108 Pax High Speed Ferry

Private Entity, Draft – June 30, 2008

Introduction

The 55 foot long ferry was constructed in 2006 and is a catamaran style passenger-only ferry which is certified to carry 108 passengers.. The vessel’s service speed is approximately 25 knots. The ferry has two decks with the main deck being the entry deck.

Main Deck — The main deck is about 55 feet long and 21.5 feet wide (approximately 1,200 square feet) and is provided with two entry points1 , one on each side of the vessel in the exterior stern area. From the stern area, an exterior stair connects the upper deck. Two entry doors connect the interior main deck seating cabin, one on each side of the stair. The two doors have 6 inch high thresholds (coamings) which are ramped on both sides. Between the stair and portside entry door, a small golf bag storage area is provided. In the cabin, two uni-sex toilet rooms are provided in a cluster. One toilet room is located on each outboard side of the cabin’s after bulkhead (wall), on opposite sides of the snack bar. Between the two entry doors a snack bar is provided. Forward of the snack bar and two toilet rooms the cabin contains a seating area. Two 30 inch wide fore/aft aisles divide the seating area into three sections (starboard side, middle, and portside). Two freight storage areas are provided in the cabin, one between each toilet room and side seating section. Forward of the cabin seating area, an exterior bow area is provided that contains one of the life raft embarkation areas which is only open to passengers in emergencies. Access to the bow area is up two steps and through a cabin window. At the bow, a narrow stair connects the upper deck.

figure108-1
Figure 1. Main Deck — Original Design

Upper Deck — The upper deck (second deck) is about 34 feet long and 20 feet wide (approximately 680 square feet). At the stern area, an exterior stair connects the main deck and divides the external seating area on the upper deck into two parts. A door connects the external seating area with the upper deck cabin which contains an internal seating area. Forward of the interior seating, the pilot house is provided. A narrow steep stair on the port side of the vessel, used only by passengers in emergencies, connects the pilot house with the open bow area on the main deck.

figure108-2
Figure 2. Upper (Second) Deck — Original Design

Methodology

A representative of the Access Board reviewed the original designs of the vessel with a representative2 of the ferry to identify passenger features that would not meet the 2006 draft passenger vessel accessibility guidelines3. The ferry representative proposed new designs for the passenger features that would meet the draft guidelines and estimated how much the new designs would add to a new vessel’s construction cost. This case study report principally focuses on the impacts to the original 55 foot design.

55 Foot Ferry. The ferry representative reported that the cost to construct the original vessel was approximately $1.9 million in 2006 dollars. The ferry representative noted that because of slip size limitations in the homeport harbor and because they wanted a smaller vessel (cheaper to operate) to balance off their larger 65 foot ferry, the new designs of the ferry should not result in a longer or wider vessel. Based on the vessel length of 55 feet and width of 21.5 feet being unchanged, the ferry representative estimated that the new designs would add approximately $18,000 to the vessel’s construction costs, an increase of about 1 percent. The new designs would also result in the loss of 6 to 8 fixed seats4 and the reduction in the snack bar counter area. Including the five square feet loss in the reduction of the golf club storage area, at least 23 square feet of freight storage out of the original 115 square feet is lost (about 20 percent), but life jacket storage space is increased at the bow by 14 square feet5.

65 Foot Ferry. In discussing the loss in seating and freight storage impact, the ferry representative noted that if the provisions of the draft guidelines were mandatory, they would probably have had to build a larger vessel to compensate for the loss of critical seating and freight space. As freight is generally passenger luggage, if passengers cannot easily store their luggage, their desire to use their ferry service is impacted. Carrying golfers with their golf bags and other luggage represents a sizable cliental. The 55 foot vessel is on the margin of what the company projected it would really need.

It is estimated a 65 foot vessel would cost approximately $2.3 million to $2.4 million in 2006 dollars and (roughly) an additional $9,000 to $15,000 would be needed to make its designs comply with the draft guidelines. As a 65 foot vessel has 149 seats, where space is needed to provide accessibility features highlighted in the analysis of the 55 foot designs, seats would be removed. It is (roughly) estimated that space needs for accessibility would reduce the seating capacity to around 125 seats (which is above the 108 capacity of the 55 foot design). Going from a 55 foot ferry to a 65 foot ferry complying with the draft guidelines represents a $418,000 to $518,000 increase, about 22 to 27 percent increase over the cost of the original 55 foot vessel. By going with a 65 foot vessel, the fuel consumption would increase by an estimated 18 percent.

