Realizing trains’ natural advantage in serving passengers with disabilities

Note: This is an update of a report I authored for the February 2013 issue of the National Association of Railroad Passengers’ NARP News, while I was employed by the Association.

Americans with physical disabilities face challenges in getting from A to B from a combination of factors that people without a disability tend to overlook. This is true no matter which mode of travel one chooses. But trains, at least in theory, should be easier to access for those with physical disabilities because passenger railcars tend to be more spacious than automobiles, buses and airplanes, and could be easier to board and alight from than other modes. Amtrak has so far been stymied in its efforts to fully realize what should be a distinct advantage over its competition that is inherent in the nature of the mode. However, the national passenger carrier is making strides, including testing out a mechanism that, if it passes muster with federal regulators and host railroads and is widely deployed, could allow passengers using a wheeled mobility device to board trains as independently as possible.

There are a myriad of factors that affect accessibility which would take too long to address in detail in a single Web column. While accessibility arrangements vary greatly within the realm of commuter rail, the station and train layouts tend to be more uniform within each commuter rail system than they do across the Amtrak system. Each commuter system tends to use only a limited number of types of coach, and the authority that governs the system tends to exercise more direct control over the design of stations. Many have level boarding, either through the use of low-floor coaches or through using high platforms on passenger-only tracks. And many of those that don’t — especially newer systems — employ onboard lifts or ramps installed on all coaches. The US Department of Transportation has separate accessibility regulations for commuter rail as opposed to intercity passenger rail.

Amtrak, by its very nature, is much less uniform, and the diversity in types of equipment —including the use of both single-level and bilevel passenger cars on the same route in many places, and the use of coaches, sleepers and food-service cars — and station layouts found throughout the network make ensuring a similar experience for passengers with disabilities everywhere an ongoing challenge. The accessibility of station buildings, parking areas, and restrooms can be outside of Amtrak’s direct control. Amtrak does not own most of the stations it serves and has a limited say over how these are designed or altered. Nevertheless, Amtrak shares the obligation to comply with the Americans with Disabilities Act of 1990 (ADA) at over 200 station in its system.

Amtrak maintains that all its trains — if not all the station facilities it serves — are functionally accessible. Many stations are equipped with a crew-operated wheelchair lift or bridge plate, or there is a bridge plate stored on board the train (as is the case with Superliners and California bilevels). Additionally, cars that accommodate passengers in wheelchairs also have accessible restrooms, and food and beverage service is available by way of crew members bringing menu items from the cafe or dining car to any passenger who is unable to move between cars. There is, however, a big difference between being partially accessible and being ADA compliant.

The ADA ideal, as interpreted by the Federal Railroad Administration (FRA), is for a passenger with a disability, including anyone who uses a wheeled mobility device, to be able to enter and exit the train, all cars and all doors for the entire length of the train.. FRA regulations adopted in September 2011 require full-length level-boarding platforms (where the platform height is roughly equal to the passenger cars’ floor height) where the right-of-way is owned by Amtrak or a public entity, and/or where the track adjacent to the platform is passenger-only. Where level boarding is not required, alternate accessible strategies can be used if approved by the FRA. These include automatically-operated lifts built into the train car, self-deploying platform extenders, and station based mobile lifts (devices to enable a passenger who is not able to climb steps to board/alight the train with crew assistance).  

In spite of these regulations, host railroads’ policies restrict platform height and closeness to the tracks on lines shared with freight trains. All six Class I railroads hosting Amtrak trains restrict the height of platforms adjacent to track used by freight trains to eight inches above the rail, ostensibly to prevent freight cars from scraping against the platform.  By comparison, the floor of a bi-level Amtrak car (Superliners, Surfliners, and California cars) is 17.5 inches above the top of the rail.  Single-level Amtrak cars’ (Amfleet, Viewliner, Horizon and most Heritage) floors are 51 inches above top of rail.  Talgo cars’ floors are 25 inches above, and they have step boxes for lower platforms. 

Where stations serve both single-level and bilevel equipment, FRA standards require separate, full-length 15- and 48-inch platforms (which are considered “level” to each respective passenger car type).  The rules’ next-best option is to have a 15-inch platform with 48-inch “mini-highs” (higher portions of the platform with ramps leading up to them).  FRA also requires platforms to be accessible from the street or parking lot via level ground, either via elevators or via ramps that are no steeper than a certain slope.  A station lacking these either has been granted approval based on other factors, has been “grandfathered in,” or is not compliant. Flag or conditional stops are exempt from ADA requirements, but Amtrak has only 25 of these, all smaller communities mostly on long-distance routes.

Host railroads can thwart the intent of the ADA because, while the US Department of Transportation has regulatory authority over passenger carriers that receive federal funds, it lacks the power to regulate privately-owned tracks and stations.  The FRA has concluded that it would take an act of Congress to change this.

Congress in 1990 set a deadline of June 26, 2010, for the Amtrak system to be brought into full ADA compliance, a deadline that Amtrak did not meet.  Under pressure from disability rights advocates, Congress has not extended the original ADA deadline. Since 2008, Amtrak has spent over $200 million on accessibility, producing new low-level platforms, new station structures, ramps, and other enhancements at several stations.  These platforms are generally long enough to accommodate the typical length of the trains serving them. The company also offers guidelines to station owners and managers on bringing stations and platforms into ADA compliance. However, the cost for full compliance is likely to be far in excess of the original $1.6 billion estimate.

The bi-level coaches being built by Nippon Sharyo in Rochelle, IL, for use on Midwestern and California corridor trains will be only Amtrak’s second equipment type (after the Talgos) to have built-in wheelchair lifts, though these will still require crew operation.  Even with a full-length level boarding platform, an excessive gap between train and platform remains. The ability of people using wheelchairs and other mobility aids to get between cars on an Amtrak train should also improve gradually with the introduction of new single-level equipment. 

In places with full-length level boarding platforms (such as will be built on the now all-passenger Chicago-Detroit-Pontiac corridor), a staff-operated bridge plate still will be needed for anyone requesting assistance or using a wheeled mobility device for the time being. But Amtrak has developed a prototype at stations north of Detroit that outfits platforms with an auto-operated shuttle platform that bridges the gap between a setback platform (located 9 feet from the center line of the track) and the train.  The shuttle platform extends approximately 48 inches toward the rail car in the deployed position, giving the extended platform the same horizontal gap as a standard level boarding platform (approximately 6-8 inches). This enables a consist to be re-spotted without stowing the shuttle platform.  Once the shuttle platform has been stowed, the device will not impede freight train movements past the platform. The goal is a simple device that both Amtrak and host railroads can be okay with, that FRA will approve, and that will permit a level boarding-type experience, even if it means stopping a train multiple times.

With what limited funds are available, Amtrak continues to work towards full ADA compliance, but its top accessibility official maintains that it would be more cost-effective to make smaller improvements that enhance accessibility and permit a greater degree of level boarding.  These could serve as stepping stones towards full compliance.