164 Northern Avenue
Boston, MA 02210
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,
Spirit Marine, 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 of November 26, 2004. Please include these comments in the official record of both your dockets as well as the corresponding U.S. Department of Transportation Docket.
Spirit Marine operates 13 dinner cruise sightseeing vessels, carrying nearly one million passengers annually. We operate out of seven cities in the U.S. and do not control any of the docks we berth at. We leave from and arrive at the same pier facility in each of the cities we operate in.
Our cruises are generally less than three hours in duration and accommodate up to 600 passengers on either two or three enclosed decks with an additional upper outside deck. We operate out of seven cities in the U.S. and do not control any of the docks we berth at.
We have accommodated passengers with disabilities throughout our 27 year history. Our vessels have handicap accessible rest moms on at least one deck per vessel and our crew have comfortably and readily assisted passengers with wheelchairs between decks. Though passengers with disabilities have been too low to measure on our vessels, we do recall specific, rare, group bookings in the past that have seen as many as 50 wheelchairs accommodated comfortably.
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:
Thank you for this opportunity to participate in your rulemaking process.