The ferry representative noted that it may not be necessary to have a 65 foot vessel to provide the capacity of the 55 foot vessel, but recognized that developing designs between 55 feet and 65 feet (which are the two proven designs provided by the shipyard) would incur a redesign cost of about 3 to 3.5 percent, and would create many unknowns about vessel operating characteristics. The following table estimates the cost of various size vessels between 55 feet and 65 feet, but no determination has been made as to which alterative design would be the minimum necessary to provide the same capacity of the ($1.9 million) 55 foot vessel as well as meet the requirements in the draft guidelines.

Vessel Size

Redesign Cost (3-3.5%)

Access Costs

Other Cost Increase

Total Cost Increase

Percentage Increase

55 x 21.5

$17.6K

< 1

58 x 22.25

$57K to $67K

$9K-15K

$114K – $143K

$180K – $225K

10 – 12

60 x 22.75

$57K to $67K

$9K-15K

$194K – $242K

$260K – $324K

14 – 17

63 x 23.5

$57K to $67K

$9K-15K

$315K – $394K

$381K – $476K

21 – 25

65 x 24

$9K-15K

$400K – $500K

$409K – $515K

22 – 27

The ferry representative also noted that bank financing would not have been available for a 65 foot vessel when the decision was made to fund the 55 foot vessel. Therefore, the ferry service would have had to delay adding another vessel and slowed the growth of the company.

Actions. Actions taken on features in the original 55 foot vessel designs to create new designs meeting the draft guidelines for a new 55 foot vessel are discussed below. The case study sought to identify actions that 1) have significant impacts, 2) incurred additional costs but did not have significant impacts, or 3) have other outcomes which should be noted.

An action is identified as having a significant impact where the redesign of the feature would add more than 0.5 percent to vessel’s construction costs; would substantially reduce the vessel’s usable space or necessitate an increase in the vessel’s size; or would present major operational issues. An action is identified as incurring an additional cost but not having a significant impact where a specific cost can be attributed to the redesign of a feature but it does not meet the criteria for a significant impact.

Actions That Have Significant Impacts

1. Toilet Rooms/Snack Bar

In the 55 foot design, two small uni-sex toilet rooms are provided, in a cluster, on the main deck. The toilet rooms are located on opposite sides of the vessel with the snack bar between them and are approximately 51 inches deep and 31 inches wide. The draft guidelines require one toilet room in this cluster of two toilet rooms to be accessible. V213.2 Exception 4. The ferry representative proposed in the new designs to enlarge the port side toilet room. This action (which is principally engineering design work) is estimated to increase the cost of the new designs by $3,200. To increase the width of the toilet room, about 23 square feet of freight space is lost out of the 53 square feet available on the port side.

In addition, as the depth of the toilet room is increased to 60 inches, this increase moved the port side stern door about nine inches toward the starboard side. This move, combined with providing a maneuvering clearance (discussed below) at the port side stern door, required the ferry representative to convert the golf bag storage closet (of about nine square feet) into a smaller capacity storage rack (of about four square feet) located on the inside edge of stern door maneuvering clearance. Therefore, a total of 28 square feet of storage space (including five square feet in the golf bag locker) is loss.

Also, because of the increased depth of the toilet room, the width of the snack bar had to be reduced by 10 square feet to insure a 42 inch wide maneuvering clearance is provided at the push side of the toilet room door. The ferry representative estimated the reduced snack bar size would have a minimal impact on their revenue.

figure108-3
Figure 3. Port Side Corner of Main Deck — Original and New Layouts (not to scale)

With changes in the port side seating section (see issue #4 below) which compensated for the loss of some storage space, the new designs lost 23 square feet of storage. The loss of freight storage space due to the larger toilet room is one of the factors that led the ferry representative to indicate a larger vessel is needed. This is classified as a significant impact.

2. Ceiling Height

 figure108-4

Figure 4. Main Deck Cabin
Area Less Than 80 Inches

In the 55 foot design, the ceiling height of the main deck and upper deck cabins is more than 80 inches, except on the main deck near the bow. The clearance along the forward circulation path which runs across the width of the vessel is less than 80 inches due to the curvature of the forward windows and projection of the bow stair. The draft guidelines require all passenger circulation paths to have 80 inches of vertical clearance or have guard rails or other barriers at least 27 inches high separating areas having less than 80 inches of vertical clearance. V204 and V307.

