TO: OFFICE OF TECHNICAL AND INFORMATION SERVICES
ARCHITECTURAL AND TRANSPORTATION BARRIERS
COMPLIANCE BOARD
1331 F Street, Suite 1000
Washington, DC 20004-1111
RE: DOCKET NO. 2004-1
REVISED DRAFT PASSENGER VESSEL ACCESSIBILITY GUIDELINES AND SUPPLEMENTARY INFORMATION
FROM: CROSS SOUND FERRY SERVICES, INC.
2 FERRY STREET
NEW LONDON, CT 06320
Cross Sound Ferry Services, Inc. (CSF), a Connecticut Corporation with offices located in New London, CT and Orient Point, NY, offers the following comments to the Architectural and Transportation Barriers Compliance Board regarding the Revised Draft Passenger Accessibility Guidelines and Supplementary Information.
Cross Sound Ferry operates vehicle and passenger vessels, classified under 46 CFR, Subchapters T, K, and H, between New London, Connecticut and Long Island, New York. CSF also owns and operates the facilities that service these ferries. CSF is one of the largest privately owned passenger/vehicle ferry services in the Country, transporting over 1.3 million passengers and 450,000 vehicles annually. CSF is committed to providing safe and reliable transportation services to the traveling public, and we welcome the opportunity to comment on the proposed rules.
Many of our concerns have been addressed by the Board in past revisions of the Guidelines, however, we would like to comment specifically on the section discussing Platform Lifts (V409). Many sections of the Guidelines allow for exceptions in the case of existing equipment or special circumstances. We suggest that existing platform lifts, which serve two landings maximum, be permitted to have manual gates and self-closing swing doors. This exception closely resembles the existing exception in section V409.6. We currently own three lifts, which have manual gates and self-closing swing doors. These lifts have been warmly received by disabled passengers, and to my knowledge, we have not received a complaint regarding their operation.
Additionally, the discussion at the beginning of the Revised Guidelines states “Lifts must not be installed which require employee assistance to use.” We recommend an exception for existing platform lifts that require employee assistance to use. Requiring employee assistance serves two purposes: we prevent unauthorized access to the vehicle deck while the vessel is underway and we prevent use of the lift when sea conditions make the lift unsafe while underway. In many respects, a ferry is more like a bus than a building. Wheelchair lifts aboard busses are generally employee assisted and only used while the bus is stationary. This prevents unauthorized and unsafe use of the lift. We understand the rule intends to allow a disabled person to be independent, but believe the unique operating environment of a passenger ferry warrants consideration of this exception.
Thank you for the opportunity to comment on the Revised Draft Guidelines.
Sincerely,
Christopher J. Anglin
Cross Sound Ferry Services, Inc.
2 Ferry St.
P. O. Box 33
New London, CT 06320
Reservations (860) 443-5281
Fax (860) 443-0263
E-mail: info@longislandferry.com
www.longislandferry.com
DATE: December 8, 2006 [Email]
Mr. Paul Beatty
Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street, Suite 1000
Washington, DC 20004-1111
RE: Docket No. 2004-1
Revised Draft Passenger Vessel Accessibility Guidelines and Supplementary Information
Dear Mr. Beatty,
In response to our earlier conversation, I would like to detail some of the benefits we have experienced through the use of enclosed platform lifts versus “marine” external chair lifts and fully automated elevators.
We own 3 enclosed platform lifts. These lifts have been installed on existing vehicle/passenger ferries. The vessels vary in size from 240’ – 310’ in length and 99 – 1500 Gross Tons. They are capable of carrying between 80 and 100 cars each. The vertical distance from the car deck to the passenger deck is 14’ to 20’.
Prior to the installation of these enclosed platform lifts, we had installed an external chair lift, which rode above an existing stairwell aboard our ferry, JOHN H. The manufacturer claimed that it was a “marine” chair lift. The lift had many electronic components to assist in its automation. The lift was meant to be operable without employee assistance, however, its unreliability necessitated employee assistance. The lift was frequently unusable due to electrical problems. Generally, repairs to the lift were made within a week’s time, however, if parts had to be replaced that were not readily available, repairs could take longer. By the third year of service, the lift was only operational 50% of the time. Passengers became very frustrated when they arrived expecting a lift, only to find out the lift was broken. The excessive maintenance problems led us to seek alternatives.
In pursuing alternatives, we spoke with other ferry operators who had elevators or lifts in service. Many of the maintenance issues with elevators revolved around the automated doors. Our highest priority was to improve reliability to reduce passenger frustration. The lifts we chose to install are direct hydraulic, enclosed chair lifts. The platform door is a manual sliding gate and the shaft door is a self-closing swing door. These lifts have proven to be extremely reliable and have been operational at least 99% of the time. Feedback from passengers has been very positive, and to my knowledge we have not received a complaint about their operation.
The marine environment is dynamic, and at times harsh. Vessels roll, heel, and pitch creating forces not experienced on land. The marine environment also wreaks havoc on electrical equipment. Most of the accessible equipment available today, such as chair lifts and elevators, are not designed to be exposed to salt water and the marine environment. In our opinion, the proposed rules will require too much automation in elevators and chair lifts, and will lead to high down time and passenger frustration.
Many sections of the Guidelines allow for exceptions in the case of existing equipment or special circumstances. We suggest platform lifts, which serve two landings maximum, be permitted to have manual gates and self-closing swing doors. This exception closely resembles the existing exception in section V409.6. This would improve reliability and reduce passenger frustration.
Additionally, the discussion at the beginning of the Revised Guidelines states: “Lifts must not be installed which require employee assistance to use.” We recommend an exception for platform lifts that require employee assistance to use. Requiring employee assistance serves two purposes: we prevent unauthorized access to the vehicle deck while the vessel is underway and we prevent use of the lift when sea conditions make the lift unsafe while underway. In many respects, a ferry is more like a bus than a building. Wheelchair lifts aboard busses are generally employee assisted and only used while the bus is stationary. This prevents unauthorized and unsafe use of the lift. We understand the rule intends to allow a disabled person to be independent, but believe the unique operating environment of a passenger ferry warrants consideration of this exception.
These exceptions could be made for existing equipment and/or small vessels (ex. less than 1600 Gross Tons or Less than 500’ in length)
Thank you for the opportunity to make additional comments on the Revised Draft Guidelines.
Sincerely,
Christopher J. Anglin
Cross Sound Ferry Services, Inc.