Checking up on Amtrak's (lack of) ADA compliance

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Don’t see it that way. The MTA Subway has a small fraction of ADA compliant stations while Amtrak is mostly all ADA compliant in a lot more total stations around the USA with projects already in the works. Its not even close. I don’t believe all stations should be ADA compliant as long as there are other nearby accessible stations and alternative transportation methods available. Amtrak is in good shape.
Many, if not most, NYC subway stations require major construction work to make them accessible: either building a new standalone elevator structure (or 2) to access an elevated platform, or new excavations thru hundreds of years worth, often unmapped, utility lines and tunnels to install 2, 3, or more elevators.

Most Amtrak stations are at grade. All that's required to make the trains accessible is a concrete platform and a portable lift. It may not even need to be a full-length platform, just long enough to spot the cars as needed. That doesn't address the restrooms and ticket office, but it's a good enough interim solution.

Apples to oranges.
 
I'm not familiar with the details of the ADA, but I have read that it has no real penalties for violations. The court can tell Amtrak that they have to upgrade the station, but as far as I know, it can't force Amtrak to pay damages to a disabled person who can't use the station. There may be some state laws that allow for damages, but not the Federal ADA.

One way Amtrak could have 100% compliance with ADA immediately is simply to shut down the non-compliant stations. If the local communities really want the stop, they could pay for the improvements themselves. However, most of these non-compliant stops have very small passenger volumes, so the localities probably aren't interested in doing such a thing.

From the point of view of a disabled passenger's access to Amtrak, the vast majority of stations are in compliance with the ADA. It seems to me that the only real problems are those three stations on the Keystone Service line, and at least two of them are shared with SEPTA.
 
I'm not familiar with the details of the ADA, but I have read that it has no real penalties for violations. The court can tell Amtrak that they have to upgrade the station, but as far as I know, it can't force Amtrak to pay damages to a disabled person who can't use the station. There may be some state laws that allow for damages, but not the Federal ADA.

One way Amtrak could have 100% compliance with ADA immediately is simply to shut down the non-compliant stations. If the local communities really want the stop, they could pay for the improvements themselves. However, most of these non-compliant stops have very small passenger volumes, so the localities probably aren't interested in doing such a thing.

From the point of view of a disabled passenger's access to Amtrak, the vast majority of stations are in compliance with the ADA. It seems to me that the only real problems are those three stations on the Keystone Service line, and at least two of them are shared with SEPTA.
I believe Amtrak is governed by FRA regulations incorporating ADA. I don’t know the penalties situation but I very much doubt that Amtrak wants to get in a fight with FRA, its primary funding agency.
 
Don’t see it that way. The MTA Subway has a small fraction of ADA compliant stations while Amtrak is mostly all ADA compliant in a lot more total stations around the USA with projects already in the works. Its not even close. I don’t believe all stations should be ADA compliant as long as there are other nearby accessible stations and alternative transportation methods available. Amtrak is in good shape.
It affects me personally. I don't know about out where you are, but here in California stations are not close together and alternatives leave something to be desired.

Two examples of the latter, neither recent but still the sort of thing that still happens judging from other wheelers I know.

1. I took an Ambus from Sacramento to my home in Oroville. The Ambus had a lift which got me on the bus. It did not operate to get me off the bus. After a half hour of struggling (and much grumbling from other passengers), the driver called the yard in Redding and was told to keep me on the bus and they would deal with it up there, nearly two hours from here. I dismantled my chair so the driver could carry it over people's heads and managed to get to the front, then scooted on my butt down the steps where I sat to re-assemble my chair. This was likely either a training or maintenance issue, two areas where Amtrak has known issues that have not improved. Now I drive to Sacramento when I want to take a train.

2. At the Seattle gathering, the Coast Starlight was delayed so passengers were taken off the train and put on buses, don't remember from where. School buses were used. I was in the H-room, the conductor knew I had a wheelchair. As is usual, they asked for me to be the last off my car so as not to delay other passengers. That meant I was last in line to be assigned a bus. Turns out, none of the buses were accessible, they "forgot" I was on the train. They called an accessible taxi who took a couple of hours to arrive. I arrived after the empty (except for crew) train.

