Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street NW, Suite 1000
Washington, DC 20004-1111
Ladies and Gentlemen:
Padelford Packet Boat Co., Inc. a member of the Passenger Vessel Association 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
Padelford Packet Boat Co., Inc. owns and operates a fleet of 4 Subchapter K Small Passenger Vessels in St. Paul, MN. We are a seasonal family run business with 50 seasonal employees and 20 year round staff, operating from April thru October. Our vessels range in size from 200 to 486 passengers the average passenger count is around 150 passengers per trip. Cruises range from daily sightseeing cruises to corporate charters including school field trips, weddings, dinner cruises and our unique Big River Journey cruises in partnership with the National Park Service.
Three of our vessels are accessible from the loading deck; the Jonathan Padelford our smallest and oldest vessel built in 1969 is not accessible and would require considerable resources to be in compliance with the proposed regulations. If required the alterations to the Jonathan Padelford would result in appreciable weight gain and loss of stability causing the passenger capacity to decrease below 150 passengers.
Padelford Packet Boat Co., Inc. has made reasonable alterations to all vessels over the 35 years to insure all guests enjoy the experience of cruising on the Mississippi River. However, we do not have unlimited resources to bring all vessels into compliance with the proposed regulations. By our estimates we could spend over $100,000 per vessel.
It is our opinion that existing vessels should be exempt from the proposed access regulations as is common in other modes of transportation i.e. planes, busses and airplanes. We strongly disagree with the Passenger Vessel Associations attempt to exempt 150 passenger vessels from the proposed regulations. Padelford Packet Boat Co., Inc. has spent considerable time and resources over the past two years complying with the Maritime Transportation Security Act which is not applicable to passenger vessels fewer than 150 passengers. We have seen the unintended consequence of excluding certain types and sizes of vessels. By excluding 150 passenger vessels from regulation manufacturers of smaller vessels are gaining a market advantage over the larger vessels thus devaluing our vessels. We feel strongly that the minority of Passenger Vessel owner sand operators with vessels over 150 passengers are bearing the brunt of the proposed regulation.
I am aware that the Passenger Vessel Association has been in frequent contact with the Access Board regarding this rulemaking, including testifying at public hearings three times in 2005. I support the following points that PVA has stressed in its comments:
Providing access in marine and aquatic environments is more challenging than doing so at sites on land. Waves, wind, tides, fluctuating river and lake levels, and various types of vessel motions must be contended with. In designing, constructing, and operating a vessel, there is no higher priority than safety.
There is a wide diversity of types, sizes, and functions of passenger vessels in the U.S. domestic passenger vessel fleet. Most vessels to be affected by the Access Board action are not cruise ships.
Any provision that passenger vessels be required to provide vertical access between decks should be tailored very narrowly to those vessel designs and capacities that are capable of safely and efficiently containing elevators or lifts. In many cases, installing elevators in vessels is technically infeasible, structurally impractical, and potentially unsafe.
Thank you for this opportunity to participate in your rulemaking process.
Capt. Gus Gaspardo
Director of Marine Operations
Padelford Packet Boat Co., Inc.