Gladding-Hearn Shipbuilding, Duclos Corp., Peter J. Duclos
November 13, 2006 [Email]

Duclos Corporation
GLADDING-HEARN
SHIPBUILDING

Office of Technical and Information Services Architectural and Transportation Barriers Compliance Board
113 F Street NW Suite 100 Washington, DC 20004-1111
(Sent by e-mail to pvag@access-board.gov.)

Re: Docket No. 2004-1

Ladies and Gentlemen:

As a builder of small passenger vessels and an associate member of the Passenger Vessel Association(PVA), Gladding-Hearn Shipbuilding, Duclos Corporation, submits these comments on Version 2 of the draft accessibility guidelines for passenger vessels.

As one of the most advance builders of passenger vessels in the US we have always taken a proactive approach to access for passengers with disabilities. Fortunately many of our customers share our views and are already well ahead of the competition by providing appropriate access. However certain areas of the latest draft go beyond what we feel is reasonable for access on board small passenger vessels.

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 can not 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.

The Passenger Vessel Association has a successful record of proactively addressing regulatory issues however the industry must remain financially viable to provide passengers with disabilities the variety of safe and competitive opportunities for transportation and leisure activities that are provided by the small passenger vessel industry.

Please carefully consider the comments of the Passenger Vessel Association.

Sincerely,

Peter J. Duclos
President
Gladding-Hearn Shipbuilding, Duclos Corp.

One Riverside Avenue • Box 300 • Somerset, MA 02726-0300, USA,(GMT-5) • Tel. (01) 508-676-8596 Fax.(01) 508-672-1873
Website: gladding-hearn.com Email: peterd@gladding-hearn.com
DESIGNERS • BUILDERS