Note: The output shown below is from the Communication Access Realtime Translation (CART) 

system used in the Boarding and Alighting Subcommittee Meeting #2 and is generally unedited. 

The CART system was used to provide an accommodation to persons with hearing loss and persons 

who are deaf, and was streamed in real-time and available to the public on the internet during the 

meeting. 

UNITED STATES ACCESS BOARD

TELECONFERENCE

*ROUGH DRAFT*

Location: United States Access Board

1331 F Street, NW, Suite 1000

Washington, DC 20004

Thursday, May 22, 2014

Boarding and Alighting Subcommittee Meeting #2

Paul Beatty. 

>> Welcome to the second meeting of the Boarding Alighting Subcommittee. Just for your general 

knowledge, your next meeting will be June 25th which is a Wednesday. 

As Rose indicated, we're having some problems with the current CART link that's on the website. 

We will shortly send out a new link to your e-mail so those of you who want to use CART, hopefully 

you will receive it and use it. 
Second, I'm not sure whether this link is on the chat box and what degree we can monitor it, so I 

suggest we continue to use the procedure that if you're using CART only and you have a question or a 

statement to make and you need to break in, please send that statement to RVAAC at Access 

Board.gov. Lastly before we do introductions, because anybody who participated in this conference 

call, we do not have the time of public comment. So pass it on to Rose for introductions. 

>> Okay. So starting with the people on the teleconference call, I do see I have Sid Goldstein. 

Sid, are you there? 

Billy Altom. 

>> Present. 

>> Marilyn Golden? 

>> Here. 

>> Joshua Coran. 

>> Here. 

>> Crystal Lyons. 

>> I'm here. 

>> Michael Chisena? 

>> Here. 

>> Dick Cogswell. 

>> Here. 

>> Ed Hoff. 

>> Here. 

>> Linda Martin? 

>> Here. 

>> Blair Slaughter? 

>> Here. 

>> And Griselda? 

>> Here. 
>> Frank Maldari? 

>> I'm here. Thank you. 

>> Ken Shiotani? 

>> Here. 

Robert Adduci? 

>> Here. 

>> Marsha Mazz? 

>> Here. Sorry. Here. I was muted. 

>> Dennis Cannon? 

>> Here. 

>> Frank Mascarenhas? 

>> Here. 

>> And once again in the room is Lisa Fairhall, Melissa Anderson, Jim Pecht, Paul Beatty and our CART 

reporter is Sherry Knox. 

Paul? 

>> Okay. I'll pass it on to Melissa, and one of those things that I failed to do, indicate your name to 

show you're talking, so this is Paul Beatty turning it over to Melissa Anderson. 

>> This is Melissa Anderson. 

I guess the first thing we need to do is, I'm just going to start on the agenda and then I'm going to 

turn it over to Marilyn, but the approval of the agenda, Marilyn and I worked on this together. I

guess does anybody have any objections or concerns or editions to the agenda? 

Okay. We'll consider it approved and the discussion of subcommittee scope and objectives, I'm just 

going to take a second to remind everybody that we have a lot of items to cover and, again, we are all 

passionate about this issue, but we don't want to get too hung up on personal stories and talking 

about things that we really can't cover as part of the scope of this committee meeting. So there are 

a lot of simple things that we need to get started on and take care of and we're going to start today --

we're going to have a review of methods from federal railroad association of staff and then have 
further discussion on that and then we also have someone who wants to submit a comment on GAP 

mitigation materials. So, Marilyn, do you want to say anything before we let Linda start? 

>> No. 

No need. Thanks. Right over to Linda. 

>> All right. This is Linda Martin. I don't have a whole lot to say. I actually brought a couple of 

experts as I promised I would to talk a little bit about -- and this is unfortunately or fortunately, 

depending on what your perspective is, it will be rather inner city or commuter rail focus because this 

is FRA and we tend to deal in those areas, so it may or may not apply to other kinds of rail, but I 

wanted Mr. Cogswell to talk about the issues related to platforms and equipment height and gaps 

and all of that. And I won't talk too long because Dick probably will. So you go, Dick. 

( LAUGHTER ) 

>> This is Dick Cogswell. Are you trying to tell everybody something, Linda? 

( LAUGHTER ) 

>> No. We love you, Dick. Go ahead. 

>> Well, I guess I've been asked to sort of outline to everybody on the call the -- primarily the 

tolerances that are involved in a railroad system and how they can build up against you both vertically 

and horizontally when it comes to setting up standards for the vertical and horizontal gap between 

the virtual of a passenger car door and the platform that you want to get on to or off of and basically 

I'll sort of start by going back to a document that FRA put together and believe me this was, you 

know, I may have started it. There are about eight or 10 other people that have been put all over 

but it was ultimately put into the latest ADA or -- excuse me. DOT regulation which ultimately 

wound up being in .402 or something. And in that document we did discuss a number of things that 
get involved here. 

So let me sort of start off and just hit the highlights of things. 

First off one of the things that people don't really understand is that a railroad track is built on ballist 

and while it may look like it's rigid or firm when you stand there and look at it, if you have ever stood 

about a track with a train going by, you will see that the rails actually go up and down, typically down 

more than up and this is because the ballist, it has a certain amount of elasticity in it and when a car 

or a locomotive goes over it, it will in fact push the rail from its static position down into the ballist 

and ultimately down into the ground a little bit. 

For a heavy freight car, this might be in the order of a quarter of an inch to 3/8 in some cases. 

Similar for locomotives for passenger cars it's probably going to be a little less than that. But it will 

be occurring. 

So that's sort of the first thing you got to understand is that the rail doesn't stay where it is vertically 

while a train goes over it. 

Now, the next thing that comes in and this is primarily in the inner city world, but Amtrak and any 

other long-distance operators use what is called a multiwear wheel. Most people look at steel 

wheels and say, well, they're steel. Nothing happens. Wrong. 

Typical steel wheels and I'll apologize for the sirens that are going on pass my window as we speak, 

but wheels over a period of time have two things that go wrong with them typically. They will have 

what they call hallowed out tread. In other words, just simply running over track for hundreds of 

thousands of miles. You will tend to create a hallowed out tread condition. Probably more 

frequently you'll get what they call a high flange condition. In which case you either have to replace 

the wheel or as in a multiwear wheels where you actually get them brand-new with thick tread and 

you can run them over either a milling machine or a lay while it's still on the vehicle. 

And typically you may remove oh, 5/8 of an inch off of this very thick tread, but in effect as you do 

this three or four or five times, whatever it happens to be, you will be lowering the height of the 

passenger car floor. 

Now, typically a commuter car, since it -- I mean, a commuter car, if it averages fleet-wide average 
120 to 150 miles a day because they wind up going into the city in the morning, parking in a yard and 

then going back out in the evening, but commuter cars generally don't use a multiple wear wheel. 

They will use a single wear wheel because they just don't rack up the miles that subject them to the 

extreme wear like something like Amtrak does where there are a number of routes where Amtrak is 

running 12, 1500 miles a day or 10 times as many or more than the commuter agencies. 

So as these wheels wear and they have to be re-machined in the Amtrak world, there is no vertical 

adjustment in the system. It simply means the floor is going to go down some. 

You will also have in a passenger car a certain amount of what we call permanent sat that occurs in 

the spring suspension system so that hypothetically and I would have to double check my numbers 

here, but if you have got a spring that is brand-new that is like eight inches high, after it has been out 

there on the railroad and running for a couple of years, if you took it out of its, you know, out of the 

container that it's in, it would no longer be eight inches high. It may be 7 and 3 quarters. It would 

become less than when it is new. 

So you got a certain amount of that permanent set in the signal -- suspension system. 

You also got center plate wear and this is where the track that holds the wheel's axle assembly meets 

the car body itself. This again has a certain amount of wear that is allowed before you have to do 

something seriously to things. 

Also the high-frequency oscillations that may occur. Again, some of these things don't work as 

they're supposed to all of the time. 

So in the vehicle side that and what we put in the NPRM, we call that basically a half inch total. The 

multiple wear wheel tread removal was two and a half so now we're up to three inches total. We 

then get into platform construction tolerance. And here again you may look at a platform and it 

may look like it's straight and leveled. But reality says it's not, that the folks doing the construction 

and/or given amount of settlement that may occur over a period of time, we threw in a half inch as 

being not something that was really out of line, but it's there and needs to be accounted for. 

And then going back to the track itself, there is a certain amount of re-alignment or wear and tear 

vertically on the track, and there are certainly FRA regulations and there are in place that limit the 
amount of vertical variations that you can have depending on how fast you want to go. 

