NeedhamLine wrote:F-line to Dudley via Park wrote:
They better have. Because if it's a stock 48-inch boarding Brightline, cue the ADA lawsuits in 3...2...1...
This has been mentioned previously, but Caltrans and IDOT could install mini-high level platforms that are set back a few inches from the clearance envelope, and make use of the gap-filler that Siemens designed for the Brightline cars. Not ideal, but (unlike the bi-level design) it would offer access to 100% of the train for most passengers using wheelchairs. The Brightline interior design went to great lengths to incorporate wide aisles for that purpose. I'm not familiar with California stations, but I would imagine getting host railroad permission would be the main issue with mini-highs, even if they are set back somewhat - it might limit the railroads' ability to carry high-and-wide movements in the future.
That will not work at all.
1) Mini-highs aren't compatible with all of the existing bi-level stock using these stops, so stopping positions will become 1 car shorter on all bi-level trains. Many platforms are constructed only to the length of the longest consist that uses them. Run a same-length bi-level to a 1-car shortened platform, and if the front or rear car can't platform it's a net reduction in accessibility and a net lengthening of dwell times. It's also not an assumption that every platform has the room to be lengthened by +1 cars to accommodate these bi-level users at no loss, or that it can be done at a cost that can put the stops on the path to no-loss accessibility for its bi-level tenants.
2) It's a bigger net reduction in aggregate accessibility, because those mini-highs must be placed at the front or rear tips of the platform where the first or last car in the consist boards. First or last car in the consist most often corresponds to nearest access to a station egress, meaning riders on bi-level trains will have a longer walk to/from an egress if those 8-inch boarding trains have to stop further away from the prime accessibility spot. With all else that would be ADA-compromised by 48-inch boarding, that just ends up piling more fuel onto the legal challenge. You need to be saving on minor additional inconveniences to help defend against these potentially toothy legal challenges, not potentially adding a bunch more little nails in the coffin by making a dozen-or-more stations instantly a longer walk from nearest boarding car to an egress.
3) Many stops
can't physically have a mini-high installed because of how they're laid out for 8-inch boarding. Or can't physically be lengthened to address #1, or have their egresses modded to address #2. ADA regs also tightly control allowable widths and slopes. So you can have an egress at the end of an 8-inch platform that slopes correctly out at that level, but would be pinned in by ramps too steep for ADA if you had to raise them 40 inches (e.g. if there's an unmovable retaining wall next to the egress, or something else structurally dumb-luck about the layout). You also have to have something like 6 feet of unobstructed platform width, and could lose that and end up running afoul of ADA if raising the floor squeezes the width because of new retaining wall or railing installations. At the number of stations in question, this is an engineering crapshoot because none of them were constructed in the ADA era or retrofitted within the ADA era with the possibility that any part of the platform would ever need to be taller than an 8-incher. Jeez...it's hard enough in the Northeast to retrofit some legacy non-accessible lows that pre-date ADA. I can't imagine what 50+ stops carefully planned from birth/renovation inside the ADA era to every width, height, slope, shelter, and railing spec in the book could throw up in individual blockers to modding one end of the platform with a 40-inch elevation change. There's no way you don't end up with dozens of stops with godawful expensive/invasive engineering problems to have to solve. Even Caltrain has backpedaled from going full-on level with its platforms because of concerns that they aren't all physically modifiable, and is buying unicorn EMU's that split the difference so it's only forced to lose sleep over 48-50 in. platform access on the stops blended CAHSR is going to share with them. So you will not...ever...get 100% compliance at every single key station by flipping the accessibility burden onto the station structures instead of the vehicles. Whereas, under PRIAA, the vehicles were supposed to guarantee that. This is a big, big legal problem.
4) Many of these stops are shared with Metra, Metrolink, Coaster, and ACE commuter rail trains who exclusively use 8-inch boarding BLV's or gallery cars. As well as a slate of Superliner-bearing LD's. Commuter trains are where the most issues with #1-3 are going to arise, and since CR ends up being a majority of the schedules and ridership at those dual-tenant stops the hits they take on accessibility outslug any gains that Amtrak gets. Worse, many of those dual-use stations are owned/operated by the commuter rail agencies and thus the platform height isn't even Amtrak's call. In California transit is particularly balkanized at the government level, and in the hands of regional administrative agencies who DON'T answer directly and subserviently to Caltrans. If SoCal Regional Rail Authority tells Caltrans to go pound sand on modding any Metrolink stations, the plan immediately falls apart. Caltrans is already having this herding-cats problem with SCRRA trying to secure their cooperation for blended HSR, which is part of the reason why the Initial Operating Segment is starting outside Metrolink territory; the state fully needs the extra 12 years at the bargaining table to pull teeth with SCRRA. There is a near-zero chance of securing sign-off from every affected CR operator on a station modding plan in time to proceed with car production with all accessibility loopholes closed. It's far too many chefs who have to agree on a recipe.
5) There is no funding mechanism in this procurement that can cover the platform mods. That's all above-and-beyond, and has to be coordinated with other agencies and station owners outside the purview of Caltrans & IDOT. So it fails as an accessibility solution, because it attempts to make PRIAA funding that was to guarantee onboard accessibility and shift the accessibility burden to a realm where the PRIAA funding can't be transferred. That's a bait-and-switch that will get pummeled in court.
