Thomas M. Susman
Ropes & Gray LLP
ONE Metro Center
700 12th Street, NW, Suite 900
Washington, DC 20005-3948
Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street, NW - Suite 1000
Washington, DC 20004-1111
Re: Request for Extension of time for filing of Comments on Docket No. 2004-2 (ADA –Accessibility Guidelines for Passenger Vessels)
Dear Sir or Madam:
I am writing on behalf of the American Gaming Association (AGA) and its member companies who operate casino vessels to request additional time for filing comments on the above numbered docket matter. The Passenger Vessel Access Advisory Committee spent over two years developing a report provided to the Board in December 2000. The Board developed draft Guidelines that were published over four years later, at the end of November 2004. Finally, 6 years after the process began, the draft Guidelines were published with less than 4 months provided for public comment.
The 113-page notice and draft Guidelines would impose entirely new requirements on the maritime-based sector of the gaming industry, which is comprised of vessels that are extremely diverse, ranging from old-fashioned riverboats to modern barges.
We believe that the AGA can be of greater assistance to the Access Board in our comments on the draft Guidelines if we are provided with additional time to analyze the Guidelines in a more comprehensive manner and to fully assess their potential impact on existing vessels, as well as on alterations and construction of gaming vessels in the future. We therefore request that the Board extend the comment period for the proposed Guidelines for an additional 90 days.
Thomas M. Susman
cc: Judy Patterson, Vice President American Gaming Association