The Impact of the Americans with Disabilities Act of 1990
FINAL REPORT, July 12, 1996
Prepared for: The Office of the Secretary of Transportation Office of Environment, Energy and Safety
Prepared by: Environmental Engineering Division, DTS-72 Volpe National Transportation Systems Center 55 Broadway, Kendall Square, Cambridge, Massachusetts 02142
- 1. EXECUTIVE SUMMARY
- 2. INTRODUCTION
- 3. APPROACH
- 4. VESSEL ONBOARD ACCESS
- 5.VESSEL ACCESS COSTS
- 6. SHORE TO VESSEL TRANSITION ACCESS
- 7. SHORE TO VESSEL TRANSITION ACCESS COSTS
- 8. COST SCENARIOS
- 9.STABILITY CALCULATIONS
- 10. ADDITIONAL OBSERVATIONS
- 11. CONCLUSIONS AND RECOMMENDATIONS
- A. Coast Guard MSIS data output and Marine Safety Offices’ fleet survey responses
- B. Engineering and cost calculations for sample vessels
- C. Unit costs from field work and literature
- D. Detailed cost spreadsheets and notes– fleet
- E. Detailed cost spreadsheets and notes– shore access
- F. Stability analysis for elevator installations
- G. Statutory issues for passenger vessel access
- H. Points of contact
- I. Minutes of April 15, 1996 information meeting
|ADA||Americans with Disabilities Act of 1990|
|ADAAG||ADA Access Guide, specifications for accessible accommodations developed by the Architecture and Transportation Barriers Compliance Board|
|ABS||American Bureau of Shipping, an independent classification society,performing inspection and certification of vessels.|
|Displacement||Weight of water displaced by a vessel, equal to the weight of the vessel|
|detectable warnings1||A standardized surface feature or a physical barrier built in or applied to the walking surface, to warn visually impaired people of hazards along the path of travel.|
|Fixed ramp1||A walking surface that has a fixed running slope greater than 1:20 but no greater that or equal to 1:12.|
|Freeboard||The vertical distance between the surface of a floating dock or ship’s deck and the water line.|
|Gangway1||A walking surface which spans any two marine facilities or vessels.Gangways are not fixed and their slope depends on the relative position of the facilities they are spanning.|
|Heel||The transverse (to starboard or port) aspect of a vessel’s static (still) condition, determined by its loading arrangement, i.e. the angle from the horizontal.|
|Incremental cost||The additional cost to making a vessel or marine facility ADA compliant, over and above what would otherwise be spent to make the vessel or facility accessible to the general public.|
|Lift||A portable or permanently installed mechanical device to move people from one level to another.|
|Navigable waterway||Waters over which commerce may travel, as defined by the U.S. Army Corps of Engineers|
|Nominal marine condition||The assumed environmental condition for providing access from shore facilities to vessels, including limits on water height ranges and the stipulation that no movement results from the effects o f wind, waves, wakes, and currents.|
|Non-navigable waterway||As defined by the U.S. Army Corps of Engineers, waters over which commerce does not travel.|
|Non-tidal||Condition at a marine facility with no tidal influence, e.g. on inland waters.|
|Passenger loading platform||A floating platform, located between the stable approach and vessel, from which passenger embark onto, or disembark from, the vessel.|
|Path of travel||The path or route connecting all elements of the marine facility.|
|Pier||A fixed structure extending from the shore into the water, usually built on pilings or stoneworks to convey pasengers from the land to a floating dock or vessel.|
|Primary function area||ADA definition for that part of a public accommodation housing its main public activities|
|Ramp clear width||The unobstructed area on a ramp, usually as measured between the two closest inside handrails.|
|Slip resistant surface||A surface specifically designed to prevent passengers and crew from slipping, especially when it is wet.|
|Stability||The characteristic of a floating structure (vessel or dock) to remain upright in the presence of externally applied forces, such as wind, waves, shifting loads,etc.|
|Stable approach||Relative to the passenger loading platform or vessel, the last non floating structure, including land, that passengers access on their way to the boat.|
|Sub-Chapter T vessels||Passenger vessels under 100 gross tons and carrying fewer than 150 passengers.|
|Sub-Chapter H vessels||Passenger vessels over 100 gross tons carrying any number of passengers.|
|Sub-Chapter K vessels||Passenger vessels under 100 gross tons and carrying more than 150 Passengers.|
|Takeoff and landing points||Points at which the gangway or ramp connects to the marine facility and the vessel deck.|
|Tidal||Related to the periodic rising and falling of waters.|
|Tidal cycles||The regular and predictable occurrence of low and high tides.|
|Tidal range||The predictable normal difference between low and high tides.|
|Transition plate1||The element connected to the end of a gangway or ramp which provides access from the end of the gangway or ramp to a level surface. The slope of the transition plate depends on the relative position of the gangway or ramp with the level surface.Transition plates are typically 3 feet in length or less.|
|Unassisted access1||The accommodation over a path of travel enabling access for persons with disabilities without the assistance of another person, except at those points and under those conditions under which individual s without disabilities would be in need of assistance from another person.|
|Vessel deck||For purposes of access from the shore, the deck of the passenger vessel designated for embarkation and disembarkation.|
|Water sheet||The horizontal surface area of the water available for maneuvering and docking or mooring at a shore facility.|
1. The source for all or part of the definition of this term was the Massachusetts Architectural Access Board’s Draft Regulation published in December 1994.
The authors wish to thank many helpful people for their contributions to this document. Ira Laster, Don Trilling and Nancy Ebersole at the sponsoring agency, Office of the Secretary of Transportation, have been most understanding and patient. Al Penn and LCDR George Cummings have been instrumental in providing the knowledge, experience, and data resources of the Coast Guard. Coast Guardsmen in the field offices, too numerous to mention, gave their time to assist in the fleet data gathering effort and helped to arrange many of the field visits. Dennis Cannon, Peggy Greenwell, and David Yanchulis of the Architectural and Transportation Barriers Compliance Board and David Parks of the National Park Service gave valuable insights into the technical, legal, and people aspects of access for persons with disabilities. David Porter of Childs Engineering in Medfield, Massachusetts graciously provided cost data for the construction of an accessible dock facility in Boston.
Many people in the passenger vessel industry have kindly contributed their time and facilities to the process of field work and interviews necessary for the project. In particular, gratitude is due the members of the Working Advisory Group. They are, in addition to those aforementioned Government representatives, Pete Lauridsen of the Passenger Vessels Association, Alan Bernstein of B.B. Riverboats, and Speed Davis of the National Council on Disabilities.
Michael G. Dyer, Volpe National Transportation Systems Center
Joseph Feiner, E.G.G. Dynatrend
Katherine McGuiness, Katherine McGuiness & Associates
1. EXECUTIVE SUMMARY
This report, undertaken on behalf of the Office of Environment, Energy, and Safety, Office of the Secretary of Transportation (OST) and the Architectural and Transportation Barriers Compliance Board (ATBCB), is an assessment of the feasibility of implementation of the Americans with Disabilities Act of 1990 (ADA) on the passenger vessel industry. The results are findings on technical feasibility and a set of cost data based on assumed access solutions. This exploration of implementation issues will be, in part, the basis for future decision making by OST in the matter of access to waterborne transportation and accommodation assets.
This document was preceded by the “Interim Report: Approach and Methodology” dated 1 October 1995, which established the approach for the cost analysis, the technical, economic, and social factors considered, and the assumptions for developing unit costs and applying them to the industry.
The scope of the cost calculations includes new construction and alterations for the Coast Guard inspected passenger vessel fleet, and access provisions to the vessels over the piers and docks serving the fleet. It does not include foreign flagged cruise ships at this time. Neither are terminals and other associated shoreside facilities included as they are already subject to ADA regulations for transportation terminals. Recommendations for additional future research are found at the end of the report.
The calculations include only the costs of implementation, i.e., capital and operating expenses and revenue impacts. The benefit of providing a civil right cannot be quantified, especially in the larger sense of the improved quality of a barrier-free society. The industry may realize benefits due to increased business from persons with disabilities, insurance premium reductions, and reduced employee injuries, but data from analogous access upgrades to quantify this are not available.
The approach characterizes, by type, the numbers of vessels and shore facilities to find the costs associated with compliance based upon assumed sets of access solutions. Unit costs reflect the access premium, that is, the increased cost of providing access relative to current practice. The industry implementation costs are scheduled based upon analysis of fleet growth and replacement rates (from 25 to 40 years), and an assumed replacement/upgrade of the existing dock and pier population within 40 years.
The access solutions do not anticipate all outcomes but were developed as widely applicable and practical designs for an industry uniquely diverse among the transportation modes, both in its services and its physical assets. The solutions also take account of the interactive complexities of ADA.
1.2 ACCESS ISSUES
A lot of good faith effort has been made by some operators to provide access accommodations. Their knowledge of ADA is weak, however, since no regulations for vessel access have been issued. This study proposes access solution sets to be flexibly applied to a very diverse industry, since vessel size or function may present difficult technical problems and because previous ADA statutes and regulations have defined areas where access specifications may be relaxed. There is precedent for this approach, which is critical for a reasonable application to marine transportation.
Multi-deck access for wheelchairs is the critical issue, from the standpoints of cost, safety, and operations. The study finds that elevators or lifts are feasible for most multi-deck vessels, but that lift technology needs improved capacity and better availability to the marine market. Integration of these features in new vessels will be a matter of good design practice. Elevator and lift retrofit on existing vessels, more difficult and costly than for new construction, is assumed for major alterations of larger vessels only.
Other access features include unisex heads (rest rooms), doors and passageways, signage and alarms, wheelchair tiedowns, and improved food service. These can be incorporated with ease in new designs, with a cost premium mainly for added space and weight. Retrofitted access features for vessel alterations may be smaller in scope, but can carry proportionally greater costs because of the difficulties encountered with modifying tightly arranged existing compartments.
1.2.2 Dock and pier
The solutions developed for access from the shore over docks and piers account for manmade and environmental height barriers for wheelchair passage along that path of travel. Features for other disabilities are considered in the cost calculation, but are small items relative to solving the wheelchair barriers. This study proposes five practicable and widely applicable access solutions which include extra long gangways, fixed intermediate ramps, extra floating docks, and accessible gangways to the vessels’ decks.
1.3 DATA ISSUES
Available industry data lacked in several key areas and was “pushed” to develop the schedule for industry implementation. On the vessel side, the study first develops a detailed snapshot of the current passenger vessel fleet based upon Coast Guard data. The determination of vessel service life values and replacement rates is based on limited available historical data and evidence from industry. An overall fleet growth projection of zero is used, based on Coast Guard and Army Corps of Engineers data.
Industry-wide shore facility population data are very weak, except for the ferry lines. Those data available were augmented by site visits and empirically linked to the vessel population to produce a national model. Industry-wide growth projections for shore facilities are also assumed to be zero because 1) available fleet data show no overall growth trend, and 2) shore facility data to support a growth assumption do not exist.
Costs are found using current Office of Management and Budget (OMB) guidance for nominal and real interest rates, assuming 1998 as the start year for implementation and present valued to 1996. The calculation of the impact costs focuses on societal cost, which is the value to society of lost or diverted resources. These include capital outlays for access on new and modified assets and increased operating costs associated with the access features; they are calculated in a forty year cost stream and the present value found at a 4.9% real discount rate. Amortization of capital outlays is not included.
The industry implementation costs are separately calculated for the fleet and shore sectors. The total societal cost for both sectors is estimated from $428.7 million to $502.6 million.
1.4.1 Fleet societal costs
The cost for phasing in an accessible fleet follows from a single set of assumptions derived from a high-confidence set of population data. Table 1-1 shows the results, sorted by Coast Guard regulatory category (in descending order of vessel size) and between new construction and existing vessel alterations. Total societal costs for the fleet are calculated at $396.7 million, including $33.2 million for technical and sensitivity training for industry personnel.
Fleet sector societal costs ($millions), 1996 present value
1.4.2 Shore access societal costs
Shore-to-vessel access costs are calculated separately for ferry terminals, because of known population data for that particular sector, and non-ferry facilities, for which two assumed facility/vessel ratios are used. Three distributions of high and low cost access solutions are used for both population sectors, since data on hydrographic features is scant. The calculation considers only capital costs phased in over 40 years. The range of societal costs is $32.0 million to $105.9 million.