The ferry representative proposed in the new designs to increase the depth by 3.5 inches of the life jacket lockers (e.g., cabinets with top lids) which are provided along the front of the main deck, from the starboard side to the area where the bow stair projects into the cabin. This increased the footprint of these lockers by 4 square feet. In addition, the ferry representative proposed for the projecting bow stair, to also increase the depth of the lift jacket lockers under the stair by 28 inches. This increased the footprint of these lockers by 10 square feet, but made the forward seats in the port side seating section unusable because no leg space is now available. The ferry representative decided to remove these 2 seats because the space was needed to provide 2 wheelchair spaces located at the aft end of the port side seating section6 and could be used to regain some loss freight storage space. By increasing the depth of these forward lockers, the forward circulation path is reduced in width7 but the entire path had a vertical clearance of at least 80 inches.

These actions are estimated to increase the cost of the new designs by $1,900. The ferry representative is unsure how readily usable8 the new storage space at the bow would be to passengers to help compensate for the loss freight storage space in the back of the cabin and suspected it would just be used to hold life jackets. The loss of seating is one of the factors that led the ferry representative to indicate a larger vessel is needed. This is classified as a significant impact.

3. Transportation Seats

In the 55 foot design, the vessel has 108 fixed seats, with 56 interior seats provided in the main deck cabin and 28 exterior and 24 interior provided on the upper deck. No designated wheelchair spaces are provided in the vessel. The seating areas on this ferry would be classified by the draft guidelines as transportation seating areas. V106.5. As a total of 108 fixed seats are provided in this ferry (none at tables), the draft guidelines require 2 wheelchair spaces be dispersed in the seating area on the main deck9 (the entry deck). V222.3.1.

The ferry representative proposed in the new designs to remove 4 seats at the after end of the port seating sections to provide 2 adjacent wheelchair spaces (each 33 inches by 48 inches) set up for a forward approach and facing the port side of the ferry. However, to make a 90 degree turn off of an aisle which is less than 36 inches wide, the draft guidelines require the combined two wheelchair spaces to be 72 inches wide10 .

To temper the loss of fixed seats, the ferry representative proposed to add 2 fold-down seats on the short bulkhead (wall) which separates the port side seating section from the port side storage area. The fold-down seats have springs which keep them in the up position so as not to project into the wheelchair spaces when unoccupied11 . Therefore, to provide the 2 wheelchair spaces, only 2 fixed seats are lost. This action is estimated to increase the cost of the new designs by $1,300.

The ferry representative noted that with some minor modifications, freight containment features could be easily installed by crew members. This would enable the 2 adjacent wheelchair spaces (24 square feet) to hold freight when persons who use wheelchairs are not passengers (although the 2 fold down seats could not be used in such cases thereby reducing the seating capacity to 100 seats). The ferry representative estimated about one to two passengers who use wheelchairs ride the vessel each month, and the vessel makes five round trips a day.

figure108-5
Figure 5. Wheelchair Spaces with Fold-Down Seats

In addition, as discussed above, 2 seats were lost to address the ceiling height issue by increasing the depth of the forward life jacket lockers. Also, as discussed below (issue #6), to provide a clear deck space at the accessible life jacket locker required in the upper deck cabin, 2 other fixed seats are lost in the new designs.

Summary – Based on all impacts, the new designs have 102 fixed seats (2 of which are fold-down), a reduction of 6 seats (8 seats, if fold-down seats can’t be used) when compared to the original layout of the ferry. Although 6 seats are lost, the ferry representative noted the vessel could still be certified to carry 108 passengers but passengers would not be sold tickets without seats being available. No estimate on revenue loss was provided. As the ferry was designed to the minimum transportation needs of the company, the loss of seating is one of the factors that lead the ferry representative to indicate a larger vessel would be needed. This is classified as a significant impact.

4. Freight Storage

In the 55 foot design, freight (which primarily consists of passenger luggage) could be stored internally in a nine square feet golf bag storage locker, and two 53 square feet storage areas (one on each side of the vessel in the main deck cabin). This represents about 115 square feet of dedicated internal storage space on the main deck. As mentioned above, with the enlargement of the port side toilet room 28 square feet of storage space is loss.

