C. E. Dettmann
Executive Vice President
Safety and Operations
Association of American Railroads

The Association of American Railroads (AAR), a nonprofit trade association representing major freight railroads, Amtrak, and commuter railroads, is strongly opposed to a provision in the revised accessibility guidelines for public rights-of-way proposed by the Public Rights-of-Way Access AdvisoryCommittee (PROWAAC). In section X02.1 .6.3 of the proposed revision, Part III, PRO WAAC is proposing a maximum 1/2 flangeway gap at grade crossings. This proposal is dangerous from a rail safety perspective.

The flangeway gap is the space between the inner edge of a rail and the crossing surface. The gap must be of sufficient width to permit a locomotive or rail car wheel to pass through. If there is inadequate space, a derailment will occur.

From the perspective of rail safety, the flangeway gap must be at least three inches (narrower gaps are permissible for rights-of-way used exclusively by light-rail equipment). Through experience, the railroads expect that if a crossing with a three inch flangeway gap is constructed, wear will result in the gap widening by as much as an additional inch.

PRO WAAC is concerned that the front wheels of wheelchairs can become stuck in flangeway gaps at pedestrian grade crossings. PRO WAAC believes that the rail industry should use flangeway fillers that narrow the gap to half an inch, but expand when rail equipment passes through the gap to provide the space needed for rail equipment.

The issue PROWAAC and the railroad industry have been wrestling with is that adequate flangeway fillers have not been developed. Fillers need to maintain horizontal and vertical stability while subject to strong forces and, in many locations, harsh weather conditions. So far, proposed fillers have not been up to the task.

PRO WAAC has suggested to the Architecture and Transportation Barriers Compliance Board (ATBCB) that a maximum 1/2-inch gap be imposed four years from the date revised accessibility guidelines are published. This recommendation, were it to become effective, could result in a major railroad accident.

AAR discussed this issue extensively with PROWAAC last summer and thought an understanding had been reached on how to address PROWAAC's concerns without jeopardizing  rail safety. The understanding was that ATBCB would facilitate research into flangeway fillers and that the railroad industry would support research. Until an acceptable flangeway filler were developed, the maximum flangeway gap for newly-constructed rail/crossing surface interfaces would be three inches. Upon development of a flangeway filler the Federal Railroad Administration deemed safe from the perspective of rail safety, a requirement for a narrow flangeway gap could become effective.

Disregarding the public interest in safe railroad operations, last month PRO WAAC recommended to ATBCB that four years from the publication of revised accessibility guidelines, a requirement for 1/2-inch maximum flangeway gap should become effective. PROWAAC’s recommendation completely ignores the failure of past efforts to develop an acceptable flangeway gap and the technical problems that remain.

It is unthinkable that ATBCB would completely disregard rail safety concerns and put the public at risk. ATBCB should reject PROWAAC’s recommendation and condition any requirement for a flangeway gap narrower than three inches on the development of a flangeway filler deemed acceptable by FRA.

AAR and its member railroads are ready to work with ATBCB on flangeway filler research. AAR would be happy to discuss this issue further with you at your convenience.

C. E. Dettmann