Terminal access societal cost summary, 1996 present value ($millions)
|Vessel type cost distribution||H/K facilities||T facilities||Total|
|All facilities, low||$8.6||$23.4||$32.0|
|All facilities, high||$26.9||$79.0||$105.9|
1.4.3 Other cost bases
The body of the report also has calculations of the “business” cost, which is the same as societal cost but includes the expense of amortizing capital outlays. Amortization is at a 7.9% nominal discount rate, also present valued to 1996. The total business cost is estimated from $483.6 million to $573.9 million. The “actual” cost is a simple total of the cost stream with no present value discounting; its total is estimated from $968.4 million to $1.15 billion.
A detailed business cost summary for the vessel access sector appears in Table 5-22; Tables 7-6 an 7-7 contain the data for shoreside access.
A brief study of the impact on five fictional small operators shows that some would bear potentially large expense for providing accessible vessels and docks. The fictional operators of fishing and commuter boats, which don’t need elevators or lifts, would face relatively low business expenses of $37.5K and $20.8K, respectively. Three other fictional operators, each with two ferries or excursion boats, would incur present value expenses from $358K to $787K.
The ADA was signed into law in 1990. Six years later, the impact on the passenger vessel industry is unclear as no regulations have been developed for that mode of transport. This may be partly due to the fact that marine transportation is the “forgotten stepchild” among the major modes. However, the marine industry’s unique missions and operating environment and the difficulties of applying ADA’s various titles thereto are probably a better explanation for the slow pace of implementation.
The original act defined lines of applicability in five Titles, none of which made use of the words “vessel”, “boat”, or “ferry”. Three Titles affect the passenger vessel industry: Title I (employment opportunity), Title II (program access and public transportation), and Title III (public accommodations and public transport). Title II applies to the public sector and Title III to the private sector. Both present a dual regulatory format, broadly dividing public agencies and private businesses into two groups: (1) those providing “public accommodations” as “facilities”, and (2) those providing “public transportation” by “vehicles”1.
While most entities must comply with either Title II or III, this is not the case for many passenger vessel operators, who may have to comply with both. The industry is subject to both sets of ADA regulations with the additional challenge of existing Coast Guard regulations.1
Passenger vessel operators have been subject to some general provisions of ADA since its passage, that is, the broad anti-discrimination language and the requirement to make “readily achievable” and “reasonable accommodations”, within limits proscribed by health and safety risks and “undue burden”.
2.1 GOVERNMENT ACTIONS
The OST has been given the lead in the investigation of access for persons with disabilities on passenger vessels. Background work was conducted by the Urban Harbors Institute (UHI) of the University of Massachusetts, Boston2 for the Federal Transit Administration (FTA). The UHI conducted two seminars for affected parties and completed a report highlighting the concerns of the stakeholders and the safety and regulatory questions implied by the ADA. The report did not identify a set of marine transportation access requirements or any associated cost impacts.
Shore facilities access has been examined by the Recreational Access Advisory Committee of the United States Architectural and Transportation Barriers Compliance Board. The Committee developed a flexible access regime for recreational boating and fishing facilities and proposed a new section in the ADA Access Guidelines (ADAAG) for such unique features as gangways from dock to vessel3. The State of Massachusetts completed a study and a negotiated regulation process titled “Marine Facilities Access” in 19924.
The Coast Guard has an advisory role relative to passenger safety issues for ADA and the existing requirements of the Shipping Chapters of the Code of Federal Regulations (CFR). Coast Guard Headquarters and the Marine Safety Office (MSO) field units have also assisted in preparation of this report by providing vessel data for the fleet characterization.
The Coast Guard has also sponsored a study by students of the Worcester Polytechnic Institute (WPI) to rank, in order of feasibility and benefit, several access accommodations on new passenger vessels5. They found that crew training, onboard ramps, signs and alarms, and accessible rest rooms were practicable and that elevators, 1:12 boarding ramps, and emergency equipment were less so. In the latter cases, the effects on small boat designs were given strong consideration.
A recently published interim final rule overhauls the Coast Guard’s inspection and certification requirements for small passenger vessels. The rule acknowledges the potential impact of ADA on the passenger fleet, but does not address ADA compliance. The Coast Guard’s response to pertinent comments in the docket is that they will work with the Department of Transportation to study the feasibility of ADA implementation6.
State and local public sector entities, such as the Woods Hole, Martha’s Vineyard and Nantucket Steamship Authority and the City of San Francisco, have developed marine access standards7, 8. We have incorporated some aspects of these documents in the access solutions proposed herein.
The Volpe Center chaired an Internal Working Advisory Group (IWAG) made up of government, industry, and advocacy representatives to steer some aspects of the cost study. They were assembled for their advice and comments on the direction of the impact study, although not necessarily to achieve consensus views. The Group met on March 23, 1995 and later reviewed the interim report; the approach used here reflects their comments.
A working meeting was held on April 15, 1996 among representatives of the passenger vessel industry, government, and national advocacy groups to consider in depth the safety and technical issues of access onboard passenger vessels. The findings of that group are included in several portions of this report, including the recommendations sections where the needs for future work are identified. The agenda and minutes of that meeting appear as Appendix I.
2.2 INDUSTRY ACTIVITIES
Passenger vessel operators have, on the whole, been slow to provide this access to their businesses, in good part because the Government has not begun a topical rulemaking process. There have, nonetheless, been many efforts to improve access using “readily achievable” modifications and, particularly among publicly operated services, to make substantial investments in access accommodations in both new and existing vessels and facilities.
Dock access modifications and onboard accommodations are appearing on a steadily increasing number of waterfronts and vessels, mostly associated with large ferries, leisure cruise and gaming boats. Several ocean-going cruise ships offer full access and berthing arrangements to persons with disabilities10. The smaller vessels and operators, however, tend to have more limited resources– as well as more daunting size-related technical problems– and have not moved as quickly to upgrade their facilities.
2.3 THE INDUSTRY AND ADA
The passenger vessel industry is notable for its great variety of services, physical assets, and operating environments. The challenge of providing access includes understanding the provisions of ADA for different types of public facilities.
The spectrum of passenger vessel types and designs is almost limitless, including large cruise ships, small charter fishing vessels, historical replicas, and state-of-the-art high speed craft, among many others. The variety of designs– the term “custom built” applies to a large number of these vessels– and services sets passenger vessels quite apart from other modes such as air and rail, which offer more narrowly focused transportation services within much more severely proscribed design limitations.
Similarly, docks and piers are constructed in a wide variety of sizes and shapes to serve the many vessel types, under diverse sets of site constraints such as available watersheet, tides, currents, and shoreside features.
The application of ADA will, generally, include the provisions for public transport and public accommodation. These definitions and the rationale for access solution sets for vessels, docks, and piers are given in Chapter 3 “Approach”. Chapters 4 and 6 describe the particulars of the solution sets, while the unit and industry costs are found in Chapters 5 and 7. Chapter 8 shows the results of several cost scenarios developed for fictional small business operators. Chapter 9 is a brief technical treatment of the effects of elevator installations on vessel stability. Chapter 10 addresses additional matters such as qualitative assessment of benefits and implementation issues, and Chapter11 is a brief compendium of conclusions and recommendations.
The cost impact study consists of onboard and dockside access elements. Vessel onboard access accommodations for both new construction and alterations are determined for the fleet during the phase-in period, which reflects estimated fleet replacement rates. Dock and pier access costs are calculated over the same phase-in period, on the assumption that ADA path-of-travel requirements will cause upgrades of access from shore facilities.
The results will be unit costs for sample vessels and dock facilities, and the cost of the industry implementation, referring to the cost of inaugurating new services and products throughout the industry. Several scenario costs are estimated for fictional small operators.
The study does not consider the cost impact of “readily achievable” access modifications to existing assets under ADA, as such accommodations are already required, and in many cases already completed. In addition, implementation of this vague requirement is not easy to gauge within the great variety of the industry.
The study addresses only the projected costs of ADA implementation. The benefits, and therefore the cost-benefit ratios, are not calculated for two essential reasons. First, the civil rights afforded by ADA provisions of access and mobility are not calculable benefits. Second, those aspects of accessibility which can be perceived to offer tangible benefits, such as ridership increases or reduced liability, cannot be supported by solid data at this time. A more detailed discussion of this issue appears in Section 9.1.
A spectrum of full access solutions is instead advanced for the purpose of finding the cost to implement the rights to access and mobility guaranteed by ADA. The practicability and acceptability of these solutions has been tested by field work, and contacts with industry and disabilities advocacy representatives.
The costs to be calculated are:
- Capital costs associated with the installation of accessible accommodations at dock and pier facilities and for the new construction and retrofitted access features during major alterations of vessels.
- Operating costs expected for such items as increased fuel consumption by heavier vessels, and maintenance of new equipment.
- Revenue losses due to onboard capacity lost to provide space for accessible accommodations. This applies to vessel alterations only, where available passenger space is a given and lost area will result in real passenger capacity reductions. For new construction, it is assumed that owner-specified capacities will be met and that access accommodation costs will be strictly a matter of capital costs and operating costs associated with added vessel weight.
- Personnel training costs for awareness, sensitivity, assistance techniques and technical matters (i.e. handling of wheelchairs).
The following steps were taken to determine the costs of access. Sub-heads indicate tasks specific to either passenger vessels or shore facilities.
Characterize affected populations by type and age
-Passenger vessel fleet
-Vessel life expectancy, build rates, and frequency of alterations in the passenger fleet.
-Dock and pier facilities population snapshot.
Identify physical barriers to access.
Identify constraints to solutions unique to the marine environment.
Develop access solutions
Calculate unit costs
-Sample vessels for calculation of unit costs
Calculate costs to industry implementation
-Linking of solutions to affected populations
3.2.2 General considerations
The following are the baseline conditions and assumptions of the analysis:
- Access standards– ADA Accessibility Guidelines (ADAAG)10 are used as the standard for full access. ADAAG deals primarily with mobility, sight, and hearing impaired people. Onboard capacity of persons with disabilities as a function of total capacity will follow the guidelines for reserved parking space densities. Some modifications and exemptions to the guidelines are suggested as a result of limiting factors; development of new standards was not however a goal of the study.
- ADA applicability– This study addresses Titles II and III of ADA, Public Services (including “public transport”) and Public Accommodations. Title I, covering employment opportunities, and other legal civil rights matters under Title IV are not included.
The study determines unit costs and industry implementation costs for new construction and alterations of vessels, and the access premium for upgrading the modeled dock and pier population. Application of ADA “alterations” language to vessels is assumed to cover modifications to “primary function” areas, that is the part of the vessel housing the main public activities.
- Economic factors– The study used current OMB guidelines11 for real discount rate (4.9% for 30 year or greater terms) and nominal discount rate for amortized capital outlays (7.9%). Time duration of the analysis is based upon assumed vessel replacement rates, fleet turnover, and expected frequency of alterations. Implementation of dock access accommodations is assumed to be over the same period of time. The assumed zero year for implementation of regulations is 1998.
The industry implementation calculations include society and business costs. For business costs, amortizations of capital outlays are included, whereas society costs count only absolute capital expenses.
- Access solutions– Two sets of variegated access solutions are advanced, one each for onboard the vessels and for shore-to-vessel transition. They all provide full access but will offer the flexibility needed for a diverse industry. Previously developed public and private standards were also used for guidance, within the legal framework of ADA. See Section 3.3 for the supporting rationale and Chapters 4 and 6 for detailed descriptions of the access solutions adopted for this study. Design and engineering impacts are assessed.
- Cost sampling– Representative unit costs are found in the field and the technical literature for both the passenger fleet and docks/piers.
- Industry implementation– Cost for the industry implementation is based upon available fleet and port data. Coast Guard passenger vessel data from the Marine Safety Information System (MSIS) and a broad sampling of data from the Marine Safety Offices (MSO) fleets of responsibility are the basis of the nation-wide fleet characterization.
Acquisition of national dock and pier facility data has proven difficult. The Army Corps of Engineers produces catalogs known as the Port Series12 for many areas, but coverage is far from complete, especially for small passenger boat facilities. A complete ferry system data base compiled by Urban Harbors Institute for the FTA13 and data gathered during field visits are extrapolated to the vessel fleet to complete a national population model.