In addition, to connect the port side group of 2 wheelchair spaces, the draft guidelines require an accessible route with at least 32 inch clear width. V206 and V403.5.1 Exception 2. To provide a 32 inch wide accessible route pass the ceiling support (mounted next to the aft-most port-side chair in the center-seating section), about three square feet of storage space is needed to provide the 32 inch clearance, bringing to total loss in storage to 31 square feet. However, with the 6 seats being removed in the port side seating section and not all the gained space is needed to provide the 2 wheelchair spaces, about eight square feet was available in the new designs to be add to the port side storage area.

Therefore, the above actions resulted in a combined loss of 23 square feet out of 115 available. This equals about a 20 percent loss, but life jacket storage space is increased at the bow by 14 square feet12 .

Actions That Incur Additional Costs But Do Not Have Significant Impacts

5. Exterior Doors

In the 55 foot design, three exterior doors are used by passengers, one at the after end of the upper deck cabin and two at the after end of the main deck cabin. The draft guidelines require one door on the main deck and the door on the upper deck13 to be accessible. These doors serve the required accessible routes on the main deck and upper deck, and required accessible means of escape which connect the main deck cabin with the stern area and connect the upper deck cabin with the stern stair. V206 and V207. Actions to provide conforming doors are described below and are estimated to increase the cost of the new designs by $6,300.

Maneuvering Clearances – The two outward swinging doors on the main deck, equipped with closures and passenger operated latches, are tightly located between features of the ferry which limit the approach paths to nearly the width of the doors. In general, the draft guidelines require non-automatic accessible doors to have maneuvering clearances on both sides. V404.2.4. To provide the additional space at the main deck port side door for its maneuvering clearances and allow the adjustment of the door location due to the toilet room enlargement (mentioned above), the ferry representative proposed in the new designs to remove the golf bag storage closet and replace it with a storage rack located on the inside of the port side stern door. This creation of the golf bag storage rack then required the ferry representative to propose to reduce the counter space at the snack bar.

As clearances existed on the sides of the upper deck door, only minor adjustments are needed in the new designs to provide it with conforming maneuvering clearances. The costs to provide the maneuvering clearances are included in the costs for other work at the doors.

Clear Width — Three exterior doors have clear opening widths which are at least 32 inches. However, at the four corners of the openings, the radius corners (versus squared corners) are provided because they add to the structural strength of the bulkheads (walls) within which the doors are located. At the radiuses, the clear width of the doors is less than 32 inches. The draft guidelines require the clear width of accessible doors to be 32 inches minimum and prohibit projections into the required clear width in the area of the opening which is less than 34 inches off the deck surface. V404.2.3. The ferry representative proposed to provide doors in the new designs which have squared corners instead of providing wider doors with rounded corners. This action is estimated to have an insignificant cost impact on the new designs. However, the impact of structural strength reductions could not be determined during the period of this case study.

Threshold Heights. The three exterior doors are required by the US Coast Guard (USCG) to be weathertight and have six inch high coamings (door thresholds). The two doors on the main deck have short steep ramps on both sides and the upper deck door has no ramp.

The draft guidelines require one door on the main deck and the door on the upper deck to be accessible. Where high coamings are required by the USCG at accessible doors, the guidelines allow either (1) a ramp on each side of the coaming provided the door is automatic, or (2) a ramp only on one side. V404.2.5 Exceptions 2 and 3. Where maneuvering clearances are required, the maneuvering clearances are permitted to function as the above coaming ramps. V404.2.4.4 Exceptions 1 and 2. Where authorized14 by the USCG, the draft guidelines also do not require the coaming ramps to go to the top of the coaming but may end ¾ inches below the top to provide a vertical surface to which the weathertight door can seal to prevent water leakage. V404.2.5 Exception 4. The non-sealing side of the door is not allowed by the draft guidelines to have a vertical surface of more than ¼ inch, or ½ inch beveled. V404.2.5.1.

