Washington State Ferries
291 1 2nd Avenue
Seattie, WA 98121-1012
Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street NW, Suite 1000
Washington, DC 20004-1111
Re: Americans With Disabilities Act Accessibility Guidelines for Passenger Vessels;
Large Passenger Vessels
Washington State Ferries, a publicly owned and operated marine transportation system operated by the Washington State Department of Transportation, offers the following synopsis of the agency's own efforts to develop and implement design standards for accessible overhead passenger loading. It is hoped that this agency's investment in engineering,research, and practical experience will be helpful in the consideration and development of accessibility guidelines for passenger vessels, as published in the Federal Register on November 26,2004.
About Washington State Ferries
Washington State Ferries is the nation's largest ferry system, carrying approximately 26 million passengers and 11 million vehicles per year. With headquarters in Seattle, service is provided throughout Puget Sound on ten routes in eight counties. Some 20 state-owned and operated terminals serve a fleet of 28 vessels, which range in capacity from a few hundred to 2,500 passengers.
Washington State Ferries has operated ferry terminals with overhead passenger loading (OHL) wallcways since the state took over the system in 1951. Early OHL walkways were in place at terminals in Seattle, Bainbridge Island, and Bremerton.
The original intent behind installation of OHL walkways was to shorten the time needed to offload and load the ferry, The ferries of the day carried both vehicles and foot passengers. If foot passengers use the cat deck for loading, more time is needed to progress through the toad cycle. For safety, foot passengers and vehicles are loadedseparately when they share the same loading ramp. This takes time. On the other hand, the overhead wallcways allow safe, simultaneous loading and unloading of both foot passengers and vehicles.
In the 1960s, WSF constructed "new" OHL wallcways at the Seattle and Anacortes terminals. Later, in the 1990s, new OHL walkways were added to terminals at Icingston, Edmonds, and a third walkway at the Seattle terminal. The Bremerton OHL walkway was also replaced with a modem walkway in the late 1990s.
WSFYs Response to the ADA, Early 1990s
With the inception of the Americans with Disabilities Act (ADA) in the early 1990s, WSF developed an implementation plan in conjunction with the Washmson State Department of Transportation. WSF examined the design of the wakways, especially in regard to the slopes of movable portions.
Although the ADA law was in effect when the walkways were designed for Edmonds, Bremerton, and Seattle, regulatory guidance spelling out the details of ADA compliance for ferries had not been issued and are now only in draft form (2005). In the absence of regulatory guidance on the details, WSF studied the issues and developed its own internal ADA design standards. At the same time, (mid 1990s) WSF was designing passenger-only ferry facilities with similar issues associated with the slope of the ramp connecting the floating berth to the pier.
Development of WSF's Internal Design Standards for Passenger Walkways
Back in the early to mid 1990s, when developing internal ADA design standards, WSF looked to existing regulatory guidance such as the Uniform Building Code (UBC) and the Americans with Disabilities Act Accessibility Guidelines (ADAAG), along with Washington State accessibility laws and administrative codes.
All of the design guidance for wallcways was similar:
The size of ramps is limited in the codes. The length of a ramp, and its rise or fall are all limited under the UBC and ADAAG for accessible routes. The rise or fall is limited to 30 inches before the 5-foot landing is required. The length of the ramp is also limited to no more than 30 feet before the 5-foot landing is needed. Level iandings are required in the codes to allow mobility-impaired persons to rest when climbing or descending a ramp.
WSF typically required ramps longer than the 30-foot maximum to access their vessels through the tidal range while maintaining an acceptable slope. Puget Sound has an extreme tidal range of approximately 19 feet. At low and high tides, the ramps would exceed the 30-inch maximum rise or fall. This meant that WSF's ramps would require level landings. Because the slopes of WSF's ramps change with the tide, the provision of a level landing would require a mechanism to facilitate re-leveling as the ramp changed its angle of inclination. WSF determined that the provision of level landings along their ramps would result in complicated contractions that wourd likely be unreliable or potentially unsafe. To avoid the issue of landings, WSF pursued design guideline utilizing walkways with slopes less than 1:20. Rather, regulatory guidance provided that walkways with slopes less than 1:20 were, in fact, not "ramps" at all.
WSF determined that ramps with slopes of 1:20 or less could economically be provided for the majority of its operations. Although Puget Sound does experience extreme tidal variations of about 19 feet, the extreme tides are infrequent. After study of tidal data, WSF arrived at a set of internal design standards based on maintaining ramp slopes of 1:20, or less, for 90% of operating hours. To accomplish this, designers would evaluate their walkway designs against projected future tides and anticipatedfuture operating hours. Tide ranges capturing 90% of the tides have been identified and walkway elevations have been optimized to maintain slope requirements within the 90% tidal range. During the infrequent case that ramp slopes become steeper than 1:20, WSF provides personal assistance to travelers upon request.
When WSF examined design guidance associated with accessibility, it also looked at its own operational needs. The old OHL walkway at Bremerton had had a steep walkway section that was approximately 1:8 in slope; this has subsequently been replaced by a moveable bridge section of 135 feet, which meets the 1:20 standard 90% of the time.
Operationally, these older walkways were considered too steep for quick, safe and efficient movement of foot passengers. This is especially a consideration for uncovered, outdoor ramps subject to rain, snow and ice. WSF Operations desires ramps with flat slopes. With flat slopes, passengers can Load on and off the ferries without assistance, decreasing the need for terminal staff.
WSF has now operated walkway systems designed to the 90% tide standard for several years. WSF Operations reports that passengers and staff are very satisfied with the walkways. Mobility impaired foot passengers utilize the ramps without need for assistance. WSF does make available electric mobility-assistance devices for passengers.
Operatioris reports that these devices are used occasionally, but more because of the length of the ramp than the slope.
It is our hope that the foregoing discussion of WSF's approach to the design of accessible passenger loading will assist the Access Board in its discussion of the proposed draft Americans with Disabilities Act Guidelines for Passenger Vessels.
Thank you for your consideration of our remarks.
Russell S. East, P.E.
Director, Terminal Engineering