EBBC Adopts Uniform Level-Platform Boarding Policy
What should have been a simple trip late at night on the San Jose’s Light Rail system turned into a nightmare for Cecilie Rose, former Vice Chair of EBBC. Unable to hoist her bicycle up into the rail vehicle, she could not board the train. Work rules prevented the train operator from helping her board. And though disabled, Cecilie was not permitted to bring the bicycle onto the wheelchair lift. Having a disability, being elderly, riding a heavy bicycle, or simply being of short stature, is not a barrier to bicycling — but can be a major barrier for using transit in the Bay Area.
BART, the first modern rail transit system built in the Bay Area, is a fine example of uniform level-platform boarding. Conceived in the 1960s, and still using railcars dating back to the 1970s, BART was designed with full platform accessibility, including elevators at stations (installed at the insistence of disabled groups). Patrons with bicycles, strollers, luggage, wheelchairs, or walkers never need to worry about climbing steep stairs.
Will eBART offer level-platform boarding?
Since the construction of BART, billions in transit funding has been spent on four other rail transit systems: VTA light rail, Caltrain, ACE, and the Capitol Corridor. Despite their recent implementation, none of these systems have platform access compliant with modern standards:
- Caltrain’s “Gallery” cars, purchased in 1998, have three very steep steps at the doorway. Caltrain has also spent vast sums rebuilding stations and platforms, without providing level boarding (and in some cases, making accessibility much worse).
- The original construction of VTA light rail had low platforms, and used railcars with steps inside the entrance. The VTA is now replacing light rail vehicles with more modern “low-floor” models in order to provide level-platform boarding. This also requires retrofitting stations to raise platform heights — a process that has cost millions and closes stations for weeks at a time.
- Even though railcars are “low-floor” models, neither ACE nor the Capitol Corridor offer level boarding. Instead, railcars have integrated wheelchair ramps and/or lifts. Their situation is further complicated by the fact that they operate on tracks owned by Union Pacific, which imposes its own platform requirements.
- The proposed “SMART” DMU commuter line in the North Bay would not have provided level-platform boarding, opting instead for ramps and/or wheelchair lifts. Whereas SMART’s staff opposes levelboarding, two recently built DMU projects provide it (the New Jersey River LINE, and the North Coast Transit District in San Diego county).
There are no technical or engineering obstacles that prevent the use of level platform boarding. Rather, these deficient designs are the product of antiquated state regulations, and a staggering amount of ignorance and stagnation among transportation planners (particularly in the Bay Area). To rectify the situation, the Federal Department of Transportation initiated a rule-making process earlier this year to modernize ADA regulations. Specifically, it would have mandated level-platform boarding for all new rail starts and new vehicle procurement in the US. Wheelchair lifts, ramps, and special loading areas would be banned. At the same time, it included various loopholes to grandfather existing systems, to keep costs reasonable and to avoid mass disruption.
Unfortunately, it seems unlikely that the rule will be enacted. A large number of transit agencies opposed the rule. Even more disappointing, many transit advocacy groups (who ought to know better) opposed the rule. While there were minor technical problems in the originally proposed rule, the objections were mainly territorial — the fact that Federal government was intruding into local matters with an “unfunded” Federal mandate, and that Congress specifically exempted railroad operators when it passed the ADA.
In the meantime, EBBC proposes that the rule be implemented anyway, as a local defacto standard. At its November 2006 meeting, the EBBC Board voted to treat level-platform boarding as a “Routine Accomodation.” Non-conforming rail projects would be viewed as deficient. Projects on the radar screen include Dumbarton Rail, eBART, and the Capitol Corridor. The EBBC will also seek to coordinate with coalition partners to push for uniform adoption of the standard.
Ultimately, some action at the state level might be required. Platform regulations fall mainly under the control of the California Public Utilities Commission (PUC). The PUC regulations are anachronistic and counterproductive, actually making things much more dangerous. At just 8”, rail platforms conforming to PUC rules are very low to the ground, encouraging passengers to trespass on tracks. This has been an on-going problem for Caltrain. The purpose of PUC regulations is to protect railway workers. Thus, it calls for low 8” platforms to protect a railroad employee hanging off the side of a train from getting clipped. Of course, this begs the question as to why employees should even be allowed to ride on the outside of trains. Except for railroad yards and other restricted areas, railway employees should never be hanging off trains. Note that in Europe, the situation is reversed: the purpose of platform regulations there is to protect railway passengers. Except in unusual cases, 8” platforms are banned as being too hazardous.