To: Illinois Department of Transportation
From: Amber Smock, Director of Advocacy, Access Living of
Re: Comments on Development of High Speed Rail for Illinois
Thank you for the opportunity to provide public comment on next steps for the Chicago-St. Louis corridor.
Access Living is the Center for Independent Living based in metropolitan Chicago. Since 1980, we have been at the forefront of change led by and for people with disabilities who want to be independent in the community. Transportation has long been a core independence issue. For example, the wheelchair lifts and ramps on CTA buses are due to a lawsuit we filed in the 1980s.
First, I would like to comment on a disability issue specific to high-speed rail in this corridor. I would like to call your attention to platform height for new or upgraded tracks and stations for the high speed trains and the provision of “level boarding.”
Under the US DOT regulations issued on October 19. 2011 and effective on design and constructions of platforms effective Feb. 1, 2012, level boarding is only required in a limited number of circumstances and for most of the stations on this route, because freight trains use the same tracks, US DOT has said so far that the new platforms only need to be 8” above the rail.
When platforms are only 8” above the rail, anyone using a wheelchair and people with other mobility disabilities will not be able to board a single level railcar without the use of a platform lift. For the bi-level Amtrak cars (Superliner cars) a wheelchair user could board using portable ramp that is carried on the Superliner cars, but it is a very steep incline. The alternative is using a platform lift which can be time consuming to deploy resulting in longer boarding times that will defeat the advantage of faster train speeds. Having 15” above the rail platforms will provide more or less level boarding but thus far, the DOT has not required them due to the opposition of the freight railroads that own the track.
I have traveled many times on Amtrak with people who used power wheelchairs or scooters. The length of time it takes people to board can depend not only on the deployment of the lift, but also on the person’s ability to navigate their chair on and off the lift, and into a safe seating spot. Factors to consider can include device width and the rider’s cognitive and motor abilities. The simpler it is to board, the quicker boarding will be. Appropriate platform height would be a huge boon and a relief to riders and staff alike.
Second, I would like to note that I have often traveled on Amtrak with more than one power chair or scooter user, up to a group size of about fifteen. Stations are usually outfitted with only one lift (and only one or two staff people to man the station). What happens is that when multiple wheelchair users want to board or debark, we have to have people go one at a time. When you have more than two or three people doing this, there can be a long delay involved. Our community wants to be able to go places quickly and without delay just like anyone else. Not having to rely on just one lift would expedite rides most efficiently, and that means bringing platform heights up to speed.
Third, Amtrak needs to upgrade its online booking software so that it can accommodate ticket purchases when more than three people using chairs want to ride the same train at the same time. Currently, the total limit of tickets online for an entire train is three wheelchair users. When one in five people has a disability and a number of those are chair users, saving only three tickets for wheelchair users on an entire train is not proportionate to the population at large. That is, the provision of tickets online is not equitable. Moreover, trains actually do have enough space to accommodate more than three chair users…generally they can accommodate around 6 to 8 people.
Overall, IDOT should be looking at how to make rail accessible to all people who live in Illinois, without limiting people to certain routes or certain times or certain boarding practices based on disability. Access Living thanks Amtrak for their efforts on access to date, but our concern is that much more remains to be done across rail as a whole.