2 Ferry St.
P. O. Box 33
New London, CT 06320
Reservations (860) 443-5281
Fax (860) 443-0263
TO: OFFICE OF TECHNICAL AND INFORMATION SERVICES
ARCHITECTURAL AND TRANSPORTATION BARRIERS
1331 F Street, Suite 100
Washington, DC 20004-1111
RE: AMERICANS WITH DISABILITIES ACT
ACCESSIBILITY GUIDELINES FOR PASSENGER VESSELS;
LARGE PASSENGER VESSELS
FROM: ADAM WRONOWSKI
CROSS SOUND FERRY SERVICES, INC.
2 FERRY STREET
NEW LONDON, CT 06320
Cross Sound Ferry Services, Inc. (CSF), a Connecticut Corporation with offices located in New London, CT and Orient Point, NY, offers the following comments to the Architectural and Transportation Barriers Compliance Board regarding the Americans with Disabilities Act (ADA) Accessibility Guidelines for Passenger Vessels; Large Passenger Vessels:
Cross Sound Ferry operates vehicle and passenger vessels, classified under 46 CFR, Subchapters T, K, and H, between New London, Connecticut and Long Island, New York. CSF also owns and operates the facilities that service these ferries. CSF is one of the largest privately owned passenger/vehicle ferry services in the Country, transporting over 1.2 million passengers and 400,000 vehicles annually. CSF is committed to providing safe and reliable transportation services to the traveling public, and we welcome the opportunity to comment on the proposed rules.
Our primary concerns with the proposed rules are the conflicts that will arise between safety and accessibility. Many changes that would improve accessibility aboard our vessels, would conflict with current Coast Guard safety regulations. These issues need to be fully evaluated and resolved prior to issuing a final rule. For example:
In addition to safety concerns, there are practical issues. Vessel designs and uses vary dramatically. Certainly a ferry vessel of 160 feet, carrying less than 300 passengers has different design constraints than a cruise ship of over a 1000 feet, carrying over 1000 passengers. The rules must be flexible to accommodate all types of vessels. The marine environment is dynamic, and at times harsh. Vessels roll, heel, and pitch creating forces not experienced on land. The marine environment also wreaks havoc on electrical equipment. Most of the accessible equipment available today, such as chair lifts and elevators, are not designed to be exposed to salt water. A “marine” chairlift installed aboard one of our ferries has been so unreliable, that we stopped advertising that it was available. The company, who manufactured it, has spent endless hours repairing and rebuilding it. Even after a complete rebuild, where it was completely removed from the vessel, the lift stopped working less than a week after reinstallation.
Aboard another of our ferries, we recently installed an elevator. In researching potential manufacturers, one vendor, who we knew had previously provided elevators to ferries, said they had stopped providing elevators to be used in the marine environment because the warranty cost was too high. We settled on a very simple, hydraulic elevator with manual doors. We have not had any maintenance problems with the elevator and the public has been very pleased with the result. In our opinion, the proposed rules will require too much automation in elevators, and will lead to high down time and passenger frustration.
The current proposed rules for new vessels and vessels undergoing alterations should be considered carefully. The Coast Guard and vessel operators have the greatest understanding of the marine environment and its unique challenges. These stakeholders should be consulted further to resolve the conflicts between existing safety regulations and the proposed accessibility rules. Safety must remain the first priority aboard passenger vessels.