3.3 ACCESS SOLUTION SETS
Passenger vessel operators occupy a unique niche in the transportation industry, providing a wide variety of services from basic A-to-B transit to a wide spectrum of leisure and entertainment activities. Many operators offer a mix of services, either on separate sailings or simultaneously. An approach of multiple access solutions is the reasonable and logical way to deal with the diverse vessel and dock populations in this sector. There is precedent for this approach, in the Federal Air Access Act regulations, the work of the Recreation Access Advisory Committee of the ATBCB, and in the draft Marine Facilities Access regulations developed for the Massachusetts Architectural Access Board4.
ADA treats vessel types according to several definitions. The primary distinction made by the Act in this arena is between “public transport” and “public accommodation”. The meaning of the former is straightforward– transportation provided by public or private entities on a regular and continuing basis– and may be directly equated with such vessels as ferries, commuter boats, and water taxis.
Public accommodation means private entities whose operations affect commerce; the relevance for passenger vessels appears to be in such “public gathering” activities as food service, entertainment, and recreation. Many vessel types are, therefore, subject to public accommodations provisions of ADA and may be subject to those of public transport as well.
ADA also draws certain distinctions between publicly and privately owned assets. Publicly owned services such as commuter ferries are expected to satisfy more demanding access standards for existing assets than private entities; there is, however, no distinction for new construction. There is, likewise, a public expectation that transport lines meeting the “fixed route” definition of regularly scheduled service, e.g. larger operations with printed schedules, will provide for access more quickly and effectively than “demand response” services.
Finally comes the marine environment in which passenger vessels operate. Weather and water create problems of motion, safety, reliability and maintenance, for both vessels and shore facilities. Addressing access needs in this milieu is the single, most unique, factor separating this industry from other modes of public transport and accommodation.
3.3.2 Docks and piers
The shoreside infrastructure presents a wide variety of construction and design types to meet the requirements of tide, current, vessel use, and space limitations. They are built to match vessels of varied size, service and number, to fit varied sizes of available “watersheet” (area available for docks/piers and vessel maneuvering), and to function in a great spectrum of coastal and inland settings. The basic engineering and design types are limited, but, in arrangement and accommodation details, their diversity nearly matches that of the vessel population.
The necessity of a multi-tiered access approach is compelling given the unique nature and wide variety of services in the passenger vessel industry. Two access solution sets are proposed, one for onboard accommodation and one for shore-to-vessel transition. These are based upon field visits and interviews as well as the input of the Internal Working Advisory Group.
The access solution sets are a well informed attempt to anticipate the regulatory standards for a complex industry. One size will certainly not fit all in the passenger vessel trade; a pragmatic approach allowing for varied access solutions is the most probable and logical outcome of the regulation. The cost impact is, therefore, calculated based upon a set of access models which sensibly provide achievable accommodations. The solutions are limited in number compared to the probable outcomes in the fleet, but result in representative unit costs for the population.
4. VESSEL ONBOARD ACCESS
The challenge of access for persons with disabilities on passenger vessels is obvious: there are intrinsically unique barriers in this transportation mode due to their function in a dynamic, waterborne environment. The approach to finding access solutions is the topic of this chapter, which follows the sequence laid out in Chapter 3. A characterization of the fleet population (4.1) is followed by discussion of barriers and constraints (4.2 and 4.3) and access solutions (4.4). The specific solutions for the selected sample vessels appear in Chapter 5 in the development of unit costs.
4.1 FLEET POPULATION
The analysis includes all passenger vessels inspected by the Coast Guard under Subchapters T and H of Title 46 of the CFR; foreign flagged cruise ships operating in the United States are not included at this time. This industry is contesting the jurisdiction of the United States Government as regards ADA; visits to representative terminals and ships were not possible.
A pending Coast Guard rulemaking suggests a new regulatory structure for passenger vessels which would establish T, K, K’ and H classes, roughly in increasing order of size and passenger capacity13. Although fleet population data currently available are sorted according to the existing regulatory framework, the fleet is characterized according to the new regulations (T, K, and H) which will be in force for the foreseeable future.
4.1.1 Approach to fleet characterization
The Coast Guard proved to be the only source of available fleet-wide data, both through the Headquarters inspected vessel data base and the knowledge of field inspectors in the local Marine Safety Offices (MSOs) (see Appendix A). A data base specific to ferry systems was recently developed for the Federal Transit Administration by the Urban Harbors Institute12.
The cost calculations require a rather detailed characterization of the present-day passenger vessel fleet, sorted both by Coast Guard’s defining regulations and the access categories found in ADA. The latter requires more specific knowledge of vessel use than is of normal interest to the Coast Guard and, therefore, is not reliably found in their data base.
The approach is:
- Obtain global regulatory definition data from Coast Guard Headquarters.
- Gather vessel use data by queries to selected Coast Guard field offices.
- Extrapolate vessel use data to the known global population.
- Sort vessel uses by ADA definitions of “public transport” and “public accommodation”.
- Compare Urban Harbors Institute national ferry data to extrapolated Coast Guard data to test the latter’s validity relative to one service segment of the fleet.
- Calculate service lives for Subchapters T, K, and H vessels using fleet age data and apply uniformly to all service types within those groupings.
Coast Guard regulatory definitions The existing 46 CFR Subchapters T (subdivided into small and large) and H define classes according to size and capacity and specify certification requirements, operations, and safety standards for construction, fire protection, lifesaving and other systems. The proposed Subchapter K creates a new group of small vessels with high passenger capacity. Definitions of inspected classes follow:
|Existing regulations||Proposed regulations|
|T-S (small)– vessels under 100 gross tons and 65’ or less carrying more than six passengers||T– vessels under 100 gross tons, carrying 150 or fewer passengers|
|T-L (large)– vessels under 100 gross tons and longer than 65’carrying any number of passengers||K– vessels under 100 gross tons, carrying more than 150 passengers|
|H– All passenger vessels of more than 100 gross tons||H– All passenger vessels of more than 100 gross tons|
One assumption for data analysis is necessary to bridge the gap between the existing and proposed Coast Guard regulations: T-S vessels are correlated with new Subchapter T boats and T-L to new Subchapter K. While the definitions do not correlate well (from vessel length to passenger capacity), the numerical comparison was tested (Section 4.3.3) and found to be valid for purposes of characterizing the affected population.
The bounds of the study except several vessel types, which are small segments of the fleet population, for the purpose of simplifying the approach to a first order cost estimate. These exceptions are not on the basis of merit relative to ADA; the reasons for each case follow below:
- Nautical school vessels (Subchapter R)– not publicly available as “for hire”, e.g. military and merchant marine academy vessels.
- Industry crew boats and offshore supply vessels– not publicly available.
- Cargo vessels carrying limited numbers of passengers for hire– not inspected as passenger vessels by Coast Guard.
- “Six packs”, small vessels carrying six or fewer passengers– not inspected as passenger vessels by Coast Guard.
- Vessels preserved for historic value– it is usually not feasible to provide access without threatening or destroying historical significance (the relevant citation is Department of Justice (DOJ) regulation 28 CFR Part 36.405). Access provision will be unique on each of these vessels, and non-quantifiable for these purposes.
- Passenger submarines– special separate provisions for safety and access need to be developed for this newly emerging class of passenger vessels.
The study also does not include passenger vessels that operate on non-navigable waterways and which are inspected by state safety authorities rather than the Coast Guard. It is recognized that these may represent hundreds of vessels, but gaining access to and acquiring the needed data from many different authorities was judged an inappropriately large task within the scope of the project.
Gaming boats will be included in the new construction cost calculation, despite the volatile and uncertain growth patterns. Gaming vessels are high-capital ventures in which no expense has been spared to provide easy and comfortable access for players of all ages, often as a requirement of state regulatory authorities, which treat the vessels as floating buildings. Indeed Coast Guard inspectors have observed that all gaming boats have come into service with full access, including elevators.
4.1.3 Fleet data
Coast Guard Headquarters and the Marine Safety Offices (MSO) were canvassed for passenger fleet data. The input from MSO field inspectors is summarized in Table 4-1 (existing Subchapter classes) as a snapshot characterization of the inspected passenger carrying fleet, including only those vessels in the fleets of responsibility of MSOs which answered the data call. It is roughly half complete, including representative areas from the Atlantic, Pacific, and Gulf coasts and inland waterways. These data may be confidently extrapolated to the entire fleet.
Data from the Headquarters Marine Safety Information System (MSIS) yielded global fleet distributions, presented for comparison’s sake as the bottom row of Table 4-1. Note that the MSIS data includes all vessels, without the service data obtained from field units. Table 4-2 shows the MSO fleet data extrapolation (ratio and proportion to global fleet population relative to MSIS) which will be used for cost implementation. It indicates the correlation between new and existing Coast Guard classifications, as well as applicable ADA use definitions.
Data checks The data extrapolation indicates a valid sampling of vessel service information from the Coast Guard MSOs. The acquired data accounts for 52.7% of the national fleet; the global/sample ratio is 1.895. The component ratios for T (T-L and T-S) and H vessels are 1.894 (nearly identical to global) and 1.961, respectively. These factors are used to extrapolate the detailed fleet characterization from Table 4-1 to Table 4-2. The Subchapter H sampling is within 3.5% of global and, therefore, valid. The only independent comparison available for a particular vessel service is the Urban Harbors Institute ferry systems report. They found, among the responders to their questionnaire, the following:
- 168 ferry systems operating 391 ferries, excluding 73 of the barge type.
- 97 Subchapter H ferries.
- 142 Subchapter T ferries carrying more than 150 passengers (i.e. future K vessels).
- 152 T ferries carrying 150 passengers or fewer (i.e. future T vessels).
Subchapter T and H fleets
|Subchapter H||Old Subchapter T||T-L||T-S|
Extrapolated Fleet Population
|ADA Use||Subchapter H||Old Subchapter T||T-L (New K)||T-S (New T)|
*Sailing vessels are assumed to all be in proposed Subchapter T, i.e. 150 passengers
The Urban Harbors Institute data validate two key points in our treatment of available Coast Guard data:
- The extrapolation of service types to global MSIS data tracks well for ferries, since all values are well within 10% of Urban Harbors Institute’s findings.
- The assumption that T-L vessel numbers will correlate with the future Subchapter K population works well for the ferry population. It may reasonably be extended to other types.
4.2 ACCESS BARRIERS
Access onboard a passenger vessel is comprised of the same generic issues as in any other venue. Rather than reiterate ADAAG requirements, this study identifies the unique aspects of marine access as cost factors to be included in a total cost calculation. Access requirements are categorized by mobility, safety, and amenities.
The primary issue is access for people in wheelchairs and those with other mobility impairments, both from cost and technical viewpoints. Access barriers for the sight- and hearing-impaired can be solved by more routine improvements; nonetheless these cost factors must also be addressed.
4.2.1 Wheelchair access
The most obvious, and difficult, barriers to overcome relate to the mobility, safety, and amenities for people in wheelchairs. The deck arrangements and safety features, particularly on smaller vessels, pose an array of problems. Skillful design on new construction vessels will solve many, while retrofit for alterations can have a larger impact.
Mobility Barriers commonly found onboard are the following: transition from dock or gangway at the deck edge, adequate passageway width (especially on small vessels), door widths, door sills, door opening arrangements, and access between decks.
Safety The attitude (still water condition) and motion of a passenger vessel will have a singular effect on a person in a wheelchair. Tiedowns and deck fittings are required. Crew training for evacuation and other assistance must be provided, covering all types of disabilities.
Amenities The heads (bathrooms) on passenger vessels are usually non-accessible, particularly on smaller craft. Food service arrangements, i.e. bar heights and chairless tables, are often lacking. There may be additional need to adapt amenities, particularly on “event” vessels such as gaming boats and tour boats.
4.2.2 Sight and hearing impaired access
Safety issues are paramount for the sight and hearing impaired. Mobility requirements are low impact, including such safety measures as tactile strips, Braille signage, and limitations on projections into passageways. Amenities such as reading cards or tapes for certain “event” vessels may be needed but are not specifically considered herein.
Safety Most vessels lack tactile hazard indicators and Braille signage for the blind. Audible and visual emergency alarms must be provided.
4.3 CONSTRAINTS ON SOLUTIONS
The design and operation of passenger vessels are driven by their unique environment. The safety of crew and passengers depends upon a stable and watertight platform and a robust structure capable of responding to dynamic loads and sustaining damage from collisions and groundings.
Space is critical on many designs, particularly on high-density craft where passenger capacity is determined by available seating. The impact of ADA space requirements varies with the Coast Guard per passenger space minima. 10 ft2 per capita area is the most commonly used, but high passenger density craft need only 3.75 ft2/seat.
