American Canadian Caribbean Line
July 28, 2005 [Email]

Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street NW, Suite 1000
Washington, DC 20004-1111

Ladies and Gentlemen:

American Canadian Caribbean Line Inc., a member of the Passenger Vessel Association, submits these comments regarding your efforts to develop accessibility guidelines for passenger vessels, as published in the Federal Register of November 26, 2004. Please include these comments in the official record of both of your dockets as well as the corresponding U.S. Department of Transportation Docket.

American Canadian Caribbean Line is a family owned business operated on a year round basis. We have operated 3 small passenger vessels, with passenger capacities of 84 to 100, for over 36 years.
Our areas of operation include the Great Lakes, St. Lawrence Seaway, New England Coastal, Mid-America/New Orleans to Chicago, Intracoastal Waterway, Eastern Caribbean and Central America (Belize to Panama). Our itineraries vary in length but range from 5 nights to 16 nights with a different port of call done on a daily basis. In the Caribbean certain itineraries do multiple stops during one cruising day. We employ approximately 75 people year round.

American Canadian Caribbean Line is particularly concerned with any changes in regulations that will impact our unique vessel design. All ACCL vessels are designed to travel small inland waterways with restricted air draft and land on beaches to allow passengers access to remote and isolated areas. (see attached photos). As the areas we travel in are remote and the marinas we visit are not under our control, setting too strict gangway requirements could put us out of business. We feel strongly that access requirements should not restrict or inhibit unique vessel design.

We are aware that the Passenger Vessel Association has been in frequent contact with the Access Board regarding this rulemaking, including testifying at public hearings three times in 2005. I support the following points that PVA has stressed in its comments:

• Providing access in marine and aquatic environments is more challenging than doing so at sites on land. Waves, wind, tides, fluctuating river and lake levels, and various types of vessel motions must be contended with. In designing, constructing, and operating a vessel, there is no higher priority than safety.
• There is a wide diversity of types, sizes, and functions of passenger vessels in the U.S. domestic passenger vessel fleet.
• Designing accessibility into a vessel becomes exponentially more difficult as the size of the vessel decreases. Therefore, it is appropriate to have one set of guidelines for vessels with a capacity of more than 150 passengers, and a different set for vessels with a smaller passenger capacity.
• The Access Board should develop its guidelines for vessels with a capacity of more than 150 passengers first, waiting until after this work is complete before further studying and developing guidelines for smaller vessels.
• The recommendations of the Passenger Vessel Access Advisory Committee, on which four PVA members participated, are preferable to the proposed guidelines put forth by the Access Board.
• Any provision that passenger vessels be required to provide vertical access between decks should be tailored very narrowly to those vessel designs and capacities that are capable of safely and efficiently containing elevators or lifts. In many cases, installing elevators in vessels is technically infeasible, structurally impractical, and potentially unsafe. This is particularly true for small vessels.
  
  Thank you for this opportunity to participate in your rulemaking process.

Sincerely,
American Canadian Caribbean Line
Nancy Blount
President