Office of Technical and Information Services,
Architectural and Transportation Barriers Compliance Board
1331 F Street, NW, Ste. 1000
Washington DC 20004-1111
Comment to Docket Nos. 2004-1; 2004-2 ADA Guidelines for Passenger Vessels
To Whom It May Concern:
This letter includes comments and opinions about our vessels and the intended ADA Guidelines for small passenger vessels. In particular, we are commenting about our ferries that carry vehicles and passengers (150 and under capacity).
Our major points, with supporting comment to follow, are these:
Washington Island Ferry Line, Inc. (WIFL) operates five small vehicle/passenger ferries on a route of 4.5 NM between the tip of the Door County Peninsula and Washington Island, Wisconsin, on protected waters connecting Lake Michigan and Green Bay.
These five ferries were designed and built for service on our particular route, using docks built for our service, with a customer base in mind that consists of year around residents as well as seasonal visitors. They are:
C.G. RICHTER - Built 1950; single diesel; 9 autos; 150 passengers. 65 x 25 x 9
This ferry was a primary ferry for many years, then used in later years only during the peak of summer tourism, and it was the sole winter ice ferry until 2003. Currently this vessel is not used and is for sale. Ferry has two decks: a main vehicle and freight deck, and an upper passenger deck with cabin and two heads. Loading is accomplished by attaching a 10 ft. wide steel plate to the port side of the ferry, or by two 30-inch gangplanks (no hand rails provided).
Ferry size and difficulty of side-loading has rendered it obsolete for present day service.
Vessel speed, as with our other ferries, is approximately 9 knots.
EYRARBAKKI - Built 1970; twin diesel; 18 autos; 150 passengers. 87 x 36 x 8.5
The open deck on this ferry carries a load of either 18 autos or a combination of autos with trucks or trailers. Bow and stern ramps permit drive-thru for autos, but large trucks and trailers must be backed on or backed off. Passenger access is over the same 16-ft. wide ramps used for vehicles. The passenger deck with cabin and men’s and ladies’ heads is approximately 10-ft. above the car deck and is accessed by stairs to port.
ROBERT NOBLE - Built 1979; twin diesel; 19 autos; 150 passengers. 90 x 37 x 9
Similar in arrangement to the Eyrarbakki with slightly more passenger seating on upper deck.
WASHINGTON - Built 1989; twin diesel; 21 autos; 150 passengers. 100 x 37 x 9
Several features distinguish this ferry from the others, most notably a centerline pedestal which is a structural support that houses engine room access, heads, storage, and stairs for vertical access to the passenger decks; there is a “sun deck” or uppermost passenger deck, and a cabin and seating on the 01 passenger level. While this ferry has the most main deck vehicle lane length, the lanes are narrow. The upper two decks have generous open air seating.
ARNI J. RICHTER - Built 2003; twin diesel; 18 autos; 150 passengers. 104 x 38 x 10
Heavily built with a hull designed for ice breaking in winter, this ferry design compromise vehicle deck space for a cabin and unisex head on the same level as the vehicles. Engine room access is located within this structural trunk, and also fore and aft passenger stairways to the mezzanine deck (inside cabin) and from that level to the uppermost open sun deck which has bench-style seating. Accommodation for elderly and disabled passengers was made with a main deck cabin and unisex head, although they are not strictly designed to ADA standards.
Route, service and seasonality – WIFL ferries operate year around serving an island population of 700, many non-resident property owners, and a summer tourism trade.
Since ferries are the only means of access to Washington Island during winter, the ferry Arni J. Richter was specifically designed and built to standards suitable for ice breaking and cold weather conditions. Winter crossing takes generally 40 minutes; the same route is less than 30 minutes in summer. Operations are profitable May through October, when revenues are greatest, but not in the remaining months.
Improvements to our ferries have been incremental, generally when equipment changes such as new motors or pumps are required. Major modifications to hulls or cabin have never been made, given the short season and short peak to the tourism season. We also find there are advantages to operating smaller and therefore more efficient ferries in the slower “off” seasons. New ferries were built as vehicular traffic changed (more trucks and trailers, less freight carried on deck, etc.). Passenger volume has not appreciably changed over a fifteen year period.
Profitability and deck area – From a service standpoint, the ability to transport trucks and trailers of all sizes throughout the year is important to our customers: modular homes; lumber; bulk cement; oil, gas and LP; food products; hardware; farm products; logs; package freight such as UPS or FEDEX…….are examples of the types of commodities carried either on trucks or trailers.