The only way to make the trainsets themselves ADA-compatible with 8-inch platforms that I can think of would be if Siemens could somehow build a ramp into a partial low-floor section of the cab cars... but that would involve a great deal of engineering and safety testing.
Physically impossible no matter what the engineering. ADA, as with platforms, sets strict limits on the maximum slope of a ramp and the amount of level landing area that must be at the end of any switchbacks on the ramp. See here:
https://www.adawheelchairramps.com/whee ... lines.aspx" onclick="window.open(this.href);return false;. California state-level law is even stricter than the federal. A 10'8" railcar physically isn't wide enough to get down an extra 30 inches from a 48-inch floor to 18 inches at the door lip with laterally-running switchback ramps (by Cali standards you'd need at least a 12 ft. wide railcar to have even ONE switchback inside), then be able to turn at a 90-degree angle at an 18-in. door lip that in turn spits out a kosher-slope retractable ramp down from the lip to the 8 in. platform surface. Doubleplus impossible if there are facing doors in the vestibule because that limits the max length of the retractable door ramp to too short to get down to 8 inches and retain acceptable slope. Staggering opposing doors offset and having single ramps down to each of them ends up cannibalizing an obscene number of seats and may require ramps long enough to foul the placement of the trucks on the carbody undercarriage.
Although the Viaggio order will have fewer overall seats, I would imagine that they can offer a significantly improved ride - I always thought the upper level on Superliners and California Cars experienced a lot of lateral swaying, and can only imagine what it might be like at 110 mph in push mode. If the Brightline/PRIIA version of the Viaggio is anything like the OBB Railjet, the ride will be fantastic (having ridden those over less-than-perfect track in Hungary).
Not all bi-levels sway like that. It's totally dependent on make/model. Since no passenger has yet ridden in a Brightline, it can't be blindly assumed that they run smoother than an Amfleet. And it definitely can't be assumed that a heavily-modded Brightline with significant design hacks for 8-inch platform boarding is going to run as smoothly as a stock 48-inch Brightline delivered for All Aboard Florida or your circa-2022 Northeast Regional. That's unknowable today.
It will be interesting to see what the cab car ends up looking like. Siemens seems to put a lot of effort into exterior design, so hopefully we will end up with something better than the new Talgo cab cars. The trainsets will definitely have a more unified look, similar to Brightline (but minus the extra streamlining). Also on the plus side for Caltrans and IDOT, 100% of their new trainsets will be built by the same manufacturer, which could make future support arrangements simpler.
Push-pull cabs are old hat for the Viaggios, so Brightline'ing them won't be that big a deal. The East Coast PRIAA specs that all cab cars be in half-baggage configuration that goes:
-- Cab-end vestibule outfitted as a small crew storage room. Regular vestibule doors because all East Coast PRIAA carbodies are to have 2 vestibules (i.e. like Amfleet I's/Horizons, not Amfleet II's), but the cab-end vestibule is off-limits to passengers and used by crew-only for moving baggage on/off the car.
-- The cab-facing half of the coach interior is an enclosed baggage room. *Light*-loading capability, like a commuter rail bike car with storage racks...no heavy-handling like a Viewbag and all items must be able to pass through the regular-size doors in the crew-only vestibule. This also makes it so the cab end has an extra-fat crash energy buffer to sacrifice away from where passengers sit.
-- The half of the coach interior facing away from the cab is regular coach seating. Using modular snap-in livery the seating is the equivalent of 2 snap-ins, bag room equivalent to 2 snap-ins. Option available in the order for the states to take out 1 seating snap-in and expand the size of the bag room by +1.
-- Non- cab end vestibule is a regular passenger vestibule.
Since Midwest/Cali PRIAA called for lower-level bag rooms on the bi-level cabs just like the Cali Cars/Surfliners have, the single-level substitute is just going to carry over this same half-bag configuration because universal light baggage handling was an expectation of this program. And as far as the East Coast was concerned, the positioning of the bag room helped keep the cabs' carbody design from needing to diverge tooooooooo much from the trailers (i.e. no need for insane excess like faux locomotive noses). Meaning that importing a Viaggio cab and upgrading it to Brightline design shouldn't be that big a deal, and if the coach is produceable the cabs by all logic shouldn't have any belly-flops on testing. The East Coast order also isn't going to be producing its first cab unit until a full 400+ cars into the order, because the pull-only national fleet of LD's and Northeast Regional coaches get their Amfleet replacements first before the statie routes on the Keystone & Empire plus New England states see any of their new equipment a good 3+ years into mass production.
Note well, however, that the half-bag setup as crash management concession means you're only getting half the seating in a cab car and need to adjust the total seating capacity in this reduced order down accordingly.
It's not at all neat-and-tidy. We still need lots of attribution on the accessibility of these replacement cars to draw any conclusions that the substitution will hold up to outside legal scrutiny. At the very least, so long as those considerations aren't nailed down the potential is still sky-high for accessibility inquiries to significantly delay (if not derail) the project. Sumitromo & the states are not out of the woods yet, for reasons that have everything to do with ADA caselaw viz-a-viz PRIAA and absolutely nothing to do with Siemens' qualifications as a subcontractor. We will just have to wait and see if those answers are forthcoming before it's safe to phone up Vegas and put down on the schedule betting odds.
