So just to confirm, having an accessibility platform sized gap without a ramp is verboten, whereas having a step up from the current height is okay?
Well, here's where it gets funny.
There is nothing in any of the Transport Canada rules that say anything about gaps between rolling stock and platforms, other than where they should be/line up within the clearance diagrams.
But.....then the accessibility rules come into play, along with the lawyers and their "silly rules" on liability. While on the railway side of things there's no issue with a gap of a foot or more between a piece of rolling stock and a fixed platform, it becomes pretty obvious that there is no way without an additional piece - the loading ramp, in this case - to allow for a wheelchair or mobility device. And then there's the issue of liability - sure, you or I could jump that gap, but could *everyone*? And thus, is it a reasonable ask that people jump that gap when there may be better ways to circumvent it?
And thus, we've come to where we are today - a fixed step on a piece of rolling stock - which fits within the clearance diagrams - is okay because it covers almost all of the above. It meets the TC rules, it fits within the clearance diagrams, and it easily allows most people to access the equipment/system without undue danger.
I haven't heard anything about the progress of any design work by Bombardier to introduce adjustable gap fillers to the coaches. There are other systems using BiLevels with level boarding, such as the Utah Frontrunner, but those systems only have level platforms. GO's challenge is dealing with the interm situation where some platforms are still at 127mm and still require a physical step on the train.
So, I think I need to issue a mea culpa here.
I referred to "TC and FRA standards for platforms" earlier. I should have just said TC, as the FRA has allowed far more standards in the US than are capable here in Canada.
For instance, there is a standard - colloquially known as the "Western Standard" - which allows for almost-floor level loading of the bottom level of a Superliner/California/Surfliner car. This standard is 15" above the top of rail. As well, the FRA allows for alternative heights to any of the standards in specific cases should certain criteria be met - and it is under this that Utah's Frontrunner has built ~22" high platforms that allow for level loading with the floor of their BiLevel coaches.
As for adjustable gap fillers on the equipment, most of the Bombardier BiLevel cars built for the US market in the past 10 or 15 years have been fitted with powered ramps/gap fillers to meet their accessibility requirements. (Most US properties running BiLevels use more-or-less the same accessible ramp design as was pioneered in Toronto.) I've always found this amusing, as while Metrolinx with all sorts of additional-cost "extras" - larger door windows, powered end doors, additional exterior lighting, etc. - the powered ramps are the one thing that they've not ticked the box on.
Dan