Nearly 65% of all annual company revenue is earned in July and August, months in which it is critical to fill ferry deck lanes with vehicles. Loss of main deck vehicle space is critical to profitability.
Vehicle revenue is also tied directly to passenger revenue. We have approximately 8000 one-way trips per year. If we lose revenue by losing one car space in order to satisfy an ADA requirement (and assume that this car space would earn revenue 50% of those trips) we would lose $11.50 x 4000 trips, or $46,000. The resulting lost passenger revenue could easily equate to $50,000, if we figure an average of 2.5 persons per vehicle.
Our ADA Suggestions for small ferry vessels –
We offer a number of suggestions:
These ferry ramp sections and ramp ends are designed to slide back and forth with sea motion, or articulate like fingers when the ferry has a list (such as with a heavy deck load). A fine ramp edge would have the potential of cutting tires, wearing over time to a knife-like taper. Overlaying a light plate to cover these gaps for passenger access is possible but not feasible, as the plate would either bend or break with usage.
(See enclosed photos showing truck tires on ramp edge….. )
Challenges in deck levels occur at doorways to heads or cabins, where ice and snow can build up and water sloshes against the threshold. A steel plate was welded to the deck rather than a threshold, but it is over ½” in height.
Is ½” change in level aboard a vessel an absolute, or is there an opportunity here for Flexibility? Unlike an ocean liner with miles of interior corridors (and little threat of water or snow), a small passenger ferry has maybe one or two points of access for passengers, plus perhaps a choice of two doorways into/from a cabin space, and where all access points are generally open to weather decks.
Current ADA wheel chair and companion seating requirements assume the person in the wheelchair and his/her companion always wish to face in the same direction, shoulder to shoulder, as if watching a movie. No allowance has been made for the companion to sit anywhere other than shoulder-to-shoulder, even though the objective
is for the two persons to travel from point A to point B, rather than focus toward a theater stage, etc.
Narrow cabins often found on passenger vessels limit ‘bump-outs’ for wheel chairs and beg for a creative seating solution. We submit that seating arrangements where two people face toward one another might actually be superior where conversation and eye contact is desired. Allowing for greater flexibility in wheel chair/companion
seating arrangements would not reduce the requirement for wheelchair spaces, nor detract from the experience of the disabled passenger.
[*** end of expanded comment section ***]
ADA Nine Questions - [Although some of the answers to the Rulemaking “Nine Questions” are found in the above text, following are brief replies to the questions posed in the Revised Draft Passenger Vessel Accessibility Guidelines.]
c. Case studies assume application of many shore-based guidelines, but do not account for down-scaled in size of vessel, especially vessels less than 150 passengers.
d. Don’t know, but it appears that the future designs we look at, in order to comply, would have to be substantially different, larger in size, and more costly to construct, than anything we have previously built.
e. Does not apply.
f. Does not apply.
g. This is a key problem, and one to which we need to be sensitive, for the needs of the disabled as well as for the general public. A single, approved means of emergency egress should suffice for small ferry, short route, small ferry. Crossing a vehicle deck with emergency egress paths restricts parking patterns. There is cost, either in sacrifice of useable vehicle space on deck, or in the increased ferry size needed to accommodate disabled access paths.
Work toward solutions that are an advantage for all passengers, and all types of vessels including vehicle ferries, without requiring increase in vessel size.
h. An increase in the range of 2-4% would be considered minimal and not a
discouragement to construction. Steel cost increases alone, or increases in main engine & transmission costs could easily exceed 2-4% due to other factors. However, that estimate seems low, given projects we’ve undertaken in the past. Changing vessel beam is even more problematic than length (although from a landsman’s point of view this may seem the easiest solution.
i. Larger vessels generally require larger power plants, which may result in greater fuel costs in the long run, possible dredging costs as draft keeps pace with length, or adjustments to docks and loading platforms as the vessel deck height changes relative to shore facility. The bottom line is this: we would consider it good business to have an ADA fully-accessible ferry, but the current limitations on small ferries as proposed don’t seem reasonable, and they offer few options in meeting the guidelines.
President, Washington Island Ferry Line, Inc.
Encl: photos of each ferry; photos of ferry ramp and vehicle tires during boarding
[Note: Six non-digital photos provided with these comments were added to the rulemaking docket but not included in this web document.]