Platform height an issue in Milwaukee station renovation

[jis]

Of course, if I wanted to be cheeky about it, I could ask, "What about Private Varnish cars?" Milwaukee does serve occasional excursion trips, especially for 261 and the cars its society owns, afterall.

Needs of occasional service I believe is explicitly excluded from the FRA rules. They apply only to regular service.

 

[NorthShore]

And, to boot, most historic cars are not especially accessible either.

 

[John Bobinyec]

Just to clarify things a bit. I did some research. Here's what I've found.

The FRA has no rules on platform height which pertain to ADA. That comes from the Department of Justice. Here they are:

Part 37--Transportation Services for Individuals with DisabilitiesSee especially section 37.43 Alteration of transportation facilities by public entities

and

section 37.55 Intercity rail station accessibility.

Here's a key sentence:

Sec. 37.43 Alteration of transportation facilities by public entities.(a)(1) When a public entity alters an existing facility or a part of an existing facility used in providing designated public transportation services in a way that affects or could affect the usability of the facility or part of the facility, the entity shall make the alterations (or ensure that the alterations are made) in such a manner, to the maximum extent feasible, that the altered portions of the facility are readily accessible to and usable by individuals with disabilities, including individuals who use wheelchairs, upon the completion of such alterations.

Notice that it says "this shall be done" but not how.

jb

 

[neroden]

That DOJ rule is a good description of the basic, general ADA rule for transportation.

The "level boarding" regulation is elsewhere. I think it's in what's known as the ADAAG (ADA Accessiblity Guidelines). It is a clarification of what is required in "altered portions". I found it in the Federal Register when it was going through the comment process, but it's going to be a pain to find now. There are definitely ambiguities in it.

The main feature of the level boarding rule is:

- If you intend to provide wheelchair access to the train, you must provide access to all cars to which able-bodied people have access.

- If you are going to provide level-boarding platforms along the full length of the platform, you can just do it.

- This does not need to be the full length of the train; it's fine to have platforms shorter than the train like at Syracuse NY.

- If you are not going to provide level-boarding platforms for the full length of the platform, you must submit a site-specific plan to the FRA for your alternative solution, explain why this option is better than other options at this specific site, and get prior approval. Lots of paperwork.