WESTPORT CHARTERBOAT ASSOCIATION
P.0. BOX 654 • WESTPORT, WASHINGTON 98595
February 17, 2005
Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street NW, Suite 1000
Washington, DC 20004-1111
Re: Comments for development of accessibility guidelines under the ADA for small vessels.
Dear Members of the Board:
My name is Mark Cedergreen. I am the Executive Director of the Westport Charterboat Association. Our Association is made up of all of the charter vessels and booking services located in Westport, Washington; a seaport located about 40 miles north of the Columbia River on the Washington coast. Our members conduct fishing trips and whale watching excursions from mid-March through late-September. Our vessels range from 32-foot "six-packs" to 65 footers equipped to carry up to 30-35 persons on ocean fishing trips. My personal experience includes having grown up in the industry, 40 years in the family charter boat business, and 10 years representing our industry following the sale of the family business in 1995. I owned and operated vessels myself during my years in the business.
First, I would like to state that our members are in substantial agreement with the written testimony of the National Association of Charter boat Operators (NACO) given by NACO president R.F.Zales, II dated January 7, 2005. All four options proposed by the Board present insurmountable problems regarding safety and stability for the size vessels we operate. We are in complete accord with NACO's option 5: namely exemption for small vessels from mandatory compliance with ADA standards.
New construction has been out of our economic reach for a number of years now. Our seasons are short and strictly regulated for fishery conservation. Our fleet has been in "survival mode" for a number of years. ADA requirements applied to new construction would simply put it further out of our reach. With regard to re-construction (or alteration), we aren't sure what the definition of those words mean in relation to your proposal. From time to time we replace engines, fuel tanks, rails, windows, and make other repairs to maintain the safety and comfort of the vessel. We add equipment necessary to improve navigation, communication, firefighting and lifesaving, all in conjunction with strict standards required by the US Coast Guard. ADA compliance mandated by any of the above could essentially nullify the safety and seaworthiness intended by the repairs.
Finally, I would like address the issue of our current practice regarding care for the handicapped. Many of our vessels accommodate persons in wheelchairs. I have personally taken blind persons fishing. We do our utmost to work together to accommodate folks with disabilities and, if one of our booking offices doesn't have a vessel they would be comfortable on, the booking office would find a vessel in another booking office on which they would be. In fact, we have some very regular passengers who are handicapped. There are days when the weather is not suitable for handicapped persons (and very marginal for others, also) that we cancel trips or recommend that folks wait a day or two. As a matter of record I am not aware of a single complaint in years past with regard to not being able to accommodate handicapped persons on our vessels.
Once again in conclusion, we support the option NACO proposed that would exempt vessels in our size class from mandatory compliance with ADA standards. Thank you for the opportunity to share our views with the Board.
USCG, MSO, Portland, Oregon