3. A bonus: The Bakersfield transfer station is often difficult but at least another bus will be by in a few hours. More than once I have arrived with a ticket that says I am bringing my own wheelchair and need a wheelchair spot on the train, and the bus that meets me is not accessible. Usually the bus has a ramp or lift but the driver says it is broken. This could be a situation where the bus really is broken but it could also be a lazy driver.

Amtrak has been sued and lost multiple times over ADA violations. The schedule Neroden references that they are behind on was part of a lawsuit settlement. The 15 percent disabled discount was also instituted on account of a lawsuit. To me it looks like they don't want passengers with disabilities. Of course, it also looks like they also don't want ambulatory passengers, or pasengers who eat, or passengers who like clean restrooms and seats, or passengers who transfer to other trains, or passengers who have a schedule, or ... So maybe this isn't discriminatory?
 
MODERATOR NOTE: several posts were removed because they involved "sniping" between members, which is prohibited. Thank you for keep your posts on topic and civilized.
 
It affects me personally. I don't know about out where you are, but here in California stations are not close together and alternatives leave something to be desired.

Two examples of the latter, neither recent but still the sort of thing that still happens judging from other wheelers I know.

1. I took an Ambus from Sacramento to my home in Oroville. The Ambus had a lift which got me on the bus. It did not operate to get me off the bus. After a half hour of struggling (and much grumbling from other passengers), the driver called the yard in Redding and was told to keep me on the bus and they would deal with it up there, nearly two hours from here. I dismantled my chair so the driver could carry it over people's heads and managed to get to the front, then scooted on my butt down the steps where I sat to re-assemble my chair. This was likely either a training or maintenance issue, two areas where Amtrak has known issues that have not improved. Now I drive to Sacramento when I want to take a train.

2. At the Seattle gathering, the Coast Starlight was delayed so passengers were taken off the train and put on buses, don't remember from where. School buses were used. I was in the H-room, the conductor knew I had a wheelchair. As is usual, they asked for me to be the last off my car so as not to delay other passengers. That meant I was last in line to be assigned a bus. Turns out, none of the buses were accessible, they "forgot" I was on the train. They called an accessible taxi who took a couple of hours to arrive. I arrived after the empty (except for crew) train.

3. A bonus: The Bakersfield transfer station is often difficult but at least another bus will be by in a few hours. More than once I have arrived with a ticket that says I am bringing my own wheelchair and need a wheelchair spot on the train, and the bus that meets me is not accessible. Usually the bus has a ramp or lift but the driver says it is broken. This could be a situation where the bus really is broken but it could also be a lazy driver.

Amtrak has been sued and lost multiple times over ADA violations. The schedule Neroden references that they are behind on was part of a lawsuit settlement. The 15 percent disabled discount was also instituted on account of a lawsuit. To me it looks like they don't want passengers with disabilities. Of course, it also looks like they also don't want ambulatory passengers, or pasengers who eat, or passengers who like clean restrooms and seats, or passengers who transfer to other trains, or passengers who have a schedule, or ... So maybe this isn't discriminatory?
I used to drive buses at WDW. Back when we still had high-floor buses, the lifts were fascinating to watch, but they were ridiculously complex mechanically. It wasn't all that unusual for one to fail during a run. Depending on the nature of the failure, it was usually possible to crank them down manually, but it required a mechanic to do so. (We did also have a few drivers who were reputed to claim their lift was broken to avoid loading a wheelchair.)

So it's very possible that the lifts were broken. But that's no excuse. The bus company should have been notified that a lift was required, and they should know which buses have lifts that are not working.

OTOH, ramps on low-floor buses could almost always be deployed by hand.
 
Amtrak has lots of ADA compliant stations with more coming out. I don’t see any real issues. The NYC subway has much less ADA compliant stations.

The NYC Subway is the absolute worst in the entire nation and has repeatedly lost multimillion-dollar lawsuits over their flagrant, deliberate, and wilful violations of the ADA. The current set of lawsuits against NYC Subway's parent organization, the MTA, are calling for its entire budget to be put under judicial supervision due to their long history of flagrant lawbreaking.

Amtrak is the second-worst in the country when it comes to ADA compliance -- that's nothing to be proud of.

Compare it to literally any other US passenger rail system in terms of legal compliance, and they're doing worse. Some other systems have more inaccessible stations, but they also weren't legally required to (there were some pretty large carveouts for commuter and urban rail systems which had budget problems).

