It's great that you have thought to consult us on this, JohnnyCache.
... after some of my "moany" posts on here it feels a bit like being told "put up or shut up". I hope we can rise to the occasion and make a meaningful contribution.
I'm definitely not an expert, but I might be able to ofer a suggestion or two about routes I use fairly frequently.
While I'm thinking about that....
Some general points to start with. Please accept these as a genuine desire to make the system more customer-friendly and so to promote rail travel, not as ATOC-bashing.
(1) I strongly support the suggestion that negative "easements" should be renamed - it IS clear that the easement system was not meant for them, and it does make it appear as though ATOC have been a bit sly (or lazy, see point 3) by slipping restrictions in here. It's in everyone's interest to be up front about how the system works, so if it IS necessary to "restrict" particular routes/times etc then why not be honest about it and call them RESTRICTIONS and put them in a separate list. Care needs to be taken that each entry either allows something extra, or restricts something otherwise allowed (no "Hybrid" entries).
(2) I also strongly support the idea of version control. Knowing what is allowed/disallowed TODAY is not sufficient if a dispute arises over what WAS allowed when. I'm sure this process applies to official documents wthin TOCs and ATOC, so why not to such an important public-facing document ?
(a) To avoid most disputes, all RESTRICTIONS (not necessarily genuine easements) could be added at least one month before they come into effect. But it should also be stated explicitly that restrictions do not apply retrospectively (ie restrictions added to the list between the date of ticket purchase and date of travel do NOT apply). Note that this is about properly approved restrictions, this does not substitute for the proposal/apporoval process!
(b) All current/entries should have an "Approved by DfT" Date ; a "Valid From" date ; either a "Valid To" date or a "Review" date ; and a "Last Reviewed" date.
(c) Outdated/replaced easements should in a separate section and have Valid From and Valid To dates.
(3) There is at least some risk of easements/restrictions becoming a substitute for careful design of the RG and Maps.
(a) It is reasonable to use an easement/restriction to apply a specific exception to a general rule when otherwise the rules and maps would have to be become very convoluted just to cope with one small change.
(b) But in my very inexpert opinion, there must be a temptation to add an easement/restriction when what is really needed is a simple change to a map (or other part of the RG) especially if the approval process for the latter is more difficult.
(c) When reviewing easements (and I'd suggest this should be annually) a general rule should be "any entry that can be replaced by a simple RG/Map change, must be" . Eg perhaps "doubling back through X is allowed for journeys passing through Y" might perhaps be removed by putting X into into Y's Routeing Group - I KNOW this is a simplistic example).
Thanks again.