Constraints arise mainly in regard to access for the mobility-impaired. Access is constrained by vessel safety features such as door arrangements, deck fittings, and cambered decks, as well as space restricted passageways, heads, and other passenger service spaces. Access features for the sight- and hearing-impaired are not substantially constrained by marine design practices. The ADAAG specifications include provisions on passageway clearances for the safety of blind people. The designer should consider these as part of the overall accessible passage configuration, whose primary purpose is for wheelchairs.
The approach to safety is in the context of Coast Guard regulations. The costs of those ADAAG specifications which exceed Coast Guard standards (e.g. passage width and door sills) are calculated; others are subsumed by regulations which exceed the access requirements.
The solutions herein are based on the best currently available solutions and information. The Coast Guard has suggested that a hazard analysis is necessary to address all access safety issues. Such an analysis might show different or additional safety solutions and may be a valuable follow on effort to this study. The following are the specific items considered for this study:
Doors and sills Several operators and Coast Guard personnel have pointed out the access problems arising from the narrow widths, high sills, and large opening force required for marine service doors, particularly watertight and weathertight doors. For the cost estimates, we assume that width requirements must be met, but that the safety provisions of sill heights and closing forces cannot be overridden by the ADAAG. Good detail design practice will solve the sill ramping problem. The operation of some doors however may require power assist or crew assistance.
Passageways The ADAAG specification for aisle/corridor widths, turns, etc. exceeds Coast Guard requirements. Passageways on most larger vessels that were observed satisfy ADAAG, but this is not the case on small vessels. Designers will provide proper passageways for new construction of almost any type, with possible exceptions among the smallest vessels. Retrofits for alterations will be problematic on many small passenger vessels and some leeway for exceptions and equivalent facilitations may be necessary.
Elevators and lifts Installation of elevators for multi-deck access is attended by two major regulatory issues, stability and fire protection. The added weight and vertical moment of an elevator can have serious impact on the intact and damage stability characteristics, especially in the case of a small vessel.
Elevator shafting must satisfy Coast Guard fire protection regulations since deck penetrations cross “fire stopper” and weathertight boundaries. These and other installation requirements (power, controls, etc.) will be addressed in greater detail in the final cost calculations.
Elevators are subject to approval by the Coast Guard, by the American Bureau of Shipping or other classification society, if the vessel is classed for insurance purposes, and sometimes by state authorities. For example, the Illinois gaming boats’ elevators were built to landside specifications and approved by the Coast Guard after weight testing. New technologies, including hydraulic and screw-column elevators, may become available, limiting the impact of shipboard elevator installations. The cost basis for this study is for conventional overhead lift types as seen in the field.
Stair lifts have been used with mixed success in some passenger vessels. Installation requires power, rails in the stairwell, storage space for the lift, and adequate stairway width for normal egress. In addition, an extra stairwell may be required to satisfy egress requirements. An emergency situation involving loss of power while the lift is in transit in the stairway can cause a serious safety problem. Stair lifts, unlike elevators, are not “universal use” and can attract undue attention to the user. Use of lifts is assumed on portions of the small boat sector in the cost model, but there is a need to define the limited situations in which lifts would be permissible since ADAAG restricts their use.
Most significant issues arising here relate to elevator installations. The vessel’s intact and damage stability characteristics must be maintained within specified limits under the influence of substantial added mass which is often “high weight”. Power requirements may dictate a larger auxiliary electric plant onboard. Regular maintenance of the system will be required.
Weight is added both for new access components and because of the extra space needed for access accommodations, resulting in vessel speed losses and/or increased power requirements. Main power plants will use more fuel and, in some cases, require extra maintenance. The stability aspect of added weight due to elevators is explored in Chapter 9, through the use of five sample passenger vessels.
4.3.3 Space requirements
The accommodations for wheelchair access taken together can require considerable deck area, with two implications. The first is that added space for new construction means added weight. Secondly, there is a revenue premium if passenger accommodation spaces are reduced, as in the case of alterations to existing vessels.
4.3.4 Egress and evacuation
The Coast Guard and some operators have expressed concern on the efficacy of emergency evacuation of persons with disabilities. Their concern is twofold: 1) safety of passengers of all abilities; and 2) the costs of added accommodations, if necessary, for egress of persons with disabilities.
Safety must be viewed both from the standpoint of existing and pending lifesaving requirements (found in 46 CFR Parts 75 and 180 and the international Safety of Life at Sea Convention (SOLAS)) and the fast evolving evacuation technology. The CFR and the interim rule cover lifesaving appliances, evacuation routes, and crew training requirements, and requires lifeboats, liferafts, or lifefloats for Coast Guard inspected vessels on sliding scales tied to vessel size, passenger capacity, and service area. All passenger vessels must provide Type 1 lifejackets for 100% of the people onboard.
Current practice and the regulations provide that crew training and lifesaving appliances will effect proper evacuation of all passengers, including the elderly, injured and persons with disabilities. While some operators request an able-bodied companion to accompany and assist each person with a disability during the trip, crew are required by statute, and bound by maritime tradition, to safely evacuate all passengers in cases of emergency. This study could not identify any appliances specially provided for use by persons with disabilities.
The regulations require adequately sized and protected egress to muster areas or locations where lifejackets are available. Vessels built to accessible standards will of course have proper corridor and door design, but assistance for movement between decks will be necessary (elevators/lifts not available). Crew on any vessel will assist entry into available lifeboats or liferafts. If passengers must enter the water, they will all wear Type 1 lifejackets, which are designed to float persons face up and should preserve even persons with severe disabilities. Crew manning requirements relative to the number of boarded passengers with disabilities have not been addressed at this time due to lack of data and experience.
No additional cost is assumed to accrue due to the evacuation requirements for persons with disabilities, because both existing and new emergency procedures must intrinsically account for all passengers, including those injured during casualties and those with disabilities, that is, they have a significant element of “universality”. It is clear that providing accessible egress from within the vessel to muster or lifejacket storage areas is the most important design issue, and that crew training and evacuation procedures are the critical pictures for safe evacuation in an emergency.
4.4 ACCESS SOLUTIONS
Previously described diversity of the inspected passenger fleet leads to a consideration of how to provide access thereto without using a rigidly applied standard. The solutions must account for vessel construction and compartment arrangements while satisfying the legal standards of ADA.
4.4.1 Affected vessel population
For purposes of the study, new construction and retrofit are separately considered and are defined as follows:
New construction: Keel laid on or after assumed effective date of new regulations of 1 January 1998.
Alteration: Alteration undertaken on or after effective date of 1 January 1998. The study will not include “readily achievable” access features on existing vessels and will limit its consideration to large “primary function” alterations, that is alterations to those parts of the vessels housing their main public activities.
According to ADA, alterations to the “primary function area” of an establishment trigger an additional requirement to provide an accessible “path of travel” to the primary function. This kind of alteration involves significant cost, occurs with predictable frequency, and implies a reasonable limit on the number of unit cost calculations needed for the cost model. Smaller alterations such as in-kind component replacement are too varied, numerous, and unpredictable to measure. In any event, they are already covered by the general access provisions of ADA and likely involve minimal cost premiums.
DOJ regulations, 28 CFR Part 36, define alteration as any “change…that affects or could affect usability of the building or facility or any part thereof.” and except “normal maintenance, reroofing, painting or wallpapering, asbestos removal, or changes to mechanical and electrical systems” which do not “affect the usability of the building or facility.” DOJ requires that any alterations meet the ADAAG to the maximum extent feasible.
4.4.2 Description of access solutions
A set of full access solutions is proposed to deal with the spectrum of passenger vessel types and sizes, both for alterations and new construction. The extent of access varies due to physical and practical limitations of the vessels. Specific requirements for access accommodations (Table 4-3) are based upon observation of vessels and facilities designed or modified for access for persons with disabilities, and practical application of the ADAAG. The following are the proposed solutions:
- Access 1– All passenger areas of all decks accessible in accordance with the ADAAG, for mobility, sight, and hearing impaired people. This includes passage widths and slopes, elevators or lifts to all decks, accessible heads, signage and alarms, food service accommodations, and tiedowns for wheelchairs.
- Access 2– Full access accommodations and passenger services provided to the extent available to all passengers, on at least one deck. Access features on a single deck will most often result, except when other amenities, for example access to open deck, are only available on another deck.
- Access 3– Access accommodations, including passage size, accessible heads, signage and alarms, and food service, provided on one deck. “Equivalent facilitation” on that single deck may substitute for some services available on other decks. Multi-deck access is not required since this solution applies only to alterations of small (T) boats, where technical and cost impacts are likely to be much more burdensome.
- Access 4 (T fishing boats)– Single deck access to and within primary function area on one deck only. Accessible head is provided, and other amenities to the extent available to all passengers. Figure 4-3 shows a generic arrangement. Access 4 should apply only to new construction and large alterations of primary function passenger areas. For the cost industry implementation, only new construction is considered since large alterations of these craft are rare.
Vessel Access Solution Set
|Access feature||Access 1||Access 2||Access 3||Access 4|
|Passage||Yes||Yes||One deck||Primary function area|
1. Access to more than one deck may be needed in some cases; single deck access with full amenities will often result.
4.4.3 Application to fleet population
The access solution set (Table 4-3) will be applied to the passenger fleet taking account of:
- The size of the vessel and its ability to support the space and weight requirements of the pertinent access features.
- The type and service of the vessel and its categorization as “public accommodation” or “public transport”.
- The differentiation between new construction and alterations.
Table 4-4 sorts the vessels by Coast Guard subchapter and ADA applicability definitions, and shows the application of the access solutions. The ADA sort is limited to the distinctions between public accommodation and transport and between new construction and alteration. Available fleet data do not distinguish fixed route from demand response vessels.
“Access 4” for T Fishing Boats
Again, the largest cost and technical impact is clearly from multi-deck access with elevators or, to a lesser extent, with lifts. The access solutions are differentiated mainly along the lines of their multi-deck access requirements. Proposed access requirements are generally along the lines of size and service, with the following main points in mind:
- New public accommodation vessels must provide full multi-deck access, excepting some T boats, where power and stability limitations may allow for full access and services on one deck only.
- Alterations of H and K public accommodations require full access and services, whether available on one deck or more; for T boats, some equivalent facilitation is allowable in a single deck access configuration. The engineering limitations of existing vessels are the reason for reduced multi-deck access.
- New and alteration public transport vessels will provide full access and services, on one deck, although equivalent facilitation will be acceptable for alterations. All vehicle ferries with separate car and accommodation decks, on runs longer than one half hour, will need elevators. Toilet and food service accommodations are not required for short run ferries (Coast Guard definition is less than 30 minutes). Access provisions on commuter boats are assumed to include only boarding, passageway, and wheelchair safety features.
- T fishing boats are generally among the smallest inspected vessels and are most often operated by small businesses. “Access 4” provides basic single-deck access.
Access Solutions by Vessel Type
|Coast Guard||Public accommodation||Public transport|
|H||Access 1||Access 2||Access 21||Access 21|
|K||Access 1||Access 2||Access 21||Access 21|
|T||Access 2||Access 3||Access 21||Access 21|
|T fishing||Access 4||Access 4||NA||NA|
Notes: 1) Elevators for ferries with separate vehicle and passenger decks only.
Table 4-4 shows a clear breakpoint between K and T public accommodation vessels in the matter of multi-deck access. Relaxation of this requirement for small vessels, particularly for alterations, is technically and legally logical. The latter point is the “elevator exemption”, in 28 CFR Part 36, provided for small existing buildings, defined as fewer than three stories or less than 3000 ft2 per story. A similar approach, with different area values, can be applied, as demonstrated by the sample boat data in the following section.
4.5 SAMPLE VESSELS
A representative sample of vessels was selected from files at Coast Guard Headquarters and field units, data available to the Volpe Center, field visits to operators, a search of pertinent literature, and an engineering analysis of several boats in the San Francisco Bay area. The sample vessels are the basis for the development of unit costs, which result in specific impact scenarios and inputs for the industry implementation cost calculations.
Appendix B includes results of the Bay area study and Appendix C is a compilation of unit cost data found in the field and the technical literature.
