July 31, 2006
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Washington, D.C.—Comments of the National Association of Railroad Passengers on the U.S. DOT’s proposed rulemaking regarding station platforms are available here on our website.
Our comments and all comments submitted to the docket can be found on the DOT website, under Docket OST-2006-23985. Comments were due Friday, July 28, the day we submitted ours.
We expressed concern that the proposed rules would result in less rail passenger service for all rail passengers. The following three paragraphs are from our statement:
NARP joins American Public Transportation Association (APTA) and Amtrak in urging the Department to withdraw this proposed rulemaking for the reasons listed below. We think the joint task force suggested by Southern California Regional Rail Authority (Metrolink, page 3 of their comments) is a reasonable next step. We note with approval the similar sentiments expressed by Amtrak: “Should DOT believe that additional steps [need to] be taken to develop practical ways to improve platform boarding access for persons with disabilities, Amtrak would be pleased to work with appropriate federal government officials, interested representatives of the disability community, and other providers of rail service (commuter operators and freight railroads) to study the relevant issues and develop appropriate proposals.”
Note also this statement by APTA (page 8 of their comments): “The proposals for commuter rail platform accessibility would require significant practical, operational issues as well as greatly expanded costs. These issues are currently being reviewed in separate efforts undertaken by FTA and the Transportation Research Board. APTA urges DOT to refrain from integrating the proposals into 49 CFR Part 37 until there has been ample time for both DOT and the regulated community to review the results of these studies and access the impacts of the proposed rules.”
Amtrak and commuter rail have a long record of serving disabled passengers well, and have refined boarding techniques for disabled persons to minimize dwell time as a result of implementing ADA regulations. Passenger rail provides important services vital to those with physical disabilities, including those with wheelchairs, and—especially on Amtrak—those who must travel with bulky medical equipment. NARP is not aware of passengers who have been denied a train ride where a platform was 8” above the rail (ATR) rather than higher.