Gateway Clipper Fleet
July 27, 2005 [Email]

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:

Gateway Clipper Fleet, 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.

Gateway Clipper Fleet is a third generation privately held company that operates six passenger vessels. We are currently operating two sub-chapter H passenger barges (1-600 passenger, 1-1000 passenger) pushed by a dedicated tow boat on each barge, three 400 passenger sub chapter K vessels, and one 150 passenger sub-chapter T vessel. The primary service that we provide is public dinner and sightseeing cruises as well as private charters and shuttle service to games for our professional teams located in Pittsburgh. Our base of operations is located at Station Square on the south side of Pittsburgh; however, 40% of our cruises originate or end at a landing other than Station Square Dock. Our vessels currently operate cruises from more thank 20 different landings, all independently owned and operated, and we carry more than 500,000 passengers annually.

Gateway Clipper Fleet has a long history of servicing passengers with disabilities. Access to our facility, including our landing barges are ramped for complete access. We provide personal assistance to and from our parking area for semi-ambulatory passengers as well as greeters on staff to assist with directions and personal attention. Our dock restrooms have been modified to accommodate passengers with disabilities as well as the restrooms on our vessels. Gateway Clipper Fleet has always and will continue to do as much as possible to accommodate our handicapped passengers.

I am aware that the Passenger Vessel Association has been in frequent contact with the Access Board regarding this rulemaking, including testifying at public hearing 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 motion 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 that 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 provisions 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 your for this opportunity to participate in your rulemaking process.

Sincerely yours,

Terry Wirginis
President Gateway Clipper Fleet
350 W. Stations Square Drive
Pittsburgh PA 15219