MR. LINDEN: Good afternoon, ladies and gentlemen. My name is Lou Linden. I'm here representing the American Sail Training Association, and I had the privilege of being the chairman of the C&T subcommittee of the Passenger Vessel Access Advisory Committee and working with all these wonderful people, including Don Backe and Jan. And it was a tremendous, tremendous opportunity and an experience I'll always treasure.
We were charged with trying to deal with small vessels. In the beginning of the process, that was a very ill defined term, but basically, there was, at least on some level, an intuitive understanding that things are very different between your basic 50,000-ton cruise ship and your Boston Whaler. And, unfortunately or fortunately, as the case may be, our mandate covered a continuum of vessels at which, you know, those are at the opposite ends but still within that continuum.
What we endeavored to do -- well, yeah. Let me go back a little bit. In our process, it was sort of a plop; okay, you're the small passenger vessel subcommittee, make it work. And we said okay, how do we do this? And we spent a number of days fighting over, well, what is a small passenger vessel, what does it mean, how do you deal with it, and how are we going to deal with it within the process. And we said okay, well, let's just take what we think the big guys are going to do and make it all smaller.
Well, you know, we fairly quickly started to realize that, at least certainly from my constituency, which is made up of people who operate sailing vessels, both as sail training vessels and as passenger carrying vessels -- they have a dual role -- for my people, you know, a very great concern was, you know, how do we do this in a way that is predictable, makes sense, and is relevant to what we do.
Now, in truth and in fact, the American Sail Training Association in its passenger carrying activities in 1998 carried approximately 335,000 passengers. Almost entirely, this market is made up of the short-term excursion trade. In other words, you get on the sailboat, Happy Days. And you get on there with the captain and Gilligan and them, and you go out for a three-day cruise, a three-hour cruse, and come back.
So, in truth and in fact, in the vast, vast, vast majority of interactions that we have with the public, there are no questions of access to heads or access below decks because nobody has access to those things. Basically, you're getting on a boat, you're going to go for a sailboat ride, and you're going to come back. And then you're probably going to go to the gift shop or the restaurant, and they've got a bathroom there and that's that.
Basically, what we came to realize is that most of the rules for the large vessels really are the sort of things that you would find applicable to a resort hotel.
And, indeed, in going over the four options, when, you know, I sort of confronted the question of, well, when should large vessel rules and when should small vessel rules apply, I guess one of the indexes I came to is, you know, the less that the accommodations on the vessel look like a motel, the greater the chance that small vessel rules should apply.
One of the reasons that we came up with the small vessel rules that we did is we came to the conclusion that really there were only a handful of things that were really important that really transferred into the small vessel world, and they had to do with getting on and off the vessel, with getting around the vessel, and being secured to the vessel. Now I think, you know, Don, of course, has already spoken to you to some extent about the dynamic issues that we face, that all vessels face. Ships are not buildings. Ships move. And the smaller they get, the more they move. So all of the things that we do have to be done within the sort of context of physics and with the small vessels of scale.
Now you can -- the difference between, say, a 42-inch opening and a 32-inch opening on a large cruise ship is more a matter of economic feasibility and money and how many of them you can get into a structure. When you're dealing with, say, a 25- or a 30-ton sailing vessel, the question is can you have an opening at all, simply because of the scale.
Our vessels in ASTA generally run a scale factor of 10, which is to say our largest vessels are generally 10 times as large as our smallest vessels. We range generally, with some exceptions, from, say, 10 tons to 100 tons, almost exclusively what the Coast Guard calls Subchapter T and Subchapter C.
Once you get above a certain point, as I said, a lot of these questions really become largely matters of economics rather than feasibility. At the smaller end, of course, the smaller the vessel gets, the more difficult it is to impose design constraints on the vessel without distorting the design of the vessel for which it was created.
I'd like to shift a bit and go briefly to the methodology issues that you all have broached with the four options. Up front, I have to say, you know, I find option 2 the most compelling, which, of course, has nothing to do with the fact that I was largely the reporter for the underlying report of that option. Nonetheless, as I went through and looked at the other options, it really reinforced my feeling that the other three options essentially just invite the same kind of process that we've already gone through to produce the small vessel rules mentioned in option 2. And try as I might over the weekend, I was hard pressed to say how any of those processes would come out with a substantially different end result.
