Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
113 F Street NW
Suite 100
Washington, DC 20004-1111
(By fax to 202-272-0081 or by email to pvag@access-board.gov.)
Re: Docket No. 2004-1
Ladies and Gentlemen:
As a member of the Passenger Vessel Association, Madeline Island Ferry Line submits these comments on Version 2 of the draft accessibility guidelines for passenger vessels.
Madeline Island Ferry Line has 4 sub chapter T passenger and car ferries. Our vessel average age in 36 years with an estimated cost of $4 million to build a new car and passenger ferry operable in our late season ice. Our operating conditions can be difficult with the wind, changing water levels, ice and storms of lake Superior.
Our route is 2.2 miles from Bayfield, WI to Madeline Island on the western end of Lake Superior. Our four ferries carry 10, 15, 20 and 25 cars respectively with 2 crew for each of the two smaller boats, and 3 crew (one captain and 2 deckhands) for each of the larger ferries. We employ 40 summer, seasonal and full-time employees and are one of the largest employers in our area.
We are a seasonal operation, far from our major markets. Summer tourism traffic provides a significant amount of our revenue, allowing us to provide off season service and keep our tariffs affordable for our local residents.
Since 9-11 and the 2000 stock market correction, our ferry traffic numbers have dropped significantly making it increasingly difficult to manage on reduced revenues. At the same time, our expenses, including fuel, health and business insurances have risen far more than the CPI.
● 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 (including 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 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. Our vessels must generate sufficient revenue for us as owners, cover operating expenses and weather poor traffic years. If installation of accessibility features results in the elimination of too much revenue-producing space, the viability of our business may be undermined. This loss in revenue would be on top of the extra costs of constructing or altering the vessel.
If our cost of construction for a new vessel were 10% higher and our car carrying capacity less by meeting accessibility guidelines, we estimate that our tariff would need to increase by a minimum of 10-15%. This would price us out of the tourism market and make it difficult for our local residents to afford ferry passage.
Sincerely,
Gary W. Russell
President/General Manager
Madeline Island Ferry Line
Robin Trinko-Russell
VP Finance
Madeline Island Ferry Line
Mike Radtke
Marine Operations Manager
Madeline Island Ferry Line
715-747-2051
Box 66
La Pointe, WI 54850