DEPARTMENT OF TRANSPORTATION 

 DISABILITY LAW GUIDANCE 

FULL-LENGTH, LEVEL-BOARDING PLATFORMS IN NEW 

COMMUTER AND INTERCITY RAIL STATIONS 

Under Department of Transportation ADA and section 504 regulations, the norm for new 

commuter and intercity rail stations is a platform running the full length of the passenger 

boarding area of the station that permits level boarding to all accessible cars of trains stopping at 

the station. Level boarding for all cars of a train is significant because, if passengers with 

disabilities are unable to enter all cars from the platform, the passengers will have access only to 

segregated service. This would be inconsistent with the nondiscrimination mandate of the ADA. 

It would also, in the case of Federal Transit Administration (FTA) and Federal Railroad 

Administration (FRA)-assisted projects (including Amtrak), be inconsistent with the requirement 

of the Department’s section 504 regulation (49 CFR §27.7), which requires service in the most 

integrated setting reasonably achievable. 

In the Department’s ADA regulations (49 CFR Part 37, Appendix A, §10.3.1(9)), level boarding 

is defined as involving a horizontal gap of no more than three inches and a vertical gap of no 

more than 5/8 inches (1.5 inches for existing vehicles operating in new stations). However, the 

Department now is convinced that meeting and/or maintaining the 3” and 5/8” inch gap 

requirements is likely to be infeasible in most commuter and intercity rail stations. Freight rail 

track sharing, ballast compression and tamping, track and wheel wear, and/or rail car sway or roll 

contribute to this infeasibility. 

The regulatory language governing situations where meeting existing gap requirements is 

infeasible is as follows: 

In...commuter rail and intercity rail systems where it is not operationally or 

structurally feasible to meet the horizontal or vertical gap requirements, mini-high 

platforms, car-borne or platform-mounted lifts, ramps or bridge plates, or similar 

manually deployed devices, meeting the applicable requirements of 36 CFR part 

1192, or 49 CFR Part 38, shall suffice. 49 CFR Part 37, Appendix A, §10.3.1(9), 

Exception 2. 

In situations where meeting gap requirements is infeasible, commuter and intercity rail operators 

still may often be able to provide full-length, level-entry boarding to all accessible cars of trains 

by using a high-level platform in conjunction with short bridge plates that provide access to each 

car. If this approach is feasible, it should be the option of choice. 

If this approach is infeasible, then another solution permitting access to all cars of the train 

should be employed (e.g., car-borne or station-based lifts serving each accessible car). This 
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approach, while less desirable operationally and as a matter of passenger service, still permits 

fully integrated service to the train. 

In cases where there are concerns about accommodating freight trains (including 

overdimensional loads) through commuter or intercity rail stations, commuter and intercity rail 

operators should employ solutions that accommodate both types of traffic in the presence of fulllength high-level platforms, such as gauntlet or bypass tracks, unless doing so is technically or 

operationally infeasible. 

In determining whether a particular station design or accessibility solution is feasible, the 

Department looks at each station on an independent, case-by-case basis. It may be possible that 

full-length level boarding is feasible at some stations but not others on a system. For example, 

suppose that, in a commuter rail system with 15 stations, the commuter rail authority 

demonstrates to FTA that full-length level boarding is infeasible at three stations. The other 12 

stations still would have to have full-length level boarding. 

In considering the facts at a given station, FTA and FRA do not view the fact that providing fulllength level boarding may entail some disadvantages or additional costs, standing alone, as 

demonstrating infeasibility. 

In any situation using a combination of high and low platforms, a commuter or intercity rail 

operator should not employ a solution that has the effect of channeling passengers into a narrow 

space between the face of the higher-level platform and the edge of the lower platform. Such a 

design is inherently unsafe. In this regard, any obstructions on a platform (stairwells, elevator 

shafts, seats, etc.) should be at least 6 feet back from the edge of a platform. Commuter and 

intercity rail operators should also take into account the uncertainties in the stopping position of 

trains in planning for accessibility solutions. 

If a new commuter station is to be used by Amtrak as well as commuter rail, then when 

designing new stations and purchasing rolling stock, the floor height of existing Amtrak cars 

should be taken into account. 

Passengers should not be expected to step down from a platform into a rail passenger car. In 

addition, the floor at all passenger car doors assessing a platform should extend at least to the 

edge of the passenger car outer-side wall. In other words, the rail car door should not be 

recessed from the platform in such a way that level boarding is impossible or that a longer bridge 

plate would be required to traverse the gap. 

The platform height should be measured with worn vehicle components (wheels, springs, center 

plate, etc.). New vehicles will typically be a few inches higher than ones with worn components. 

This guidance has been approved through the Department of Transportation’s Disability Law 

Coordinating Council as representing the official views of the Department on this matter. 

September 1, 2005