I think that option 2 has largely captured a fairly reasonable place at which they should begin to be applied, and it has also, through its exception structure, managed to include enough flexibility to deal with the very great diversity within the class of small vessels, and remembering, of course, that the smallest one is a tenth the size of the largest one.
I think option -- the first option sort of points up the fact that most of what's in the large vessel rules has no relevance to our operations at all. Just looking at just a few of the things in the scoping section of the large vessel rules, we do not have water slides, boxing rings, diving boards, stairs and escalators, performance areas, drinking fountains, ATMs, dressing and locker rooms, medical care facilities, shooting facilities, swimming. We have none of those things.
Most of our vessels are traditional monohull sailing vessels. So a very -- you know, perhaps the largest portion of verbiage in the large rules simply has no relevance to what we do or how our vessels are constructed.
Option 3 invites us to create general performance rules, and I must say that this has a certain allure to it for us. In truth and in fact, ASTA has been providing these services without any rules or without any standards for many years. In 1998 -- actually, in '99, late '99 and the beginning of 2000, we did a survey specifically to generate some information for the PVAAC. Forty-one percent of our constituent vessels answered the survey.
And we discovered that, out of that 330,000 people that ASTA carried as passengers, we also carried 2,913 passengers who had either a mobility impairment or a sight impairment, and there were a handful of other instances. We did this without any injuries and, as far as we could tell, with 100 percent satisfaction.
In the survey, it's very apparent that our operators are very proud of the fact that they turn no one way. I think, to some extent, that is based on the fact that our constituent operators are very resourceful and prudent seamen. And, you know, getting large bundles on and off ships is something that we've been doing for hundreds of years and we can do real well.
I think a second factor that accounts for the great satisfaction reported -- and, of course, I have to say this is self-reported, so, you know, I can't say J.D. Powers said this, but there's a dearth of other information.
Nonetheless, I think that one of the reasons that we've been so successful is that our operators and our passengers have a willingness to negotiate the experience, which is to say that the very concerns that Don Backe just mentioned have been made a matter of conversation between the prospective passenger and the prospective carrier, and they've worked it out, and quite apparently to everyone's satisfaction.
So I guess, in reality, the question that comes of option 3 is how specific are those general performance requirements going to be.
There's a saying that there are only three rules to seamanship, okay: you keep the water on the outside, you keep the people on the inside, and you keep the boat off the land. Anything after that's gravy.
Well, you can say the same thing about surveying the disabled population in vessels. You get them on the boat safely, you give them the best experience you can that's as close as possible to what everybody else gets, and you get them off the boat safely. Cucharacha, that's it. The rest of it's details.
And the fact of it is we have been doing that. I think the major problem with that option, though, is this inevitable tendency to start getting down and saying, well, you know, we need to be more specific about this and say that a person needs to be put on in thus and such a way. Or, you know, the more specific those performance recommendations become, the more and more they begin to look like what? They begin to look like the C&T rules in option 2.
In option 4, I think, basically, there is no magic number when it comes to passengers. The fact of it is, as Paul pointed out, we inherited this, obviously, to some extent arbitrary line from the Coast Guard and from their relatively recently overhauled framework of vessel classification.
I have to say that, even though it was not purpose made for us, it does, I think, reflect some very valuable characteristics, some of which are economically driven and some of which are feasible or infeasible as a matter of physics.
The fact of it is you are never going to find a 51-passenger cruise ship. It just is never going to happen because it's not economically feasible. You are probably not going to find a 60-passenger cruise ship. I mean, at some point, you know, there is a number there where economic feasibility makes it possible.
And, likewise, I think that what this really points to is that probably more important than some sort of arbitrary number of passengers are the programmatic aspects of what the vessel does, all right, because that is also going to be interrelated with the physical thing.
It's very unlikely that you're going to find a 5,000-person sailing ship. It's very unlikely you're going to find a 50-person cruise ship. Okay? So, as predictors go, you know, the size and the number of people have to be taken with the actual intended design of the vessel. And, once again, I think we did that pretty well.
So thank you very much. And if anyone has any questions, I'd be happy to answer them.
MS. [JAN] TUCK [BOARD CHAIR]: Thank you. Okay. We have a phone call. Thanks, Lou.
MR. LINDEN: Seeing none, thank you.