For Want of a Door: Special Liability from Single-Door Vehicles

In the last installment of NBT, the notion of adding a rear door to motorcoaches used in certain duty cycles – primarily transit-oriented commuter/express and some scheduled/intercity service – was raised as a solution to both safety- and efficiency-related issues. Because all motorcoaches must have two doors by 2012 to comply with provisions of the Americans with Disabilities Act, variations of this requirement are worth discussing: A “lift door” between the axles would accommodate wheelchair users and other disabled passengers needing the lift. But such a door would provide few other benefits. So alternatives – particularly those employed in the transit industry for decades – are worthy of consideration.

Some motorcoach services – particularly tour and charter operations – have considerably less need for a rear stepwell than their transit counterparts. Stopping every few blocks to pickup or discharge passengers, transit drivers control the rear door largely to prevent passengers from boarding there, since doing so might help them avoid paying the fare. Tour and charter services do not have this need since passengers generally board at only a single stop, or a handful. In contrast, commuter/express passengers – for whom a rear door would be of most benefit – lie in a gray area: Their fares must be collected, yet the number of stops is considerably greater than for tour and charger service – although commuter/express services typically involve a handful of stops at the beginning of the run, and thus, fare collection and front-door boarding are manageable. In contrast, having a rear stepwell for alighting purposes would be of considerable value in commuter/express service in terms of both efficiency and safety – particularly where schedules are tight, and passengers seated in the rear might be induced (or required) to arise and begin walking toward the front stepwell while the coach is decelerating, braking and/or pulling into the bus stop. In such cases, the rear stepwell will accelerate alighting even while passengers remain seated until the coach comes to a complete stop.

Boons and Benefits

Including a rear stepwell – which could morph into an “active” wheelchair lift – would appear to offer a noteworthy range of benefits to motorcoaches deployed in commuter/express service:

  • Since a second door is required by the ADA anyway, the marginal additional costs of formatting it as an “active” lift would permit the rear stepwell to accommodate both disabled and non-disabled passengers, speeding up alighting, and making it safer. Particularly for passengers seated in the rear, they could remain seated until the coach comes to a full stop, since the rear stepwell would lie only a few rows away, at most. Overall, with the rear door providing a stepwell that all passengers could use to alight, the extra time that passengers remaining seated would encompass could be largely offset by the access to two stepwells in different parts of the coach.
  • Having a rear stepwell would also greatly facilitate vehicle evacuation in those rare instances where it is needed.

Certainly, an active lift is more costly than a passive one, and maintenance problems are generally more severe. However, problems with active lifts have decreased considerably since the ADA’s full implementation: The “bugs” have been worked out, lift technology has evolved considerably, and lift maintenance is not remotely the nightmare it once was.

Echoes of the Past, and Exceptions of the Present

Particularly in Europe, two-door motorcoaches are not uncommon. In many, restrooms have been carved out of the luggage space surrounding them, although passengers must descend much of the stepwell to reach them. Otherwise, to keep the rear stepwell from penetrating too deeply into the passenger aisle, these stepwells have often been steep.

In contrast to these mostly-European variations, certain domestic motorcoaches becoming more commonplace include simple, plug doors – particularly the double-decker units deployed in mostly urban sightseeing service. Given the size of the passenger capacities of such vehicles, having a second door available for evacuation purposes is almost essential, since many passenger have to first descend a spiral staircase from the upper deck to even reach whatever exit doors are available. Taking the ADA at face value – the 2012 deadline for full motorcoach compliance does not excuse double-decker sightseeing vehicles – these vehicles will need to be accessible by this deadline, just like every other motorcoach. Since this is the case, it would be an egregious mistake, as a safety matter, to install only a “passive” lift and its door in the rear, since a double-sized load of passengers (with half of them seated or standing on an upper deck) might have to evacuate through a single front door on the lower level. It is my strong hope that this constraint is not tested in a lawsuit following a catastrophic accident, where the absence of a second door would almost certainly become a central issue.

Compromises and Conundrums

One enigma that two doors would create is the fact that it is the industry standard for motorcoach drivers (commuter/express service excluded) to stand at the base of the stepwell to assist passengers onto or down from the bottom step, and remain in position to “spot them” should they become unstable and begin to fall down the stepwell. Of course, this requirement is not always followed in the real world, and a common theme of accidents where passengers indeed tumble from the stepwell is that their drivers are nowhere to be found. In contrast, European operations involving two-door motorcoaches generally have tour guides on board, providing a trained adult to monitor and assist passengers at both stepwells.

Further, on single-door U.S. motorcoaches, drivers providing physical assistance to passengers ascending and descending the stepwell is a rarity, even though it is a formal requirement for disabled passengers under the ADA where the coach-in-question does not contain a wheelchair lift. Regardless, two door coaches present opportunities that could be worked out at the operating level. For example, passengers unable to board or alight safely via the stepwell could use the lift, and drivers could sort out those passengers requiring boarding or alighting assistance, and funnel them to the rear door, where the driver could physically assist them up or down the steps. The more able-bodied passengers could fend for themselves. The availability of modern coaches’ kneeling features, and the ability to kneel the entire side of the coach (as some configurations allow), could ameliorate the risks to able-bodied passengers, permitting the driver to provide a higher degree of assistance to those less able to ascend and descend independently. Because of the rear door’s width (the ADA requires the lift platform to be at least 30 inches wide), and with an “active” lift providing a stepwell, the door and stepwell width otherwise constrained by the small distance between the front cap to the front tire could be expanded, providing more space for a driver to physically assist passengers up and down the stepwell. And the constraints lying at the front doors that interfere with the installation of continuous handrails (yet another ADA requirement) could more easily be addressed by a broader choice of door designs.

Connecting the Dots

Vehicles with rear doors and motorcoach-quality safety and comfort features are easily obtainable in urban transit applications in either bus or coach format. A short five years from now, every single motorcoach will contain a rear door. Since this is the case, it would make sense to install one formatted so that every passenger can use it – not just disabled ones. Transit buses have contained “active” lifts (which morph into stepwells) in either the front or rear doors for more than three decades now. Little work would be needed to adapt this technology to motorcoaches, and there is no need to follow the restroom-location formats common to many European coaches. If we continue to deploy these vehicles in multiple-stop scenarios like commuter/express service, we should give some thought about installing an active lift, and providing the additional stepwell for all passengers that comes with it.

Patent and Latent Benefits

Some benefits of this approach – such as facilitating vehicle evacuation – are obvious. Such approaches should perhaps be given special consideration given our recent history and its likely replication as we continue melting our icecaps, raising sea levels, and exacerbating both the frequency and severity of tropical storms. Improved evacuation is also invaluable given our escalating and flagrant tendency to curry disfavor with practically every nation on Earth, and the vulnerability our public transportation network necessarily experiences as a consequence. But the generally-ignored consequences of tightly-scheduled operations deploying single-door vehicles also merits some consideration. This is true even while it may be cheaper for a defendant in a slip-and-fall accident to make an occasional pay-out or settlement.

One fine sun-shiny day, some motorcoach CEO may actually roll out of bed with this solution, and it may even last through breakfast. Let’s hope so. It would be really nice if the first coach offering this solution was designed and built right here.

Publications: National Bus Trader.