Office of Technical and Information Services Architectural and Transportation Barriers Compliance Board
113 F Street NW
Washington, DC 20004-1111
Re: Docket No. 2004-1
Ladies and Gentlemen:
As a member of the Passenger Vessel Association, Hone Heke Corporation dba Expeditions submits these comments on Version 2 of the draft accessibility guidelines for passenger vessels.
Expeditions is a Passenger Ferry operation traveling between the Islands of Maui and Lana`I in the State of Hawaii. Expeditions is governed by the Public Utilities Commission and has a capacity of 149 passengers or less on all of its vessels with an operations requirement of a Captain and two crew.
Total passenger counts for Expeditions in 2004 was 149,000, in 2005 159,000 and through September of 2006 132,000. Revenues for the same periods were $3,400,000. for 2004, $3,700,000. for 2005 and through September 2006 $3,100,000. All this was achieved with 20 employees of whom 14 are shareholders. Expeditions has been able to keep the same ticket price since it started in 1989 due to this increased volume and the carrying capacities of its 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 (especially 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 the 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 estimated loss in revenue due to lost space for Expeditions is somewhere between 10% and 20%. This fact would directly impact ticket prices and in turn could cause a further decline in rider ship due to the price increase.
Expeditions respectfully request that you follow the guideline revisions proposed by the Passenger Vessel Association. Until the recent release of version 2 of the draft guidelines, all prior drafts and recommendations had the guidelines applicable only to ferries with a capacity of more than 150 passengers. Version 2 of the guidelines has abandoned this delineation. Instead, Version 2 proposes to apply the guidelines to all ferries regardless of passenger capacity. This is a poorly-thought-out proposal and must be reversed!
Steven T. Knight