Madeline Island Ferry Line, Inc.
July 26, 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:

Madeline Island Ferry Line is a private entity and a member of the Passenger Vessel Association. We are submitting 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.

Madeline Island Ferry Line operates 4 Sub Chapter T ferries (149 or less passengers) in the Lake Superior waters of Wisconsin. Our company philosophy is to provide excellent/accommodating customer service to all who ride our ferries.

Our ferries carry vehicles in addition to passengers. The route is approximately 2.2 nautical miles in length, less than 25 minutes en route. We transport vacationers to and from Madeline Island, along with residents, their vehicles, and the goods and materials needed to supply the island community. In addition, we operate a ferry landing on the mainland. Our piers and boarding areas and vehicle queue lines are open to customers, onlookers, and accessible from the water, consistent with a northern Lake Superior tourism community.

We own our landings and docks on the mainland, while the Town of La Pointe manages the island dock on Madeline Island. Our ferries operate from ice break-up in the spring (mid March to April) to freeze-up (January to February). Our smaller ferries can break up to 7 inches of ice. Our operating, loading and unloading conditions are tough to hazardous during the spring and fall as well as with the snow, ice and brutal winter weather.

We employ up to 40 employees, a mix of summer, seasonal and longer season employees. We carry over 200,000 passengers and 55,000 vehicles per year.

Two of our vessels have main deck level passenger cabins. One vessel has room for a wheel chair. We ask (in our brochure) our customers to “ask if crew assistance is needed”. We have several handicapped parking spots available in our Bayfield landing. When parking a vehicle on the ferry (with a handicapped license plate) we allow ample space around the vehicle and attempt to provide that customer with a “good view of lake Superior”. If a handicapped customer is more comfortable staying in their vehicle, we will allow them to take their vehicle on the ferry at no charge. We allow leashed dogs on our ferries.

Our Bayfield passenger terminal has handicap accessible bathrooms and ample space during most of the season to get out of the weather. We estimate that we serve from 2-3 handicap customers a week in our busy season, less in the off season and we make every effort to accommodate them.

Our impression of the Access Board guidelines is that the cost of ferry modifications for small companies (like ourselves) may well push operators (who with the recession and still poor economy) that have marginal traffic numbers out of business. Besides the enormous capital expenditures for deck layout changes and the USCG stability tests, we could permanently lose car carrying capacity.

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.

Respectfully,

Gary Russell
President

Robin Trinko-Russell
VP Finance

Mike Radtke
Marine Manager

Madeline Island Ferry Line, Inc.
715-747-2051
100 Main Street
La Pointe, WI 54850