Clipper Navigation, Inc., DBA Victoria Clipper, Darrell E. Bryan
November 13, 2006 [Email]

Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
113 F Street NW, Suite 100
Washington, DC 20004-1111

VIA EMAIL pvag@access-board.gov

Re: Docket No. 2004-1

Ladies and Gentlemen:

As a member of the Passenger Vessel Association, Clipper Navigation, Inc., DBA Victoria Clipper, submits the following comments regarding Version 2 of the draft accessibility guidelines for passenger vessels.

Clipper Navigation, Inc. was established as a Washington State Corporation in 1985 and inaugurated service from Seattle to Victoria, British Columbia on July 1, 1986. It is the owner/operator of the “Victoria Clipper” vessels which have transported more than five (5) million passengers in our first twenty (20) years of service. Clipper is also the first and only marine transportation carrier in modern history to operate year round service on this route without a subsidy.

Clipper’s business is seasonal in that over eighty (80%) of our transportation business is generated between May 15 and September 15. This in turn provides the financial basis and ability to provide year round service and employment. Our employment fluctuates from an off-season base of approximately one-hundred-thirty (130) to two-hundred-fifty (250) employees during our peak summer season.

We currently operate four (4) vessels on our various domestic and international routes. They range in passenger capacity as follows: 150, 237, 296 and 330. The vessels’ build dates were between 1985 and 1993. The cost to replace our larger vessels would be in the range of a minimum of eight (8) to nine (9) million dollars whereas the two (2) smaller vessels would be two point five (2.5) million for the smallest vessel to five (5) million for the 237 passenger vessel.

Please refer to the detailed comments submitted by the Passenger Vessel Association as to specific portions of the draft guidelines. The following concepts are important:

• The Access Board should use the applicability thresholds found in Version 1 of the draft guidelines, not those of Version 2. Specifically, the guidelines should apply only to those ferries with a capacity of more than 150 passengers. The Passenger Vessel Access Advisory Committee noted that design challenges increase dramatically for smaller vessels (including ferries) with a capacity of 150 or fewer.
• Whenever accessibility and safety goals conflict, safety must be paramount. We cannot decrease safety of passengers and vessels from standards set by the Coast Guard.
• With regard to alterations of existing passenger vessels, there may be instances in which compliance with the draft guidelines is “technically infeasible”.
• The Access Board must understand the economics of operating a passenger vessel. Vessels must generate sufficient revenue for their owners. If installation of accessibility features results in the elimination of too much revenue-producing space, the viability of the business may be undermined. This loss in revenue would be on top of the extra costs of constructing or altering the vessel.

Yours truly,

Darrell E. Bryan
Executive Vice President and General Manager

CLIPPER NAVIGATION, INC. • 2701 ALASKAN WAY, PIER 69 • SEATTLE, WA 98121
PHONE 206.443.2560 FAX 206.443.2583 WEBSITE: WWW.VICTORIACLIPPER.COM