Railway’s 3Rs- Roles, Regulation, Responsibility.

The Office of rail regulation responded to this article as follows.
‘Thanks for your letter and blog post: understand your points and will reply soon.@railregulation
The response will be posted on NVAG. END OF UPDATE

Roles- Who Regulates Noise Pollution& Vibration Emitted by UK Railways?

Is it Richard Price, CEO of the UK Office of Rail Regulation? Or the team of ORR executive directors listed here.

Corporate social responsibility (CSR), and sustainability are high profile for any organization of good standing. For a publicly-funded body, a body responsible to government and public, a body that regulates national infrastructure, one would have thought CSR and sustainability would be the bread and butter of what they do. On the basis that ORR and the rail operators should act in a socially responsible manner, have a look at this ORR infographic of Network Rail targets for 2019 (this graphic was produced by ORR, not NVAG).

Anything Missing ?
There’s plenty in the infographic on increasing capacity, improving the network, reliable trains, maintenance, cutting costs . . . but what about CSR and sustainability?

News headline-grabbing issues such as safety at crossings, prevention of accidents to workers, passenger safety are all included. These are depicted as the persons shielded by caring hands in the graphic, and indeed they should be protected. But no mention of the five million people in the UK who live next to the lines or the environment they live in. Presumably another set of hands just beyond the edge of the graphic is pushing then away making sure they’re kept out of the picture.
To be fair, in ORR’s written statement, the environment does get a mention: there are targets for reducing CO2 emissions tagged on at the end, apparently an afterthought. But the immediate environment didn’t make it, nor did the five million UK citizens who live next to the track and whose health and well being are highly dependant on the railways being run in a responsible manner. Public health stats and environmental scrutiny aren’t always welcome and ORR have been busy with their cutting red tape challenge and deregulation. It seems the people next to the rail lines are inconvenient, don’t fit in with business strategy, and are ignored in targets, infographics and policy.
Social responsibility doesn’t reach too far, not beyond the security fences, galvanized metal fencing that keep people off railway property and that allows railway noise though to their homes.
Image showing coal wagons passing property and complete lack of protection (edge of building on the right).

So There’s No Pollution Problem?
Actually, there is. It seems that either the ORR doesn’t know or simply doesn’t want to know.
The World Health Organization, the health arm of the United Nations, has, for thirty years, been publishing substantial, fully-referenced reports derived from numerous expert studies about the dangers of noise pollution. In 2011 they published the actual numbers of healthy years of life lost due to noise pollution in Western Europe (mostly transport noise), and the numbers are huge. High blood pressure, ischaemic heart disease, stress-based illnesses, the undermining of child development . . . these and others are described at length. And, crucially for ORR and Network Rail- sleep deprivation. Chronic sleep disruption and deprivation that result from repeated sleep cycle disruption and awakening is inevitable for those exposed to bursts of loud noise (eg heavy freight during the night).
As warnings from health authorities about noise pollution intensify, exposure from rail traffic continues to increase. Increased daytime traffic whilst better for passengers, pushes increasing freight traffic onto available ‘paths’ during the night when passenger trains are not running. The overall result is more and more freight being routed past bedroom windows at all hours of the night (on the SAK line, though not a main line, 10 to 16 train movements were recorded each night, approx 2 per hour).

ORR are setting targets for and are actively promoting increased passenger traffic and freight knowing this will increase noise and vibration pollution for residents. ORR are not monitoring, regulating, funding or ensuring protection for families who live next to the lines, and merely requires the submission of sustainability policies that are never checked for compliance. This is about responsibility, corporate social responsibility, CSR.

Paying to be Polluted
Night noise levels on the SAK line, (see previous posts) was found for Class 66 locomotives, the most common freight locomotive in the UK, to be four to eight times louder than the level that allows a reasonable standard of sleep (BS8233), WHO night guidelines. This isn’t opinion. It’s there in the figures.
We have several big numbers: the levels of noise, the number of people next to UK railway lines, and the number of years of healthy life lost from noise pollution, but the other big number is the amount of subsidy the UK public pays to keep this situation going – a whopping £38 billion between now and 2019 according to the infographic. It’s the ultimate irony that those tax payers whose health is undermined and whose sleep is disrupted by the railway, are paying Networkrail through ORR approved subsidy over £1000 per head for the privilege.

Open letter- Addressed To Mr Price and the Board
Dear Mr Price,

According to the documentation, ORR regulates the UK railways and requires that Network Rail and rail operators provide you with sustainability policies . . . but you don’t monitor or in any way check to see that these policies are being upheld. Neither, as far as we can ascertain, do you set targets or standards to control noise or vibration levels, nor do you impose penalties (as you does for punctuality breaches) for exposing the public to unreasonable levels of noise.

Railways are an important part of the UK infrastructure, they inevitably make a certain amount of noise and vibration. That is not the issue. The issue is when these levels become harmful. Based on the advice of the world’s most eminent health body, the World Health Organization, night noise levels next to certain UK lines are a significant risk to public health.
Does the ORR honestly believe that requesting sustainability policies and filing them in a cabinet means that ORR, Network Rail, and the operators have fulfilled their social responsibility? Or do these bodies claim the right to conduct their business in a socially irresponsible manner?

And, looking to the future, how will the ORR, you as the CEO and the other members of the board, justify imposing penalties for poor time-keeping, an inconvenience, whist ignoring the much bigger issue of pollution, health warnings and years of life lost due to unregulated rail noise and vibration?

I’m sure the public would be pleased to know your views on the above and NVAG will happily publish your response.

Yours Sincerely,

A McIver, NVAG Chairperson

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  1. Pingback: Railway’s 3Rs- Roles, Regulation, Responsibility. | Leadership Champions Blog
  2. Pingback: Richard Price, CEO of of ORR, on Residential Railway Noise, Vibration and Sustainability | Noise Vibration Action Group

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