July 28, 2005
Office of Technical and Information Services,
Architectural and Transportation Barriers
1331 F Street, NW., suite 1000
Washington, DC 20004-1111
Subject: Comments on Proposed Rule “Americans With Disabilities Act (ADA) Accessibility
Guidelines For Passenger Vessels; Large Vessels; Small Vessels”
The Delta Queen Steamboat Company (DQSC) is the largest and oldest U.S. privately-owned and operated Passenger Vessel Company in America. DQSC has been providing overnight passenger service on the U.S. Western Rivers and Inland Waters since 1890. Today the company operates with three full-service, overnight passenger vessels: the Delta Queen (174 overnight passengers), Mississippi Queen (484 overnight passengers), and the American Queen (476 overnight passengers). A total of 65,000 passengers per year take inland cruises aboard our three boats. A sizable proportion of our passengers are 70 years of age and above. Many of our older passengers are partially or completely disabled and DQSC takes pride in providing the best of accommodations and services for our passengers with disabilities.
The three vessels visit Ports of Call in numerous cities and towns on the Mississippi, Ohio, Arkansas, Tennessee, Cumberland, Tombigbee Rivers and Gulf Inter-Coastal Waterway, including New Orleans, LA, Baton Rouge, LA, Natchez, MS, Vicksburg, MS, Memphis, TN, Nashville, TN, St. Louis, MO, Dubuque, IO, St. Paul, MN, Paducah, KY, Louisville, KY, Cincinnati, OH, Wheeling, WV, Pittsburgh, PA, Mobile, AL, Pensacola, FL, Galveston, TX. The facilities or docks at the above locations are not owned/controlled by Delta Queen Steamboat Company. The only facility leased/controlled by DQSC is Robin St. Wharf, New Orleans, LA. DQSC vessels operate over ten months per year and the company employs over 700 persons.
The following comments pertain primarily to “alterations” to existing passenger vessels that carry more than 150 passengers or more than 49 overnight passengers as the new final rule may impact Delta Queen Steamboat Company’s three existing steam-powered paddle boats.
During yearly vessel lay-ups, our company routinely performs remodeling, redecorations, or renovations to include changing carpet, new wall papering, and painting. In some cases, we may change partitioning in or around spaces that do not affect existing accessibility layouts to/from cabins or to/from primary spaces or areas. In our opinion, the terms Remodeling, Renovation, Redecoration and possibly Rehabilitation as they are used to define “alterations,” may trigger requirements to improve or modify existing deck or space layouts to comply with ADA standards where existing accessibility already includes cabin openings, passageway, direct paths to primary areas that accommodate wheelchair and disabled passengers. In most cases, the above activities associated with “alterations” can be accomplished without changing the current layout of cabins, passageways, or decreasing the existing accessibility to or from the altered area.
We recommend that the definition of “alterations” to existing passenger vessels must clearly delineate between specific alterations that would trigger accessibility improvements and alterations that would not trigger accessibility improvements. Guideline language should be specific as to when accessibility improvements are and are not required. Accessibility improvements must be limited to larger scale changes such as vessel lay layout reconfiguration or significant structural modifications that clearly or directly affect passenger access to crucial spaces.
For past decades up to the present, this company’s record has been exemplary in providing an acceptable and sufficient accessibility level that successfully accommodates a substantial number of disabled/wheelchair passengers.
Thank you for your carefully considering our comments and questions.
Vice President, Marine Operations
Delta Queen Steamboat Co.
1380 Port of New Orleans Place
New Orleans, LA. 0130-1890