MR. BEKOFF: Good afternoon, Madam Chair and Board members. My name is Bob Bekoff. I'm the president of a company called Water Taxi. I'm another Floridian that's up here to get cold today.
We operate in -- well, I guess I've got to do my own bidding here. We've been in business since 1988. We run a service in four different cities: in Ft. Lauderdale, Florida, in Miami, in Oklahoma City -- and yes, there are water taxis and there is water in Oklahoma City -- and also in a place called the Woodlands, which is 25 miles north of Houston. And we run a water taxi service. We do some tours. And we run point-to-point service for special events. We do quite a bit of that.
In total, those are pictures that are representative of some of the vessels that we either have run, owned, built, sold, so on and so forth, in different degrees over the past 16 or 17 years. And, currently, we operate 28 vessels that are all accessible under the definition of "readily achievable" and "functionally" and "operationally feasible."
Our contention -- in request for the input at this meeting today, our contention is that small vessels -- and I think you've heard this from just about everybody -- have more challenges than large vessels. The accessibility on larger vessels seems to get easier as the size increases up to a point, until the size is reached where the increases really don't make very much difference.
For instance, the difference between an 80-foot dinner boat and a 100-foot dinner boat probably isn't enough to make it that the aisles aren't wide enough or the doorways aren't wide enough; there's
not -- that there's enough room for an accessible bathroom and so on and so forth.
Conversely, what happens when you go down in size? The accessibility on a smaller vessel becomes exponentially more difficult as the size decreases. Now, up there are three different vessels, a 42-, a 38-, and a 26-foot vessel.
And, at one time, we operated eight of the type of vessels on the bottom lefthand side. Did we ever have people with disabilities on board? Yes. The only way to get them on board was to carry them on board, unless they could use the handrails to support themselves and get on board.
That is probably the most common type of certified Coast Guard passenger vessel that exists in the United States, all your yacht club launches and small water taxis and some small tour boats and so on and so forth. There's probably literally maybe over 1,000 of those. That's probably the most common type of vessel on the water today.
In your recommendations or in your information, it talks about a 65-foot vessel with a 16-foot beam with 700 square feet of program area and 149 passengers. And while this complies with a United States Coast Guard cutoff for certain standards of design and stability and so on and so forth, to say that that is -- and you even used the term -- that that is a "water taxi," I'm going to tell you that I would beg to differ with you to the extreme.
That is a vessel that is really the top end of a size range rather than anything that you'd commonly find in small boat service.
Vessels of this size typically can carry up to 149 passengers. They generally operate -- if they're in ferry service, they'll generally operate between two points. And operating between two or three points means something very significant from an accessibility standpoint, and that is that they probably have dedicated landings that they control on all sides so that they can control the accessibility.
Again, the length, the beam, the passenger capacity conform to the Coast Guard parameters, but the square footage of the program areas and the beam suggest that they are much larger than the usual small passenger vessels.
For instance, here's an interior of a typical dinner boat, an interior of a tour boat. Many small excursion boats and water taxis are usually under 45 feet, and most run to 35 feet. Again, the type of vessel, the 26-footer, that builder has probably built, I don't know, maybe 200 or 300 of those boats all out of the same mold.
The 26-footer that you see is licensed for 27 passengers plus a master. The 35-footer carries 49 passengers. And when you look at those and you look at a 65-footer, it's a remarkably different set of circumstances.
All passenger vessels, small passenger vessels in particular, they're built to maximize the seating, the maneuverability, and the stability, which are the core criteria. The safety aspect comes into all of that.
And the reason that I say things like maneuverability is, generally speaking, like in a water taxi operation, you don't get the front of the dock. You don't get all of the wide open space that you'd like to have.
They say, well, if you want to land over here at my restaurant or if you want to land at my marina or if you want to land at my hotel, you can go around the back over there, okay, and see if you can find a little bit of space. It's the main reason why we came up with the idea where we load off the bow with very many of our boats. And, as the floor plan decreased, the problems intensified. The resulting costs of these criteria remain fixed for the life of the boat.
We also build boats. We built 34 passenger vessels in the last 10 years. Whatever you start out with -- and we call it kind of like how much per rear end are you going to pay for this boat -- and when I see boats that come up and somebody is going to put them into passenger service and they're spending $12,000, $14,000, $15,000 per seat, I can tell you, unless my mathematics is very bad, that they will never make a dime with that boat. It's absolutely impossible.
Things such as -- I say here size matters. Aisle width, program area size, and space for transfer devices decrease dramatically as sizes are reduced. This is one of our old boats right here. The center seat, if you will, that you're looking at down the middle is actually the engine box. The engine protrudes up above the deck. There's not an aisle there that, if you've got a size 12 shoe, that you can walk through without turning sideways. That's a 27 passenger vessel.
Now, just to show you in scale what the differences are, we just drew out a 149-passenger boat. It's actually about 156 seats. So I didn't put any heads in or anything like that, but if you wanted to put a couple of heads in there that were ADA accessible and everything else, you'd probably still wind up with about 148, 149 seats. But that's 65 feet. It would fall under all of the categories of the 700 square feet. It would meet the 16-foot beam, the 65-foot length.
Now I've superimposed one of our 42-footers over the 65-footer, and you can see that it's a very dramatic difference as to what you're left with. And those boats will carry up to 72 passengers.
When you bring it down to 35 feet, superimposed over the 42 and the 65, it becomes even more noticeable.
And now let's go to maybe the heart of the matter. Here's a boat that was one of the first boats that we had. It's a 21-foot Crosby launch. It was licensed for 21 people. And that's a very, very common club launch. There's literally hundreds and hundreds of those floating around in the waterway carrying Coast Guard certificates and carrying passengers every single day.