Table 4-5 groups sample vessels roughly by service and Subchapter, showing total and per passenger areas. Gross areas of passenger accommodation (hotel, restaurant, and public spaces) are found and reduced by the areas taken by other appurtenances such as lifesaving equipment, vents, and rails. Table 4-5 shows that reasonable passenger area breakpoints can be found in the structuring of the Coast Guard’s passenger vessel categories. While a strict application of 3000 ft2 per deck would eliminate all but the largest passenger vessels, a total deck area of 3000 ft2 appears to fall nicely between the proposed T and K Subchapters. Some exceptions, notably the high density craft, appear among the representative existing designs shown in the Table (see shaded rows).
Common per passenger areas run from 10 to 20 ft2 (Coast Guard requires 10 ft2/passenger as one measure of allowable capacity) resulting in less than 3000 ft2 for almost all T boats (150 or fewer passengers). K vessels will tend towards capacities significantly greater than 150 as a matter of optimal revenues and, for the unit areas required, will most often be above 3000 ft2 of accommodation spaces.
Sample Vessel Passenger Accommodation Areas
|VESSEL||ld/new Sub-ChapterO||Passenger capacity||Passenger decks||Accom’d’tion feet2||feet2/passenger|
|52’ excursion boat||T-S/T||49||2||900||18.4|
|64’ excursion boat||T-S/T||130||2||1440||11.1|
|65’ dinner boat||T-S/T||149||1||895||6.0|
|91’ crew boat conv.||T-L/T||149||3||2305||15.5|
|102’ crew boat conv.||T-L/T||150||2||3200||21.3|
|122’ crew boat conv.||T-L/T||149||3||2558||17.2|
|180’ cruise boat||T-L/T||112||4||17475||156.0|
|80’ shuttle boat||T-L/K||200||2||1560||7.8|
|100’ crew boat conv.||T-L/K||185||3||2400||13.0|
|105’ dinner boat||T-L/K||600||3||8301||13.8|
|106’ dinner boat||T-L/K||550||3||7200||13.1|
|183’ dinner boat||T-L/K||1000||3||8280||8.3|
|192’ excursion boat||T-L/K||600||4||14272||23.8|
|200’ excursion boat||T-L/K||800||3||12250||15.3|
|80’ paddle wheeler||T-L/K||500||3||5920||11.8|
|198’ casino boat||T-L/K||1900||5||32400||17.1|
|274’ paddle wheeler||T-L/K||1200||4||32100||26.8|
|84’ ferry, veh. dk. only||T-L/T||90||1||2000||22.2|
|40’ fishing boat||T-S/T||15||1||275||18.3|
|45’ fishing boat||T-S/T||10||1||300||30.0|
|59’ fishing boat||T-S/T||149||2||1118||7.5|
|60’ fishing boat||T-S/T||12||2||820||68.3|
5. VESSEL ACCESS COSTS
Fleet costs are developed in parallel for both new construction (5.2) and alterations (5.3) by the following steps:
- develop installation schedule (5.1)
- calculate unit capital, operating, and life cycle costs for sample vessels
- calculate cost for industry implementation based on installation schedule and sample unit costs
Section 5.4 is a brief consideration of personnel training costs. Selected cost scenarios, including shore access expenditures, are presented in Chapter 8. The following are brief descriptions of the cost categories used:
- Capital costs
Direct cost of access features including elevators and lifts, signage/alarms, embarkation access, food service, and tactile materials for the blind. There is a significant cost difference for the installation of these items between new construction and alterations, since in the latter case ripouts of and intereferences with existing systems will often result. It is assumed that these items are installed only once for the service lives of the affected vessels.
The space requirement for the access accommodations on new construction, expressed as a capital expense due to the added area and hull weight required.
- Operating costs
for vessel alterations, lost revenue due to deck area and passenger capacity reductions.
for all vessels, the effects of increased power requirements due to increased displacement and wetted surface area. The costs are expressed as increased fuel consumption, ignoring the possible speed loss.
- Life cycle costs. Maintenance costs associated with elevators, lifts, and other access features, calculated for all cases.
Cost factors are calculated using Office of Management and Budget guidance11:
- Nominal interest rates: from 7.3% for 3 year term to 8.1% for 30 year term.
- Real interest rates: from 4.2% for 3 year term to 4.9% for 30 year term.
This study does not develop an algorithm to predict how owners’ decisions to modify or replace will be affected by ADA “alterations” requirements, nor does it account for the “preemptive” effect ADA on alterations of vessels and shoreside facilities. Building and alteration rates are assumed to continue as found in current practice.
5.1 FLEET POPULATION PROJECTIONS
The calculation of industry-wide costs entails the extrapolation of unit costs to the fleet, based upon vessel service lives and replacement rates, and the frequency of alterations. A detailed and accurate current fleet snapshot was developed in Section 4.1.3. Historical data for the fleet consists of yearly Treasury Department reports from the late 1800s up to 1965. A large data gap existed for the period from 1966 to 1987. The Coast Guard data management system resumed data collection beginning in 1987.
Because the recent data history is limited, development of fleet growth and service life/replacement factors is problematic. The rough half-life data found in Section 4.1.3 is used with supporting evidence from industry to assume average vessel service lives. The outlook for fleet growth is suggested from these data and independent Coast Guard work in support of their passenger vessel rulemaking. The trending results for fleet growth and alterations will be combined with the fleet snapshot to develop installation schedules in Sections 5.2 and 5.3, respectively.
5.1.1 Fleet replacement
Approximate average vessel service lives, according to the half life calculations (para. 4.3.3) and discussions with industry are 40 years and 25 years for Subchapter H and T vessels, respectively. The Coast Guard found that 25 years is the average service life for T boats in their regulatory evaluation for the small passenger vessel rulemaking (1990)14. Vessels built under the new Subchapter K are assumed to replace those under the present T-L.
The annual replacement rate for K vessels is assumed in between those for H and T and closer to H because of similarities in size and service. Replacement of the fleet is therefor calculated at annual rates of 2.5%, 3%, and 4% for H, K, and T vessels respectively.
5.1.2 Fleet growth
Overall fleet growth has been stagnant for 30 years; that is, replacement and scrapping rates have been roughly equal. The last annual Treasury Department Merchant Marine Statistics15 report in 1965 listed 5862 passenger vessels, compared to the current fleet of 5770 according to Coast Guard MSIS.
Treasury data indicate that in the 1950s and early 1960s, the passenger fleet expanded dramatically with the post-war economic expansion and as World War II surplus craft such as PT boats were brought into such services as fishing and charter. Table 5-1 indicates this trend for the build years 1942-46; the same may be observed for build years in the late 1950s as craft from other services moved into the passenger trade.
In the data gap between 1965 and 1987, most of those boats fell out of service while the revival of passenger boats for transportation and leisure bloomed, especially on inland waters and around the large cities. Passenger vessels have become more specialized with a much larger proportion of the fleet purpose-built for particular services. Volatile growth and decline of particular fleet segments (e.g. construction booms in dinner/excursion boats in early 1980s and gaming boats in the 1990s) often occur, reacting to public trends and regulations which cannot be forecast.
Overall, however, the available data indicate a flat to very slow growth rate over the last five years. While Coast Guard MSIS reports the large passenger (Subchapter H) fleet has increased dramatically in that time (approximately 30% to a total of 205), due mainly to new gaming boats, the T fleet has grown at an average annual rate of only 0.4%. The Coast Guard’s regulatory evaluation for small passenger vessel certification concluded in 1990 that the T fleet population was staying constant, replacing itself at a 4% annual rate (about 210 per year), with an estimated average service life of 25 years.
The Army Corps of Engineers annual Waterborne Transportation Lines16 reports support these conclusions. The scope includes ferries and “passenger, steam or motor” vessels, the latter of which are excursion boats and the like. Passenger fishing boats are not covered, and the remaining fleet size tracks reasonably well with the Coast Guard’s data. While the summary data in Table 5-2 shows obvious inconsistencies (the ferry fleet certainly did not grow 450% from 1989 to 1991) in data definition and reporting, it is clear that they show no recent growth trend.
The foregoing data leads to the conclusion that the fleet growth rate will be near 0% for Subchapter T, K, and H vessels for the foreseeable future. Gaming boats make up nearly all of the Subchapter H growth since 1990. Otherwise, the statistics do not support any suggestion of growth.
Post-World War II Passenger Fleet Statistics
|Build Year||Treasury Reports||CG MSIS|
Army Corps “Waterborne Transportation Lines” Data
|Year||Ferries||Ferry passenger capacity||Other passenger vessels, steam or motor||Other vessels passenger capacity|
Passenger vessels are assumed to undergo alteration of the primary function area as follows, based upon evidence from interviews with operators:
- H and K– every ten years. Those within ten years of retirement will not be included in this calculation.
- T boats– also every ten years, for dinner, excursion, and cruise boats only. The ten year retirement exclusion also applies. Access for all vessels is in accordance with Tables 4-3 and 4-4.
Note that the foregoing assumption is based upon anecdotal evidence which cannot be supported or refuted by available data bases. The ten year alteration cycle may be agressive; a longercycle would reduce business and societal costs.
The installation schedules specifically address the provision of elevators and lifts for multi-deck access, the most important impact item. An accurate cost appraisal must include those vessels which will not provide such access, since the access solutions as structured allow for some flexibility in its application. The affected portions of the existing (without exclusions due to the ten year retirement window) and new portions of the fleet are shown in Table 5-3. These numbers are not supported by available data but from knowledge of the fleet gained through interviews and site visits. Explanatory comments follow:
- “Access 1”– All vessels must provide multi-deck access. Multi-deck construction is assumed for Access 1.
- “Access 3 and 4”– No elevators or lifts are required by definition of these solutions, which provide for one full access deck. These smaller vessels are, for the most part, single decked and otherwise are the most likely to have technical feasibility issues.
- “Access 2”– This solution provides for full access and services on one or more decks, depending on the boat’s service and configuration. Assumptions for installation of elevator/lifts follow:
Public accommodation vessels
Alterations to Subchapter H public accommodation vessels– 75% will need multi-deck access due to the distinct nature of services usually available on different decks. 25% are assumed to provide all services on one deck.
Alterations to Subchapter K public accommodation vessels– 50% will require multi-deck access, and the remainder will not due to single deck accommodations arising from service and technical limitations.
New construction Subchapter T public accommodation vessels– 50% will not require multi-deck access because of single deck arrangements or equivalent facilitations, or technical design limitations.
Public transport (ferries)
Multi-deck access is assumed to be required only for those vessels with separate vehicle and passenger accommodation decks. The percentages in Table 5-3 are based upon the Urban Harbors ferry lines study12. Otherwise, wheelchair access will be to the vehicle deck only or will be supplied by shore access to an accommodation deck.
All Subchapter H and K ferries– Those with car decks, according to the Urban Harbors Institute are assumed to have separate passenger accommodation decks and, therefore, require elevators or lifts.
New construction T ferries– Half of those Ts which carry cars are assumed to need multi-deck access.
T ferry alterations– Some of those requiring multi-deck access may have structural or stability limitations; therefore the percentage requiring elevators or lifts is reduced. T ferry barges are not included in this category and have no elevator/lift requirement in any case.
Elevator Requirements by Vessel Type
Access Solutions and Percentages of Vessels Applicable
|Public accommodation||Public transport|
|H||Access 1, 100%||Access 2, 75%||Access 2, 80%||Access 2, 80%|
|K||Access 1, 100%||Access 2, 50%||Access 2, 20%||Access 2, 20%|
|T||Access 2, 50%||Access 3, 0%||Access 2, 35%||Access 2, 20%|
|T fishing||Access 4, 0%||Access 4, 0%||NA||NA|
5.1.5 Installation schedules
Tables 5-4 and 5-5 are the installation schedules for new construction and alterations, respectively. The schedules include “elevator” and “lift factors”, which anticipate the split between those multi-deck access devices and the resulting cost differentials.
New Construction Schedule
|Sub-Chapter||Vessel service||1995 pop.||Annual replace-ment rate %||Annual new-builds||with elev/lift||without elev/lift||Vessel elevator factor||Vessel lift factor|
|Sub-Chapter||Vessel service||1995 pop.||10 year excl’sion||Affect’d pop.||10 year schedule||Vessel elevator sector||Vessel lift factor|
|Total annual||with elev/lift||w/o elev/lift|
5.2 NEW CONSTRUCTION
5.2.1 Unit costs
New construction costs will be calculated as 1) the capital cost of building in the extra space required for accessible accommodations, 2) the direct costs of individual access components; and 3) added operating costs.
