### Issues associated with requiring bridge plate car ramps to be

**automatically deployed and connected to the cars**



# Preliminary **DRAFT for discussion purposes only** 

**. This**  **is not an**  **official position**  **paper.**

Currently most wheel chair ramp s used in commuter applications are portable and in the case of LIRR and MNR they are manuall y deplo yed when necessary by the train crew. LIRR and MNR sto re ramps on the equipment near the wheelchair seatin g areas, as well as on certain station platforms to ensure that the ramps are readily available when needed. This manual effort allows the train crew to ensure the safety of boarding and alighting of passengers with wheelchairs and mobility devices to and from the train , while not interfering with rapid passenger flow on most cars at most stations.

If automated ramps are applied to the car they will reduce the safety of boarding and alighting for passengers with wheelchair s and more so for walking passeng ers on all cars at all stations . In addition

, the complicated deplo yment sy stem and associated safety interlocks required for their use will increase station dwell times , significantly increase procurement and maintenance costs

, and car weight and reduce the overall reliability of the transportation s ys tem, while providing minimal benefits for passengers with mobi lity aide devices such as wheel chairs.

There are safety concerns associated with the use of automaticall y deplo yi ng bridge plates which are **exace rbated by the requirement that**  **all accessible door**  **s of**  **all car**  **s use the device at every single station**  **stop , even when there may not be a need for the**  **devices at any station s on a particular train**  **and even when only on e**  **station may need to have a bridge pl**  **ate**

**.** Currentl y , the manually deplo ye d bridge plates are used only on the car that they

are needed and only

at the station s that they

are needed. The safest boarding and alighting for everyone is to have level boarding with minimum gaps, which for most auth orities, can be achieved onl y at certain stations. Some of the safety concerns related to the use of automated car ramps are as follows:

1. **The deployment of the bridge plate will pose a safety hazard to passengers on the car as well as passengers on the pla**  **tform**

. In order for the ramp to fold out onto the platform it will likely be stored inside the car and likel y i nside the vestibule in a locker and deploy to the outside of the train onto the platform when the doors open. A. **Passengers in area for deployment on the car**  **will need to be kept clear so that no one is injured during the deployment**  . Currentl y man y rush hour trains are filled to capacity and people are standing in the vestibule. Keeping the vestibule clear of people is nearl y impossible as passengers need to traverse the area during boarding and alighting. Additional audible and visual alarms will be necessary to warn passengers to move from thevestibule areas. However when the cars are filled to capacity , which is likely during peak periods , it wil l be impossible for them to clear out of vestibule areas, and thus it will not be possible to safe l y open the doors and deplo y the bridge plates. Therefore under these conditions opening the door will create a safety concern at every accessible door with c rowded vestibules on the train. Even when the train is not overly crowed, passengers generally

congregate at the vestibules before their stop, so that the y are ready to alight when the train comes to a stop. I f a fold out bridge plate is used

, the doors w ill need to open before the bridge plate can fold out onto the platform. If will be difficult to prevent walking passengers from walking through the door if it is open, consequentl y it will be difficult to tie the bridge plate actuation to the door operati on. B. **Passengers on the platform**  **waiting for a train must clear the area when a train arrives so that they do not get hit by the deploying**  **bridge plates.** Keeping the platform area clear of passengers will be very difficult

. T ypically passenger s stand near th e door openings when the train arrives so that they

can get on and get a seat. Often the passengers are so close to the door that they obstruct passengers getting off the train. In addition, identifying the areas of bridge plate deploy ment on the platforms will be difficult because the car door s do not alway s align with the same exact location on the platform. This misalignment can be due to difference s in door spacing on different equipment and/ or accuracy of train berthing at platforms

. The deplo yi ng brid ge plates will take up significant space on the platform depending on the length of the bridge plate which can be 12 inches to 18 inches for vertical gap between 3 inches and 6 inches and significantl y longer for larger vertical gaps, and larger horizontal gaps. **The bridge plate for all accessible doors**  **on all** 

**car s**  **will need to be designed to accommodate the larges t**  **vertical gap**
**p r**  **esent on the system as well as the largest horizontal gap on the system**  , which could be quite large due to platforms on curves. Additionally

for locations where the car threshold is lower than the platform an addition al limited rotation hinge would need to be added to the bridge plate to allow it to conform to the height difference. A straight rigid plate would not work in these instances. C. **Since only newer cars would be equipped with the new devices not all**  **trains will need to clear the vestibules and platform areas at station stop as outlined above.**  This would require that the c ustomers know the difference between new cars and older cars so they are prepared for the device to deplo y . There will be a learning curve for regular commuters, but it will alway s be difficult to teach transient customers.

