Cruise West
July 26, 2005 [Email]

Cruise West
Up-close, casual and personal
2301 5th Avenue, Suite 401 * Seattle, WA * 98121
Phone (206) 441-8687 * Fax (206) 441-4757 * Reservations 1-800-888-9378 * www.cruisewest.com

July 26, 2005

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:

Cruise West, 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.

West Travel, parent company of Cruise West, was established in 1973, and is owned by the West family of Seattle. During the 1970s and early 1980s the firm operated motorcoach tours and sightseeing as well as dayboat cruises in Alaska. In 1989 the company acquired a 58-passenger small cruise ship and began offering a new series of overnight cruises from Juneau in 1990.

Cruise West now owns and operates a cruising motoryacht (70 passengers) plus a fleet of six small cruise ships with overnight accommodations for 78 to 120 guests. The majority of Cruise West’s vessels are American-owned, American-built and American-crewed. All of the company’s U.S.-flagged vessels are less than 100 GRT (gross registered tons), between 90 and 217 feet in length, and were built between 1976 and 1986. The latest addition to the fleet is 295 feet in length with a capacity for 120 overnight guests, 1,263 tons (net), and was built in Italy in 1991. Seasonal company employees (vessel crew and land staff) number approximately 300 and full-time employees number about 120. The overnight vessels have a compliment of 21-28 crewmembers and the daylight yacht carries 8.

The sightseeing itineraries are focused on the people, culture, and natural surroundings. The vessels frequently operate in seldom-traveled waterways with port calls at remote Native villages or small isolated towns—and even a lone dock or secluded beach. Some can only be accessed by inflatable motorcraft (i.e., zodiacs). All ports of call are owned or controlled either by private entities, Native corporations, or local port authorities.

Combined, there are approximately 50 various locations where guests might have the opportunity to disembark the vessels. Shore excursions are contracted with local vendors, who also provide ground transportation. Cruise West maintains vessel support staff including ground transportation in Seattle, Portland, San Francisco, Juneau, Ketchikan, Petersburg, and

Anchorage. Besides Alaska, destinations feature British Columbia, the Columbia and Snake Rivers, California, Baja Mexico’s Sea of Cortes, Costa Rica and Panama, the South Pacific and Japan.

In 2005, Cruise West vessels will have 223 departures and carry 13,000 passengers, with the vast majority of those sailing between April and November. Approximately 150 passengers with disabilities will sail on the vessels, generally including those with hearing/sight impairment and mobility limitations.

Cruise West vessels are small with close quarters for both passengers and crew. Crewmembers assist as much as possible with embarkation and disembarkation of passengers with disabilities. Written materials and visual aids that are itinerary-specific are provided on all cruises. Hearing-impaired hotel kits are made available; Braille signage, handrails and grab bars have been installed. At the time of making a reservation, passengers who identify themselves has having disabilities are given information about the vessel and itinerary limitations. They are advised that, due to tides or weather conditions, some off-vessel activities might not be safe and might be limited by the vessel Master.

Access between decks is by stairways except on the two vessels that have elevators. Providing vertical access on the other vessels is infeasible. The vessels do not have the space, stability margins, or electrical capacity to accommodate an elevator. All of the stairways are escape paths making the use of a wheelchair lift problematic.

I was invited to make a presentation during the Access Board hearing in Seattle on September 9, 2003, regarding accessing small cruise ships from dock facilities. My presentation then and arguments now stress the serious impracticalities of the draft guidelines regarding passenger boarding. It is very unclear how zodiac operations can comply with the draft guidelines requiring at least one wheelchair accessible passenger boarding system connecting an entry deck to fixed piers, floating piers, or undeveloped land.

We would encourage members of the Access Board to visit our website at www.CRUISEWEST.COM in order to better understand the operations and vessel layout of small cruise ships.

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 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. Most vessels to be affected by the Access Board action are not cruise ships.
• 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,

Bryce Brockway
Vice President, Marine and Hotel Operations