Capital costs The added space results from extra area required for access accommodations and is expressed as a cost by multiplying area with the weight/area and cost/weight ratios found for the sample vessels in the engineering study (Appendix B). There is a space premium for elevators, accessible heads, and, for high density craft, wheelchair tiedown spots provided for safety from ship motion. Details of these calculations are in Appendices B and D. The added weight of the access features (e.g. elevators) themselves does not result in added shipbuilding cost.
The engineering study also showed that no area and weight premium results from design of accessible passageways, signage and alarms, accessible embarkation station and main doors, and food service bars, which for the most part can be smoothly integrated with skilled design practice.
Direct costs The costs of individual access components including installation in the shipyard, are calculated according to the solution set in Table 4-3. These are elevators and lifts, accessible heads, embarkation stations, main doors, signage and alarms, and food bars. No extra design or engineering costs are included for new construction.
Tables 5-6 and 5-7 show the component and total unit capital and direct costs for each vessel type. Detailed notes on these costs appear in Appendices B and D.
The largest cost item is elevators and lifts. Table 5-7 calculates that cost and adds it to the costs found in Table 5-6 for all other items; it includes the average number of decks serviced and “blends” the unit cost to account for the assumed elevator lift factors across the fleet.
The unit elevator cost is $25,000 per deck serviced, multiplied by the factor of 1.50 for installation expense, a result of $37,500 per deck. The installed cost of a stair lift is $20,000 for two decks, plus $20,000 for each additional deck. Single elevator or lift service is assumed for all vessels.
Operating and life-cycle costs The operating cost premium calculation is limited to the extra fuel consumed by the main propulsion plant to drive the added weight of access accommodations. Added weight is from added areas for access accommodations and the component weight of elevators. Other components do not contribute significant weight. Notional values for ship’s power, displacement, and annual operating hours are given and the effect of added weights calculated in Table 5-8. The following formula yields the annual fuel cost premium: (added wt./loaded vessel wt.)X(annual operating hours)X(0.05 bsfc)X(brake horsepower)X($0.70/gallon); where bsfc = brake specific fuel consumption. See detailed spreadsheets in Appendix D.
Unit new building costs, excluding elevators
|Class and Type||Costs in (quantity) @ (unit cost)||Total cost|
|Tie-d cost||Head||Embark||Door||Sign||Food||Deck area||without|
|H||Ferry||8 @ $250||2 @ $1K||$2K||2 @ $ 1K||3 @ $6.5K||1 @ $500||20sqft @ $500/sqft||$38,000|
|H||Dinner/excursion||8 @ $250||2 @ $1K||$2K||2 @ $1K||3 @ $6.5K||2 @ $500||20sqft @ 500/sqft||$38,500|
|H||Gaming||8 @ $250||2 @ $1K||(none)||(none)||3 @ $6.5K||2 @ $500||20sqft @ 500/sqft||$34,500|
|H||Cruise||8 @ $250||2 @ $1K||$2K||2 @ $1K||3 @ $6.5K||2 @ $500||20sqft @ $500/sqft||$38,500|
|H||Whalewatch/sightsee||8 @ $250||2 @ $1K||$2K||2 @ $1K||3 @ $6.5K||1 @ $500||20sqft @ $500/sqft||$38,000|
|H||Other||8 @ $250||2 @ $1K||$2K||2 @ $1K||3 @ $6.5K||2 @ $500||20sqft @ $500/sqft||$38,500|
|K||Ferry||6 @ $250||2 @ $1K||$1K||1 @ $1K||2 @ $5K||1 @ $500||24.5sqft @ $500/sqft||$28,250|
|K||Dinner/excursion||6 @ $250||2 @ $1K||$1K||1 @ $1K||2 @ $5K||2 @ $500||24.5sqft @ $500/sqft||$28,750|
|K||Gaming||6 @ $250||2 @ $1K||(none)||(none)||2 @ $5K||1 @ $500||20sqft @$500/sqft||$24,000|
|K||Cruise||6 @ $250||2 @ $1K||$1K||1 @ $1K||2 @ $5K||1 @ $500||20sqft @ $500/sqft||$26,000|
|K||Whalewatch/sightsee||6 @ $250||2 @ $1K||$1K||1 @ $1K||2 @ $5K||1 @ $500||24.5sqft @ $500/sqft||$28,250|
|K||Commuter /shuttle||4 @ $250||0 @ $1K||$1K||1 @ $1K||2 @ $5K||(none)||12sqft @ $500/sqft||$19,000|
|K||Fishing/dive||4 @ $250||2 @ $1K||$1K||1 @ $1K||2 @ $5K||0.5@ $500||23sqft @ $500/sqft||$26,750|
|K||Other||6 @ $250||2 @ $1K||$1K||1 @ $1K||2 @ $5K||1 @ $500||24.5sqft @ $500/sqft||$28,250|
|T||Ferry||4 @ $250||0.5 @ $1K||$1K||1 @ $1K||2 @ $3.5K||(none)||14sqft @ $1000/sqft||$24,000|
|T||Dinner/excursion||4 @ $250||1 @ $1K||$1K||1 @ $1K||2 @ $3.5K||1 @ $500||21sqft @ $1000/sqft||$32,500|
|T||Gaming||4 @ $250||1 @ $1K||$1K||1 @ $1K||2 @ $3.5K||1 @ $500||15sqft @ $1000/sqft||$26,500|
|T||Cruise||3 @ $250||1 @ $1K||$1K||1 @ $1K||2 @ $3.5K||1 @ $500||15sqft @$1000/sqft||$26,250|
|T||Whalewatch/sightsee||3 @ $250||1 @ $1K||$1K||1 @ $1K||2 @ $3.5K||1 @ $500||20sqft @ $1000/sqft||$30,750|
|T||Commuter /shuttle||2 @ $250||0 @ $1K||$1K||1 @ $1K||(none)||(none)||6sqft @ $1000/sqft||$8,500|
|T||Sailing||3 @ $250||1 @ $1K||$1K||1 @ $1K||2 @ $3.5K||1 @ $500||15sqft @ $1000/sqft||$26,250|
|T||Fishing/dive||2 @ $250||1 @ $1K||$1K||1 @ $1K||(none)||(none)||16sqft @ $1000/sqft||$19,500|
|T||Other||3 @ $250||1 @ $1K||$1K||1 @ $1K||2 @ $3.5K||1 @ $500||20sqft @ $1000/sqft||$30,750|
Unit newbuilding costs, with elevators
|Class and Type||Total cost||Elevator Costs||Total cost|
|without elevators||Ave. decks||elevator/lift||elevator / lift||elevator / lift||including|
|Table 5-6)||serviced||factors||equip. costs||area costs||elevator|
Unit annual newbuilding fuel costs
|Notional||Notional||Annual||Elevator||Elev.||Access||lb. per||Annual fuel||Annual fuel|
|Vessel type||displ’c’mt||hp||hrs||weight||ft^2||ft^2||ft^2||$ premium||$ premium|
The addition of elevators/lifts and other access features means extra maintenance costs. Operators have reported elevator maintenance contracts from $1,000-$4,000 per year. The number used is $1,500 per year since many smaller operators will probably use cheaper service or perform some maintenance themselves. The annual cost for lift maintenance is assumed to be $500.
Additional maintenance for other access features such as signage and alarm systems and special doors are difficult to estimate. Values between $250 and $500 per year are assigned, depending on vessel size. The unit costs appear with the industry implementation calculations in Table 5-10. Detailed notes are in Appendix D.
5.2.2 Industry implementation cost
The unit costs (5.2.1) and installation schedule (Table 5-4) are the basis of the industry implementation cost calculation. The unit capital costs found in Tables 5-6 and 5-7 result in industry implementation present value (PV) society costs of $113.7M (Table 5-9). The amortized industry cost is $132.4M (Table 5-10). The following are the main points re: Tables 5-9 and 5-10:
- Capital costs for each year amortized at nominal discount rate of 7.9% for 10 years (Table 5-10).
- Present values are found to 1996 at a real discount rate of 4.8%.
- Assumed implementation of the regulation is in 1998.
- Annual cost in 1996 dollars given in first cost column, followed by present value samples for selected years. Totals are shown for selected years and by vessel type.
- Present value costs increase to year #10 as the portion of the fleet with access grows, and decline slowly thereafter as debt is retired and real discounts over the long term take effect.
- Capital costs for H vessels are spread over a 40 year phase-in period plus, for Table 5-10, ten more years to amortize the last outlays. Phase-ins for K and T vessels are 33 and 25 years, respectively, and ten additional years are likewise required to finish the amortization.
Operating costs for the industry implementation consist of extra fuel and maintenance, given in Table 5-11. The table includes the annual maintenance costs as calculated in Appendix D. These costs are discounted to 1996 at 4.8% and not amortized. The calculation for total costs covers the 40-year period from 1998-2038.
The annual unit maintenance costs in Table 5-11 are samples which include elevators. The industry implementation costs reflect the model of Table 5-4, which includes a blend of vessels with elevators, or lifts, or neither. The 40-year operating cost premium for new buildings is $57.1 million for fuel, $17.7 million for maintenance, and a total of $74.8 million.
Industry implementation, newbuilding capital expenses
|Vessel Subchapterand service||Annual||P.V.||P.V.||P.V.||P.V.||P.V.||P.V.||P.V.|
|cost||year 1||year 5||year 10||year 20||year 30||year 40||Total|
Industry implementation, newbuilding capital expenses
Industry costs, with amortization
|Vessel Subchapter and service||Annual||P.V.||P.V.||P.V.||P.V.||P.V.||P.V.||P.V.||P.V.|
|cost||year 1||year 5||year 10||year 20||year 30||year 40||year 50||Total|
Industry implementation, Newbuilding Operating Costs
|Vessel type||unit maint.||P.V. year 1||P.V. year 5||P.V. year 10||P.V. year 20||P.V. year 30||P.V. year 40||40 year fuel||40 year maint.||TOTAL|
“Alterations” for the purposes of modeling the access costs for the existing fleet here means major work involving the vessel’s primary function area and path of travel to that area. It should, however, be recognized that any alteration to passenger areas, of whatever scope, must result in an accessible installation (for example, replacement or addition of a water fountain). Industry must be keenly aware of the legal requirement and the good business practice of building in access whenever replacement, upgrade, or restoration work is done.
Alteration costs include direct costs for components required in the access solutions (Table 4-4), added operating costs (fuel and maintenance), and lost revenue due to passenger space losses.
The cost models will be based upon accessible retrofit to all passenger accommodation areas of one deck for all sample vessels, and two decks if “Access 2” specification for all amenities (e.g. weather deck access) is required.
5.3.1 Unit costs
Capital costs Again, access accommodations are per Table 4-4. The 20% ceiling provision of ADA is ignored since available data do not support projections of total vessel alteration costs. This may result in high cost projections for some cases. Table 5-12 tallies the unit installation costs, exclusive of elevators and lifts; Table 5-13 adds in the costs for cases where multi-deck access is required.
While the capital costs for retrofitting access accommodations do not include the premium for building extra deck space, component installation costs are higher than those for new construction, as noted previously.
The costs for each item are uniform for all vessel types, except the signage and alarms, where deck coverage requirements will vary the costs from larger to smaller boats. Unit cost for an elevator, assumed in all cases to serve two decks only, is $50,000 X 200% for installation ($100,000). Auxiliary power upgrade due to elevator is not specifically considered. Stability analysis for the weight and moment additions of the elevator is estimated at $5,000, and is assumed not to be required for other access features, including stair lifts. The impact of corrective actions for stability problems, e.g. adding low ballast, is not considered.
Explanatory notes for unit alteration costs follow:
- Costs for gaming boats are limited to safety features (tiedowns and alarm systems) and food service amenities; other access items, particularly doors and elevators, have been observed as standard in the business.
