Lawrence W. Roffee, Executive Director
U.S. Architectural and Transportation Barriers Compliance Board
1331 F Street, N.W., Suite 1000
Washington, D.C. 20004-1111
Reference: Fed. Reg. Vol. 71 No. 27 Page 38563
Docket No. 2004-1
Americans with Disabilities Act (ADA)
Accessibility Guidelines for Passenger Vessels
Availability of draft guidelines: notice of hearing
Dear Mr. Roffee:
The International Council of Cruise lines (ICCL) requests that the closing date for comments to the referenced docket and Accessibility Guidelines for Passenger Vessels be extended for 60 days. This would place the closing date at approximately Friday, November 3 or Monday, November 6, 2006.
ICCL is a Virginia based trade association that represents the interests of 16 of the largest cruise ship companies which operate over 115 cruise passenger ships. In 2004, ICCL operators carried over 11.5 million vacationers to over 400 ports around the world and in the United States. Consistent with ship safety and operations, it is a priority of ICCL members to provide accessible vacation experiences to all guests needing extra assistance and consideration.
ICCL appreciates the effort that the Access Board and staff have made in the past 12 months to review and evaluate; seek additional details and clarification; and make sense in terms of access needs, the many comments received regarding the initial draft of the Passenger Vessel Access Guidelines (PVAG). We note that a significant number of the comments resulted in a redrafting of various sections of the guidelines in the current version. The Board and staff are to be congratulated on their desire to learn more about the industry to be regulated and their understanding as to how and why ships are different than land based structures.
This being said, there are still complex and compelling issues that remain to be solved. Evidence of this fact is seen in the posing of 8 questions incorporating 24 sub-questions plus an additional 10 part question addressing the sample case studies.
Additionally, based upon our quick review, ICCL believes that there remains substantial issues to be reviewed and further discussed as the industry and the Board together continues to seek appropriate and reasonable solutions. For instance and in particular, the point ICCL raised regarding referencing or incorporating United States engineering standards for applicability to ships built in other countries does not appear to be resolved.
While we believe that great progress has been made in refining these guidelines, we believe that continued due process necessitates the opportunity for further meaningful review and comment. Given the above concerns and recognizing the fact that other segments of the international community, federal government and state governments have published no less than 7 other major rulemaking proposals that must be commented on in the same time frame assigned to this docket, that August is the height of the summer vacation season, and that ICCL is in the throes of a merger with our sister organization the Cruise Line International Association (CLIA), ICCL requests an appropriate extension, to the ending date for comments on these draft guidelines as suggested in the opening paragraph.
T. E. Thompson
Executive Vice President
cc: James J. Raggio, General Counsel
International Council of Cruise Lines
2111 Wilson Boulevard, 8th Floor
Arlington, Virginia 22201