So if you hypothetically wanted to do 150 miles an hour and you were operating on class 8 track or 

something, that may be very, very small. But at the same time the vast majority of the rail lines 

throughout the country are nowhere near class 8. They may be class 4 or 3 or in some cases 2. 

And the lower you go class-wise, the greater the vertical variation is allowed. 

So what we came up with and was put in the NPRM basically says the vertical variations between the 

passenger car floor height in inner city service and a platform could be as much as 5.5 inches. Could 

reasonably as much as 5.5 inches. Hopefully it would be less than that. But in any case, it's going 

to be dramatically above what has been in the regs for level boarding of 5/8 of an inch plus minus. 

There's no way you can live with that. So vertically that's sort of the summary of various 

components that make up in the real railroad world the vertical differences between platforms and 

floor height of cars. 

Let me stop there and open up for any questions that I may answer on the vertical stuff. 

Silence. 

>> This is Dennis Cannon. Let me jump in here. 

Can everybody hear me, by the way? 

>> Yes, sir. 

>> Yes. 

>> Okay. 

Because I'm having trouble with my Skype connection here. Anyway, let me explain a little bit about 

where the old reg came from and how it was derived. First of all, when we wrote it we really were 

talking -- we were using the ADAAG as a model, and so to some extent we used the kind of format 

that's found in building codes, and so that's been a source of kind of confusion for people who are in 

the rail business and are not necessarily building code people. 

In building code you typically -- or may have a specification for a maximum or a minimum and then 
there is an exception that says when you can't do it, do this. 

In writing the new proposed -- anyway, people were looking at the old reg that says max 4 inch 

horizontal max plus or minus 5/8 inch vertical and kind of tore their hair out and said oh, my God, 

there's no way we can do all that. It's impossible. 

When writing the proposed rule for the updates for the buses where we were also talking about 

possible level boarding buses in bus rapid transit, we changed the approach. The approach is simply 

saying instead of setting a maximum that nobody can really achieve, what we said was when the 

vertical display a difference between the floor and the platform is X, you will have to ameliorate it 

with a bridge plate for example. 

When the horizontal distance is greater than Y, you will have to ameliorate it with a bridge plate. 

So it takes away the requirement that says you have to meet this kind of standard which may not be 

practical and instead says we don't really care what the displacement is, either horizontally or 

vertically. But assumes it reaches some number greater than some other number, you have to put 

in a bridge plate and that takes away this kind of hair-tearing idea of saying, oh, my God, we have a 

maximum requirement for a 4-inch horizontal gap which we could never make. So it essentially 

eliminates that part of the problem and as I recommended in one of the other subcommittee

meetings or maybe it was the full meeting the other day, is that that's the approach we should take 

with rail instead of trying to set these sort of artificial numbers for minimum and maximum. We can 

simply say if it's greater than this, you have to go at something like the bridge plate. 

Or in some cases if the displacement is very large like for example an 8-inch or 42-inch car floor, then 

you may have to have something like a setback platform or even a car boarding ramp. But anyway, 

it gets away from this issue of trying to specify an unrealistic number that says maximum horizontal 

gap maximum vertical displacement. 

>> This is Ken Shiotani. I have a question, Dick, that you may not be able to respond to because it's 

more in the realm of light rail and streetcars and subways. But they don't -- they tend not to use 

ballist or the places where they run where they don't use ballist, so a lot of the tolerances issues in 
terms of vertical are much different in light rail and streetcar and subway? 

>> Yes, I would say they are if the rails are direct fixation on, you know, concrete slab or something 

like that. There are in some terminals around the world, in the rail passenger world places where 

they have also done that. But it is such a very, very small percentage of the total passenger 

platform vehicle interface locations that it really is not something that we generally discuss because, 

yes, if you do that, a number of these things do in fact get pretty close to zero. But at the same time 

you do have -- as I indicated, the wheel wear issues, the permanent set in the suspension systems and 

things like that, which are still not trivial. 

>> And, Dick, this is Linda Martin. 

What about -- are there certain rail cars that you know -- I mean, I'm talking about subway-type cars 

that have suspension which are adjustable. I sometimes see Metro doing that. 

>> I am really not that conversant with light rail, Metro system. They may -- question mark -- have 

some kind of system so that they can adjust things. Some people have suggested the air suspension 

bags on the inner city service could if re-designed serve similar purposes. But then you get into the 

question of what happens when something goes wrong and the air suspension system fails on a 

particular car. And it can be more than just a rough riding car. Then you have got things that in 

fact I did not even put in here as a realistic happening, but it can and does occur. 

>> Hi. This is Frank Maldari and I just wanted to supplement some of the things that Dick was 

outlining. In the east here, we typically use a multiwear wheels and it's usually around two inches 

radius, 4 inches in diameter of wheel wear available. And one of the other reasons while there 

might be wheel trueing in addition to what Dick mentioned is flat spots. 

We have pretty aggressive breaking rates in this area when it gets slippery out and the wheels tend to 

skid a little bit. So majority of our wheel trueing is usually for flat spots more than anything else, so 
that accelerates the wear of the wheels. 

As far as the suspension system goes, and the commuter rail in our area here it's typically, you have a 

primary suspension system which is the springs as Dick was outlining before that sag and a secondary 

is typically the air suspension which provides for a really good ride. 

The air suspension does compensate for passenger load. But it does not compensate for the 

primary suspension. 

The two suspension systems are in series and you can compensate for passenger load with the air 

springs but you can't adjust the primary suspension for passenger load or for, you know, anything 

else for that matter. 

>> Thank you. 

>> Okay. Do we want to move on to I guess Melissa and Access Board folks, I mean, are we okay on 

time? 

Can we get Dick to do the horizontal issue piece or -- as in the gap issue? 

>> Sure. Yeah, Marilyn, unless you have something else, I think that would be fine. 

This is Melissa. 

>> Okay. Well, I will proceed then in a similar fashion to discuss the horizontal gaps between again 

the threshold of the door and the edge of the platform. 

First off, everybody needs to understand that where you have shared track age with freight service, 

the width of plate -- they're called plates in the freight world, but the width of a freight car from track 

center line is up to a certain length, it's five feet and eight inches wide. Excuse me. 

10 feet 8 inches total. 5 feet 4 inches from track center line. 
Okay. 

As the length of a car, whether it's freight or passenger increases, the width of the vehicle is required 

by industry standards to decrease so that for the last century or so the width of a passenger car has 

wound up being a total of 10 feet or basically five feet from track center line. 

This means that to start, you're going to have a 4-inch difference between a freight car and a 

passenger car going past a platform. 

Then you get in to the track gauge limits and again in the FRA office of safety world, it varies because 

it depends on whether or not you're trying to go 200 miles an hour on class 9 track or wobbling down 

the track at 15 miles an hour on class 1. But we picked class 4, and there they give it as a deviation 

from a few straightness. But sometimes it may go against the platform or it may go the other way. 

And we threw in collectively an inch and a half for that kind of variation. You have also got flange 

wear. The flange of these steel wheels as I said, they wear not only vertically but also horizontally. 

So as the flange wears typically going through curves ultimately reaches the point where there are 

industry standards that say get that wheel out of service until you re-true it or replace it. 

We wound up putting in three quarters of an inch total for that. That may be a whisker on the high 

side, but that's what everybody agreed to. 

Another thing that comes in, and people don't really think about this frequently, but when you go to 

mount a steel wheel on a steel axle, it's what they call a class 5 interference fit. It means that the 

axle is bigger than the hole in the wheel, and you wind up putting it on a wheel press where it takes in 

the vicinity of 100 to 110 tons to push the wheel on to the axle. 

There is certainly a tolerance that you have to have in that process because it's impossible when 

you're dealing with these kinds of pressures to stop the mounting press exactly precisely where it 

should. 

So we have axle mounting something like 3/8 of an inch total variation. 

Also in the truck suspension system, in the center plates wear and tear horizontally, we had half inch 

total there between a like-new condition right out of the plant and what it would be when you wind 

up having to condemn things and throw it to the steel scrapping. 
We then had a tolerance in here for construction of the platform itself and, again, going back to my 

previous discussion, even though it may look straight, it is not perfectly straight. So we threw in a 

half -- excuse me. A quarter of an inch for that kind of deviation as you have this long platform. 

The track alignment as well as the track gauge, the track gauge as I said we came up with an inch and 

a half. Again, wear and tear, which class are we dealing with. If it's, you know, class 2 or 3, there's 

lots of slop in this also. When all was said and done, everything was sort of static. A passenger car 

stopping at a platform could wind up with a passenger gap of 6 and 3/8 of an inch which is way 

beyond what anybody has ever discussed for having someone in a wheelchair unassisted cross. 

