Fire Island Ferries, Inc.
July 27, 2005 [Email]

Fire Island Ferries, Inc.
Dave Anderson
99 Maple Ave Box 5311 Bay Shore, NY 11706
Phone: 631-665-3600 Fax: 631-665-7656
E-Mail: captdav@optonline.net

Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street NW, Suite 1000
Washington, DC 20004-1111

Dear Ladies and Gentlemen:

Fire Island Ferries, Inc. is a member of the Passenger Vessel Association and submits these comments regarding your efforts to develop accessibility guidelines for passenger vessels, as published in the Federal Register of November 26, 2004. I ask you to please include these comments in the official record of both your dockets as well as the corresponding U.S. Department of Transportation Docket.

Fire Island Ferries, Inc. is a private company operating twenty-two vessels varying in size from twelve passengers to four hundred passengers. We provide service to a barrier island called Fire Island. We are primarily a seasonal operation however, we do provide year round service to three of eight communities. We operate on the waters of the Great south Bay located just off the south shore of Long Island, New York and are very much constricted to our draft due to operational depths of the Great South Bay. One hundred percent of our rider ship is pedestrian walk on. We do not carry any cars. Cars are not permitted on Fire Island.

Most of the vessels we operate are of two-deck construction. The main deck is an enclosed cabin and the upper decks are open to the weather. We have three access gangways to board our over 150 passenger vessels and have made accommodations with a larger gangway to accommodate wheelchair accessibility with the assistance of our crewmembers. Never, in the fifty-seven years of operation were we unable to assist or deny access to a handicapped person. There are always ample personnel on board to aid and assist all passengers in any situation. In addition to having ample personnel we also have handicap removable ramps at all of our destinations to ease the transitions for the handicapped.

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 do support the following points 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, tide, and various types of vessel motions must be contended with. In design, construction, and operation of 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 more than 150 passengers and another set for vessels less than 150 passengers.
• The Access Board should develop its guidelines for vessels with a capacity of more than 150 passengers first, and an alternative guideline for smaller vessels.
• The recommendations of the Passenger Vessel Association 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 vessels designs and capacities that are capable of safely and efficiently containing elevators or lofts. In many cases, installing these devices is technically infeasible, structurally impractical, and potentially unsafe. This is particularly true of the small passenger vessels.

Fire Island Ferries, Inc. has been providing passenger ferry service since 1948 and has been doing so with a superlative operating history. I view our operation as a model one for the industry. I encourage the Access Board to view all operators and theiroperating parameters in the passenger vessel industry before placing such stringent requirements on our industry.

I would like to thank you for this opportunity to participate in your rulemaking process. If you have any questions or concerns about our operation, please feel free to contact me at the above address or telephone number.

Sincerely,

Dave Anderson
General Manager
Fire Island Ferries, Inc.