Freeport Shipbuilding Group, Inc.
July 25, 2005 [Mail]

FREEPORT SHIPBUILDING GROUP, Inc.
116 SHIPYARD ROAD P.O. BOX 49
FREEPORT, FL. 32439
PHONE 850-835-4125 FAX 850-835-4873
July 25, 2005

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

Ladies and Gentlemen:

Freeport Shipbuilding Group, an associate 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.

My company, Freeport Shipbuilding Group, has been designing and building U.S. Coast Guard certified passenger vessels since 1981. During that time we have built in excess of sixty (60) certified passenger vessels ranging in capacity from 49 passengers to 1600 passengers. The majority of our vessels have been in the 150 to 300 passenger range. These vessels typically vary in length from approximately 60' to 120'. As you can well see these are not cruise ships.

In our designs we make every reasonable effort to accommodate passengers with disabilities, including but not limited to ramps at boarding doors, handicap accessible restrooms, etc. The physical size of these vessels, especially those certified for 150 passengers or less, simply will not allow the space to install an elevator or lift.

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,

James M. Murray,
President-Freeport Shipbuilding Group, Inc.