A manually

deployed bridge plate operation allows the train crew to clear the area on the platform and in the car vestibule before deploy ment of the bridge plate

. Since the bridge plate operation is not tied to the doors, train crew personnel can open the doors and then wait for cro wds to disperse before deplo yi ng the bridgeplate. This deploy ment process mitigates the hazards to p assengers with and without mobility devices associated with automatic deplo ym ent outlined above.

2. **Once folded out the bridge plate will be a tripping hazar d to persons**  **on the station platform**  **walking on to or off**  **the train**

**.** The bridge plate will extend into the platform area 12 inches to 1 6 inches or more . This will require that every walking passenger at every single door opening at every single station will need
to use the entire ramp. On crowded platforms it may be difficult to see the ramp. For persons with visual impairments it may also be difficult to sense the ramp. People exiting the train may attempt to walk off the sides of the ramp instead of
proceeding down the entire length , which will create a tripping hazard. Similarly people entering the train may attempt to step onto the side of the ramp near the door, instead of walking the entire ramp, which will create a tripping hazard. 3. **Once folded ou t the bridge plate will be a tripping hazard to**  **persons on the train**  **attempting to board or alight.** The platform will need to fold out and sit on top of the finished floor, which will create a tripping hazard as people generally expect a flat floor without steps once they walk onto a train and are typically not looking down as they

walk

. 4. **In order to ensure that the plates are only deployed when stopped at a station and the doors are open,**  **safety interlocks will need to be provided between**  **the bridge plates and the side door and/or car propulsion system.**  The interlocks will prevent the car from moving when the plates are extended and prevent the plates from extending when the car is moving or the doors are purposely kept closed. Should any

of the interlocks fail an unsafe condition would exist, therefore the sensors would need to be redundant to reduce the likelihood of a false indication. Consequently the high number of sensors increases the likelihood that a train will be prevented from moving due to a fail ed sensor or failed actuating device. To address these concerns by pass devices would need to be provided to allow train movement in case of an emergency due to sensor and or device failure. 5. **Inclement weather conditions will create additional safety concer ns.**  Built up

snow and ice on the platform, vestibule and bridge plate will inhibit deploy ment and retraction of bridge plate . This may result in the bridge plate being prevented from fully

deploying or retracting or properl y interfacing with the platform which will cause unsafe conditions for the passengers attempting to board and or exit the train . This will also result in train delay s since operation will be tied to train
movement.

In addition to the safety concerns outline d above there are additional co ncerns with the automatically

deploying bridge plates which include complexity of the device, storage space, increase d station dwell times, infrastructure restrictions, significantly increase d procurement and maintenance costs, car weight and reduce d overall reliability of the transportation sy stem . These concerns are explained in more detail below:

**1. In order to**  **meet the slope, stowage and range of vertical and horizontal gaps required by the regulation and automatically deploy and retract safely the** **design of the device ma**  **y be more complicated tha**  **n it may appear** 

**.** If stored on the vestibule wall

, the device would need at least two hydraulic or electrical motion devices or a single motion device and a mechanical actuating device, so that it can fold ont o the vestibule floor th e n fold onto the platform. If space is a constraint, additional levels of folding may be required to fit in the available
space. In order to allow for deploy ment or retraction due to device failure, mechanical back s ys tems would nee d to be provided to deploy and retract the device, further complicating the s ys tem design. Due to concerns of snow and ice build

- up under freezing conditions, heating provisions or other methods will be
necessary to clear the bridge plate , and platform and bridge plate of built up snow and ice. **2. In order to meet the slope, stowage and range of vertical and horizontal gaps**  **required by the regulation and automatically deploy and retract, the**  **size of the device will be quite large** 

