OFA provides comments to the Director of Regulatory Affairs of the Department of Transport regarding the Canada Gazette, Part I, Volume 155, Number 25: Regulations Amending the Grade Crossings Regulations, June 19, 2021. OFA fully recognizes the need for these proposed regulatory changes. With about 14,000 public and 9,000 private grade crossings along more than 40,000 kilometers of federally regulated railway tracks in Canada, inspecting, assessing the work to done, communicating the results of these assessments and completing the identified work is a huge undertaking. The date of November 28, 2021 for the regulatory requirements as currently written to take effect is not practical. This has caused undue anxiety and hardship for farmers. OFA supports the development of a measurable framework to determine the level of risk of a crossing.

OFA continues to recommend enhancing the Rail Safety Improvement Program to provide financial assistance to fully cover the cost of grade crossing improvements required of the private landowner on crossings through farmland. Unsafe private crossings must be upgraded to keep farm families, farm workers, and the farmers themselves safe. Finally, OFA requests that at least 24 months prior to the new November 28, 2024 deadline, private landowners with private crossings requiring work to be brought up to the Grade Crossing Standards receive written notification informing them of the specific upgrades required. We believe a 24-month period may be required to apply and receive financial assistance from the Rail Safety Improvement Program to fully cover the cost and allow enough time for any improvements to be made.