limits of a grade crossing warning system interconnected with a “prepare to stop at railway crossing” sign and the work might result in the failure of the sign to activate when a train or engine is approaching or occupying the grade crossing,
(a) the railway company must, before carrying out that work, notify the road authority; and
(b) the railway company must ensure the safe and orderly flow of road users and railway equipment in the vicinity of the crossing and the interconnected “prepare to stop at railway crossing” sign.
(3) The railway company must restore normal operations of the system as soon as possible.

Notifying the Road Authority may not be enough.  It should be incumbent on the proponent to coordinate the works with the parties and gain approval for the work.  There may be other nearby works or events that may impact the scheduling.  With any detours or work creating large delays it may be necessary to inform emergency services, reroute buses, issue public notices and advise adjacent Road Authorities if detours/diversions use their road network. Comments for section 47, 48 and 49 also can be applied to section 50.

52. (3) A railway company is not required to conform to paragraph (2)(a) if it deactivates the traffic signal preemption immediately or corrects the condition which could lead to the failure of a “prepare to stop at railway crossing” sign to activate before the arrival of a train or engine.

Notification to the Road Authority is still required.  With the advent of remote monitoring a call may go in requiring attention.  During the time when pre-emption is circumvented it is imperative that trains do not activate the railway crossing signals or enter the crossing.  Pre-emption is designed to allow safe road operations when a train is approaching and occupying a crossing.  To have anything less than full coordination will unduly increase accident potential at the crossing but also adjacent and approaching roads and intersections.

Although I did not see a section related to testing railway signals and interconnected traffic lights or Active Advance Warning Flashers I would like to see a maximum time of test to be the advance pre-emption time plus operation time before a train would normally enter the crossing.  This would most often be less than a minute.