MR. WATERHOUSE: Good afternoon, and thank you for the opportunity for me to speak. I had the great privilege of serving on the Passenger Vessel Access Advisory Committee, getting to know the fine folks at the Access Board. I think we tested Paul Beatty's patience on a regular basis, but it was a marvelous example of industry and government trying to learn from each other as to what the issues were.
And the work product that we produced I think represents a fair balance between the needs of the community we're discussing, persons with disabilities, and also the needs of the vessel operating community.
And I would like to take today a chance to speak about just four projects that we as a firm are working on. And I'm speaking today as a naval architect who has been busy designing ships for the past three to four years, trying to apply these draft guidelines that we had created.
The first project I'd like to talk about is a replica canal boat for LaSalle, Illinois. This is a vessel that is designed to be just like the boats that operated on this canal in the 1880s.
So we have an imperative from our customer to design a vessel that is historically authentic to the greatest extent possible. It must also comply with U.S. Coast Guard regulations. And we tried to make it accessible to the extent we could for persons with disabilities. This is a vessel that is 62 feet long but only about nine feet wide, so we're very constrained in beam.
It has -- again, to be an authentic canal boat, it has a raised deck, where access goes on, and then a cabin down a set of steps. That was the first problem for access. We looked at its three or four steps down into the cabin. The opportunities to put a lift on the vessel were limited because of its small size. The alternative was to put a passenger in a wheelchair out in the open.
So here's a problematic example for a vessel under 149 passengers where we adopted the C&T guidelines, where we relied upon transfer devices to help get people down into the vessel's cabin and into fixed seating down below.
The second example is a brand new ferry that we designed for Martha's Vineyard, a 1,200-passenger capacity, 60 automobiles, operating between Woods Hole and Vineyard Haven on a route that, during the summer, if you've ever been up that way, you have kids, dogs, bicycles, cars, trucks, everything you can imagine crowding the parking lot trying to get over to the vineyard.
That vessel, which would be a subchapter H boat, we designed in full compliance with the proposed guidelines. The vessel actually has two elevators on board. That was the customer's decision because they did not want the situation of it being a holiday weekend and one elevator being out of commission. So, again, there we felt that the rules worked quite well for that vessel and that installation.
Another example is a project we're working on right now which is a dinner boat, which would be a 149-passenger dinner boat. There would be three passenger decks on the vessel. And even though, under the proposed rules, we would not be required to have a full elevator on board, we're electing to -- because of space, weight, and electrical constraints, we are putting on instead a wheelchair lift that will actually be serving three different decks.
This is a problem for us in that the ANSI standard governing wheelchair lifts do not allow you to go to multiple stories. So here we have a challenge as engineers and designers. We know there are products out there that we can apply, but they don't fully meet the existing ANSI standard that exists, but we think it's a good solution for this class of vessel.
So we urge the Access Board needs to be looking at these other regulatory agencies that are setting third-party standards to try and get the word out that we need as much latitude when we're dealing with vessels because products designed for buildings will not work without consideration.
So I've touched upon a ferry boat. I've touched upon a canal or excursion boat. I've touched upon a dinner boat. A third example of a type of vessel we're working on right now is an overnight passenger ship for 144 passengers. This would be a small cruise ship regulated under subchapter K.
We have put an elevator on board. We have looked at providing accessible staterooms in the proportions proposed by the guidelines. That all seems to work well.
The issue of doorway widths for visiting other staterooms again was problematic in a smaller vessel, and so we were not able to incorporate the 32-inch wide doorways and still have the features we would like to have within the cabin.
The other challenge we see is that this is an operator that does ecotourism, so they're looking to load people from their ship into other boats. To do that, they're going to be operating off of the swim step on the stern of the vessel. We had no practical way to provide wheelchair access from the main deck of the vessel down to that swim step area to allow people to transfer into smaller boats.