So, there are two basic provisions: one requires anything being renovated to be made accessible. The other requires a list of "key stations" to be made accessible -- or for Amtrak, that list was every station.

Everyone except NYC complied with the renovations law (including Amtrak) -- NYC violated that law dozens of times.

Everyone except NYC and Amtrak complied with the rule regarding the list of stations which had to be upgraded -- NYC blew its deadline by about a year (I think they either finished or have one key station still under construction at this time). Amtrak is about 12 years out from its deadline.

[P.S. I checked, NYC still needs to make 68th St./Hunter College accessible -- now expected to be completed in 2024 -- and their deadline was the middle of 2020. Still, they got all the other key stations in 2021. Upper East Side Subway Stop Finally Becoming Accessible For $101M NYC's behavior has been absolutely appalling, but now Amtrak is left as the last scofflaw.]
 
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I'm not familiar with the details of the ADA, but I have read that it has no real penalties for violations. The court can tell Amtrak that they have to upgrade the station, but as far as I know, it can't force Amtrak to pay damages to a disabled person who can't use the station. There may be some state laws that allow for damages, but not the Federal ADA.

Wrong.

Disabled people, or the federal DOJ, can sue under the ADA both for specific performance (forcing them to upgrade) and for actual damages. Amtrak just paid out millions in settlements -- damages -- the lawsuit settlement is linked to earlier in this very thread!

What you may have misinterpreted is this: "actual damages", being the actual costs and trouble incurred, are often pretty small amounts financially in a single individual's case (as opposed to a class action, where it can add up), small compared to the lawyers' fees. Laws with more teeth will have specified dollar amount damages.

One way Amtrak could have 100% compliance with ADA immediately is simply to shut down the non-compliant stations.
180 days notice for station discontinuation, legally, remember?

If the local communities really want the stop, they could pay for the improvements themselves. However, most of these non-compliant stops have very small passenger volumes, so the localities probably aren't interested in doing such a thing.

These stops are mostly trivial to fix. Amtrak needs to explain why they haven't been fixed.

If Amtrak is having trouble getting agreement from the host railroad, or permits from the local government, or a private landowner, or the National Park Service, or whoever, the ADA allows Amtrak to sue the host railroad or local government or private landowner or National Park Service to force agreement -- that's explicit.

From the point of view of a disabled passenger's access to Amtrak, the vast majority of stations are in compliance with the ADA. It seems to me that the only real problems are those three stations on the Keystone Service line, and at least two of them are shared with SEPTA.
And they're Amtrak's legal responsibility (Amtrak spent quite a while working out legal responsibility for each station, which is complicated).
 
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To me it looks like they don't want passengers with disabilities. Of course, it also looks like they also don't want ambulatory passengers, or pasengers who eat, or passengers who like clean restrooms and seats, or passengers who transfer to other trains, or passengers who have a schedule, or ... So maybe this isn't discriminatory?

Snort. Yeah, that would be an interesting approach in court. "Your honor, we hate and attempt to mistreat all of our passengers."
 
I believe Amtrak is governed by FRA regulations incorporating ADA. I don’t know the penalties situation but I very much doubt that Amtrak wants to get in a fight with FRA, its primary funding agency.

DOT regulations, I believe (and DOT is Amtrak's primary funding agency)
 
So, there are two basic provisions: one requires anything being renovated to be made accessible. The other requires a list of "key stations" to be made accessible -- or for Amtrak, that list was every station.

Everyone except NYC complied with the renovations law (including Amtrak) -- NYC violated that law dozens of times.
(Emphasis added.)

You don't see the slightest thing circular, unfair, or illogical in a law declaring that, for only one rail operator in the entire nation, every single station is key?!

For CTA, Irving Park Rd. station isn't the same as Clark/Lake. Ditto for SEPTA, MBTA, MTA (whichever one you choose), etc. For everyone else with a pre-ADA* network, a recognition of priorities. For only Amtrak, a somber formal declaration that a station in a small town is indistinguishable from Chicago Union or New York Penn. Reminds me of the story of Lincoln and calling a dog's tail a leg. A dog still has only four legs, and every station in a network isn't key just by decreeing it is.

