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Or answer questions within the C-RIS below.

Policy options

Which is your preferred option for each recommendation?

It is proposed that all the reforms would be made nationally (avoiding separate pieces of legislation for NNI and other networks), but it is recognised that the application of the legislation may vary between networks. Are there specific reforms that should only be applied to some networks?
Will the relationship between the WHS legislation and RSNL change because of the expanded scope? Will WHS law still prevail to the extent of any inconsistency? If so, would this negate any legislative change designed to facilitate interoperability - if for instance a safety requirement under WHS prevails over an interoperability requirement of the RSNL.
How can the RSNL be amended to reflect its focus on rail operations, while clarifying WHS legislation’s focus on other workplace safety matters?
What additional or different functions and powers will ONRSR need to support compliance with interoperability requirements? For example, requiring additional periodic reporting from RTOs, additional powers to publish data, any additional functions related to the certification, registration and testing of rolling stock etc.
Rec 2 - Will it be necessary for a RTO to consent to the Regulator having a coordinator or facilitation role in any specific issue? If not, how will the Regulator assume such a role?
Rec 2 - What skills and qualifications would the Regulator's delegate need to possess in order to competently provide a coordination or facilitation role?
Rec 2 - Is there a need to have a new class of ‘rail safety officers’ within ONRSR who would only carry out the coordinating and facilitating role, and not any enforcement role?
Rec 2 - Will there be an immunity from prosecution or other enforcement action if a RTO acts on any advice given by the Regulator when the Regulator is carrying out a coordination or facilitating role?
Rec 2 - To the extent that the Regulator is empowered to make any decisions in connection with its coordination or facilitation role, would those decisions be reviewable?
Rec 3 - What factors should the Regulator consider, beyond the definition of interoperability, to ensure that any general duty for interoperability under the RSNL is clearly understood and practically enforceable?
Recommendation 3 to mandate requirements to achieve specified interoperability outcomes includes options to include interoperability as a sub-part of the general safety duty or as a separate explicit duty in the RSNL. How do you think these options may work in practice?
Rec 4 - Do the current consultation provisions allow for input from affected workers and/or their representatives?
Rec 4 - How should the principle of ‘meaningful consultation’ be applied to strengthen the consultation requirements of the RSNL?
Rec 4 - What evidence should be relied upon to demonstrate that meaningful consultation has occurred? Who should determine non-compliance?
Rec 11 - What safety information should the Regulator make available to the industry to improve safety outcomes? How should this information be shared between parties?
Rec 18 - Should recommendation 18 to compel RIMs to consider implications to the wider network in implementing network rule or infrastructure changes be extended to rolling stock operators, network authorities, and/or infrastructure owners?
Rec 18 - How should the SFAIRP principle apply to any interoperability requirements? If not qualified by SFAIRP, are there any other qualifications that would apply?
Rec 18 - What kind of tangible evidence would be required to satisfy ONRSR that a RIM had in fact given consideration to interoperability?
Rec 19 - Should the ability of a RTO to mutually recognise the approval of technology be optional or mandatory?
Do you think the governance suite of options are effective to support interoperability?

Option benefits and costs: Interoperability

Given the GHD report was originally developed for a different purpose than its use in the RSNL C-RIS, can you provide any input, data, or point us to additional information sources that could help strengthen the cost-benefit estimates presented in this C-RIS?

Are there any additional impacts (costs or benefits) arising from each of the proposed reform topics other than those identified by GHD?

Benefits

Do the baseline estimates and annual benefit estimates (as a percentage improvement) shown in Table 10 appear appropriate?

Are the timings proposed in the GHD report (25 years of implementation) appropriate? Would some benefits be realised earlier than others?

Costs

Do the GHD cost estimates set out in Table 11 appear appropriate? What changes do you consider would improve the accuracy of the estimates?

Options benefits and costs: Transparency and Accountability

Are there any additional impacts (costs or benefits) arising from each of the proposed reform topics other than those identified by GHD?

Do the annual benefit estimates (as a percentage improvement) appear reasonable?
Do the cost estimates appear appropriate? What changes do you consider would improve the accuracy of the estimates?

Option recommendations 

Is the proposed approach (implement the least intrusive reform that is considered likely to be effective) appropriate?

Option implementation and evaluation

What timeframe for implementation do you consider suitable?

Are there specific reforms you believe could be advanced ahead of others, and are there any that should be delayed in implementation?
Are there any barriers and risks to the reforms that should be identified in the D-RIS?