figure108-6
Figure 6. Coaming (Threshold) 1.5 Inches High

The ferry representative proposed in the new designs to seek a waiver15 from the USCG to allow the door coaming to be reduced to 1.5 inches. With this reduction in coaming height, on the exterior side of the coaming, a 36 inch long portion of the maneuvering clearance at a 1:48 slope would slope up to a point ¾ inch below the top of the 1.5 inches high coaming. The ¾ inch vertical surface above the deck surface would provide the weathertight door sealing surface required by the USCG. On the inside of the door coaming, a 48 inch long portion of the maneuvering clearance at a 1:48 maximum slope would slope up to a point ¼ inch below the top of the coaming. To grant the waiver, the ferry representative expects the USCG to require all down flooding points in the main deck cabin to be eliminated by adding watertight hatches and suitable deck drains. These actions are estimated to increase the cost of the new designs by $5,700.

Although only two of the three exterior doors had to be accessible, because of trip and fall liability/safety reasons, all door thresholds need to be the same on the main deck. Therefore, the above threshold changes are also proposed to be made at the starboard side stern door. The cost of this action is included in the above costs for addressing door threshold access.

Vertical Clearances – The vertical clearance at the main deck passenger doors is less than 78 inches due to the ramps over the six inch coamings. The draft guidelines require all doors used by passengers to have at least 78 inches of vertical clearance to provide access for passengers who are blind or visually impaired. V204 and V307.4 Exception 1. Where coamings are present, the draft guidelines allow the vertical measurement to be taken from the finished deck surface adjacent to the coamings. V307.4 Exception 2. Where ramps are provided at the coamings, the finished deck surface would be the top of the ramp surface.

With the new coaming height of 1.5 inches, the ferry representative proposed to provide slightly larger exterior doors which would provide the 78 inch minimum vertical clearance. The action is estimated to increase the cost of the new designs by $600 (at $200 per door).

6. Life Jacket Storage

In the 55 foot design, the only passenger storage facilities provided on the ferry are life jacket storage facilities (which are used by passengers in emergencies) and are located in the three seating areas (i.e., main deck cabin, upper deck cabin and upper deck exterior). The draft guidelines require that one life jacket storage facility in each of the three spaces be accessible. V225.2. At an accessible storage facility, a clear deck space is required to hold a wheelchair. V309.2. The hardware of an accessible storage facility (such as a cabinet or chest) is required to be operable by one hand, not require tight grasping, pinching or twisting of the wrist, and not require a force greater than 5 pounds to operate. V309.4.

The ferry representative proposed to modify the storage hardware to ensure the three accessible life jacket storage lockers could comply with the draft guidelines. In addition, two fixed seats are proposed to be removed in the upper deck cabin to provide the necessary clear deck space to make one storage facility accessible in the cabin. Outside the upper deck cabin, sufficient clearances already existed to provide the clear deck space at the exterior seating area life jacket locker. In the main deck cabin, the ferry representative proposed to add an accessible locker to a shelf on the portside bulkhead (wall) between the port side seating section and the storage area, so as not to lose two to three seats at the bow in providing access to the forward life jacket lockers. These actions are estimated to increase the cost of the new designs by $2,000.

7. Snack Bar Counter

In the 55 foot design, a snack bar is provided in the main deck cabin which has a 36 inch high service counter with a 36 and ¾ inch sea rail around its edge. The sea rail helps prevent objects from sliding off the service counter when the vessel is in motion. Where a counter is set up for parallel approach, the draft guidelines require a 36 inch long portion of the counter, including the sea rail, to be no higher than 36 inches. V227.3 and V904.4. The ferry representative proposed in the new designs to lower the counter top and sea rail to 36 inches overall. This action is estimated to increase the cost of the new designs by $600.

Other Outcomes

8. Stairs

In the 55 foot design, the US Coast Guard requires the upper deck to have two means of escape (MOE) down to the main deck, to the stern and bow area. These MOE consist of stairs, one at the stern and the other a narrow stair at the bow, which have slopes of more than 35 degrees. Because the forward MOE is through a window, the draft guidelines only require one accessible means of escape (AMOE) from the upper deck to the main deck running to the stern16 . V207.2 and V207.2 Exception 1. The draft allows stairs to be components in the AMOE to an evacuation station17. V410.1.2. Where stairs are open to the weather, the draft guidelines do not require the AMOE stairs to comply with any access provisions (except protruding objects). V410.2 Exception 3. As the stern stair is open to the weather, the stair (which functions as a component in the AMOE path) is not required to comply with the draft guidelines.