We also get into passenger car roll angle because if a train is going past a platform, but not stopping, 

you have to allow for dynamic things occurring between the train and the platform. So we used --

we have historically used a little over 7-degree roll on a passenger car, especially if it's lower-class 

track, and that can cause the threshold of the door to move closer to the platform or further away 

from it. 

The closer version is what's causing us troubles. So that would -- and that can be serious. I mean, 

that can be as much as -- a little over six inches that it can under certain circumstances move the car 

door towards the platform. 

We thus wind up with just over a foot that can exist between the threshold of the car and the 

platform face. 

Does it occur frequently? 

No. Does it occur? 

Yes. Because we have seen the scratches on the face of the platform. 

So that, you know, it is sort of a summary of the horizontal and again to elaborate on what Dennis 

was saying, this gets back where -- and I know he and I and a few others had a conversation years 

back when he was with the Access Board right after the regs were issued, again, in the real world of 

railway passenger service, you're going to live with a bridge plate whether you like it or not, even if it 

is quote level boarding, end quote. 
So at that point again I'll open it up to questions, comments, what have you. 

>> You have sung them to silence, Dick. 

>> Sorry about that. 

>> No. 

>> This is Melissa. 

How much of this could reasonably be mitigated with better maintenance? 

More frequent maintenance? 

>> Well, that's an interesting question because it becomes a question of what class -- what FRA class 

and RVAAC and stuff like that this you want to get to. What we did when we did this analysis was 

use class 4 which is basically good for 79 miles an hour, and that's why also we said we're never going 

to get to 12.5 because by then you have got more problems than you want to accept. 

But it's more than most people want to discuss and it will not get you anywhere near the 3-inch 

maximum that was in -- that is still is in the reg. You can't do it. 

It's -- as I said, when you start out in the freight world with a freight car being four inches wider on 

each side than a passenger car, you're automatically into things that you -- you just can't get 

anywhere near the three inches as far as I can see ever. 

Now, if it were hypothetically a station that had no freight there, you never had reason for either a 

freight locomotive or a freight car to ever be there, you might tighten things up a little bit, but, again, 

I've seen too many situations where it just isn't what it's supposed to be. 

>> This is Ed Hoff, New Jersey Transit. Dick, I appreciate your presentation. It was very thorough. 

I agree absolutely with the latest -- the summary portion of your presentation that in all likelihood --

in fact, it's virtually impossible to provide level boarding without providing some form of gap plate or 

bridge plate as we call them here in New Jersey Transit to bridge that not just horizontal, but vertical 
gaps for the same reasons you cited earlier about how rail is laid down and how it's maintained. 

You will always maintain a vertical gap that's going to be an access of something that is tolerable of 

somebody who is going to use a mobility device mostly because of the mobility of the rail but also 

that you want to provide in most cases a rail car that is above the boarding platform because of

boarding and alighting alone as pedestrians cross into a vehicle, you want to step up into the vehicle 

in most cases. Not a huge step. But you certainly don't want to step down into the vehicle that 

has limited head clearance. 

So for those reasons alone, we're going to have a vertical component of the gap. We're also going 

to have a horizontal component of the gap that is going to be more than is going to be tolerable than 

something using a mobility device in most cases whether it be powered, manual or otherwise. 

So what I think we should concentrate on is if we do provide level boarding, we have in New Jersey 

Transit, Long Island railroad does the same and many parts around the country, how do we best 

mitigate that? 

Do we use on board bridge devices? 

We should talk a little bit about on board versus station base and the advantages of both those and 

perhaps even mechanizing sub bridge plates. As the report shows, that was in the attachment to 

everyone that there is quite a bit of information out there about movable platforms and different 

types of devices and we should get into those. So these are basically where there is level boarding, 

we certainly need to still minimize or eliminate that gap. 

>> That's a perfect segway into Robert Adduci's conversation if that's okay. Robert is in our safety 

office and deals with passenger station issues and the FRA issue, the gap mitigation guide in 2007 and 

Robert is going to talk just a little bit about that. We sent it around. It may have some useful 

information for the subcommittee to use as it decides --

>> This is Ken. Just before we switch into him, I just want to make clear -- I just want to make sure 

that people understand that this is -- that some sort of gap mitigation is probably inevitable for rail 

and commuter rail. But that is not necessarily the case for light rail, streetcar and subway-type cars. 
Is that correct? 

>> I don't think that's completely true. I think it's just going to be different. I know you all ride on 

the Metro around here and even on the Metro they have rubber pieces that maybe the gaps smaller 

for wheelchairs to roll over. So I think even in closed subway-type systems you're going to have 

issues with wheelchair wheels which is why what Dennis said is really important, that you might set 

minimums, but then you figure out how to, you know, bridge them if you can't meet them. 

>> This is Ed Hoff again. We operate two -- actually three light rail systems in New Jersey. Two of 

them use the same vehicle and we have direct fixation in many of those stations with the one type of 

vehicle which -- also, another one where we don't have direct fixation we are able to maintain a gap 

very small. In fact, it does not require a bridge plate. But it's the nature of the light rail. It is -- it 

doesn't wear on the -- all the wearing parts are a lot less than the commuter rail obviously being 

lighter than a commute car. Lots of other factors go away and certainly it's not a conclusion that 

either way that you're going to need bridge plates or not going to need bridge plates. But certainly 

we have been able to provide such close tolerances that a bridge plate is unnecessary in all three 

systems. 

>> This is Linda Martin again. But is there nothing on the edge of the car itself that makes either the 

edge beveled and/or brings the car closer to the platform? 

>> This is a part of the car that I assume it was designed to -- I don't know whether it protrudes out 

from the door because the doors are on ours so when the doors are shut, you don't see any 

protrusion, but when the door opens up because there is a gap at that point, that does appear to be 

protruding from the side of the car. 

>> Okay. 

>> One last thing, Linda. This is Dick again. 

And the previous gentleman just jogged my brain. Everything I've been discussing assumes that the 

threshold of the door is even with or slightly outside of the car body cross section itself. 
There are manufacturers that wind up building the threshold of the door in some cases 8 to 10 inches 

inside the outer body cross section and that just adds another 8 to 10 inches to a gap and it becomes 

virtually impossible at that point to have level boarding even for fully ambulatory people because 

they would with practicing their Olympic broad jump every time they get on or off a car. 

>> This is Frank. I want to jump in real quick before Dick leaves us. All those dimensions that you 

were giving out, I didn't see them in the document that Melissa sent. Are they available 

somewhere? 

>> There was a dozen pages plus minus that was in the original NPRM from what, '06 when DOT first 

initiated their rulemaking and I won't get into why it took five years to get it out. But that was in the 

docket at that time. 

>> This is Linda Martin again. It's probably still there. But I'll see if I can track it, track it down. 

It's certainly a public document. 

>> Well, it would be nice for everybody to have to see at the meeting. I mean, he went through a 

very good explanation of where the numbers came from and it's good information to have. 

>> This is Michael Chisena. Can I be heard? 

Mr. Cogswell, the one foot that you came up with, I'm trying to understand, is that like a clearance, 

safe clearance distance between the face of the platform and threshold plate when a car goes 

through a station but doesn't stop? 

>> It is sort of the maximum dimension that we came up with that a passenger car, again, operating 

on something other than high-quality track could reasonably have as a safety clearance-type thing 

where you would not scratch the side of the platform. Reality is that you can probably do 

somewhat less than that. But certainly up and down the northeast corridor, we have been using for 

literally a century because both Penn Station New York, Grand Station New York were built a century 

ago and there they have located the platforms at 5 feet 7 inches off of track center line. So that 
means that you're starting with a 7-inch gap if everything else is perfectly centered. If it's not, you 

get up into 8, 9 inches of horizontal gap with reasonable frequency >> So from the perspective of -- so 

you're with the FRA, Mr. Cogswell? 

>> Yes. 

>> So what is the FRA's recommendation if the train goes at maximum speed but doesn't stop at the 

station? 

Are you saying it's somewhere between 7 inches to a foot? 

>> We're saying, and we had our input into what is now part 37.42, it's either E or F, I have forgotten 

which that says that the maximum gap for level boarding on tangent track is allowed to get to as 

much as 10 inches maximum and 13-inch maximum on slight curves. I have not discussed curves 

because there you get into overhang of passenger car as well as super elevation of track and in the 

internal caucusing we agreed that we would allow a little bit more for curves, but very quickly 

something has to change dramatically if you're going beyond mile curves. We have normally cut off 

any level boarding at I believe it's 1 degree 40-minute curve as appropriately adjusted for any super 

elevation. 