So, again, according to the proposed regulations, that could be considered an entry or an exit point on the vessel, but you're not -- it's not the primary avenue by which people get on the vessel for the purpose of the trip or get off. So, there again, the range of different vessel operations has to be brought into consideration.
We heard today Lou Linden talk about, within the sale training market, the ratio of a factor of 10 from their smallest vessel to their largest vessel. I need to remind this committee that, when they're dealing with buses or trains or the typical landside transit applications, they're dealing with a fairly small population of sizes and capabilities of that moving vehicle. On the water, we have everything from, as we've heard today, small open sport fishing boats. We have rowing vessels that are certified to carry passengers on up to the largest cruise ship.
So I certainly urge the Board as we go through this rulemaking process to keep in mind that boats certainly aren't like buildings. We have this incredible diversity within our industry that needs to be guiding our thoughts as we work to improve access for all passengers on vessels. Thank you.
MS. TUCK: Thanks, John.
Okay. Thank you.
MR. GROWICK: Yes. Jan?
MS. TUCK: Oh. I'm sorry. Bruce.
MR. GROWICK: Yes. Thank you, sir, for a very informative presentation. I'm wondering, from your experience so far, have you looked at the potential cost-benefit analysis of these modifications that were made as these new vessels were being built?
MR. WATERHOUSE: As I'm sure everyone can appreciate, cost is always a concern, be it a public operator or a private operator. Yes. A good example is on the dinner boat, the cost difference between an elevator installation and the wheelchair lift that I mentioned was probably on the order of $80,000 to $100,000 difference all up when you looked at the ship. That's a lot of money when a person is trying to look at the cost per seat or the cost per passenger over a life.
When we got into discussions of cabin arrangements on the small cruise ship, the difference in doorway widths ended up with the possibility of, if we kept the vessel physically in its overall length to the same size, we would have had to drop some cabins off the vessel. And I think you can appreciate the revenue per cabin to a cruise ship is the critical number. It's their make or break, so it's a constant discussion among customers.
Customers that we've been working with want access for their passengers, but it has to be balanced out with the economic comparative.
MS. [JAN] TUCK [BOARD CHAIR]: Ken, and then J.R.?
MR. [KENNETH] SCHOONOVER [BOARD MEMBER]: Ken Schoonover. To follow up on that, these projects are all still in the works, I guess. So have you reached a point where you've been able to aggregate any kind of cost comparison in trying to comply with these guidelines?
MR. WATERHOUSE: We haven't been running on a systematic basis any cost comparison data. We have designed a number of vessels over the past four to five years where we can point to features that we put in the vessel and could probably approximate the costs.
The challenge comes in is that you get into the cost of adding an elevator is not physically just the elevator. You have to figure out what is the impact of that elevator on the electrical system for the ship, on the stability for the ship, on the fuel it carries to run the additional generating.
So there's a whole ripple effect in ship design any time you start looking at adding an item or a feature that's hard to tease out of an overall cost estimate, so we haven't been trying to deliberately break that out.
MR. SCHOONOVER: Thank you.
MS. TUCK: J.R.?
MR. [J.R.] HARDING [BOARD MEMBER]: Thank you, Jan. You began to touch on it. I wanted to know, what was the cost difference between a building elevator versus a ship elevator, and was it significant? And it sounds like it is.
MR. WATERHOUSE: Well, part of the problem is that, again, a building elevator is not designed for shake, rattle, and roll out on the ocean. So the hardware itself for the elevator is built to a higher standard.
And then, as I said, in addition to it, you've got to -- the challenges of finding the space for it and making it all work together because, again, there are fire protection requirements on ships associated with elevators that have to work with your overall fire scheme. So it's a -- it's part of the art of ship design as how to make all those components work.
MR. HARDING: All right. And one last follow-up question. You mentioned an ANSI standard that prevented you from using a lift for multistories on multilevels of a deck?
MR. WATERHOUSE: That's correct.
MR. HARDING: I don't know, perhaps maybe I'm being ignorant here, but we had those 25, 30 feet in Florida. Is that a boat rule or something? I mean, we've got lifts that are doing 30, 35 feet in Florida.