Altogether, this sounds to me more than a bit like the requirement that the Postal Service fully fund benefits for employees that don't exist yet. "Why can't you simply live up to your legal obligation (that only you and nobody else in your industry bears)?" 🤔 The Postal Service is a deadbeat, and Amtrak is a scofflaw, by "virtue" of being defined into being one. In stark contrast, NYCTA isn't fulfilling a duty that's been imposed on all its peers, none of which are as big but many of which are about as old.

*For public works with federal money, some of the accessibility requirements actually go back to the 1970s Rehabilitation Act.
 
It affects me personally. I don't know about out where you are, but here in California stations are not close together and alternatives leave something to be desired.

Two examples of the latter, neither recent but still the sort of thing that still happens judging from other wheelers I know.

1. I took an Ambus from Sacramento to my home in Oroville. The Ambus had a lift which got me on the bus. It did not operate to get me off the bus. After a half hour of struggling (and much grumbling from other passengers), the driver called the yard in Redding and was told to keep me on the bus and they would deal with it up there, nearly two hours from here. I dismantled my chair so the driver could carry it over people's heads and managed to get to the front, then scooted on my butt down the steps where I sat to re-assemble my chair. This was likely either a training or maintenance issue, two areas where Amtrak has known issues that have not improved. Now I drive to Sacramento when I want to take a train.

2. At the Seattle gathering, the Coast Starlight was delayed so passengers were taken off the train and put on buses, don't remember from where. School buses were used. I was in the H-room, the conductor knew I had a wheelchair. As is usual, they asked for me to be the last off my car so as not to delay other passengers. That meant I was last in line to be assigned a bus. Turns out, none of the buses were accessible, they "forgot" I was on the train. They called an accessible taxi who took a couple of hours to arrive. I arrived after the empty (except for crew) train.

3. A bonus: The Bakersfield transfer station is often difficult but at least another bus will be by in a few hours. More than once I have arrived with a ticket that says I am bringing my own wheelchair and need a wheelchair spot on the train, and the bus that meets me is not accessible. Usually the bus has a ramp or lift but the driver says it is broken. This could be a situation where the bus really is broken but it could also be a lazy driver.

Amtrak has been sued and lost multiple times over ADA violations. The schedule Neroden references that they are behind on was part of a lawsuit settlement. The 15 percent disabled discount was also instituted on account of a lawsuit. To me it looks like they don't want passengers with disabilities. Of course, it also looks like they also don't want ambulatory passengers, or pasengers who eat, or passengers who like clean restrooms and seats, or passengers who transfer to other trains, or passengers who have a schedule, or ... So maybe this isn't discriminatory?

Thanks for posting this, Alice. Although I'm not mobility-impaired myself, when I was traveling with my elderly father (who was), it was a constant nagging worry whether the next transfer from one form of transport to another would actually work as advertised: Would there actually be a redcap wagon available to get him to/from a train? Would the steps going up to train or bus be too high for him to manage? Would he be able to get in/out of the rental car (which might not be the one we requested)? Is there a place where he can sit while I park the car after dropping him off at a place where no parking is allowed near the entrance?

One lesson I learned, which your post confirms: Even when a facility is listed as ADA-compliant, the accommodation might not be in working order, and there might not be any backup implemented until we arrive and insist it's needed. My dad wasn't in a wheelchair when we were traveling, but he couldn't stand or walk very long or far---best gift I ever got him was a sort of folding stool that doubled as a cane. During several years of travel, he spent a lot of time sitting on that while I improvised ways around ADA accommodations that weren't working as expected.

I hope Alice's post (and mine) illustrate why Amtrak really needs to be fully ADA-compliant, at all stations all the time, and on buses it uses when trains or connections fail. ADA accommodations need to be RELIABLE.
 
Nobody is arguing that Amtrak should be anything less than fully ADA compliant. I see the discussion centering on the timeline to achieve that goal - and whether or not Amtrak is acting in good faith in furtherance of the goal.
 
Nobody is arguing that Amtrak should be anything less than fully ADA compliant. I see the discussion centering on the timeline to achieve that goal - and whether or not Amtrak is acting in good faith in furtherance of the goal.
You seem to have a short memory. Here, let me remind you of a post that YOU even quoted later.
https://www.amtraktrains.com/threads/checking-up-on-amtraks-lack-of-ada-compliance.73749/post-939291From the link above
“I don’t believe all stations should be ADA compliant as long as there are other nearby accessible stations and alternative transportation methods available. Amtrak is in good shape.”
 