We did go I believe it was Metro Park, New Jersey where they already had high platforms. That was 

class 6 or 7 track. I have forgotten which. And we actually replaced the platform with a new 

platform. I think it was two degrees, four minutes or something like that. But certainly you get 

above that and the gap just is too much for a normal person to go across, much less anybody in a 

wheelchair or a walker. 

>> So from the safety perspective for the challenged or the disabled, what should the minimum gap 

be for the train to pass through the station as high or authorized speed, what should it be? 

>> Well, again, what we have been doing in the northeast has a nominal 7-inch gap. 
>> Okay. So that's the minimum. 7 inches --

>> That is typically what you will see and we know freight goes by it -- I mean, heck I in my career 

here uncounted times, platforms anywhere between here and Boston with freight trains rumbling 

past me. They do it, we have got what, 65, 70 freights a day on the northeast corridor now. Every 

now and then they do scrape. I don't question that. 

>> So anything less than 7 inches is not really safe? 

>> You get under 7 and they start getting dicey if you have got freight there or if you have got 

locomotives which are built to freight standards. In some of the -- you get into which builder is 

doing what, but some of the -- especially the diesel locomotives that are used on commuter trains, 

they may in fact be built to freight standards which is basically the same as a freight car. 

>> Got it. Thank you very much. 

>> Do we want to just have Robert talk about the gap guide or should we --

>> That's fine unless, Marilyn, you want to do something different. 

Go ahead, Robert. 

>> Okay. 

>> Robert again is with our office of safety and he's going to talk about a guide on how we developed 

to help manage gap and passenger platforms. 

>> Yeah. Back in 2007 we came up with a guide and some of the folks in the room, Frank, and some 

other folks I think helped input some of this. 

But I think when you listen to what Dick had to say and everybody else, you really have to look at this 

as a system. This is a system which include the track, infrastructure, platforms, vehicles and all of 

the subsystems that are in the vehicles, wheels, suspension systems and so forth. So when you look 

at this, it's not an easy situation. First of all, you have to look at some of the systems that are in 
place right now. I've been here for a long time and we have a lot of concaved platforms and convex 

platforms which create a whole issue of platform gap, width, and so forth. And one of the things that 

we have done as far as new starts that's gone out and work with railroad and say don't build 

platforms on curves because you create an issue with gap when you're building them on curves and 

again one of the other things we looked at, Dick talked about a lot of numbers and all, but, you know, 

one size doesn't fit all. So one of the things we tried to come up with, we tried to come up with the 

platform gap and suggest to the railroads use the hazard management process to develop gap 

management plans within their railroad. Things they could talk about maintenance, wheel wear, 

suspension systems and other things. But it allows the railroads to each look at their systems and 

use this hazard management process to control the gap. And some of the railroadsed that gaps that 

were like 12 inches. Nothing they could do to reduce that gap. So some of the rails said, hey, 

we're not going to open doors in this area where the train is backed up because the gap is just too 

big. So we suggested that the railroads use this process to identify hazards and then look 

at mitigation and then we have to have a program every six months and then we look at the tracks or 

whatever. And again, I guess the best thing to say is, again, use this hazard management process 

and I think Frank if some of his other people have used this process to go out and develop their gap 

management programs to look at this and it seems to have helped and allowed the railroads to 

control it. But, again, no size doesn't fit all. There's no magic number or anything else but we 

suggest to the railroads you have to look at what's practical that works within your railroad. Some 

have freight, some don't, whatever. So this hazard management process is a tool and if you look at 

the guide that was sent out, it goes through this whole process of helping railroads identify the 

hazards and come up with some mitigations and the mitigations may be, hey, we have to use bridge 

plates or we won't open doors on certain platforms because of the shape of it. So, again, that's kind 

of a quick overview of what the document does and says and how the railroads are utilizing it to help 

control the gap, let's put it that way. It's never going to go away. But at least it's going to help 

them control them and develop mitigations. 
>> Thanks, Robert. 

>> Any questions? 

>> This is Ben Skin. You're referring to the document which was attached, right? 

It's called -- what it's it called? 

FRA approach to gaps... 

>> Approach to managing the gaps. 

(Dog barking) 

>> The dog liked your presentation as well. 

( LAUGHTER ) 

>> This is Chris Hart. I've been working for quite some time and I heard it said up here in Boston 

that having rail gaps we now do quarterly survey of all our gaps at all our heavy rail stations. The 

number one thing that we have realized very early on was when you maintain a lower level and once 

we begin to put that out in terms of what our expectations were on that track, we begin to noticeably 

make headway about reducing vertical 8 horizontal gaps. 

And I just want folks to be aware that several times it is a -- of how you maintain the track. 

>> You know, and I think part of this who process of managing the gap too is you're looking at a 

system and it involves boarding and alighting and, you know, a lot of the railroads have 

announcements, you know, watch the gap and so forth, and it include training of opening and closing 

doors so the train crews are looking -- you know when they open and close doors and so forth. And 

I think FRA is in the process of issueing an NPRM on the door regulations on door operations and so 

forth so that in case anything does go wrong, at least we're not going to trap people in between the 

car and platforms. 

So a lot of that, you know, we're looking at this in a lot of different ways but I think again we have to 
look at it as a system because that's how the whole thing works and you just can't focus on one thing 

and I don't think we will ever eliminate the gaps but I think we can come up with some solutions to 

mitigate them and make it so that people can then negotiate them safely. 

>> This is Robert Carlson. 

I've come across an article in the BPC news about the cars they had built that were too wide for the 

platforms in the stations and they had to order 2,000 of these cars and trains and now are back to 

actually retrofitting all the platforms to fit the new trains because of the cost that they put into 

buying those trains, so technically they had a negative platform gap and, you know, I don't know why 

or how they came about ordering these trains wrong, but someone wasn't consider the fact that the 

track gauge to the platform was a bit smaller. 

>> This is Frank. As Bob was saying about managing the gap and it not being a one-size-fits all. I

mean, that's exactly what we found -- you know, we worked with the FRA back when they were 

developing that program and the hazard analysis is really what gave us the guidance and the 

directions to go with the signage, with, you know, trying to reduce the gap in any areas that was 

possible and the whole thing you're hearing today should be an understanding that minimizing the 

gap vertical and horizontal is good for everybody and we are trying to do the best that we can in 

doing that, but there are limitations and, you know, as Dick pointed out, I mean, no matter -- you 

know, what you have on a particular day, it may change on another day with a different train when 

it's different wear on the rail. So we're stuck putting these bridge plates on because you want to 

make sure the person can always get on the train regardless of what particular train they're taking 

and what particular day and what kind of maintenance was done just recently. From my point of 

view, I work in the equipment department, it was an eye-opening experience to see that the difficulty 

that the track department does have in just getting track time. To do the maintenance that they 

have to do to maintain the class standards specified by the FRA and then go go further to try to 

minimize the gap at the station platforms is not as easy as you might think. It's not a matter of 

doing more maintenance. It's possible delaying training and cutting back on service. A lot of the 
lines are used to a maximum capacity and when you have to have time to get in there to do 

maintenance, you're cutting somebody out. You may cause delays or reducing service. But there's 

certainly a service impact with trying to do more maintenance than you already are on the track. 

>> When you're adding direct fixation track, it may be more complex as to what you can or what you 

cannot do. 

>> I think we have usurped enough of the meaning FRA. This is Linda Martin again and we want to 

turn it over to Marilyn or Melissa and the next agenda item. 

>> What was that, Linda? 

>> I just say I think we have usurped enough of the time, FRA, and we'll turn it back over to Marilyn or 

you or whoever's got the next agenda item. 

>> Thank you. We appreciate you guys having providing us with so much information. It's really 

good information to have and we're glad you're on the committee to help us out. 

We have a gentleman who wants to speak about gap mitigation material. Michael, are you on the 

call with us? 

>> Yes, I am. 

>> Okay. Do you want to go ahead? 

>> Yes. Thank you. 

Madam chair, I have a question, please. As I said before, I'm not a member of government or with 

the industry. 

The recommendations that the subcommittee is charged with coming up with with a standard, is that 

standard to include the ability of those who are challenged and disabled to have access to all doors of 

all accessible cause to a station that a person who is not challenged or disabled can board and alight 
the train from? 

Is that a charge that a committee --

>> That's the intent is that we provide equal access for everyone. 

>> And equal access -- I'm trying to understand, does that mean every car door of every train car that 

a person who's not challenged or disabled can exit and enter? 

