Share the water. Share the wonder.
1101 Alaskan Way • Pier 55, Suite 201 -Seattle, WA • 98101• 206-623-1445 • FAX 206-623-5474
Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board 1331 F Street NW suite 1000
Washington, DC 20004-1111
Dear Sir or Madam:
Please accept these comments as regards to developing accessibility guidelines for passengers vessels, as published in the Federal Register on November 26, 2004.
Argosy Cruises has operated our of Seattle, Washington since 1949. We carry close to 500,000 passengers a year on a variety of cruises including narrated tours, educational field trips, dinner and entertainment cruses, charters and ferry services. We operate 12 vessels on both the tidal waters of Puget Sound and the fresh waters of Lake Washington and Lake Union. The Hiram Chitenden Locks which connects these waters, allows us to operate all our vessels on both the lakes and on Puget Sound. We operate out of five primary facilities owned by five different landlords. Four of these are privately owned and the fifth is a municipality. We regularly pickup and drop off passengers at an additional 25 Public Access Facilities owned by parks, city, county, state and federal governments as well as privately owned residences and marinas. Our vessels range in capacity from 25 to 800 passengers. Our oldest vessel was built 1924 as a wooden car ferry, and is now on the National Registry of Historic Vessels and our newest vessel was launched May of 2000.
In other words, our fleet is diverse and underlying our business success is a flexibility of operation. Over the years we have worked to improve our ability to accommodate passengers with disabilities. Profitable years and technological improvements enable us to make such changes more rapidly. Most companies in the hospitality business understand the value of accessibility to their customers. But we also know the cost and have to balance these improvement against complying with growing number of state, federal and local regulations.
We currently have ramps for boarding most of our vessels however wave and tidal variations can make them temporarily steeper than current recommendations. Even our lakes facilities are subject to seasonal variations that can effect this, but every year we budget some improvements along these lines. We currently handle the variations with staff and training, extending our brand of customer service to assisting everyone whether disabled or not.
We have an elevator on our newest and largest vessel, the Royal Argosy. We use it regularly and appreciate the benefit to our customers however we also know the cost. The elevator onboard the 180 foot Royal Argosy, connecting three decks is a constant maintenance challenge due mainly to the rocking motion of this vessel. Until elevator technology improves as well as installation and maintenance cost drop, installing a lift or elevator on one of our smaller vessels would be a severe hardship for us.
All of our vessels have built in thresholds required by Coast Guard in the design and construction. These cannot be removed but many can be minimized with ramps and wedges if safely installed. And again every year, as budget allows we work to buy and build these and improve the overall experience for all customers onboard.
I am aware that the Passenger Vessel Association has been in frequent contact with the Access Board regarding accessibility guidelines for passenger vessels like ours. As a long term member of PVA our company supports their efforts to communicate the challenges these regulations can have on our industry. I sincerely hope my comments regarding our company, Argosy Cruises, can be of similar use in helping the Board in developing any regulations. Please don't hesitate to contact me if I can clarify or answer any further questions on this issue.
VP of Operations