In addition, another provision of the draft guidelines also applies to stairs and requires that stairs which connect levels and decks not connected by an onboard accessible route must be accessible. V209. However, where the largest deck of a vessel is less than 3,000 square feet (as in the case of this ferry), this provision does not apply. V209.1 Exception 3. Therefore, no change is required in the new designs to the passenger stairs in this ferry.

9. Electrical Power, Fuel Consumption, and Vessel Stability Impacts

In the 55 foot design, the ferry representative estimated the proposed changes to meet the draft guidelines would have no impact on the electrical power needs of the ferry. The ferry’s stability would more than likely have to be recalculated at a cost of $2,300 because of the modifications. Fuel consumption should not change as the new vessel would have a similar displacement as the original ferry. However, the loss of seating and storage (due to the provisions of the draft guidelines) necessitates a larger vessel. It is estimated the 65 foot design would use 18 percent more fuel.

Summary

55 Foot Ferry. The ferry representative reported that the cost to construct the original vessel was approximately $1.9 million in 2006 dollars. The ferry representative noted that because of slip size limitations in the homeport harbor and because they wanted a smaller vessel (cheaper to operate) to balance off their larger 65 foot ferry, the new designs of the ferry should not result in a longer or wider vessel. Based on the vessel length of 55 feet and width of 21.5 feet being unchanged, the ferry representative estimated that the new designs would add approximately $18,000 to the vessel’s construction costs, an increase of about 1 percent. The new designs would also result in the loss of 6 to 8 fixed seats18 and reduction in the snack bar counter area. Including the five square feet loss in the reduction of the golf club storage area, at least 23 square feet of freight storage out of the original 115 square feet is lost (about 20 percent), but life jacket storage space is increased at the bow by 14 square feet19.

Modifications to Three Exterior Doors

$6,300

Portside Toilet Room Enlargement

$3,200

Providing 2 Wheelchair Spaces

$1,300

Stability Calculations

$2,300

Providing 3 Accessible Life Jacket Lockers

$2,000

Ceiling Height – Bow Locker Enlargements

$1,900

Snack Bar Counter Modifications

. $600

Total

$17,600

65 Foot Ferry. In discussing the loss in seating and freight storage impact, the ferry representative noted that if the provisions of the draft guidelines were mandatory, they would probably have had to build a larger vessel to compensate for the loss of critical seating and freight space. As freight is generally passenger luggage, if passengers cannot easily store their luggage, their desire to use their ferry service is impacted. Carrying golfers with their golf bags and other luggage represents a sizable cliental. The 55 foot vessel is on the margin of what the company projected it would really need.

It is estimated a 65 foot vessel would cost approximately $2.3 to $2.4 million in 2006 dollars and (roughly) an additional $9,000 to $15,000 would be needed to make its designs comply with the draft guidelines. As a 65 foot vessel has 149 seats, where space is needed to provide accessibility features highlighted in the analysis of the 55 foot designs, seats would be removed. It is (roughly) estimated that space needs for accessibility would reduce the seating capacity to around 125 seats (which is above the 108 capacity of the 55 foot design). Going from a 55 foot ferry to a 65 foot ferry complying with the draft guidelines represents a $418,000 to $518,000 increase, about 22 to 27 percent increase over the cost of the original 55 foot vessel. By going with a 65 foot vessel, the fuel consumption would increase by an estimated 18 percent.

The ferry representative also noted that bank financing would not have been available for a 65 foot vessel when the decision was made to fund the 55 foot vessel. Therefore, the ferry service would have had to delay adding another vessel and slowed the growth of the company.


1 An entry point is where passengers embark or disembark a vessel. Not every entry point is used at each stop on the ferry’s route.

2 Although the report references decisions made by the ferry representative, it should be noted that the Access Board hired a consultant (acceptable to the ferry representative) to provide most impact information (including cost estimates) which was used by the ferry representative in the case study decision making process.

3 The 2006 draft guidelines, as amended by Board action at the 2007 and April 2008 meetings.

4 If the 2 fold-down seats at the 2 wheelchair spaces could not be used because the wheelchair spaces are occupied by wheelchairs or used to compensate for the loss in freight storage, 8 fixed seats are lost in the new designs. Although the guidelines do not allow vessel features (fold-down seats) to project into wheelchair space clearances, the study assumes DOT would allow such operational solutions.