>> This is Dennis Cannon. Let me play out that in the current regulation that -- for inner city rail 

guards for example, Amtrak, what it requires is that there is at least one door on each side of the car 

from which passengers board that is available to a -- that is accessible, and the reason for that is there 

is no requirement -- so you get in the doorway on one end of a car for example. At that end is an 

accessible restroom and at that end is also a space for wheels to sit. There is currently no 

requirement to have the aisle of the car wide enough that you would be able to go down the car and 

go down to the other end of the car and get out that door. 

So in the current regulation the only requirement is that there's one door on each side of the 

passenger door that is as close as practicable to the space where wheelchairs are to sit inside the car, 

and the accessible restroom. That is not the case as something like a Rapid Rail system and also an

inner city rail like Amtrak, typically not all the doors open at one time. They're opened by a 

conductor and it's quite frequent that conductors will open only a handful of doors to let people out. 

With Rapid Rail like the Metro system, all of the doors are accessible at that point. But that's not 

true of inner city and not necessarily commuter rails whereas for example if you have a bi-level car or 

a tri-level, actually the mid level, accessible entrance to one at the end where the accessible restroom

is locate and that may not be -- you cannot necessarily get to the other end of the car. The double 

deck cars in the Amtrak system for example, the connection from one car to another is on the upper 

level and apparently there's no requirement for any vertical access. So you get in on one door of 

the car that you're on for the compartment and that's the door exit. 

>> And is that applicable for commuter rail also or the commuter rail is every door? 
>> It would depend on the design of the car. Some of many of the commuter rail systems are very 

similar to rapid rail. I think New Jersey -- or at least some of them you basically enter virtually any 

door and there's maybe three doors on a car. There are other commuter rail systems where they're 

very much like the inner city rail car for example where you would only have a door on the other end 

of the car and that's accessible. 

>> So the bottom line is --

>> This is Marilyn. I just wanted to jump in to perhaps clarify that Dennis was talking -- Dennis, as 

you said, you're talking about the current requirements what they are. You're answering Michael's 

question from the perspective of the current requirement, but that doesn't mean it's necessarily the 

case of what the suggestions for requirements out of this subcommittee or the full committee will be. 

>> Correct. 

>> And the current requirements just in conclusion on this point is there has to be at least one door 

for every car that stops at a station that's accessible to those who are not challenged or disabled, 

right? 

>> Well, for adversity -- you would not have a subway station only one door unless it says so for 

obvious reasons or are involved and it's possible and the way you do that is you --

>> There can't ever be a situation where any proposed guideline would be that a person who is 

challenged or disabled would have to use only one particular car of a train stopping at a station, am I 

right? 

>> No. 

That would be -- that would not at all apply. 

>> Okay. So --

>> And, in fact, as Marilyn and Dennis can speak to the regulation was written, no transportation 

would put all of the accessible seats in only one car for that reason because there was a mentality in 
the 1980s that we would essentially build a car and put all of those -- build a challenged car and put Al 

of those quote, unquote people into that car. 

>> Got it. Amtrak gap elimination plan that was discussed on April 10th which I pulled down off the 

net, that seemed to have a situation and correct me if I'm wrong, whereby the disabled would be 

focused to utilize in the getting on and getting off one particular car or two of the transit and I said to 

myself, how can that be? 

>> No, there is an assumption by Amtrak that they would be boarding everyone at that platform. 

And would be doing a double shot as we --

>> This is Linda Martin at FRA. Just to be clear, while every car should have an accessible spot and 

there should be an accessible door to that spot, it doesn't mean that necessarily every door the car 

will be opened at every stop. So what we said is that the cars that are accessible to other individuals 

should be accessible for a person, you know, using a wheelchair and needing boarding assistance. 

But we have also said in a more recent rulemaking, you know, cars that are -- a person shouldn't be 

forced on to one car of the train except for if they're only opening that particular car and that 

particular car then that's probably where they're going to end up. So having each car accessible and 

having each door accessible doesn't necessarily mean that it will be open and that people will use 

that. 

>> Just to clarify unlike a lot of the regional transportation authorities we operate little bit of -- not a 

little bit of everything, but a variation of things and to give you an example a train leaving New York 

going to Florida -- sorry. A train leaving New York going to lynchburg, Virginia is going to go through 

high level and low level platform areas. When it's typically in a high-level platform, when it's the 

right kind of equipment it may open all of its doors because of the nature of the high-level platform. 

All doors are open, people go on, people come off. But when it's in low-level territory, we can only 

open doors where there is a crew member to assist people safely on and off the train. 

And with the gap mitigation device that actually better in our more rural stations because we don't 

have platform lengths that allow us to open up as many doors as we have connectors. So it actually 
is a real benefit all the way around because you're not just boarding folks who may be using 

wheelchairs but everyone else is as well and they're able to get on the train much faster going across 

with the gap mitigation dedevice than they are climbing the steps. So there may be areas where 

you would put multiple of these things but it would replicate what we have today where there is a car 

attendant or there would be a door open. 

>> How can a person who's challenged or disabled would board using one of your platforms that do 

come out to meet the train. When they get off the train, do not they have then use the particular 

car door that mentions up with the platform that moves out to the train car doorway? 

And isn't that against the rules? 

Because you're cattleing them, forcing them to use a particular car. Whereas other who is are not 

challenged and disabled can get off at an Amtrak station which is not adjacent to your move-out 

platform. 

>> Well, in that case the doors that open at that particular station are going to be the door where is 

that person is. I mean, that's just a matter of positioning the train when it comes in. The crew is 

aware of the folks getting off the train and how they need to position it. And if they need to make 

multiple stops -- well, let me back up and say that on our long-distance trains unlike trains that run on 

the corridor, we're very much concerned about where everyone is in the train. 

So a train going let's say to Lynchburg or to Charlotte, people are boarded in that train typically by 

where they're getting off the train. So you may have 100 people get on in Wilmington, Delaware 

and they're getting on in multiple spots because they're going to multiple places and so the train 

that's going to Salisbury, North Carolina is going to stop its car, its doors where the people from 

Salisbury are. So that is -- it's the same for everyone regardless of where they got on the train. 

>> This is Marsha Mazz, U.S. Access Board. I understand that the speaker has some 

recommendations regarding gap filler material. I don't know how productive it is for us to use the 

time we have here to debate the facts. I mean, the rule is what it is at this point in time. It can 

potentially change. But did you have some comments you wanted to make about gap mitigation 

and the rails used, was that my understanding? 
Am I right about that? 

>> Yes. I had one other comment about the Amtrak from which you allowed me to do that. I

appreciate the ability to allow me the questions of Mr. Cogswell. But I'm asking the subcommittee 

on the basic point because I had addressed the committee in writing in January and also in February 

at your meetings. My point is should not the subcommittee be looking for a gap mitigation device 

from the gap width perspective which addresses all possibilities, all gap distances between car door 

and platform, regardless of where the particular train may stop at the platform? 

Everyone recognizes that gap widths are different and they vary station to station. Am I correct? 

And we have to look for a solution which addresses all possible gap widths that each train car and the 

train set may come to. Movable platforms I don't think are the answer. I think the answer is a 

device that is attached to the car itself which is activated by a computer at each particular station and 

it addresses the particular width necessary to be mitigated at each doorway for each car door that is 

opened. That is the only system that would work to allow the disabled and the challenged across 

that gap. 

From what Mr. Cogswell said, you need 7 inches, let's say for a foot that are that safety clearance 

matter and I know that in the -- how do you address that? 

You address it by an onboard device that is computer operated such as the device of my invention. 

I'm not trying to sell something. I sent this out in writing to the committee, subcommittee in 

January. I spoke about it several months ago and I address it again and I urge the committee if it has 

the power to make a recommendation to full committee for research and development funds to be 

used I think the necessity for research is paramount to develop the device of my invention because of 

the fact that it can address every particular gap width mitigation issue that can come up regardless of 

the kind of rail system that we're involved with. 

The 3-inch rule that is now in place is not insurmountable. It is not insurmountable even given the 

facts that Mr. Cogswell has set forth both prior to the NPRM which came to a final rule a couple of 

years ago. You have to have a system that is variable and that can meet all the needs and I beseech 
the subcommittee to take a look at the patents which I presented to the committee in writing. They 

were on the net. Michael Chisena. They're on the net. Please look at them and if it is in the 

power of the subcommittee to research the development by FDA and FRA, I think they should be 

looked at. Bridge plates are not the answer. If they were the answer, members of the 

subcommittee, then we would not have the issues that we have today. Bridge plates have been 

around for years. If that was the solution, you would not have the issue of gap widths still 

perplexing the rail industry and government and it would not be beyond each of the indexes for 

agenda discussion. Please --

>> Excuse me, Mr. Chisena, is that Michael, right? 

