One Riverside Avenue • Box 300 • Somerset, MA 02726-0300, USA,(GMT-5) • Tel. (01) 508-676-8596
Fax.(01) 508-672-1873 Website: gladding-hearn.com Email: email@example.com
Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street NW, Suite 1000
Washington, DC 20004-1111
Subject: ADA Accessibility Guidelines for Passenger Vessels
Ladies and Gentlemen:
Duclos Corporation dba Gladding-Hearn Shipbuilding, an associate member of the Passenger Vessel Association(PVA), submits these comments regarding your efforts to develop accessibility guidelines for passenger vessels, as published in the Federal Register of November 26, 2004. Please include these comments in the official record of both of your dockets as well as the corresponding U.S. Department of Transportation Docket.
Since our founding in 1955 our company has constructed more than 355 commercial vessels of all kinds, of which more than 60 are passenger vessels. Since 1987 we have been vigorously pursuing business in the high-speed catamaran passenger ferry market and have delivered 32 vessels to customers throughout the US and in Bermuda. Years before ADA became a reality, we were designing features into our high-speed catamaran ferries to accommodate passenger with disabilities. It has been our belief that in order for passenger vessels to be taken seriously as a form of public transportation, they must accommodate passenger with disabilities. We are pleased to point out that the high-speed catamaran ferries Flying Cloud and Lightening, illustrated in the Volpe Center’s “Door Coaming Research Report”, were delivered by our company in 1996.
We are aware that PVA has been in frequent contact with the Access Board regarding this rulemaking, including testifying at public hearings three times in 2005. We support the following points that PVA has stressed in its comments:
In addition to the above PVA comments we would like to point out some areas where the proposed regulations are in conflict with the current USCG Subchapter K passenger vessel regulations.
While these points may seem minor, they are in conflict with established USCG regulations to which hundreds of existing vessels are designed to meet. Stair dimensions and deck heights are some of the most basic elements around which vessels are designed. Changing these basic design elements will adversely affect vessel stability, safety, passenger capacity, speed and cost.
Thank you for this opportunity to participate in your rulemaking process.
Peter J. Duclos
Director of Business Development