Bill — I wanted to re-submit a public comment I made in writing (via email) earlier to the Access Board relative to proposed guidelines for Federal outdoor developed areas which seek to address new or altered trails, beach routes, and picnic and camping areas (Docket No. 2007-02).
My comment specifically pertained to the at-grade intersection of any present or future “Federal outdoor developed areas” governed by the proposed ATBCB guidelines with any type of inactive, active, or planned railroad or rail-transit right-of-way.
Specifically, the proposed / revised ATBCB guidelines do not include or attempt to address the specialized equipment needs and industry accepted safe operating infrastructure and right-of-way requirements associated with the close proximity and/or intersection of passenger railroad, freight railroad, heavy rail transit, or light rail transit system operations with any “Federal outdoor developed areas.”
Please note that there was some prior discussion of this issue by the Access Board, however I don’t believe the Board is currently aware that the latest proposed guidelines do not appear to specifically address or (preferably) exempt at-grade crossings with a railroad or rail-transit right-of-way.
Therefore, I again recommend that “Final” guidelines issued by The Architectural and Transportation Barriers Compliance Board (ATBCB) either include strict engineering guidelines adopted and approved in conjunction with the American Public Transportation Association (APTA), American Railway Engineering and Maintenance-of-Way Association (AREMA), and the Association of American Railroads, or a complete exemption for any incidence of at-grade intersection with a railroad or rail-transit right-of-way.
In the event one or more intersections between an “outdoor developed area” and a railroad right-of-way occur subsequent to the issuance of the Guidelines in their present form, the Access Board would then be faced with a significant technical interface problem that can easily be mitigated now with adequate prior planning.
To facilitate acceptance and issuance of the Guidelines, ATBCB could conceivably add an appropriate Exemption to the proposed guidelines indicating that “The intersections of existing or planned railroad, rail-transit or light rail right-of-way with any ‘Federal outdoor developed area’ are specifically excluded from these Guidelines.”
I also again suggest that this specific subject be referred to a joint Working Group of ATBCB, APTA, AREMA, and AAR representatives for further discussion.
Alex P. Goff, PMP
Director – Rail Systems Engineering,
Washington Group International
(Vice-Chairman, AREMA Committee 12, Rail Transit)
(Member-APTA Rail Transit Committee, Rail Grade Crossing Subcommittee)