Letter to Amtrak on Accessibility for Next-Gen LDR Equipment

August 31, 2023

Mr. Stephen J. Gardner

Chief Executive Officer

Amtrak

1 Massachusetts Avenue NW

Washington, DC 20001

Re: Rail Passenger Association Comments on Accessibility in New Equipment for the Long-Distance Rail Network

Dear Mr. Gardner,

The Rail Passengers Association appreciates the opportunity to provide our views on Amtrak’s procurement efforts for the next generation Long Distance rail fleet. The Rail Passengers Association is the oldest and largest national organization serving as a voice for the more than 40 million rail passengers in the U.S. This procurement effort is a key part of achieving our organization’s central mission, which is to improve and expand conventional intercity and regional passenger train services, increase connectivity among all forms of transportation and ensure safety for our country's trains and passengers.

Our organization believes that, as our country collaborates on building the next generation of intercity passenger rail equipment, we must find innovative ways to improve accessibility for passengers with disabilities while also increasing capacity on the next-generation Long Distance equipment.

Additionally, Rail Passengers is compelled to emphasize that the primary obstacle to access for passengers with disabilities—whether that disability is based on reduced mobility, vision, hearing, or something else—remains the lack of frequent, reliable, and affordable train service that is the status quo in much of the U.S. Any effort to improve access for passengers with disabilities must include a timely solution for this generalized lack of affordable access.

Endorsement of Amtrak’s Proposed Alternate Method of Compliance

Based on our review of the publicly available materials, we support Amtrak’s proposed Alternative Design Standards, as they represent a significant improvement in access for passengers with disabilities, without unduly impacting overall capacity.

After conferring with passengers with disabilities within our organization’s volunteer leadership, we believe Amtrak’s focus on using semi-permanent coupling to create accessible corridors at the heart of each trainset satisfies key goals for passengers with disabilities:

• Equity: Amtrak’s Alternative Design Standards substantively satisfies the intent underlying 49 CFR Part 38.111 by providing an equivalent—or greater—number of accessible spaces and bedrooms on each trainset. Additionally, passengers with disabilities will have equal or better access to all the onboard amenities—dining car, café care, lounge car, and sleeping car.
• Autonomy: Amtrak’s accessible core trainset design will allow passengers with disabilities to move about the train at their own discretion, accessing amenities as and when they desire. In conversations with our membership, one of the key features passengers value in train travel is the freedom to move about the train, unencumbered by turbulence and ‘fasten seatbelt’ lights. The accessible core design satisfies this goal, and it is a substantive improvement over any design which satisfies a per-car-accessibility rule but fails to allow for the unencumbered movement of passengers with disabilities between onboard amenities.
• Redundancy: Based on the experience of our membership on the National Network, the redundancy allowed for in Amtrak’s accessible core trainset design is a key feature. It is far too often the case that individual railcars will experience mechanical difficulties over a long-distance trip; while we can reasonably hope that replacing the aging National Network fleet with new equipment will address many of these mechanical issues, providing redundant access to restroom facilities and vertical access points is a necessity. This is particularly true given the unwillingness of many Host Railroads to address Freight Train Interference and the harmful impact on Amtrak passengers and on-time performance; these delays place undue stress on restroom facilities and increase the need for redundant access.

Recognizing the Needs of Coach Passengers

Rail Passengers supports Amtrak’s proposed Alternative Design Standards because they improve access for passengers with disabilities while maintaining adequate levels of comfort for all coach passengers.

Our membership has been quite critical of the narrower seats featured on the new Venture railcars introduced on several Midwest State-Supported services. Coach passengers inevitably bear the brunt of any reductions in seat width and reclining capacity, and what is tolerable on shorter-distance corridors is completely unacceptable on long-distance services.

Respecting the needs of low-income passengers—many of whom are senior citizens, have larger bodies, or both—requires maintaining access to wider coach seats as part of every trainset.

Addressing the Generalized Lack of Access to Frequent and Reliable Passenger Rail Service

It is critical that the U.S. increase access to frequent and reliable intercity rail service. Having accessible trainsets does very little good for a passenger with a disability if that train only stops once per day in the middle of the night, or if a room on a sleeper car costs upwards of three thousand dollars during the peak travel season. It does no good for that passenger with a disability if there is no service to their city at all.

According to the 2023 "Annual Report on People with Disabilities in America", the poverty rate for Americans with disabilities is more than twice as high as for those without disabilities. Providing frequent and affordable transportation alternatives for people who can’t drive long distances or afford ever-increasing airfare should be a key goal of U.S. rail policy.

Rail Passengers implores Amtrak and the Federal Railroad Administration (FRA) to immediately move to the next step of the procurement process for the next generation of Long Distance equipment. Simply renewing the existing fleet is insufficient. The FRA’s Amtrak Daily Long-Distance Service Study envisions an expanded network, necessitating a larger fleet of Long Distance railcars. The success of this effort, and passenger rail programs more generally, depends on the ability of the FRA, Amtrak, and the rail manufacturing industry to work together to speed the delivery of new equipment. Waiting another ten to fifteen years before new equipment and corridors enter revenue service effectively ensures that Baby Boomers, America’s largest generational cohort, will be denied the benefits of this investment. It also means another ten to fifteen years of unnecessary flights, unnecessary highway deaths, and indefinitely deferred trips to see family and friends.

Thank you in advance for your consideration of these comments. Rail Passengers and our members stand ready to assist you to advance this critical project.

Sincerely,

Jim Mathews

President and CEO

Rail Passengers Association