This is Marilyn Golden and I want to thank you for your comments. Everyone as we said earlier can 

participate and you have done so several times and we appreciate your contribution. I also want to 

try to head off a further prolongation of any kind of debate or discussion about you may not think 

there is a role for bridge plates, other people may think there is. 

But this committee is in essence working from an assumption that's been presented about bridge 

plates and I don't think it's -- I don't want to take the rest of our small time that we have left to 

debate that. 

I also want to thank you for your recommendations about research and bringing your invention to our 

attention. But that we can't make it a further major focus of what we're doing today. So thank 

you. 

Melissa, in terms of the agenda, I mean, we had intended to sort of go over all of the boarding 

alighting efforts but we focused so much on gap that maybe we should just go right to 5. Your 

thought? 

Given a half hour left. 

>> Well, I think the half hour that we have left might be just enough time to -- because going through 

the pictures and talking about the different methods may be a good way to fill -- because we're not 

going to really accomplish something concrete but this will give everybody a good idea. 

>> Okay. That's a good point. 
Okay. This is Marilyn. 

Sort of shifting gears a bit, we had wanted to look at -- for the purposes of getting everybody on the 

same page, we had wanted to look at the different methods of boarding and alighting trains and 

discuss their advantages and disadvantages so that we have a better sense of where to head next in 

terms of the work we need to do to develop recommendations back to the full committee. 

There needs to be a -- I wanted a -- the staff warned me and I agree with them that I want to clarify 

clearly that just for this short of short discussion, we're going to be talking about things that really as 

a subcommittee or really the full committee have no authority to recommend changes on because 

we're talking about train cars. That's our assignment on RVAAC, but just to understand the 

approach, we need to for discussion purposes only widen our gauge and look at the platform even 

though we can't specify or recommend anything about the platform. So with that as a frame work, 

we tried to list and it's on your agenda, the basic five methods for boarding. Roughly in order and 

here I'm in some degree taking off my chairperson hat and putting on my participant hat, roughly in 

order of preference to the disability community and they as far as I know are -- and has done good 

job in developing photos for them which we can go over in a moment. The first one is pull platform 

level boarding which I think everybody agrees the best solution for accessibility but it's got many 

other benefits in terms of rapid boarding and alighting of all passengers and Chris had mentioned 

some other benefits earlier that are very important. There are times when full platform level 

boarding won't be required. We know that from the 2011 DOT regulation. 

And the next most accessible method appears to be the large platforms that are in development and 

that are put in and I'm trying to see if we -- I mean, we may not have been able to get a photo of 

them. 

>> We don't have a picture of the set-back platforms from Detroit. 

>> Okay. But people are I think becoming more familiar with them and we can talk more about 

what they are in the discussion. 

But in essence they're a portion of the platform that is raised and level at set back at some amounts 

of the train and used with a ramp or bridge plate or some of the newer ones that are being developed 
have moving parts to get you over to the train. 

And as we get down to sort of the lower level preferences from the perspective of the disability 

community as to what is the most accessible, many high platforms and card board lifts -- some people 

prefer card board lifts. Some people find there are disadvantages to them and for many high 

platforms. But anyway, those are the solutions that are lower on the list in terms of the disability 

community's preference. And at least -- the least favorite are station mobile lifts. Now, this is 

looking at it from a perspective of inner city and commuter rail. 

Light rail and rapid rail, it's easier to say to the top of the list as full platform level boarding. Melissa, 

did you want to go over the photos? 

>> I can. You can go over the pictures if you want, Marilyn. 

>> Excuse me, can I ask you, this is Dennis Cannon. This came out e-mail, right? 

I'm trying to find it. I can't locate it. Who is this from and what's it say? 

>> If you're looking at the photo document or the agenda, they're both on the RVAAC website. 

>> You click on meeting materials for this meeting. 

>> And I did send them out in an e-mail late yesterday evening Dennis. 

>> I didn't find it but okay I'll go to the website. 

>> One other thing that I wanted to say about mini high that came out just last year is that there are 

some transit agencies that are sort of developing them and justifying to FRA or FTA to put them in by 

saying, you know, they will do stopping -- that's purported that we'll do double stopping at the drop 

of the hat if riders need it and not advertising that policy and nobody knows about it and double 

stopping is not happening. Double stopping not being a favor of either the rail or the disability 

community anyway. So that's another reason why the mini highs are further down on the list. 

In terms of the photos, Melissa, I think you're more familiar with the changes made to the document 
at the last minute, so if you wouldn't mind going ahead, that would probably be more efficient. 

>> No. That's fine. This is Melissa from the Access Board and Marilyn and I were talking and with 

the variety of people that we have on the line and everybody comes with different backgrounds. 

With that, we thought we'd put some pictures together to help people understand some of the 

boarding methods that are frequently found. And so some of these we pretty much all know. 

Some of them may be a little less familiar to people. And I guess the first ones that are shown are 

level boarding. And with the level boarding, you have a doorway that aligns pretty much directly 

with the platform. It's required in rapid rail, and I'm not sure, somebody on the line can -- you can 

see on the first slide the train says Long Island Rail on it. I'm not sure if that's a commuter train or 

rapid train. 

>> That's the long island rail commuter service. 

>> Thank you. And you can see there appears to be a short bridge plate or some type of gap 

mitigation that provides direct access from the vehicle floor to the boarding platform. So a person 

using a wheelchair can just wheel off and on. Someone pushing a stroller, you know, carrying heavy 

bags, just walk right on without any problems. 

>> Melissa, this is Frank again just to break in quickly. That is basically a threshold plate. 

It's not meant to be -- well, it performs the function of being gap mitigation device but that's not it 

only function. Every door opening has a threshold plate which you cross over to get into the car. 

These were extended a little bit to try to minimize the gap. Yeah, most of the time most areas you 

can get in there without any help. But, you know, as we went through this morning there are times 

even when you have this type of -- these type of features you're still are going to wind up with a large 

gap and you may need a bridge plate if you are going to be able to get over it. 

>> So are those stationery -- I mean, there's no variable distance from the train car? 

They're just a threshold that stays --

>> Oh, yeah, they are a fixed part of the train. They don't move and they're -- well, they move with 

the car whenever the car is moving but they're a fixed part of the car. They're not folding out or 

anything like that. They're always out there. They're two inches wider than the car width. You 
can't really tell. But they were extended to minimize the gap. We went through this whole gap 

mitigation plan based on what Bob had mentioned before when we did that whole safety hazard 

analysis and we have found a way that we can extend the cars a little bit wider, minimize the gap 

most of the time. But as you heard earlier before, you can't guarantee it all of the time which is why 

we still carry bridge plates, but I think everyone would agree that full-level boarding, meaning every 

car on the train opening up to a high-level platform is the ideal method in comparison to some of the 

other methods you have. The thing to recognize is that there are going to be times and situations 

even when you have full platform level boarding that you may need a bridge plate. 

>> That's right. And one thing that I forgot to say is bridge plates are a thing that are often used 

with any of these methods, so they're not another category of methods. They're supplements to 

these other methods sometimes and I don't think anybody disagrees with the fact that -- or at least in 

the disability community that at level boarding if you need a ramp or bridge plate that reduces level 

boarding as the ideal substitute, even if a ramp or bridge plate is needed. 

>> Thank you, Marilyn. And that kind of goes to what Dennis was saying before, is that maybe we 

don't want to fix sate on the exact distance of the gap. But know that at some point that a ramp or 

a bridge plate will have to be provided if we exceed a certain gap. 

So the second picture -- and I just pulled these off of Google so the fact that I got Frank's train was 

kind of handy. The second is a high-speed rail train from China and it looks a lot like a rapid rail. 

You can walk directly from the train to the platform and it looks like the gap was very minimal in this 

particular picture. Another example of level boarding is it shows the full platform level boarding and 

its light rail and with the variation light rail is say Loued to have a ramp or bridge plate to mitigate --

or any kind of gap difference. And then some of the other platforms that we can talk about but I'm 

not sure everybody understands is like the mini high platform is where you have -- and this is the 

fourth picture. The mini high platform is where you have a lowered platform for the majority of 

boarding but then you have a small area specifically for boarding for accessibility and people using 

the lower portion may be getting on to the train using stairs and people using the higher platform will 

be using a ramp or a bridge plate to access the doorways. 
And Marilyn and I talked about these a little bit and frequently it's the place where nobody gets on 

the train except people with accessibility needs. 

And they may or may not have the same amenities as the rest of the platform. This is a good 

example where they do have shelter and seating and it may actually be the only place where 

passengers board in this particular station. 

Card board and lift in the fifth picture, this is just a picture of someone getting on to a card board and 

lift. The lift folds back into the train when it's not in use. 

