36 CFR Parts 1190 and 1191 ADA and ABA Accessibility Guidelines - Preamble (Discussion of Comments and Changes)

Comment. The referenced vehicle guidelines (like those of the proposed rule) permit the use of mini high platforms, car-borne or platform-mounted lifts, ramps or bridge plates, or manually deployed devices where it is not operationally or structurally feasible to meet the specified changes in level or horizontal gaps. In the case of commuter and intercity rail systems, this is often due to track that is also used by freight trains because the passage of oversized freight precludes a high level platform. The American Railway Engineering and Maintenance of Way Association had previously recommended a new platform height of 8 inches above top of rail. This height allows for freight passage while reducing the height of the first step of a rail car above the platform. Often a portable step stool is used to make up the height difference between a lower platform and the first step. Negotiating such a step can be difficult for ambulatory passengers, especially since handrails are usually not available. Also, requiring the 8 inch height would reduce the vertical travel distance for a lift. The Board sought comment on whether new platforms for commuter or intercity rail stations should have a height of 8 inches above top of rail (Question 47). Most comments supported such a requirement.

Response. The Board had added a requirement that low level platforms be at least 8 inches above top of rail (810.5.3). An exception intended for light rail systems allows a height below 8 inches where vehicles are boarded from sidewalks or at street level.