. The size will vary dependin g upon the infrastructure present at each operating authority

. Since the bridge plate for all accessible door s on all car s will need to be designed to accommodate the largest vertical gap present on the sy stem as well as the largest horizontal gap on the
sy stem, it may

be much larger than necessary at most stations. T he length of the bridge plate will need to be at least 20 i nches long to provide some overlap on the car floor and meet the slope requirements for typical 3 in ch to 6 inch vertical gap. Secondly the device will need to span the entire door width so as not to create a tripping hazard and provide the necessary passe nger flow rates required . Many authorities including LIRR and MNR ty picall y have 50 inch wide door openings. In order to accommodate both positive and negative vertical gaps, the ramp will either need to have a curved arch or have a flexible hinge, both of which will take up additional space for storage of the ramp alone. Add to that operating mechanism and the size of the storage space for the ramp will be on the order of 50 inches b y 20 inches by about 8 inches of depth. For a typical commuter rail car wi th 4 doors this would be equivalent to a box of 50 inches b y 20 inches b y 32 inches, which is significant for a commuter car where every inch of space counts. When considering that some subway cars have more then 4 openings per car, the amount of space occ upied by the device s is even greater. **3. Deployment and retraction of the devices will increase dwell time**  **at each and every station stop.**  Itis estimated to take approximately 20 seconds or more to safel y deplo y the bridge plate and another 20 seconds or m ore to retract the bridge plate. In addition there will need to be an additional waiting period of at least 20 seconds to allow for the vestibules to clear, before the bridge plate can be deployed. Considering there is onl y 3

- 5 minutes to load and unload a train during rush

- hour conditions, the additional time required on top of the current time required for opening and closing doors will require that additional time be spent at the station reducing the capacity of the trans portation sy stem to more people , which will lead to more crowded trains. **4. Deployment of the device may not be possible at all station loc**  **a tions due to**  **existing infrastructure.** The existing infrastructure at stations including columns and other obstructions would prevent the deplo yment o f the devices. Considering the size of the devices is approximately 15 inches long and 50 inches wide, theresimply is not always enough space at every door opening to accommodate the fold out bridge plates. **5. Due to the complexity of the system as outlined**  **above the cost of purchase and maintenance of the devices would be significant.**  Maintenance costs would include the added expenses associated with maintaining a significant new pool of spare parts from a single source of suppl y and addressing obsolescence issues associated with complicated controls sy stems available only from the OEM. **6. Additional weight associated with the implementation of bridge plates is not**  **insignificant.** Heavier cars use more energy to move. Federal carbody safety regulations require significant structure which adds weight to rail cars. Many operating agencies are at the limits for weight for their vehicles. Consequently the authorities and the car builders are alway s looking for way s to reduce the weight of the rail cars. A rough order of magnitude estimate of the weigh assoc i ated with one device is 200 pounds. Considering that there are ty picall y 4 doors on each car, the increase in weight per car would be 8 00 pounds. **7. Due to the complexity of the system as**  **outlined above and the required interlocks associated with safe operation, the overall reliability of the rail car**  **will decrease.** As outlined above, the bridge plate sy stem will require several new components, which if failed would prevent the car from co ntinuing in service

carryi ng passengers. Every new component added to a rail car that can fail, and prevent the rail car from continuing in service reduces the reliability of the car and the transportation s ys tem.

Near level boarding is generall y considered the best boarding and alighting condition for
everyone, and most authorities expend money and resources to reduce the gap to the extent practical but cannot achieve compliant small gaps at all stations. Considering the difficulty associated with bridge plates, would it be better to have more stations with small gaps, especiall y high transfer stations, and use bridge plates onl y when necessary than to require everyone use a bri d g e plate at every station, even those with very small gaps? By requiri ng bridge plates be used at all stations by requiring automatic deploy ment , you are providing an incentive to increase the gaps at the stations with small
gaps since bridge plates will be required at these stations due to possibly a few problem stations on the infrastructure. The one size fits all approach, dictated by an interpretation of the proposed requirement is not in the best interest of all passengers.