Mechanical and they sometimes --

>> Melissa, I'm sorry to interrupt. But somebody is turning pages or something right next to the 

microphone and if they would stop it, it would be easier to hear you. Thank you. 

>> Thanks, Marsha. 

>> So if you can mute your phones if you're not speaking that would be great. So the last two 

pictures are car born lifts that and there is a person who is getting on the to the lift in a wheelchair 

and you can see it partially raised as that person is raised up to the height of the floor. And as 

always there's always a chance of mechanical failure so there is a manual back-up to that if the lift 

fails. 

First picture on the third page is about station base lifts and, you know, this picture shows the need 

for a method to get on to that -- on to the train from that low-level platform. We have people 

standing on the platform. The lift may be somewhere handy. It may be that think don't need it for 

this particular boarding or alikeing. The picture -- alighting. The picture under that is a picture of 

the station base lifts that at one of the Union Station platforms when we took a tour there. So you 

can see it's kind of big and cumbersome. Someone has to go and get that lift and bring it to the area 

where it's needed on the platform. 

So it takes extra time and draws attention to people who may need to use that. 

Then the last picture is a picture of a ramp or a bridge plate and like Marilyn said, they can be used 

with almost any of these modes and platform heights to help mitigate that horizontal and vertical 

gap. And the picture that we don't have is of the set-back platforms and there is research going on 
currently to help mitigate the huge distance between the platforms on rail that are frequently used 

by freight, can be as much as four or five feet. So there's research and development going on trying 

to develop a platform that actually moves out toward the train and then allows fairly level boarding, a 

bridge plate is still being used on it. 

It's research that's in process so we don't have pictures to put in here. 

So does anybody have any questions about the different methods, the high level, low level platforms? 

Okay. Has everybody gone to sleep out there? 

Okay. 

So, Marilyn, do you have any comments? 

>> No. No. I think that's fine. I'm just trying to figure out what we should do next. 

We had intended to talk about lift ramps and bridge plates and in the context of each review the 

current -- Melissa was going to review the current rules and hopes that our discussion begin to 

develop recommendations on them. 

I also just wanted to comment that I know that there were some various questions about -- well, I --

we have been presenting these larger categories and I think that the fact that there's various types of 

cars on various types of rail systems means there is a lot of different considerations about what 

would have to be used in these situations. I know there's been some discussion among different

subgroups about X method apply to Y car, et cetera, et cetera. So if people have questions or 

thoughts on those situations, this is a good time to present them. 

>> This is Ed Hoff, New Jersey if transit. I have a suggestion. Unfortunately I don't know much 

about any of the other rail system, commuter rail systems from across the country but certainly from 

New Jersey Transit. Where I see improvement could be made we currently use station-based bridge 

plates wherever we have level boarding, mini high level platform with full high length, full high level 

platforms. Certainly the issues surrounding platform base bridge plates are quite a few and could 
be somewhat problematic and the time that it takes to retrieve one, put it down, put it back and all of

that. I think it would be a tremendous advantage if -- and this would fit perfectly well into our 

charge on the RVAAC that we have a vehicle base of type bridge plate whether it be manual or 

operated by a crew member or perhaps integrated with the door of the car, something to put that 

bridge plate out there when the door opens. As we have talked, there is a greater advantage of 

providing level boarding with eliminating the gap or minimizing the gap. Not just for people with 

mobility impairments, mobility devices but to everyone stepping across that gap. 

And I don't think it's impossible to provide an onboard gap mitigation solution that can adjust to 

certain situations. Certainly there are some out there on light rail vehicles in the country and I think 

perhaps we can explore that area as well. 

>> Others? 

>> This is Dennis Cannon. I was told, I did not see it when it was here in D.C. 

But apparently the Ice Train that was brought in when Amtrak was first thinking about doing 

high-sped rail, it brought in an Ice Train from Germany and a Swedish train. The Swedish train had a 

car board lift but the Ice Train had a draw lift that flipped out when the door opened to both take 

care of the vertical and the horizontal gap and so it was automatic on the train itself whenever the 

door opened, the bridge plate or whatever you wanted to call it deployed and so everybody got on 

and off that particular door. 

The second thing I'm aware of is in San Francisco light rail vehicles which both operate on the street 

and in the tunnel. 

In the tunnel the stairs collapsed to be leveled and when you opened the door, there is a -- I don't 

know what you would call it exactly, but a gap filler that folds out from underneath the step because 

of the gap because the cars have plug doors which means there has to be a lot more distance 

between the car and the platform than there is on say the BAART system and that's an automatic --

you know, those are things that can -- I believe Cowsocki is the one that developed that and I don't 
know how reliable that is but I know I used it before. It does drop the gap considerably. Doesn't 

eliminate it completely but it drops it from say four inches to two inches and I've not seen Ice Train so 

I'm not sure how that one works. 

>> It is very common to see a...rail cars -- that deploy prior to door opening or gap fillers and I believe 

IRE is...of that equipment for I think...if I'm not mistaken. 

So a lot of this stuff is out there and it's maybe an eye opener for the committee to think about 

requesting presentations from manufacturers that do already have this equipment in operation. 

Like you, I am familiar with the San Francisco gap filler. I never had it fail in all my travels. Perhaps 

Marilyn has, but I haven't. 

>> This is Bob speaking. I'm just thinking about Portland, Oregon's MAC system where they have on 

their light rail system a passenger upgraded lift ramp assembly. Basically it's a ramp on the doors 

that you press the button inside when you want to get out and it deploys the bridge plate unit down 

to the sidewalk and then you can get off and you press the same kind of button on the outside to get 

in. Requires no operator assistance and it's pretty much an autonomous system for passengers at 

the doors where they have the lift for this ramp assembly. 

So there are -- you know, again, their gaps aren't big and they're not high, but they're enough that 

you need some sort of a mitigation. 

>> Hi. This is Frank again. 

Just following along with the discussion here, it seems like we're getting caught up in how to bridge 

the gap and not whether you need to or not and I think, you know, having a lot of different methods 

to achieve the goal of boarding and alighting is a good thing because every -- you know, like we 

learned with Bob when we were doing research minimizing the gap, not one answer is going to fit all 

the problems that are out there. Everybody is going to want to do things differently. What works 

on the Long Island may work on New Jersey Transit, may not work with Amtrak. The flat forms --
platforms have to be, you know, a foot away from the trains and you're not going to have a device 

that's going to work in that instance. So what Dennis was saying a few times I think was what is the 

gap that you can safely negotiate and if you can't maintain a gap within that criteria, then provide 

some kind of device to bridge it. 

And I'm just thinking from -- we're learning a lot of stuff about what's out there and that's very 

helpful. But the end document that we come up with, the end thing that we're going to propose 

should be this is a performance standard. This is what you have to try to meet and if you can't meet 

it, it's open for you to come up with the ways that are best to allow for boarding and alighting. If 

you have a thousand cars and five platforms, maybe you put it on the platform. If you have a 

thousand platforms and five cars, maybe you put it on the cars. But to dictate what you have to do 

or the method of doing it should not be what we're doing because that's going to make the best 

solution not the solution that somebody has to use if they have to follow that guideline. 

So I think we should focus more on what is the gap needs to be or what does the gap need to be 

vertically and horizontally to allow people to get on and off with a wheelchair and mobility device and 

then leave it up to industry and the authorities to figure out how to mitigate that if you can achieve it. 

I mean, there's certainly an incentive in the industry as it is to minimize that gap from a safety 

perspective for everybody involved. 

And if you can have high platforms for all your authorities, they would do it and boarding and 

alighting as quickly as possible for most of the commuter agencies and transportation agencies is 

ideal. The reason why you don't is because it's very costly and it's a very small, depending on where 

you are, maybe it's a small population of people getting on and off the train in that particular area. 

So the economics of it may drive the solution as to whether you can have the ideal situation of 

leveled boarding or not. But, you know, I still think we need to get back to what is the maximum 

gap vertically and horizontally that you can safely go over with a mobility device and then let 

everybody else figure out what to do outside of that and you can give options. 

>> This is Dennis Cannon. Let me get back on my flagellating and deceased line...again I think what 

we should do is say whenever the gap horizontally exceeds X and the vertical displacement between 
floor and platform exceeds Y, you must provide some kind of device to get around it and typically in 

the -- technical assistance manual could then go through and, you know, explain some of these 

options that people have and get them some ideas but not to get into the regulation of trying to say 

what it is. Typically in a regulation you have a scoping provision and a technical provision. 

