Changes in Greyhound business practices jeopardize the already-limited options for cross-country travel by people in the USA who don’t have, or don’t chose to show, government-issued  ID credentials.

For local transportation, undocumented people who want or need to travel further and/or faster than they can walk can ride bicycles (although there have been proposals in some jurisdictions to require registration of bicycles and/or bicyclists), or use public mass transit (where it exists, and where fares can be paid anonymously in cash, which isn’t the case with some cashless transit fare payment schemes).

Long-distance travel options for people without papers are even more limited. Policies adopted by airlines and Amtrak, combined with ID requirements for drivers of private motor vehicles, have left long-distance bus companies as the carriers of last resort for long-distance travel by undocumented people.

The options for the undocumented get even narrower when one starts looking at specific routes. Greyhound is the only company providing scheduled transcontinental bus service, a truly national route system, or any intercity bus service to many destinations in the USA.

That makes Greyhound’s route system and ID policies, or the lack of any Greyhound policy conditioning domestic US travel on possession or display of government-issued ID, of paramount importance to anyone who wants to move about the US without showing ID.

To be clear, these are business choices by Greyhound, as they are for competing intercity carriers, not government requirements. No law requires airline, Amtrak, or intercity bus passengers to show ID, or requires any of these transportation providers to demand that their customers have papers. But Greyhound, at least to date, has made different business choices in this regard than have airlines or Amtrak.

All US airlines operating scheduled services have clauses in their conditions of carriage which, despite the airlines’ obligations as common carriers to transport all would-be passengers, purport to require all passengers to show government-issued ID on demand of airline staff and/or airline contractors.

You can fly without showing ID to the TSA or its contractors. But before you get to the TSA checkpoint, you have to provide the details of your ID document to the airline, which will then pass this information on to the TSA.

As a Federally-chartered government entity, Amtrak should have at least as strong an obligation and commitment to universal access to its services as any private carrier. But like the airlines, Amtrak has also promulgated conditions of carriage that purport to require all adult passengers, including purely domestic passengers, to show ID on demand.

Greyhound voluntarily allows US Customs and Borders Protection (CBP) agents to board its buses, requires (or purports to require — so far as we know, this provision of Greyhound’s tariff has never been challenged or reviewed by any court) international passengers to show ID, and voluntarily provides information about all passengers on international routes to CBP. We’ve seen records of cross-border bus travel, provided voluntarily to CBP by Greyhound, in files from the CBP Automated Targeting System.

But, crucially, Greyhound to date has not tried to adopt or enforce conditions of carriage requiring passengers traveling entirely within the US to have or show any ID.

Recently, however, Greyhound has entered into an “interline” agreement for Amtrak to provide transportation on Amtrak trains to passengers holding Greyhound tickets on certain routes, including a section of the key transcontinental route along Interstate 80.

Greyhound has discontinued all service of its own between Reno and Salt Lake City on this route. That leaves undocumented travelers (who don’t or aren’t willing to meet Amtrak’s requirements for all adult passengers to be prepared to show ID to the train crew on demand) out of luck, or at risk of being put off the train in the middle of the night in the middle of Utah or Nevada if they can’t or won’t produce their papers on demand.

Earlier this year Greyhound discontinued its last route to or through Montana, leaving it with no service between Minneapolis and Seattle along either I-90 or US-2. With the termination of Greyhound service across Nevada on what used to be its main route along I-80, there’s a huge hole in Greyhound’s national route map (although, as with airlines, “codesharing” obscures the gaps). Undocumented travelers between San Francisco and Salt Lake City or all points east  will be detoured 500 miles south through Los Angeles.

If Greyhound continues to cut long-distance routes in favor of “interlining” with Amtrak, without insisting on terms in its interline agreement insuring that Amtrak will act only as a subcontractor providing transportation subject only to Greyhound’s terms of service and not acting as an agency of the surveillance state, routes open to undocumented travelers between other places in the US could become similarly circuitous, or cease to exist at all.

The terms of the interline agreement between Greyhound and Amtrak have not been made public, and it’s not mentioned on Amtrak’s website. It could include provisions forbidding Amtrak from demanding ID from passengers holding valid Greyhound tickets or disclosing information about Greyhound passengers to government agencies other than Amtrak itself.

We doubt, though, that Greyhound tried to negotiate any such terms, or that Amtrak would have agreed to them.

In our experience, Amtrak staff — to their credit — almost always ignore their orders to demand ID from passengers.  Amtrak had to lie to its software developers, telling them falsely that requiring ID and providing information about passengers to the government was “required” by US Customs and Border Protection,  to get them to code this into Amtrak’s IT systems. Amtrak’s legal department and in-house police department, however, appear to have been willing accomplices in government surveillance of travelers.

We’ve made a Freedom of Information Act request to Amtrak for the interline agreement between Amtrak and Greyhound as well as any other Amtrak records related to ID demands or sharing of information about Greyhound passengers with third parties. We’ll let you know what Amtrak discloses in response to our request.

In the meantime, if you’ve traveled on Amtrak on a Greyhound ticket, please let us know if you were required to show ID, if you were warned when you bought your ticket (or later) that you might be required to show ID, or what (if anything) you were told when you bought your ticket about whether you would be subject to Amtrak’s conditions of carriage.