Blue & Gold Fleet
July 27, 2005 [Mail]

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

Ladies and Gentlemen:

Blue & Gold Fleet is 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 official record of both of your dockets us well as the corresponding U.S Department of Transportation Docket.

We are a private company who operate fifteen vessels in the San Francisco Bay Area year round. The vessels are certified to carry between 300 and 693 passengers depending on the vessel. We provide ferry service between San Francisco and six municipalities in the Bay Area as well as Angel Island and Alcatraz Island. In addition, we do sightseeing cruises and charter our boats for private events. We carry in excess three million passengers annually.

We seek and receive input from Richard Skaff Disability Access Coordinator for the City and County of San Francisco on matters related to accessibility. Following his recommendation our landing facilities at each location where we dock have been designed to accommodate passengers with mobility needs. Aboard our vessels the heads have been modified so that they are handicap accessible. In addition, our deckhands have been trained to assist passengers who are in wheelchairs if they request or require assistance. Of the approximate 3 million passengers we carry annually about 1.3 million go to Alcatraz Island. It is impossible to estimate how many passengers with disabilities we transport on an annually basis, but on Alcatraz we operate a tram which is available for wheelchair users and passengers with mobility needs who are unable to walk up the quarter-mile, 12% grade hill.. That tram on Alcatraz Island carries about 25,000 people a year to the top of the hill where the cell house is located.

I am 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 a t 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... Most vessels to be affected by Access Board action arc not cruise ships.
• Designed 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 completed 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 lists. To 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,

Carolyn Horgan
Vice President, Operations
Blue & Gold Fleet
Pier 41
San Francisco, Ca 94133