So I think it's pretty easy to see that lumping everything together as a 65-footer and under and to come up with one criteria for that is pretty hard.
Now I try not to be the kind of person that says you've got something wrong with your program and then I walk away without making any suggestions, so I've made a few. And I've to got to apologize right off the bat, and I hate to do that in a presentation, but I've got a typo in here and I'll bring it out to you.
I like option 2, but I think option 2 has to be even more specific than it is, even though it goes into quite a bit. I think language must be added to include operating and functional feasibility, and I think it has to be more than just that sentence.
I think it behooves the Board to do some more homework on what is operationally and functionally feasible. You know, for instance, when you talk about a transfer device on a 21-foot boat, well, okay, you're all done now. You've probably got the capacity to handle the transfer device and that's about it.
I'm going to propose some subcategories, and here's where my typo is. Under "length," that should say 36 feet to 45 feet -- excuse me, 36 feet to 65 feet. But that being as it may, with a beam of 13 to 16 feet, 700 square feet in your program area, a capacity not to exceed 149, and then let's get into some of the more specifics.
The number of wheelchair placements and / or transfer locations, as you know, some of them can be shifted off. You can have up to 50 percent. I'm saying three tie-downs and three transfer seats, which would basically comply with what your regulation is now for that size boat.
Now let's go to a 36- to 45-foot boat and a beam of 10 to 13 feet, which is, practically speaking, what someone would probably build a boat like that to have the necessary maneuverability. That's not going to have 700 square feet of program area. It's going to have far less than that. You wouldn't have 700 square feet, you know, unless it was a doubledeck boat, and then you're not going to have the stability in that size.
Passenger capacity of less than 99, one tie-down, one transfer seat. And then I'm saying under 36 feet with a beam of less than 10 feet, 49 passenger capacity and one tie-down and one transfer seat.
The boat operators that are here will recognize some of the numbers that I pulled out, where 149 is the Coast Guard regulation for construction and stability, as is 99 passengers and as is 49 passengers. So it's not something that I just pull out of the air. It is, in fact, in the regulations now as to what you need for certain things like subdivisions and fire prevention and so on and so forth.
On smaller vessels, entry and gangway requirements with some wider latitude. Think of what Pat said with 14-foot tides in the main area, and now think about how you get somebody on and off a 26-foot boat or a 42-foot boat. It's incredibly difficult, incredibly difficult.
So many small vessels are forced to use more constricted loading areas and with less room for longer transition plates. Transition plates are fine, but, you know, in some of these vessels, the transition plate or ramp might exceed the length of the vessel.
Make allowance for trained crew to be used in lieu of larger devices. There's no reason why trained crew can't assist people, especially when you're talking about a small vessel, and make them feel very comfortable. And I can tell you that from personal experience; we do it every single day.
Every single day, we have training regulations in our employee manuals as to how to assist somebody on board, no matter what the impairment is, and what to do. There are things in the regulations about latchdowns and chair restraints and lap belts and so on and so forth.
Just for the heck of it, when I saw the notice come out back in November, I said to my crews, I said would you start just filling out this little piece of paper. I gave them a little form with about three lines on it. Tell us when you pick up someone with a handicap, especially if it's a wheelchair, where you picked them up, where you dropped them off, so on and so forth, and what you did and did they need assistance, did they not need assistance, and all this type of thing.
Number one, the thing that really struck me was this: probably 90 to 95 percent of the people that came on board with a chair got up out of the chair and sat in a regular seat. And I was really surprised to see that.
The thing that people objected to the most and almost, I think with one exception, they all refused to have the chair strapped down or to have a lap belt put in place, every single one of them. But I think there was one exception. So a trained crew I think is vitally important.
Make allowances for the trained crew. Again, many small vessels are licensed to operate with a master only. For instance, that boat right there, which is a 38-footer, which is licensed up to 74 passengers, if we only carried 27 passengers, we can operate that vessel safely with a master only.
So now, if we're talking about doing something like operating a transfer device or transition plates and so on and so forth, it gets pretty problematical because now the only way that you could assist anybody or even just make sure that they're not in any danger of having any kind of a mishap is the operator now has to leave the helm. The Coast Guard says you're not supposed to do that.
Any new regulations must conform with the United States Coast Guard requirements. All the rules of the road must be upheld. You can't put the vessel operator in the position of violating the rules of the road, violating what we're licensed to do, asking the operators of the vessels themselves to violate their master's agreement.
The rule of prudent seamanship must be observed, which basically says, when all else fails, do whatever you've got to do to avoid a collision or an accident. So, you know, right now, you cannot refuse anybody entry to your vessel because of a disability.
What do you do if that one master by himself, if he had to assist the person, gets injured? And there are cases where that can absolutely happen. So I'm not saying, boy, throw everything out the window. I'm saying just consider it. And consideration must be given to those master-only vessels.
Develop different guidelines for coamings on smaller vessels. You know, I don't know if there's a vessel out there that operates in a marine environment right now that's got a Coast Guard COI that has a doorway that doesn't have to have a three-inch coaming.
Now what do you do for a 1 and 12 ramp if you've got a three inch coaming and you don't have three feet on either side of it? Okay? Right off the bat, you're licked. So it's something that has to be considered and, again, consider using trained crew where the ramp length is restricted.
And that's me. I'd be happy to answer any other questions. And thank you very much for the opportunity to appear.
MS. [JAN] TUCK [BOARD CHAIR]: Any questions?
Thank you very much.
MR. BEKOFF: Thank you.