MR. SCHOONOVER: J.R., I think what he's referring to is the fact that the standards for platform lifts now do have an overall travel component, but there's also a condition that it's not applicable for use in essentially a multistory, multistop application.
MR. HARDING: Right. Okay. Okay. And that would be the difference --
MR. SCHOONOVER: Yeah.
MR. HARDING: -- because these 30, 35 --
MS. TUCK: How many story?
MR. HARDING: -- historical buildings on the backside can go to the, say, second floor or the third floor which is now you're coming in from the basement --
MS. TUCK: Right.
MR. HARDING: -- and you're not altering the structure of whatever. Right?
MR. WATERHOUSE: Correct. And so I was using that as an example where we need to be careful when we cite platform lift, which is a term of art in the building code, and not look at how that gets translated onto a vessel.
A similar example is with the emergency alarms on ships. We've had quite a bit of discussion on the committee as would the standard fire alarms and visual alarms for fires in buildings, how would that get translated into a shipboard environment dealing with the established Coast Guard regulations.
So there's a -- as designers and regulators keep referring to third-party standards, we have to be very careful that we have a full understanding of what those third-party standards mean and imply because I can tell you I don't believe there's anyone in the marine industry who is on that ANSI elevator committee, nor are there people in the marine industry who are on the NFPA building emergency standards committee. So we've got to be very cautious about just citing third-party standards is my caution.
MS. TUCK: Pam?
MS. [PAMELA] DORWARTH [BOARD MEMBER]: When you were talking about the door width of the cabins, were you talking about the cost of doing all of them versus just a couple?
MR. WATERHOUSE: I wasn't specifically referring to the cost of the doors because it really doesn't cost that much more for a slightly wider door, but the thing you have to remember is, in a ship, the width of the cabin module --
MS. DORWARTH: Mm-hmm.
MR. WATERHOUSE: -- is dictated by the doorway width.
MS. DORWARTH: Right.
MR. WATERHOUSE: So, if you make the door two inches wider, then the cabin gets two inches wider. Then the next cabin to it is also two inches wider.
And so you have this aggregate as you keep adding cabins and length of making the boat physically feet longer in order to accommodate all of these just two inches per stateroom because everything is built as modules for these ships. So it's not the cost of the door; it's the overall cost on the ship of having to make all of the staterooms slightly wider.
MS. DORWARTH: Are all staterooms the same size?
MR. WATERHOUSE: Certainly not. It depends on the ship and how it's laid out, but, usually, when you look at the arrangement of the door, beds, the toilet facility that you have, those are all things that are space constraints on a vessel, far more so than in a building. And --
MS. TUCK: You can't just widen a door without widening the cabin to compensate for --
MS. DORWARTH: Well, I realize that, but what I was asking was you said the cost was cost prohibitive to do the -- the cabins, all of them obviously.
MS. TUCK: Right.
MS. DORWARTH: So would it be cost prohibitive to just do a couple versus every single one?
MS. TUCK: Well, each time you do it, there's that cost element involved.
MS. DORWARTH: But it wouldn't be as much as if you had had two on the whole ship, right?
MS. TUCK: Well, two is going to be less then.
MR. WATERHOUSE: No. On the example I cited where we had 144 passengers, that was 74 cabins, if I remember correctly.
MS. DORWARTH: Mm-hmm.
MR. WATERHOUSE: We had cabins that were accessible cabins with full 32-inch wide doors and all the accessibility features that were necessary. We were just talking about the visitation feature of people in a wheelchair being able to go to any cabin on the vessel to visit other people.
MS. DORWARTH: I see. Okay. I see where you're coming from.
MR. WATERHOUSE: So, again, that's part of the dialogue to just drive home that, again, what works on a building in like a hotel does not work on a vessel.
MS. TUCK: Okay. Thank you, John.
MR. WATERHOUSE: Okay? Thank you.