Here are the comments from North Country Independent Living regarding:
Revised Draft Passenger Vessel Accessibility Guidelines issued July 7 , 2006
As an independent living center located in a small city on the largest freshwater lake in North America, we feel it important to stress that recreational and commercial activities on the water contribute significantly to community life for residents and visitors alike. To fully participate in our communities on Lake Superior means nothing less than access to the water and water-borne transportation.
Presently, we have two services which fall under the new Revised Draft Passenger Vessel Accessibility Guidelines; a passenger vehicle ferry which operates boats on Lake Superior as speeds of 10+ knots with 150 or fewer passengers, 20 or fewer vehicles, and a harbor cruise service the largest of whose boats has 2+ decks and a passenger capacity between 150 to 400 passengers. There are also numerous other smaller charter craft.
At present the ferry-boats which carry passengers and vehicles from Bayfield, Wisconsin to Madeline Island and back are only accessible in that all wheeled vehicles may rest on the main vehicle deck which is used for vehicle transport. Passengers in wheel chairs have no access to the passenger decks above the vehicle deck. Given the small size of the Ferry service and the advanced age of its fleet, we must emphasize both the likelihood and apparent expense of significant alterations. In implementing the guidelines that apply to these small boats, we suggest the need for maximum flexibility so that owners may comply with the new accessibility guidelines in a manner best suited to both their customers and our communities. We are concerned that these services will need to make their craft accessible only if and when they choose to purchase new vessels, something which does not seem likely to happen soon.
We also applaud the Department’s decision to continue to evaluate the weathertight and watertight requirements of exterior doors with coamings in order to determine that the basic water closure and pressure functions are in no way compromised for threshold accessibility. The exceptions listed in the PVAG draft appear to address this and we are confident that Coast Guard is indeed the appropriate authority to determine which designs best serve to further accessibility for people with disabilities without compromising basic aquatic engineering.
We are also concerned that the new draft guidelines will do little to provide ferry and small commercial craft owners here with positive incentive to invest in accessibility. Thus, access to the aquatic activities so important here for many of our community members will wait until these services choose to buy new boats. We therefore also encourage the Department to closely examine what implementation mechanisms may be available in order that the new guidelines will operate as a strong motivator for small services which operate here (the services mentioned above and smaller) to make the investments in accessibility. Whether in dockside access or on- board facilities, operators will need incentives to meet not only the letter of the law but also the spirit and ultimate objective of the ADA, access for all community members to all things which enrich our lives and our communities.
Bob Olsgard, Transportation Coordinator
North Country Independent Living
2231 Catlin Ave - Superior, WI 54880
715-392-9118 v/tty or 800-924-1220 v/tty