Patrick Christian, Casco Bay Island Transit District
January 10, 2005 [Hearing Testimony]

MR. CHRISTIAN: Thanks for allowing me to speak today. For some of you, we've met in the past. I'm the general manager of the Casco Bay Island Transit District. My name is Patrick Christian. Fortunately, we had the Access Board and the staff come to Maine in 2002 and 2003, and they made stops off at our little ferry boat operation.

And our little ferry operation has five boats. We operate 365 days a year to six islands off the coast of Maine. And they would be classified here as subchapter K vessels. They're 300 to 399 passenger vessels, although they're fairly small boats, 65 feet, about 24 feet for two of them, ranging from 85 to 120 feet for the other three.

And what I'm going to bring to you today are three issues that I'd like you to consider. And I'll give you a brief background, and then I'll get out of here. The access from vessel to shore of 1 and 12, the exemptions for that or the exceptions for that are critical in our operation, and I'll come back and talk about that later. And, by the way, I do appreciate all the work that the Passenger Vessel Access committee did. It was really good work.

Two, the so-called grandfathering of existing vessels and facilities are important, although we do have some issues about making sure the term "alterations" are clearly identified.

Three is where we'll lead a little bit away from our Passenger Vessel Association. We feel

that -- Casco Bay Island Transit District feels that the demarcation line is arbitrary at 150 passengers. There should be a subchapter, a super K or 600 passengers would be more realistic. Our little ferries, although they seem big to some, it's very difficult in the environment we operate in to meet all of the requirements.

But let me just go over and tell you very quickly about our operation. I think one of the things I'm proudest of, the Casco Bay Island Transit District came into being in 1982 when the bankrupt Casco Bay Lines went into receivership. And, starting in 1984, we've had a record of every time we've dealt with the boat we've tried to improve its accessibility. We've never denied anybody transportation. We help everybody on and off the boat. We have two deckhands at the gangway any time we're operating.

As a matter of fact, last week, the conditions were so rough out that it didn't matter what kind of condition you were in. We had to help people on and off the gangway at the islands.

And, in 1985, we designed our first ferry, made sure it had handicapped accessible heads, an area for wheelchairs. In 1987, when the ferry terminal was built, we made sure it met all the requirements.

In 1994, when we built our first passenger boat, we had an elevator between decks. So, a 399 passenger boat, we put an elevator between decks. In 1998, we retrofitted the Island Romance, a 65-foot boat. We couldn't put an elevator in it because the boat was too small, but we did put a lift in it. We call it a passenger lift. I'm not quite sure where that fits between a lulu and a platform lift, but we put a passenger lift in there.

In 2001, we did the same thing to the Bay Mist; we put a lift in that boat. And in both these last two boats I'm talking about, we increased the size of the heads and made those accessible.

Our new boat that is currently under construction, the Aucocisco III, is replacing a 38-year-old ferry, the Island Holiday. And, once the Board and staff came to visit us, we submitted our plans and asked for and consequently made changes in the design of the boat to try and make it more accessible.

So, I mean, our effort has been to try to make our operation accessible, and it's not for all altruistic reasons. I think it's the right thing to do, but I think it's good business sense. The thing I'm asking for today is that we keep everything realistic.

Our tidal range is upwards of 14 feet. We have to operate the fixed piers. We cannot put floats in. They get blown away. Any time we have any kind of severe weather, anybody who is operating on all floats, they're hurting in Maine.

In our case, we have fixed piers on the islands; we don't have steel vessels. We have a fixed facility in Portland. When we looked at designing the ferry terminal to put a ramp that would meet the 1 and 12 at the ferry terminal, it would start at the waterside and run through our entire building and be out as far as the parking lot. And I don't say that to be humorous. I'm just telling you, that's the kind of conditions we're having to deal with in Maine. And, again, what we try to do is we've designed and worked with the Maine Department of Transportation as they built the fixed docks and the down bay islands. It used to be that you just had a top level, and then a midrange or a low level.

We've actually put in intermittent level ramps so that we can actually meet the standard about half the time. But the other half of the time, we won't be close to meeting the standard if it were required to remain at 1 and 12.

And so I think it's been very important that the work done by both the PVAAC and the Access Board has taken those kind of things into consideration. That exception is important to us.

The other exception is the so-called grandfathering. And, again, I want to tell you that operations like ours are going to try every way we can to continue to keep our boats accessible, but I'm concerned about whether we'd be required, if we did any major alterations to one of our smaller boats, that we'd have to put an elevator in it, as opposed to a passenger lift. From a stability standpoint and a space standpoint, it would be very difficult.

So that's why we had to go -- but with our newer boats, because we can design around and they're bigger, we're happy to put elevators on that.

We have a little concern about also our car ferry that we built in 1985 that we put accessible heads and areas for wheelchairs to be located and assistance to be able to sit by them. We did that back in 1985. That is a three-deck boat. It does not have an elevator to either the second or third deck. That would be a major concern if we did something of major alteration where we'd have to put an elevator on that boat. There's just no room on it right now. But I just want to make sure that I got that mentioned.

The last, and probably the most difficult maybe for you, and I've been told this is the hardest nut to crack, is the idea of the arbitrariness of establishing a 150 passenger limit for small versus large.

We have a small operation. We're publicly owned and operated. We carry between 300 and 399 passengers on our boats, but as you see, with a boat that's only -- well, it's technically a 65-footer, but there's only 59 feet of deck space fore and aft and 22 feet from a beam.

And it's difficult to think of the idea that only through the mastery of the naval architecture profession that you could actually cram 300 people on this boat. It's actually a small boat. So we would encourage you to at least consider that.

I'll be glad to answer any questions. I have my comments that I'll pass along to staff and then we'll, of course, make our written comments. We do want to echo the statement made by Ed Welch that any extension of time, especially if we get 60 or 90 days beyond the current I guess it's March 28 deadline, would be helpful because we spent a lot of time trying to read the regulations. I can't pretend to tell you that I really understand them or the impact of them, but we would like to have a little more time to think through this. Questions?

MS. [JAN] TUCK [BOARD CHAIR]: Any questions?

MS. [PAMELA] DORWARTH [BOARD MEMBER]: Pat, my question to you would be also, any of your vessels --

MS. TUCK: Can you speak into the mike, please?

MS. DORWARTH: Oh. I'm sorry. I can't hear, so I don't speak too good either. Are any parts of your vessels or anything constructed outside of the country?

MR. CHRISTIAN: Oh, no.

MS. DORWARTH: Okay.

MS. TUCK: Anything else? Great.

Thanks, Pat.

MR. CHRISTIAN: Thank you.