NYC did much better with buses than with the subway, all buses lift equipped, although on the older high floor buses, maintenance and driver compliance was sketchy, Now, all transit buses are low floor with relatively simple ramps, and all coaches used on express routes are equipped with lifts. They definitely have dragged their feet on the subways.
 
(Emphasis added.)

You don't see the slightest thing circular, unfair, or illogical in a law declaring that, for only one rail operator in the entire nation, every single station is key?!
No. Transit systems often have alternate conveyance - often free for the disabled. Their stations are not far apart so if someone can use a bus or other transportation to get to am accessible station, it is not in the realm of impossibility. The chances of getting to an accessible station and finding that the solution is not working usually gets good response.

Now that doesn't excuse the failures of transit systems to do, at a minimum, what is required but Amtrak is different.

Its smaller stations are often a LONG way apart - an hour or many hours and in areas where there is minimal alternate transportation. The need is minimal - accessible restroom, wheelchair lift or high level station but Amtrak makes little attempt to do even a wheelchair lift at all stations. I even wonder if the conductor knows that a handicapped person needing assistance is even waiting at that station prior to the train's arrival. Amtrak personnel are apparently not taught that anyone needing assistance to climb onto a train should be helped because I often see them just look at people who are struggling to lift their bags and themselves onto the train. They remove agents at stations so there is no local person to prepare for the arrival of the train to assist with boarding and disembarking those in wheelchairs. I don't think any of the cars on order have built-in ramps or lifts.
 
(Emphasis added.)

You don't see the slightest thing circular, unfair, or illogical in a law declaring that, for only one rail operator in the entire nation, every single station is key?!

For CTA, Irving Park Rd. station isn't the same as Clark/Lake. Ditto for SEPTA, MBTA, MTA (whichever one you choose), etc. For everyone else with a pre-ADA* network, a recognition of priorities. For only Amtrak, a somber formal declaration that a station in a small town is indistinguishable from Chicago Union or New York Penn. Reminds me of the story of Lincoln and calling a dog's tail a leg. A dog still has only four legs, and every station in a network isn't key just by decreeing it is.

Conisdering that Amtrak is also the only pre-ADA rail system in the US with stations more than a few miles apart, it seems fair to consider that differently than agencies that often have station spacing a mile or less apart. Telling someone that they have to board the train in St. Paul when they live in Staples, MN (if Amtrak only considered St. Paul and Fargo "key stations") is very different from telling someone to board at 34 St or 14 St when they are near the 23 St station.

Even then, I believe the ADA still requires that all stations have to become accessible at some point. Amtrak has their major transfer points already accessible, so yes, it's time for Amtrak to get everything up to snuff (that time was 20-30 years ago, imo, but now is better than later.) Same with CTA, MTA, etc. - eventually all stations should be upgraded to meet ADA standards - and have those accommodations be reliable enough that they can be counted on 24/7/365.
 
(Emphasis added.)

You don't see the slightest thing circular, unfair, or illogical in a law declaring that, for only one rail operator in the entire nation, every single station is key?!

Oh, it wasn't entirely reasonable, but that fight was back in the 1980s. Amtrak knew what it was in for in 1990 when the ADA passed. (Huge fight over what stations would be "key" with the commuter and urban rail systems; was Amtrak management asleep?). Amtrak then did nothing significant to comply with the law until 2008.
 
The wheelchair lift was out at Flagstaff tonight for #3, so it's definitely there and working. It was for a person not in a wheelchair but who couldn't manage the steps.

I've contacted someone in Amtrak IT who is notifying the people who maintain the stations database to get this straightened out. I sent a list of all the stations which claim not to have a lift (most of them do have lifts) and they're going to go through them and update the database for all the ones which have a lift.
 
Even then, I believe the ADA still requires that all stations have to become accessible at some point.

So, I know this stuff. The ADA doesn't *technically* require that, but it does in practice. The ADA requires that any station which is *renovated* become accessible during renovation. (There are some super-nitpicky exceptions which almost never apply.) And also all new stations must be accessible. The belief was that this would, eventually, make all stations accessible, because you can't leave any station unrenovated forever -- it'll crumble away!

