To Whom it May Concern:
This letter is in response to the proposed vessel construction and alteration requirements to provide accessibility of passengers with disabilities.
We support the Board's efforts to enhance accesability of persons with diabilities aboard passenger vessels.Our insurance agency specializes in insurance of passenger vessels, and we insure more than 90 excursion boatowners, ferry operators,and boat builders around the country.The majority of the operators are small, one or two vessel operators. These are not large 400 to 500 foot passenger liners, and a stong distinction should be made between such large vessels and the majority of small boats carrying passengers on US waters today.Most of our clients carry between 49 and 500 passengers, and the boats are between 65 and 100 feet long.
These operators are most often family owned businesses, which have been operating for 10 or more years in the same location.They are already being squeezed by high fuel costs, increasing labor and insurance costs, and, in many cases, alterations to boat and landing area brought about in response to requirements of compliance with Homeland Security concerns.
These businesses are not high profit margin businesses,yet they give millions of people,many with disabilities, the opportunity to be out on the water .Even before this proposed legislation,I am hearing from many clients that the costs of doing business are increasing at such a rate that many wonder how they can continue to keep operating their boats.I am afraid that the substantial increase in cost of altering vessels to provide broad accessibility to disabled persons would be the final straw which puts many boats out of business.Similarly,when applied to new buidings,the increased costs due to handicap accesibility might well make a new vessel financially unaffordable.
I am an associate member of the PVA, and have been for 20 years.During at least the last 10 years, the Association has been monitoring the interface between Coast Guard Safety regs, and the requirements of handicapped persons as may exist under the ADA.There is a true dilemma in providing access in passenger vessels, and insuring that the safety of ALL passengers remains intact.Vessels are inherently different from a building, in that there are stability,watertight integrity and crewing concerns that affect the vessel, and consequently, all aboard that vessel.In addition, every time a vessel gets underway, it has the very real capability of sinking, which could put the lives of handicapped and non handicapped , alike, in serious jeopardy.The construction of every passenger vessel must recognize this fact.
Most of my clients have been very responsive to handicapped clients, encouraging all with disabilities to ride their boats.They have become very adept at making individual accomodations,and in the process dealing with the idiosyncracies of individual boats, which in some cases are 70 to 80 years old.We can recall no injuries to handicapped patrons of our insureds, in over 30 years of handling this type of account.Passenger vessels in the US continue to provide efficient ,entertaining ,safe service and transport to a diverse group of users.
The PVA represents many of our boat owning clients,and others in admirable fashion on a wide range of technical,legal and governmental issues.They truly understand the difficulties faced today by the operators of small and mid sized passenger vessels in US waters.We urge you to work with the PVA Vessel Access Advisory Committee to modify some of the proposed access regulations(such as those requiring vertical access between decks)so that they are not punitive or burdensome to small and mid sized passenger vessel owners.If these boats go out of business, everyone loses.
Thanks you for your consideration.
Sincerely,
Peter Robinson
Peter Robinson
Robinson and Son, LLC
77 Main St.
PO Box 432
Hudson Falls, N.Y. 12839
P 518-746-9230
F 518-746-9234
C 518-683-0876