LAKE MICHIGAN CARI'ERRY SERVICE, INC.
7171 Maritime Drive • P.0 3ox 7r9 • Ludington, Michigan 49431 • (231)845-5555 • Fax (231) 843-4558
Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street NW, Suite 1000
Washington, Dr.200011111
Ladies and Gentlemen,
The Lake Michigan Carferry Service, 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 Lake Michigan Carferry Service is a privately owned company that operates one vessel - the S.S. Badger -- between the ports of Ludington, Michigan and Manitowoc, Wisconsin on Lake Michigan. This vessel operates between the middle of May to the middle of October carrying passengers and vehicles. The S. S. Badger is a sub chapter H vessel with a passenger and crew capacity of 680 persons and a vehicle capacity of ISO standard sized autos.
The S.S. Badger is equipped with a Garaventa stair lift for passenger boarding from the entry deck to the cabin deck. This lift has a capacity of 450 pounds and accommodates wheelchairs and many motorized chairs. Passengers and chairs exceeding 450 pounds are taken separately.
We are aware that the passenger Vessel Association has been in frequent contact with the Access Board regarding this rule making, including testifying at public hearings three times in 2005. We support the following points that the PVA has stressed in its comments.
I) Providing access in marine and aquatic environments is more challenging than doing so at sites on land In designing, constructing, and operating a vessel, there is no higher priority than safety.
2) 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.
3) The recommendations of the Passenger Vessel Access Advisory Committee, on which four PVA members participated, arc preferable to the proposed guidelines put forth by the Access Board.
4) 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.
Our vessel was built in 1953 and does not lend itself to the addition of an elevator or stair-lift between decks without extensive and expensive design changes to the vessel.
Thank you for this opportunity to participate in your rule making process.
Very truly yours,
James E. Anderson
Executive Vice President
Lake Michigan Carferry