Red and White Fleet
July 25, 2005 [Email]

Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street NW, Suite 1000
Washington, DC 20004-1111
 
 
 
Red and White 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.
 
The Red and White Fleet is a privately owned company that provides scenic cruises on San Francisco Bay aboard its fleet of four vessels that range in capacity from 225 passengers to 500 passengers.  Our vessels depart primarily from our leased facility at Fisherman’s Wharf though they call on both private and public boarding locations throughout San Francisco Bay and its tributaries.  We operate year round, carrying approximately 300,000 passengers annually.  As our business responds to the seasonality of tourism, our staffing changes from about 20 people in the slow season to about 30 in the peak season.
 
We have made major structural changes to our boarding facility and our vessels to accommodate passengers with disabilities, including the installation of new boarding ramps and the modification of restrooms. Our most successful way of accommodating passengers with disabilities is providing crew assisting.

We 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.

Joe Burgard
Director of Operations
Red and White Fleet
Pier 43 1/2
San Francisco, CA 94133
P. 415.901.5248
F. 415.447.0619
[email address]