And indeed this has largely been how it has worked for most systems. A station needs some repairs, it has to be brought up to code and made ADA compliant -- so there are a lot of non-"key" stations which are accessible in every legacy urban and commuter rail system. They're all getting more and more compliant over time.

Do you (a transit agency) have crumbling stairs and a dangerous platform, and are losing million-dollar lawsuits over people falling and injuring themselves? In order to fix the stairs and platform, you have to make the station ADA-compliant. This is how a bunch of Metra stations became ADA-accessible.

NYC Subway flagrantly broke this provision of the law repeatedly, renovating stations for millions of dollars without making them accessible. LIRR and Metro-North, also MTA subsidiaries, also violated this legal provision. They all lost a bunch of legal cases over it. Everyone else complied with it.

Amtrak... well, I think maybe the reason Amtrak was required explicitly to make all stations accessible was that someone in Congress realized that Amtrak was quite capable of not renovating a station for 50 years plus.

For Amtrak, the renovation rule is actually older than the ADA: the rule has been in effect for Amtrak since Amtrak was created, thanks to the Architectural Barriers Act of 1968 which requires that any train station (or other public building) renovated using federal funds be accessible. Amtrak's history of substandard unrenovated stations was something Congress was well aware of in 1990.

Amtrak has their major transfer points already accessible, so yes, it's time for Amtrak to get everything up to snuff (that time was 20-30 years ago, imo, but now is better than later.) Same with CTA, MTA, etc. - eventually all stations should be upgraded to meet ADA standards - and have those accommodations be reliable enough that they can be counted on 24/7/365.

CTA has a plan to make all stations accessible. Boston MBTA has a plan to make all stations accessible. Philadelphia is working on a plan. These are agencies with *difficult* station work. (Philadelphia's City Hall station alone is well over half a billion dollars. MBTA Green Line surface stations are in the middle of narrow street medians and require agreement from the city which owns the roads to widen the platforms to acceptable-for-wheelchairs width by removing car lane space. Boylston is a historic landmark and requires a ton of paperwork to alter. All of them have underground stations which are expensive to alter.)

They all provide annual status reports on their accessibility projects progress, and respond to "what's the holdup with making station X accessible" questions. Cleveland RTA has always suffered with even less money to work with than Amtrak, and *they* have been issuing reports on their accessibility progress (and managed to meet the legal deadlines).

Amtrak mostly has *easy* stations left -- the least they can do is to provide the annual report on progress required by the settlement with the DOJ. I mean, I can imagine that there are genuine reasons why Harper's Ferry work is delayed (being a national park and historic site) but I don't actually have any information as to why it's delayed. For the Keystone line stations it's even less excusable.
 
I don't think any of the cars on order have built-in ramps or lifts.
The Siemens Ventures do, though I'm not sure whether Amtrak's variant does, but I think it does if I'm remembering the San Joaquin show-and-tell correctly. Though I guess that only tells us that the *California* order does -- state of California does try to comply with the ADA
 
A more historical comment: the first federal law requiring any accessibility was the Architectural Barriers Act of 1968. The Architectural Barriers Act is basically the first legislative victory.

From 1968 onward, the handwriting has been on the wall: all buildings should be made accessible eventually. The lawsuits started in the 1970s, starting with forcing WMATA to comply in its new-build subway system. Periodically, the laws are tightened, or enforcement stepped up, in response to bad actors who don't want to comply (often NYC Subway).

The laws will be tightened again. The exemption for unrenovated urban and commuter rail stations will probably be removed at some point. Some agencies will get ahead of that, others will be behind.

So, Amtrak management should have known since Amtrak was founded in 1971 that it would have to make everything wheelchair-accessible eventually.

Our neighbors in Ontario already set a hard deadline of 2025 for all stations in Ontario to be made accessible (in the AODA law). It's particularly difficult for the Toronto subway, but they'll at least get close -- they have 26 stations to go, but only two stations, Islington and Warden, are causing real delays, and they're being very open about that. The GO Transit commuter rail system should meet the deadline, with four stations to go (Eglinton, Georgetown, Long Branch, Mimico). VIA Rail is already compliant, although they're using inclined chairlifts at at least a few stations (Kingston), which is a suboptimal solution.

I do believe that the current head of accessibility at Amtrak is trying, but he can't even get a status report out on time. That's not OK. I'm currently expending my advocacy effort on timetables, but getting that status report is next in the queue.
 
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