City of Seattle Fire Department - Comments

These are minimum upgrades that will enhance safety. The issue of Rooftop Access for emergency personnel may be updated to increase the size and number of rooftop access portals. The ability to "cut in to" passenger trains as part of emergency rescue is extremely limited due to heavy steel construction. Rooftop access is critical for Emergency Responders. Although not mentioned in this proposed rules, the requirement that passenger trains must stop when the 'emergency door open request' is made by anyone on the train should be reviewed. This may not be the safest operational requirement in all situations. Specifically for trains on fire in a tunnel, opening a door and therefore stopping the train in a tunnel may endanger more people than allowing the train to exit and stopping after exiting. Newer passenger trains are, in some cases installing on board fire detectoin, cameras, and fire suppression systems that may provide critical information and therefore an informed decision on whether to stop the train or not. In some cases automatically opening the door for minor smoke in the car, may be far worse simply because the fire could then grow substantially while the pasengers are still inside the tunnel vs alllowing the train to exit to an area of safety. Thanks