Unit capital alteration costs, excluding elevators/lifts
|Costs in (quantity) @ (unit cost)||Total cost|
|Vessel type||Tie-downs||Head||Embark station||Door||Signage/alarms||Food bar||without elevator|
|H||Ferry||8 @ $250||2 @ $15K||$ 2 K||2 @ $5K||2 @ $6.5K||1 @ $2.0K||$59,000|
|H||Dinner/excursion||8 @ $250||2 @ $15K||$ 2 K||2 @ $5K||2 @ $6.5K||2 @ $2.0K||$61,000|
|H||Gaming||8 @ $250||0 @ $15K||(none)||0 @ $5K||2 @ $6.5K||2 @ $2.0K||$19,000|
|H||Cruise||8 @ $250||2 @ $15K||$ 2 K||2 @ $5K||2 @ $6.5K||2 @ $2.0K||$61,000|
|H||Whalewatch/sight||8 @ $250||2 @ $15K||$ 2 K||2 @ $5K||2 @ $6.5K||1 @ $2.0K||$59,000|
|H||Other||8 @ $250||2 @ $15K||$ 2 K||2 @ $5K||2 @ $6.5K||2 @ $2.0K||$61,000|
|K||Ferry||6 @ $250||1 @ $15K||$ 1 K||1 @ $5K||2 @ $5.0K||1 @ $2.0K||$34,500|
|K||Dinner/excursion||6 @ $250||1 @ $15K||$ 1 K||1 @ $5K||2 @ $5.0K||1 @ $2.0K||$34,500|
|K||Gaming||6 @ $250||0 @ $15K||(none)||0 @ $5K||2 @ $5.0K||1 @ $2.0K||$13,500|
|K||Cruise||6 @ $250||1 @ $15K||$ 1 K||1 @ $5K||2 @ $5.0K||1 @ $2.0K||$34,500|
|K||Whalewatch/sight||6 @ $250||1 @ $15K||$ 1 K||1 @ $5K||2 @ $5.0K||1 @ $2.0K||$34,500|
|K||Commuter /shuttle||4 @ $250||0 @ $15K||$ 1 K||1 @ $5K||2 @ $5.0K||1 @ $2.0K||$19,000|
|K||Fishing/dive||4 @ $250||1 @ $15K||$ 1 K||1 @ $5K||2 @ $5.0K||1 @ $2.0K||$34,000|
|K||Other||6 @ $250||1 @ $15K||$ 1 K||1 @ $5K||2 @ $5.0K||1 @ $2.0K||$34,500|
|T||Ferry||4 @ $250||0.5 @ $15K||$ 1 K||1 @ $5K||2 @ $3.5K||1 @ $2.0K||$23,500|
|T||Dinner/excursion||4 @ $250||1 @ $15K||$ 1 K||1 @ $5K||2 @ $3.5K||1 @ $2.0K||$31,000|
|T||Gaming||4 @ $250||1 @ $15K||$ 1 K||1 @ $5K||2 @ $3.5K||1 @ $2.0K||$31,000|
|T||Cruise||3 @ $250||1 @ $15K||$ 1 K||1 @ $5K||2 @ $3.5K||1 @ $2.0K||$30,750|
|T||Whalewatch/sight||3 @ $250||1 @ $15K||$ 1 K||1 @ $5K||2 @ $3.5K||1 @ $2.0K||$30,750|
|T||Commuter /shuttle||2 @ $250||0 @ $15K||$ 1 K||1 @ $5K||1 @ $3.5K||0 @ $2.0K||$10,000|
|T||Sailing||3 @ $250||1 @ $15K||$ 1 K||1 @ $5K||1 @ $3.5K||1 @ $2.0K||$27,500|
|T||Other||3 @ $250||1 @ $15K||$ 1 K||1 @ $5K||2 @ $3.5K||1 @ $2.0K||$30,750|
Unit alteration capital costs, with elevators/lifts
|Total cost||Elevator Costs||Total cost|
|Vessel type||elevators||ratio||equip. costs||analysis||elevator|
- The scope of work, e.g. the number of accessible cabin doors or food bars, is varied with the size and service of the affected vessels; these access elements are representative only, not all-inclusive.
- T fishing vessels are not considered candidates for primary function alterations as specified for the purposes of these cost calculations.
- Elevator/lift ratios are not supportable by significant data at this time, but reflect field observations and the belief that lift technology for passenger vessels will improve and find wide application as a practical alternative to elevators.
- Large ferries, which tend towards car carrying arrangements, will most likely service vehicle decks with elevators; this retrofit has already been accomplished on several vessels. Those T ferries requiring multi-deck access will be more likely to utilize lifts, due to space and stability limitations.
Operating costs Fuel and maintenance costs are found in much the same manner as for new construction. There is the additional aspect of revenue losses since passenger accommodation area is lost to make way for elevators, accessible heads, and wheelchair tiedown spots.
Fuel costs are based solely upon the added component weight of elevators. The added area premium calculated for new construction does not pertain when backfitting on an existing vessel, and the net added weight of other components is assumed to be insignificant. Sample unit costs are shown in Table 5-14. The reader should note that these do not allow for speed reduction and that full power operation is assumed for the annual operating hours specified.
Unit annual maintenance costs may be found in Table 5-18, with the industry implementation maintenance costs. Detailed notes and spreadsheets for all costs are in Appendix D.
Sample unit fuel cost for retrofit elevator installation
|Service||(LT)||added wt/||horse-power||annual hrs||Annual fuel cost|
Note: = displacement of loaded vessel
Lost revenue will be the result of alterations which take existing passenger space for access accommodations. The calculation starts with finding the areas needed for the new access features, i.e. elevators, accessible heads, and wheelchair tiedown spots. Lost passenger capacity results from simple division of the lost area by unit passenger areas. Lost revenue is then found by multiplying the trip frequency by representative fares and the lost capacity. The assumed full capacity ratio (portion of trips at full capacity, when revenue losses will actually be incurred) is 0.4, corresponding approximately to a peak (summer) season plus holidays and some weekends.
Several calculations were needed for each vessel type because of two regulatory provisions for minimum per passenger areas, and since elevators, lifts, or neither will be needed for different individual vessels. The Coast Guard generally requires at least 10 ft2 of deck space per passenger, but also allows for a minimum of 3.75 ft2 per seat for high density craft. Space reductions clearly have different proportional effects on each category.
Table 5-15 shows the development of unit revenue losses, with four possible outcomes for each type of vessel. The term “NA” appears when the configuration shown is not applicable, based upon knowledge of the fleet, field visits, and, primarily, the specifications of the access solutions offered herein. Specifically, no T boat alterations in this model will have elevators. It is also assumed that no H vessels are “high density” and that all commuter/shuttle boats are.
It is assumed that elevators do not result in lost vehicle capacity on ferries. One domestic operator stated that a parking space had been lost due to retrofit, while a study for Transport Canada indicated no loss of space17.
Further details on the area loss calculations appear in the notes in Appendix D.
5.3.2 Industry implementation cost
The total society cost for alterations to the existing vessels in the fleet, according to the model’s schedule and access solutions, is $173.6 million, including $54.6 million for capital improvements (Table 5-16), $11.0 million for fuel (Tables 5-18), $7.3 million for maintenance (Table 5-19), and $100.7 million for lost revenues (Table 5-20). Industry costs are $191.8M, including amortized capital costs (Table 5-17).
Capital costs The industry implementation costs will be spread over a period of twenty years, as the alterations are modeled as a ten year phase-in, and the amortization runs out for ten additional years.
Operating cost– fuel and maintenance All operating costs are calculated for a period of forty years, in which time the presently existing H vessel population is modeled to decay to zero. The K and T portions of the fleet likewise drop out in 33 and 25 years, respectively.
Operating cost– lost revenue The industry implementation model is the same as described above for fuel and maintenance.
Sample unit revenue costs for alterations
|Vessel service||Ft2 loss,unisex heads||Ft2loss, elev.||Wheel-chair capacity||Fare||Daily trips||Days per week||Weeks per year||Annual loss w/elev, 10 ft2/pax||Annual loss w/o elev,10 ft2/pax||Annual loss w/ elev,3.75 ft2/pax||Annual loss w/o elev,3.75 ft2/pax|
Industry implementation capital costs for vessel alterations
|Vessel type||Total annual cost||P.V. year 1||P.V. year 5||P.V. year 10||Total P.V.|
Industry implementation capital costs for vessel alterations
Industry costs, with amortization
|Vessel type||P.V. year 1||P.V. year 5||P.V. year 10||P.V. year 15||Total P.V.|
Industry implementation fuel costs for vessel alterations
|Vessel type||Annual retrofits w/elev/lift||Elev/lift factor||P.V. year 1||P.V. year 10||P.V. year 20||P.V. year 30||P.V. year 40||Total fuel $|
Industry implementation maintenance costs for vessel alterations
|Vessel type||Units per year w/elev/lift||Unit annual cost||Units per year w/o elev/lift||Unit annual cost||P.V. year 1||P.V. year 10||P.V. year 20||P.V. year 30||P.V. year 40||Total type cost|
Industry implementation lost revenue costs for vessel alterations
|Vessel||Pop. factor 10 ft^2/pax||Pop. factor 3.75 ft^2/pax||Elev/lift factor||P.V. year 1||P.V. year 10||P.V. year 20||P.V. year 30||P.V. year 40||Total per type|
5.4 TRAINING COSTS
Passenger vessel crew training for vessels in the industry is needed to assure proper assistance to passengers with disabilities, including passage from the dock to the vessel. Estimates have varied from zero to the cost for one day training per year for all crew. One half day of training per year is assumed for all passenger vessel crews, regardless of the vessels’ accessibility status.
Industry manpower data are not readily available for this calculation, and a rough estimate only is possible. Therefore, it is assumed that an average of three crew per vessel are affected, a total of 17,310 personnel. At an assumed average labor rate of $250/day, the annual cost will be $2,163,750. Present value for the forty year period considered herein is $33.2 million.
5.5 FLEET COST SUMMARY
Table 5-21 (society cost) and 5-22 (business cost) show the categorized summaries of costs among the three Coast Guard subchapter passenger vessel categories. Table 5-23 is a summary calculation of “actual” costs, i.e. the total of the cost stream with no present value discounting.
Industry-wide fleet access implementation costs ($ millions)
Industry-wide fleet access implementation costs ($ millions)
|Sub Total||New construction||$140.3||$58.5||$17.7||$0||$216.5|
Fleet sector actual costs (1996 $millions)
|Sub Total||New construction||$228.7||$193.7||$60.9||$0||$483.3|
6. SHORE TO VESSEL TRANSITION ACCESS
The unit costs for providing access at dock and pier facilities are calculated and the industry implementation cost for ADA compliance determined in a six step process, as presented in paragraph 3.2.1. The access requirements for this segment of the industry are driven mainly by the needs of mobility-impaired persons, in particular specified path of travel geometries for wheelchairs.
This chapter presents dock and pier access solutions. Chapter 7 presents the unit incremental costs and industry implementation costs. Introductory comments on each step of the process follow:
- Physical barriers to access from land to vessel (Section 6.2)– Up to three pathway elements must be considered in the construction of access solutions: the stable approach (land or fixed structure such as a pier), passenger loading platform (dock), and the vessel deck.
- Constraints on solutions (Section 6.3)– The unique dynamic nature of the marine environment imposes cost, reliability, and operations constraints upon the design of access solutions. These must be integrated into the solutions.
- Classification of marine facilities (Section 6.4)– The classification matrix will model the facility population by vessel type serviced and hydrographic features.
- Proposed access solutions (Section 6.5)– The set of practicable and cost-effective solutions for the population of marine facilities is based upon identified barriers and constraints.
- Incremental costs of proposed access solutions (Section 7.1)– Incremental costs, relative to providing non-compliant access, are calculated for each proposed solution.
- Industry implementation cost (Section 7.2)– Industry implementation costs are based on the proposed solutions, the estimated number of affected facilities, and logic linking the solutions to the modeled facility population. The population is modeled on limited data; a range of industry costs is, therefore, projected.
6.2 PHYSICAL BARRIERS TO ACCESS FROM LAND TO VESSEL
Access from shore to vessel involves transit along three path-of-travel elements: stable approach, passenger loading platform, and vessel deck (Figure 6-1). The access barriers result from the intervening differences in height among those elements, whose descriptions follow:
- Stable approach– The start point of the path of travel, land and/or a fixed pier.
- Passenger loading platform– The intermediate component along the path of travel, i.e. a floating dock. This is the most common configuration, but access is sometimes provided directly from the stable approach to the vessel deck.
- Vessel deck– The end of the shore facility portion of the path of travel.
Physical Access Barriers from Dock to Vessel
The accommodations to overcome the barriers will satisfy a set of “nominal marine conditions”, which include tidal or non-tidal height limits of ten and twenty feet, respectively, and the assumption that severe weather is not causing excessive motions. The approach to categorizing shore facilities sorts on this assumed hydrographic condition (yes or no). Combinations of the physical access barriers along the path of travel determine the designs of the proposed access solutions. Description of the barriers follows:
- Height difference between the stable approach and the water-- The stable approach to a passenger boarding facility is typically high enough above average water level to prevent submergence in all but the most extreme conditions. The height of the stable approach can range from several feet to over 20 feet, and is based on historical data.
