Federal Transit Administration November 4, 2015 Subject: americans with disabilities act (ada): guidance



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3.5Platform-Vehicle Coordination


For new construction and alteration projects, Section 810.5.3 of the DOT Standards requires rail platforms to be positioned to coordinate with vehicles in accordance with the applicable requirements of Part 38. With “level boarding” (see Figure 3-5), the platform height is coordinated with the height of the vehicle floor and gaps are minimized, ideally allowing persons who use wheelchairs to board independently. Where it is not operationally or structurally feasible to meet the horizontal gap or vertical difference requirements of Part 38, mini-high platforms, car-borne or platform-mounted lifts, ramps, bridge plates, or similarly manually deployed devices, meeting the requirements of Part 38, will suffice. Figure 3-6 includes examples of mini-high platforms, platform lifts, and bridge plates.

photograph showing level boarding of a train car

Figure 3-5 – Level Boarding

Section 37.42(e)(2) requires transit agencies to provide barriers to prevent the flow of pedestrian traffic through the area between the front of the mini-high platform and the train. The photo in the upper left of Figure 3-6 depicts an example of an appropriate barrier.

series of 4 photographs, 1 with mini-high platform and required passenger barrier, 2 of another mini-high platform, 3 of deployed bridge plate, and 4 of platform-based manual lift device

Figure 3-6 – Mini-High Platforms, Bridge Plate, and Platform Lift


3.6Rapid Rail Platforms

Rapid-rail-specific requirements are provided in Part 38 Subpart C.
Requirement

Coordination with boarding platform—(1) Requirements. Where new vehicles will operate in new stations, the design of vehicles shall be coordinated with the boarding platform design such that the horizontal gap between each vehicle door at rest and the platform shall be no greater than 3 inches and the height of the vehicle floor shall be within plus or minus 5⁄8 inch of the platform height under all normal passenger load conditions. Vertical alignment may be accomplished by vehicle air suspension or other suitable means of meeting the requirement.

(2) Exception. New vehicles operating in existing stations may have a floor height within plus or minus 11⁄2 inches of the platform height. At key stations, the horizontal gap between at least one door of each such vehicle and the platform shall be no greater than 3 inches.

(3) Exception. Retrofitted vehicles shall be coordinated with the platform in new and key stations such that the horizontal gap shall be no greater than 4 inches and the height of the vehicle floor, under 50% passenger load, shall be within plus or minus 2 inches of the platform height” (§ 38.53(d)).

Discussion

The general standards for rail platforms can be found in Section 810.5 of the DOT Standards; Section 810.5.3 references the platform-to-rail-car gap standards found in Part 38. For rapid rail, § 38.53(d) establishes the platform-to-rail-car gap required for new vehicles operating in new stations, new vehicles operating in existing stations, and retrofitted vehicles operating in new and key stations. Unlike commuter or light rail, there is no exception that permits platform configurations that do not provide level boarding. It is important to note that the platform-to-rail-car gap dimensions are a maximum standard, and may still present barriers to some persons with some disabilities. Project sponsors are encouraged to minimize the gap as much as possible.

3.7Light Rail Platforms

Light-rail-specific requirements can be found in Part 38 Subpart D.
Requirement

“(1) Vehicles intended to be operated solely in light rail systems confined entirely to a dedicated right-of-way, and for which all stations or stops are designed and constructed for revenue service after the effective date of standards for design and construction in §§ 37.21 and 37.23 of this title shall provide level boarding and shall comply with §§ 38.73(d)(1) and 38.85 of this part.

(2) Vehicles designed for, and operated on, pedestrian malls, city streets, or other areas where level boarding is not practicable shall provide wayside or car-borne lifts, mini-high platforms, or other means of access in compliance with § 38.83 (b) or (c) of this part” (§ 38.71(b)).

Coordination with boarding platform—(1) Requirements. The design of level-entry vehicles shall be coordinated with the boarding platform or mini-high platform design so that the horizontal gap between a vehicle at rest and the platform shall be no greater than 3 inches and the height of the vehicle floor shall be within plus or minus 5⁄8 inch of the platform height. Vertical alignment may be accomplished by vehicle air suspension, automatic ramps or lifts, or any combination.

(2) Exception. New vehicles operating in existing stations may have a floor height within plus or minus 1 1/2 inches of the platform height. At key stations, the horizontal gap between at least one door of each such vehicle and the platform shall be no greater than 3 inches.

(3) Exception. Retrofitted vehicles shall be coordinated with the platform in new and key stations such that the horizontal gap shall be no greater than 4 inches and the height of the vehicle floor, under 50% passenger load, shall be within plus or minus 2 inches of the platform height.

(4) Exception. Where it is not operationally or structurally practicable to meet the horizontal or vertical requirements of paragraphs (d) (1), (2) or (3) of this section, platform or vehicle devices complying with § 38.83(b) or platform or vehicle mounted ramps or bridge plates complying with § 38.83(c) shall be provided” (§ 38.73(d)).


Discussion

The general standards for rail platforms can be found in Section 810.5 of the DOT Standards; Section 810.5.3 references the platform-to-rail-car gap standards found in Part 38. For light rail, § 38.71(b) requires that light rail systems confined entirely to a dedicated right-of-way provide level boarding, and establishes standards for new vehicles in new stations, new vehicles in existing stations, and retrofitted vehicles in new and key stations.

There is an additional exception for light rail, under which platform or vehicle mounted ramps or bridge plates can be used where the vertical and/or horizontal gap requirements cannot be met.

Where light rail systems are operated on pedestrian malls, city streets, or other areas where level boarding is not practicable, then wayside or car-borne lifts, mini-high platforms, or other means of access such as ramps or bridge plates must be provided.

In its October 30, 2006, final rule adopting the DOT Standards for accessibility, DOT clarified a related section of 49 CFR Part 38 that has been the source of some misunderstanding. Section 38.71(b)(2) provides, “Vehicles designed for, and operated on, pedestrian malls, city streets, or other areas where level-entry boarding is not practicable shall provide wayside or car-borne lifts, mini-high platforms, or other means of access in compliance with § 38.83 (b) or (c) of this part.” DOT received suggestions that this provision should be interpreted to mean that, if there is any portion of a system in which level boarding is not practicable, then the entire system can use some method other than level boarding. Such an interpretation is incorrect. The authority to use alternatives to level boarding pertains only to those portions of a system in which rail vehicles are “operated on” an area where level boarding is not practicable.

For example, suppose a light rail system’s first three stops are on a pedestrian/transit mall where it is infeasible to provide level boarding. The transit system could use car-borne lifts, mini-high platforms, etc., to provide access at those three stops. The system’s next 10 stops are part of a right-of-way in which level boarding is practicable. In such a case, level boarding must be provided at those 10 stops. There is nothing inappropriate about the same system having different means of boarding in different locations, in such a case.

Section 810.5.3 of the DOT Standards requires low-level platforms to be at least 8 inches above top of rail. Where light rail vehicles are boarded from sidewalks or street-level, such as in streetcar operations, low-level platforms are permitted to be less than 8 inches.

Also note where level boarding is provided, § 38.85 requires the provision of between-car barriers to prevent, deter or warn individuals from inadvertently stepping off the platform between cars. These can include, but are not limited to, pantograph gates, chains, motion detectors or other suitable devices. (See Circular Section 4.3.5.)



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