Party Line Cruise Company
July 26, 2005 [Email]

Party Line Cruise Company
301 Broadway, Suite 142
Riviera Beach, FL 33404
Tel: (561) 472 9860 Fax: (561) 841 0472

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:

Party Line Cruise Company, 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.

Party Line Cruise Company is located in Palm Beach, Florida and operates a U.S. registered Passenger Fast Ferry, M/V Cloud X from the Port of Palm Beach to Freeport, Grand Bahama Island. After a temporary suspension of operation, the vessel is due to resume service August 19, 2005.

The vessel was designed and built to fly the United States flag with Classification by Lloyd’s Register of Shipping. The M/V Cloud X was constructed to comply with the International Maritime Organization’s (IMO) High Speed Code (HSC) and must also comply in most respects with Subchapter H of the US Code of Federal Regulation. The vessel can transport up to 367 passengers and has no provision for overnight accommodation. The services offered on board are food, bar, casino and gift shop.

The service will operate year round. When in full operation, the Company will employ approximately 70 people.

The vessel particulars are:

Name M/V Cloud X
Registry Riviera Beach, Florida (U.S.A)
Official Number 1130416
IMO Number 9065027
Length Overall 123 ft.
Beam Overall 59 ft.
Gross Ton. 1010 Tons
Max. Speed 26 knots

The vessel is a High Speed SWATH-hull ship built with safety, speed, and comfort in mind. The vessel was designed between 1990 and 1993. The vessel has two passenger decks that are accessible by two stairways. Access to the vessel is done either by mean of a jet way connected to the upper deck of the vessel or by a gangway at amidships. The vessel has a total of 8 restrooms including one, on the main deck, designed to accommodate passenger with disabilities.

While PLCC has endeavored to provide accommodation for persons with disabilities whenever practical, the installation of an elevator to allow vertical access between decks aboard the M/V Cloud X is not feasible. As previously indicated, the vessel was designed and built in accordance with High Speed Code as a fast passenger ferry. The additional weight incurred by such an installation and flag-state approved modification process would be operationally prohibitive.

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.
  

Antoine Gurrey
General Manager