November 13, 2006
Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
113 F Street NW
Washington, D.C. 20004-1111
By Fax to 202-272-0081
Re: DOCKET NO. 2004-1
Ladies and Gentlemen:
As a member of the Passenger Vessel Association (PVA), our company – Hornblower Cruises and Events – submits these comments on Version 2 of the draft accessibility guidelines for passenger vessels.
Our private company operates over 40 Subchapter T, K and H passenger vessels primarily on the inland waters of San Francisco and San Diego Bays, and within the Los Angeles/Long Beach, Newport Beach and Marina Del Rey Harbors. Our business provides over 500,000 passengers each year with dinner cruises, harbor cruises, private charters, and a variety of other events afloat. Many of the events are for groups that know each other before they come aboard the vessels, e.g., wedding parties or corporate events. We load and unload our passengers from over 30 different locations at public and private pier and dock facilities that range from secured marinas to public ferry terminals. Our operations are seasonal, with a busy month providing ten times the passenger count of a slower month.
Currently we employ approximately 675 crewmembers. About 250 crewmembers are full time employees. Looking at last year’s total hours worked, our FTE for 2005 was 472. We hire about 350 employees each year. Many of our crewmembers are Coast Guard licensed, many have families, and many have been in our employ for 5 to 15 years. Their duties range from vessel operations and maintenance, to food service, to entertainment, to administrative support duties such as reservations, sales and accounting.
The breakdown of our fleet is roughly as follows: twenty-five (25) Subchapter T vessels, fifteen (15) Subchapter K vessels, and two (2) Subchapter H vessels. These vessels range in size from about 50’ in length to 300’ in length, are designed with anywhere from one to four decks, and carry from 50 to 2000 passengers each. The vessels range in age from a few years to several decades and their hull materials run from wood to fiberglass to aluminum to steel. Their typical routes are inland Lakes, Bays and Sounds; a few vessels also have Limited Coastwise routes, which allows them to go out to 20 miles from shore. A recent replacement value estimate of one of our Subchapter K vessels came in at $5.5M.
Our twenty-five (25) Subchapter T vessels represents 60% of our fleet. By definition, they carry less than 150 passengers. Most of these vessels are small, one- and two-deck vessels and they have significant dimension, crowding and boarding limitations. They represent a unique challenge when it comes to accessibility and they should be treated separately and distinctly from the larger passenger vessels when it comes to developing appropriate accessibility guidelines.
Please refer to the detailed comments submitted by the Passenger Vessel Association as to specific portions of the draft guidelines. The following concepts are very 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 vessels 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 the safety of passengers and vessels from those standards set by the U.S. 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. Our company operates on a narrow margin of bottom line profit. A 10% drop in revenue would take us from black to red ink very quickly. We strive to add vessel inventory each year, but a 10% increase in vessel construction costs would severely deter our capability to do so. A 10% increase on $5.5M is $550,000!! Obviously, any combination of the two (10% drop in revenue and/or increase in construction costs) would be devastating to our business.
Thank you for the opportunity to comment to this Docket. The U.S.-flagged passenger vessel industry needs the Access Board to respond positively to the suggestions and observations offered by us and the Passenger Vessel Association. The federal government needs to implement workable ADA guidelines that offer proper accessibility and, at the same time, will preserve our economic viability.
Corporate Director of Marine Operations
Hornblower Cruises and Events
Pier 3, On the Embarcadero
San Francisco, CA 94111