Dear KiwiRail,

I am requesting the following information regarding the Parker Street, Hornby level crossing and its integration with the wider Christchurch cycleway network:

1. Decision to pause of defer design work

a. Who made the decision to place the design of the Parker Street level crossing signals and cycleway integration on hold?

b. On what date was that decision made?

c. What was the rationale or justification for pausing or deferring this work?

d. Was a formal decision paper, briefing note, internal memo, or email trail produced? If so, please provide a copy of all relevant documentation.

2. Consultation

a. What communications were sent or received between KiwiRail and the Christchurch City Council (or any other stakeholders) regarding the decision to pause design work?

b. Please provide any minutes, notes, or summaries from meetings or correspondence where the Parker Street cycleway integration or related design delays were discussed.

3. Mitigation of delays

a. What specific actions is KiwiRail taking to mitigate the delays in design work on the Parker Street crossing?

b. Have any resources (e.g., staff, funding, contractors) been reallocated away from this project? If so, please detail when and why. If not, what is the cause for the delays?

c. What is the anticipated timeline or criteria that must first be achieved before restarting this now paused design work?

4. Project management

a. Has this pause been formally acknowledged through any internal project change controls, such as a re-baselining or scheduled risk assessment?

b. What project governance or oversight mechanisms are in place to monitor progress and address the status flagged as “amber” in recent Council reporting (if any)?

5. Contaminated land risk

a. What information does KiwiRail hold relating to the risk of contaminated land associated with this package of work?

b. Has KiwiRail conducted or commissioned any site investigations or risk assessments? If so, please provide copies of these reports.

6. Liability under law

a. Has KiwiRail sought or received legal advice regarding its duties under Section 145 of the Crimes Act 1961, particularly as the risk of endangerment from level crossings is well known and there has been a failure to take reasonable steps to mitigate or design safe infrastructure in a timely way?

b. Has KiwiRail ever assessed whether the deferral of this or any other level crossing design work could give rise to liability under this section of the Act?

c. Has any internal risk register, health and safety report, or legal review identified this cycleway, the Parker Street crossing or any other crossing as a safety risk that could trigger a duty of care under criminal or civil law?

Yours faithfully,

Cody C