Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street NW, Suite 1000
Washington, DC 20004-1111
To Whom It May Concern:
My name is Rick Mosteller and I am a partner in a small family owned business in Charleston South Carolina. SpiritLine Cruises operates three boats for daytime sightseeing, dinner cruises and charters. Our oldest vessel the General Beauregard, a 75' aluminum vessel built in 1971. We also operate the Spirit of Charleston, a 102' aluminum vessel built in 1986. Our newest boat is the Spirit of Carolina, a 92' steel vessel built in 1998. We operate from three separate docks in Charleston Harbor and our office address is 360 Concord Street, Suite 201, Charleston, SC 29401-6305.
I am writing to express concerns regarding the proposed accessibility guidelines for passenger vessels. We operate under a concessions contract with the National Park Service to ferry visitors to Fort Sumter National Monument, an island fort in Charleston Harbor. The Park Service has a fixed pier at their visitors center and at the fort. Charleston has an average tide swing of 6 ft., but at certain times of the year it approaches 8 ft. It is exceedingly difficult to provide access to passengers with disabilities under these conditions. Passenger vessels operate in many different settings. Our boats operate charters from the Isle of Palms and Kiawah Island, each of which has a unique docking scenario. We believe it is a mistake to lump these small vessels that operate in such diverse settings in with large cruise ships.
We can accommodate disabled passengers when operating from our floating dock. In fact we designed our newest vessel, the Spirit of Carolina, with handicapped accessible restrooms to provide the best service possible to all of our guests. I am sure that people can disagree over the definition of reasonable accommodation. We believe the recommendations of the Passenger Vessel Access Advisory Committee represent very reasonable accommodation and are preferable to the proposed guidelines in the current proposed rule making. I sincerely hope these guidelines will be revised to reflect the unique challenges of operating boats in a plethora of different environments and provide more flexiblility for small operators.
Sincerely yours,
Rick Mosteller