So the scope says at one or more doors, whatever the decision is for the particular rail, you will have 

to meet this requirement. If you use a bridge plate, it has to comply with this technical 

specification. There is a technical specification already in the standard, the proposed one for level 

boarding buses that talks about the minimum width and so forth and you simply leave it up to to 

make sure that they're providing a bridge plate that meets that spec. If they're providing a lift, it 

meets another spec. If they're providing a level high platform, as long as you can and I would say 

going back to the bus proposal already, if the horizontal gap is bigger than two inches you have to do 

something. If the vertical gap or displacement is greater than 5/8 inches, you have to do something. 

Rapid rail systems can meet those standards. We know a couple of them, Metro and MARTA in 

Atlanta which developed a bridge plate extension -- I mean, an extension which they both put on the 

cars to retrofit and now a lot of the cars come in them automatically. Reduces gap two inches 

vertical height. Controlled by suspension and self- leveling and they managed to meet it and again 

the specification would say something like you measure the gap at maybe 50 -- when the car is 

stationery at perhaps 50% passenger load so that you acknowledge the fact that a car is moved when 

you get on and off a car, when you go and board a Metro here for example you notice that the cars 

tilt back and forth as the people get on and off. I used to always be sure to time it to when people 

were getting on so the car was rocking in my direction which would minimize the gap and that's just a 

technique. But the gaps aren't static even if you managed to meet the goal. They change as 

people get on and off the cars. So you measure it when the car is at 50% passenger load, when it's 

not moving. 

And then from that point you assume that the mechanical devices will be maintained which is already 

required by the regulation so you have to maintain if you don't let the air bags or the springs or 

whatever to get way out of line. 
And so you don't have to worry about what mandating in the regulation what the specific method of 

dealing with the gap that you use as long as the method meets -- if it's a bridge plate, it meets the 

technical specs for the bridge plate. If it's a lift, it meets the technical specs for the lift. 

>> This is Bob again. To follow up on what Dennis is saying, this would need to be at like the station 

with the least gap, you know, in order to say if you have 20 station stops and most of them meet the 

requirements of not having a bridge plate but one does, then that one does rules for what you have 

to do? 

You can't --

>> No, what I'm saying is it would depend on the station. In other words, there may be a number of 

stations where you don't have to do anything but there may be another station where you have a 

bigger gap and you have to do a bridge plate. You have to use your bridge plate at that station. 

>> Right. Well, you would have to have a bridge plate either at the station or on board the train if 

you're talking about on board equipment. It would be that if any station in your system requires it, 

then your cars require it. If it's stationed based, then it's station by station. 

>> Right. 

>> This is Marilyn. It would be great if there was a way to not have a very steep slope on them, even 

though I understand that the gaps vary. 

>> Well, you can also specify the maximum slope that's permitted on that which means that your 

station, if it has a 3-inch rise in a particular plate, you need a 3-foot ramp, bridge plate. If it's only 

two inches max and placed in your station any given time of the day or loading, then you would only 

need a 2 foot. But there's also some level of safety factor in there that you would need to say well, 

we know it's not going to be more than three, so we're going to make it kind of a 4 feet. But if you 

don't want to go any steeper than a legal curb cut at 8%, then you would want that one inch. Not 

get too steep. 

>> The propose for the buses and level boarding for bus rapid transit has a specification for bridge 
plate that include the maximum slope and I know I boarded some of the Amtrak station, the super 

cars which have a ramp, they carry on board a ramp which is actually a bifold ramp in other words 

depending on what you need if it's a relatively high platform. They put it out in one length. And if 

they -- if it's steeper than that, then they fold it out and it's a double length platform -- I mean, a 

double length ramp. So you can make a device that works for a number of them if it's a station base 

device and again I wouldn't in the regulation, I wouldn't require either one. I would say there has to 

be available period. If you think that you can do it on a station base, that's reasonable. I think. If 

you want to do it on a car, that's also allowed, but the idea is that you would have to provide this 

device somehow and in some cases this discrepancy in platform might be --

>> This is Ed Hoff, New Jersey Transit. I agree with Dennis whole heartedly. I do differ to the fact 

that there is a huge advantage with keeping it on the vehicle. It's more in tune with being -- with 

meeting the phrase the least -- or the most integrated setting possible. Having it on board the 

vehicle I can deploy that if I'm a crew member relatively easily if they are available at every door. 

I'm a crew member. I deploy the device whatever I have and whether or not a person who has 

difficulty getting over the gap uses it or not, at least I have provided it right then and there very 

quickly. The platform base solutions all require you to first identify someone who needs it, then 

retrieve it, put it down, let them board, put it back and then get back on the train. 

It calls attention to peoples' need of having to use that mitigation device. 

So I -- that and several other things. Certainly in some commuter rail systems like New Jersey 

Transit, while you're retrieving the plate, you may already have a fairly full train entering the station, 

by the time you retrieve the plate and put it in place, the train is now crashed packed and makes it 

very difficult for someone to get on there and you're stuck as in having to tell the person, well, we're 

trying to get you on, let's see if I can get some people off or you're going to have to wait for the next 

train. Not a good solution. If I had an onboard device right then and there, I could deploy it right 

there whether or not there is a person who needs it. If a person happens to identify themselves 

quickly, I can get them on without having to retrieve the plate. Huge advantage in that. Also no 

missing plates. If it's somehow tethered to the vehicle, it's always there. It's not being borrowed 
by some other user, being transported someplace else. It's right there on the door of the vehicle. 

>> This is Bob Carlson again and of course following up on that, the onboard crew can get that bridge 

plate ready in place before the train stops and can stow it after the train has continued on its way >> 

I'm going to wrap this up because we are over our time right now. 

This is Melissa. 

Marilyn, did you have anything else to say? 

>> I was going to chime in, but -- it's Marilyn. Ed has persuaded me that this is better than platform 

baseed and I'll be thinking and exploring ways we can, you know, can we require it or if not, you 

know, there is a lot to -- there is yet a lot to say, but I appreciate, Ed, that contribution very much. 

>> Okay. We have -- I don't think we have very many home work assignments for next time. 

Linda, you mentioned that there was some gap info from the NPRM docket. 

Did you want to try to find that and have it distributed? 

She may have left us. I'll talk to her later. We may or may not get that. And it may or may not 

make much difference to our discussion. I'm just going to determine our maximum gaps and then 

the use of a device. 

>> And, Melissa, we're not going to distribute the materials so we have to make sure they are before 

we distribute them. 

>> And if anybody wants more information about the gap fill device that was being talked about, it 

can be found on the docket, in the comments and then I'm going to encourage everyone to read the 

regulations that were part of the meeting materials for the first meeting so that next time we can get 

right down to business talking about the current requirements for lifts, ramps and bridge plates and 

maybe have some discussion on sizes and weights and, you know, start getting down to the 

nitty-gritty of determining what the requirement -- recommendation should be for devices. 

>> Yeah. This is Dennis Cannon. I urge you to look at the proposed bus regs because the bridge 

plate requirements are different from the current ones and it may be that those are the ones you 
want to reference rather than the old ones. 

>> This is Frank --

>> So don't reinvent the wheel. If it's already been fixed in a new proposal, you don't have to worry 

about trying to fix it better. 

>> Could you send it around then? 

>> Are you talking about the proposed rule? 

>> The proposed bus rule has requirements --

>> I understand. But please appreciate that we have been working on a final rule for many, many, 

many months and there have been changes. 

Okay. So I'd hate for people to think that, you know, everything in that proposed rule is a concrete, 

done deal. 

>> No, it's not. And that's not the issue. The issue is that some of the things that people have said 

were wrong with the bridge plate in the current regulation have been fixed. 

>> It might be more profitable for people to look at the public comments as well to the rule. 

So, again, I'd hate for the committee to get wed to something that we have already committed to 

change it. 

>> How do you get to that area, Marsha? 

>> The public comments are available on regulations.gov and Melissa can send a link out to 

everybody. 

>> That would be very helpful. 

>> And, you know, you can search on various terms. You can search on section numbers or on 

questions. So it wouldn't hurt for people to -- not only look at what was proposed but how people 
responded. 

>> Melissa also mentioned the regulations that were part of the minutes of the first meeting. 

>> The first boarding and alighting meeting. And I'll send those out again too. 

>> If you could either send out the link or sometimes it's hard to navigate the site but if you send out 

the link, it's a lot easier. I would appreciate it if you could do that. 

>> Will do. Okay. 

I think we're over time and our next meeting -- our next meeting is Wednesday, June 25th. So we'll 

try to get materials out soon enough so that everyone can review and be prepared to really get some 

work done next time. 

And thank you very much to our presenters today. 

>> Indeed. 

>> Thank you all.