Long Beach Transit
P.O. Box 731
1963 E. Anaheim Street
Long Beach, CA 90801-0731
Phone: (562) 599-8571
Fax: (562) 599-8574
www.lbtransit.com
Members of the Board
Architectural and Transportation Barriers Compliance Board (Access Board)
Office of Technical and Information Services
1331 F Street, NW
Suite 1000
Washington, DC 20004-111
Dear Members of the Board,
Long Beach Transit is pleased to have the opportunity to comment on the ADA Draft Accessibility Guidelines for Large and Small Passenger Vessels. We hope the outcome will reflect reasonable and realistic guidelines that recognize the diversity of small passenger vessels and the environments in which they currently operate. In addition, I would like to commend the US Access Board on its efforts to ensure that all customers are able to utilize the amenities offered by US flagged passenger vessels. I understand some of you were able to see our AquaLink and AquaBus vessels in Rainbow Harbor during your recent visit to Long Beach, and I appreciate your efforts to explore the variety of passenger vessels that would fall under the guidance of these proposed rules.
Long Beach Transit is a nationally recognized, multi-modal transit system serving nearly 27 million boarding passengers in southeast Los Angeles County. Long Beach Transit’s service area includes 96 square miles, covering the City of Long Beach, it’s coastline, and surrounding communities. Long Beach Transit customers ride on 221 low floor busses and shuttles, 15 Dial-a-Lift vans, and 3 water taxi vessels.
Long Beach Transit has been a leader in ensuring that its public transit system is accessible to all customers. Our agency was the first system nationwide to offer reserved seat paratransit van service to persons with disabilities long before the ADA requirements, the first in California to be 100% wheelchair accessible, and the first to introduce low-floor buses for the ease of access. Our fleet of public transit passenger vessels, operated under contract by Catalina Express, is also ADA accessible. The fleet includes two 40-foot, AquaBus water taxis carrying up to 49 passengers each, and one 68-foot, AquaLink catamaran carrying 75 passengers.
In general, the draft guidelines disproportionately affect small vessel operators in their ‘one-size-fits-all’ approach. The provision of access in marine environments makes for unique operating challenges, as compared with accessibility guidelines for land based facilities. There are numerous types of small vessels, each providing different services and amenities, and each operating in very different marine environments. Therefore, it is critical to recognize these unique challenges when developing guidelines to regulate access for passengers with disabilities. Long Beach Transit owns three vessels of two different varieties, and like many other smaller vessel owners, we operate in a marine environment that often faces tidal changes and water level fluctuations, as well as unexpected motion while aboard the vessel. These fluctuations and movements make access/egress more problematic, and consequently more difficult to regulate for accessibility.
Another challenge faced by many small vessel owners/operators is limited control over docking facilities. Long Beach Transit does not retain the legal right or ability to make structural modifications to the docks at which we call. While we own the vessels and manage the contract for their operation, we do not have the ability to modify the docks. It would also be difficult for vessel owners, such as LBT, to require or persuade docking facility owners to modify the non-compliant access/egress facilities we use. The final guidelines should account for this limitation on the part of some smaller vessel operators.
In closing, a ‘one size fits all’ approach for smaller vessels places a difficult burden on operators. I urge you to maintain a degree of flexibility within the guidelines, and to recognize that accomplishing the goal of accessibility for persons with disabilities, will require a variety of solutions. This flexibility will allow owners/operators to find solutions that both ensure equal access to passenger vessels, and meet critical business and productivity needs.
Thank you for your consideration of our comments, and please don’t hesitate to contact my staff if you require additional information.
Sincerely,
Laurence W. Jackson
President and Chief Executive Officer