Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
113 F Street NW, Suite 100
Via E-Mail email@example.com
Re: Docket No. 2004-1
Ladies and Gentlemen:
We hereby submit the following comments regarding Version 2 of the draft accessibility guidelines for passenger vessels. As members of the Passenger Vessel Association, we are greatly concerned with applicability thresholds found in Version 2 and urge your consideration of those found in Version 1.
We operate two marine transportation companies:
One company, Victoria Rapid Transit (VRT), has provided passenger ferry service between Port Angeles and Victoria, British Columbia for the past sixteen years, using, two vessels, each certified for 150 passengers. VRT operates seasonal international passenger service from late May through the end of September as well as both international and domestic private charter services during the off-season. We have given high priority to accessibility to both vessels.
The second company, Arrow Launch Service, Inc (ALS), is stringently regulated by the Washington Utilities and Transportation Commission and operates “24/7" year-round. We have provided water taxi services to ships at anchor in all Puget Sound ports for the past seventeen years. ALS operates a total of eight vessels plus ancillary equipment in the form of barges, landing craft, etc. The vessels used in the water taxi business range from 32 feet to 70 feet, carrying from a low of 15 passengers to a high of 45 passengers. It should be noted that, in this particular industry, we are in the business of providing transport for crewmembers of tankers and other large ocean-going vessels.
Between the two companies, we provide full-time, family wage jobs to 45 families year-round and supply part-time employment, mostly to college-bound youth, during peak travel season.
Accessibility to our vessels is something we take quite seriously, and we have kept abreast of current mandates on all of our vessels. Requirements to the extent suggested in Version 2 could very well mean alterations at a cost that would be prohibitive to our ability to maintain safety aboard our vessels while continuing to provide the quality of services needed to operate successfully.
We urge you to carefully consider the detailed comments submitted by the Passenger Vessel Association; to be aware of the types of clientele using smaller vessels such as water taxis to commercial vessels; and to be especially cognizant of the economics of operating passenger vessel services and the need for a careful balance between the safety of and accessibility needs of all passengers.
We would be happy to make ourselves available should you have further need to discuss this important matter.
Jack L Harmon, President
Victoria Rapid Transit, Inc,
Arrow Launch Service, Inc.