Lindblad Expeditions
July 28, 2005 [Email]

1415 Western Ave. Suite 700
Seattle, WA 98101
Fax: (206) 403-1501
Tel: (206) 403-1500

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

Ladies and Gentlemen:

Lindblad Expeditions, 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, both of your dockets as well as the corresponding U.S. Department of Transportation Docket.

Lindblad Expeditions is a private company operating six year round small passenger vessels worldwide. We have two US flagged vessels that offer trips in Southeast Alaska, the Pacific Northwest, the Columbia and Snake Rivers and Baja California. The M/V Sea Bird was constructed in 1981 and the M/V Sea Lion in 1982. Both ships are 152’ long and can accommodate 64 passengers and 24 crew. We have been offering expedition style cruises for over 20 years. These trips generally last one week in length, sailing primarily to remote destinations where we offer guided hikes, kayaking, and snorkeling. Most of our shore landings are done with 19’ inflatable Zodiacs as opposed to a more traditional dock or pier.

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 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.
• Designing accessibility into a vessel becomes exponentially more difficult as the size of the vessel decreases and the age of the vessel increases. Therefore, it is appropriate to have one set of guidelines for large vessels and newer vessels and a different set for older vessels or those with a smaller passenger capacity. Establishing a blanket set of regulations that is clearly more feasible on certain vessels than others is not appropriate.
• 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.

Lindblad Expeditions’ vessels have historically been able to successfully accommodate passengers with disabilities largely through the assistance of our officers and crew. We feel that any regulatory provisions not taking into account the above-mentioned concerns would be exceedingly onerous.

Thank you for this opportunity to participate in your rulemaking process.

Peter Butz
Michael Jones
Dwayne Stevens
Lindblad Expeditions
1415 Western Ave. Suite 700
Seattle, WA 98101
Tel: 206-403-1500
Fax: 206-403-1501