5 The ferry representative is unsure of how readily usable the life jacket storage space would be for passenger freight due to its location from the stern entry doors.

6 The ferry representative did evaluate moving the port side seating section (contains 2 wheelchair spaces) aft into six square feet used by the port side storage area, but this would also impact the location of the port side engine exhaust stack (and for aesthetic reasons, also the starboard side exhaust stack).

7 The cross aisle, after the reduction, has a width of 27 inches which meets US Coast Guard requirements. As the draft guidelines do not require any elements or spaces at the forward end of the main deck to be accessible, the cross aisle is not required to be part of an accessible route or accessible means of escape.

8 Passengers carry and deposit their own luggage. Depending on the size of the luggage, bringing luggage to the bow could be difficult.

9 The draft guidelines do not require an onboard accessible route between the main deck and upper deck (nor is one provided), see V206.2.1 Exception 1. Therefore, section V222.3.3 requires the 2 wheelchair spaces to be placed in the seating area on the main deck.

10 Although an onboard accessible route is not allowed to overlap the wheelchair spaces (WcS), the accessible route must be positioned to facilitate a 90 degree turn. Therefore, as the accessible route stops at the WcS, section V403.5.2.2 would require the combined WcS to be wider. Normally, two adjacent WcS are each 33 inches wide, allowing one wheelchair to park in a space 30 inches wide and the other to have a space 36 inches wide to maneuvering. To comply with the draft, one space is still 30 inches wide but the other would need a 42 inch width (30+42=72). The seat pitch (distance between seats) is about 34.5 inches. Therefore, two rows of seats occupy 69 inches in length. The 2 seats removed (issue #2) for head clearance reasons provide space for the additional three inches. The remaining space is used for storage (issue #4).

11 As the fold-down seats do not require passenger operation for passengers who use wheelchairs to occupy the wheelchair spaces, the fold-down seats are not subject to the operable parts requirements in section V309. Although the guidelines do not allow vessel features (fold-down seats) to project into wheelchair space clearances, the study assumes DOT would allow such operational solutions.

12 The ferry representative is unsure of how readily usable the life jacket storage space would be for passenger freight due to its location from the stern entry doors.

13 Although vertical access is not required by V206.2.1 Exception 1 to the upper deck, section V206.2.2 still requires an accessible route connecting elements and spaces which are required to be accessible and therefore the upper deck exterior passenger door must be accessible, including a ramping system to address the coaming.

14 For purposes of the case study, it is assumed the administrative authority (the US Coast Guard) would allow use of Exception 4 in V404.2.5.

15 The ferry representative had received a waiver from the US Coast Guard (USCG) for a similar situation and is cautiously optimistic the USCG would grant a waiver in this case study new design situation. However, if no waiver is granted, the impacts of providing a ramping system over six inch high coamings would seriously impact the new designs of the vessel on both the main and upper decks. For example, the stern door would have to be moved forward one foot to provide space for an exterior ramp and landing. If the inside of the door had a ramp, the golf bag storage rack could not meet its accessibility requirements because no level (i.e., 1:48) clear deck space could be provided at it and the interior ramp’s landing would require removal of seating.

16 Although a circulation path to the bow stair is available through the pilot house doors, to avoid passengers interrupting the ship’s captain directing crew actions in an emergency, the US Coast Guard (USCG) requires another way to connect the bow stairs. Due to the size of the upper deck, a window is allowed by the USCG to connect the bow stair. Likewise, on the main deck, the connection to the bow is through a window so the corresponding AMOE is not required to the bow from the main deck cabin.

17 Section V106.5 defines an evacuation station as the end point in a path of escape travel on a passenger vessel. The definition further notes that evacuation stations include life boat embarkation stations, life raft embarkation stations, or other places where passengers depart the vessel in an emergency. It was reported that this vessel is not required to have life boats or rafts and has no formal evacuation stations.

18 If the two fold-down seats at the two wheelchair spaces could not be used because the wheelchair spaces are occupied by wheelchairs or used to compensate for the loss in freight storage, 8 fixed seats are lost in the new designs.

19 The ferry representative is unsure of how readily usable the life jacket storage space would be for passenger freight due to its location from the stern entry doors.