- Water level changes– All waterfront facilities experience changes in the height of the water relative to the stable approach. Coastal facilities undergo tidal cycles twice daily, with normal ranges from little more than a foot to over twenty feet. Non-tidal (inland) facilities experience water level changes as the result of rain, snowmelt, dam releases, etc., which tend to occur in predictable patterns over time. The changes are less frequent than at tidal facilities, but can be more severe, with normal ranges often in excess of 20 feet. Extreme weather conditions can add considerably to the range at all facilities.
- Height difference between passenger loading platform and the vessel– When a loading platform (dock) is in the pathway between the stable approach and the vessel, the freeboard difference between the dock and the vessel is an access barrier. Because freeboards of docks and vessels vary greatly, there will be widely varied and unique height differences for dock-vessel combinations. This height difference may also vary for a particular dock-vessel pair with loading and weather conditions.
6.3 MARINE DESIGN REQUIREMENTS FOR ACCESS SOLUTIONS
The following are the unique design constraints imposed by the marine environment for providing access from shore facilities to vessels:
- Dynamic nature of the marine environment– Shore facilities are exposed to a dynamic marine environment, with the impact of waves, wind, tides, current, and weather. The functional design of access features must account for the resulting loads and motions.
- Changes in height differences– Access solutions in the marine environment differ from those on land in that height differences change, over both short and long time frames. Changing height differences drive a unique set of solutions for accessibility.
- Lift and stability requirements of floating structures– Excluding fixed piers, access structures are floating components subject to the same static and dynamic effects as vessels. The design of access solutions for docks must take into account lift (weight), heel and trim due to shifting of weight, and the dynamic effects of wind and waves.
- Exposure to harsh weather conditions– While any outdoor system for accessibility must be designed and built to withstand the impacts of weather, marine facilities are especially impacted by their environment, i.e. the effects of water, salt and air on durability and reliability.
6.4 CLASSIFICATION OF MARINE FACILITIES
Development of access solutions requires a system for facility classification. The following attributes define shore facilities and result in sixteen facility types as shown in Table 6-1 below:
- Normal range of water height–The normal range of water height can vary from less than one foot to in excess of 25 feet. Industry’s experience has of course been that access with greater height changes is the more difficult. The evidence is that height changes of more than ten feet for tidal facilities and twenty feet for non-tidal facilities are logical breakpoints for characterization, based upon the Army Corps of Engineers Port Series, showing 90-95% of port facilities below that threshold.
- Available water sheet– Space limitations are frequently a factor in how easily a facility can be made accessible. Available watersheet, the area over the water available for docks and piers and vessel maneuvering, is often a critical matter and is defined by issues of property ownership and navigable waterways. The breakpoint of 40,000 ft2 was suggested during the Massachusetts negotiated regulation for waterborne transportation access because it provides area for a 100’ vessel to turn, a large-scale full access solution, and dock space.
- Scheduled versus unscheduled service– From a user perspective, there is generally a greater presumption that scheduled service will be accessible. Although ADA does not specifically make any references to scheduled or unscheduled service, there are several analogous concepts in ADA and other rulemakings.
- Type of vessel using facility– The type and size of vessels using a facility relate directly to passenger volumes and the size of a facility to accommodate them. Facility size and passenger volumes are key factors for determining access requirements. As in Chapters 4 and 5, vessel size roughly corresponds to Coast Guard subchapter classifications H/K (large) and T (small).
Table 6-1 describes the facilities by service and hydrographic characteristics. Each category is scored with “+” and “-“ for tidal height, available watersheet, schedule, and vessel size. “+” scores indicate the need and practicality of full access, while “-“ scores indicate less intensive use or greater site-related difficulties. The results are then expressed on a scale from 0 to 4, corresponding to the number of “+” marks received.
This categorization is used in the calculation of industry implementation costs, specifically in Section 7.2 which establishes the linkage between the shore facility population and the fleet.
Marine Facilities Matrix
|H/K (+)||Scheduled (+)\|
|T (-)||Unscheduled (-)\|
|H/K (+)||Unscheduled (-)\|
|P F||Water height < 10’/|
|20’ (+) (Note 1), water sheet > 40K ft2 (+)||++++|
|**h e y|
|a s t**||Water height < 10’/|
|20’ (+), water sheet < 40K ft2 (-)||+-++|
|**i u c r|
|a e**||Water height > 10’/|
|20’ (-), water sheet > 40K ft2 (+)||-+++|
|l s||Water height > 10’/|
|20’ (-), water sheet < 40K ft2 (-)||–++|
Note 1: Water height limits shown for tidal/non-tidal facilities.
6.5 PROPOSED ACCESS SOLUTIONS
The process for identifying design constraints and developing facility classification criteria drives the development of practicable access solutions. A limited number of solutions are advanced for the purpose of calculating unit costs. These solutions are not all inclusive but provide a reasonable spectrum for modeling industry costs. Given the variety of facilities now in service and the possibilities for new engineering approaches, it is expected that accessibility solutions will vary widely.
The following four criteria inform the design of proposed shore-to-vessel access solutions:
- Broadest possible applicability– Access solutions apply to a broad cross section of shore facilities. A limited number are chosen to simplify the process of developing industry-wide costs.
- ADAAG specifications– All solutions will satisfy ADAAG ramp specifications for slip-resistant surfaces, handrails, gaps, clearance, and live loads. Non-compliance with ADA slope requirements for transition plates at either end of the gangway would be allowable if properly identified for potential users. Depending on the facility classification, exemptions to ADA slope and length regulations could be acceptable (discussion in Chapter 7).
- Unassisted access– Solutions should provide unassisted access to the vessel.
- Reasonable cost– Low installation cost will mean faster compliance. The proposed access solutions defined for this report will not be universally adopted as new engineering approaches will emerge; low cost solutions will, however, be the most likely outcome.
- Low maintenance– An access system that is not properly maintained will not provide access for very long.
6.5.2 Proposed Solutions
Four components are selected as the basis of unit cost calculations and the cost roll-out.
COMPONENT 1: Either a 60’-80’ accessible gangway (1) or a “Double entry” ramp (1a) and twin 30’ accessible gangways (1b) from stable approach to passenger loading platform. Double entry means that there are two start points on the land at different heights; one of the start points will require a fixed ramp.
COMPONENT 2: 120’ fixed ramp system (2a) and associated floating platform (2b).
COMPONENT 3: 12’ accessible boarding gangway.
Selected combinations of these components make up five solutions which have been found to be feasible for application to all of 59 terminal facilities visited. Solutions 1 through 4, shown in Figures 6-2 through 6-5, are for the “high access” facilities, that is, those rated “3” or “4” in
“High Access” solution with Components 1a, 1b, 2a, 2b, and 3
High Access solution with Components 1, 2a, 2b, and 3
High Access solution with Components 1a, 1b, and 3
High or Low Access solution with Components 1 and 3
“Low Access” solution with Components 1 and 3
Table 6-1, based upon intensity of use and hydrographic characteristics. Solutions 4 and 5 (Figures 6-5 and 6-6) are lower impact designs for those facilities with lower access profiles, that is, rated from “0” to “2”. The range of water heights at affected facilities implies that low cost solutions will often provide full access for category “3” and “4” facilities. Likewise, Solutions #4 and 5 may often provide full access at category “0-2” facilities.
All of the high access solutions may be varied to suit greater height differences for the small percentage of such facilities. Higher unit costs for those facilities are included in the full implementation calculation in Chapter 7.
Note that Solutions 4 and 5 are variations on the simplest possible design, including Components 1 and 3. The ramp from land to float is either 80’ or 60’ long. Solution #4 may be either a “High” or “Low” access design, depending on the local hydrography. It is used for both situations in the industry cost calculations.
6.5.3 Safety concerns
Costs for the proposed solutions will be developed with all pertinent safety features and ADAAG specifications in mind. These safety issues may not be readily apparent in examining the proposed solutions, but they were considered in every solution examined:
- Information on travel path- The path of travel at a marine facility is likely to differ from what someone would encounter on land. As a result, it is critical that information on these differences be made available to all users.
- Guardrails– Because of the inherent dangers of accidentally leaving the path of travel at a marine facility, guardrails are critical to insuring passenger safety.
- Edge Treatments/Detectable Warnings– Tactile edge treatments and detectable warnings for the sight-impaired are also critical to insuring passenger safety.
- Changes in slopes, heights, materials, etc.-- The path of travel from land to vessel is likely to have frequent changes, particularly slopes. For user safety, it is important to identify these at the proper time.
- Non-slip surfaces– Most areas at a marine facility will periodically get wet or damp from water spray. The wide use and application of non-slip surfaces is important for passenger safety.
- Assistance- - Assistance by crew for all passengers in the marine environment is standard practice due to its dynamic nature. This positive tradition in the industry will be a part of the growing need for access for persons with disabilities.
7. SHORE TO VESSEL TRANSITION ACCESS COSTS
The industry cost calculations have the following three steps:
- Development of unit costs for the access components
- Calculation of unit access solution costs (Scenarios 1-6)
- Cost of industry implementation based upon finding the number, or range of numbers, of terminals affected nationally
The first two steps are straightforward, given the availability of component costs data and the access solutions advanced in Chapter 6. The industry cost is limited by available shore facility data, and are of necessity presented as a range of cost scenarios based upon different data extrapolations. The extrapolations result from varied inputs for numbers of terminals, tied to the vessel population, and the distributions of unit access solution costs within the terminal population.
7.1 UNIT INCREMENTAL COSTS
The incremental, or premium, costs of providing access for each solution are calculated, that is, the additional costs of fully accessible systems relative to existing industry standards. The incremental cost elements for all components in the proposed solutions are:
- Extra gangway width
- Extra gangway length
- Extra handrails/guardrails
- Non-slip surface
- ADA compliant approach
- Strengthening to ADA required weight limits
Cost units begin at the component level and add together to give unit scenario costs. The access scenario premiums are the differences between the scenario costs and those estimated for non-compliant construction.
7.1.1 Unit component costs
Table 7-1 shows sample unit costs developed for the access components. They do not include costs for current industry construction practices. Detailed supporting data and notes are in Appendix E.
Component unit costs
|1. 60’ accessible gangway||5’||60’||$15,900|
|1. 80’ accessible gangway||7’||80’||$21,200|
|1. 100’ accessible gangway||8’||100’||$26,500|
|1a. Double gangway entry ramp.||5’||60’||$30,000|
|1a. Double gangway entry ramp.||8’||100’||$50,000|
|1b. Two 30’, accessible gangways.||5’||(2) X 30’||$10,500|
|2a. 120’ fixed ramp system.||10’||120’||$31,000|
|2. Supporting float for 120’ fixed ramp||NA||NA||$70,000|
|2a. 180’ fixed ramp system.||15’||180’||$46,500|
|2b. Supporting float for 180’ fixed ramp||NA||NA||$105,000|
|3. 12’ accessible boarding gangway||1’||12’||$2,100|
Note: Height and length refer to height of barrier and 12:1 length to overcome.
7.1.2 Unit solution costs
The component cost units are added to find the unit cost for each access solution in Table 7-2. Access barrier height differences vary over a wide range for each access solution; however, uniform representative heights and lengths were chosen for each solution. These are reflected in the access solutions and costs.
One baseline non-accessible configuration is used in order to determine the access premium for all solutions. It consists of a standard 50 foot gangway and a set of portable stairs to the vessel’s deck edge. The gangway cost was based on standard, currently available equipment. No costs were assigned to the stairs, nor for the baseline float, which is assumed to be required for any solution. The baseline cost is $5,300.
Table 7-2 includes notional costs developed for solutions for high tidal/non-tidal water height changes, identified as “High 1/2/3/4/5”. The water heights given in Table 7-2 are representative of a range; the “high” solutions therefore do not solve for the most extreme situations. Longer ramps and gangways for each solution raise the component costs. The baseline cost for non-accessible solutions in these situations is $10,000.
Detailed scenario unit cost calculations are found in Appendix E.
Solution unit costs
7.2 INDUSTRY ROLL-OUT COSTS
The industry roll-out cost calculation includes existing facilities only and does not account for new construction trends. The difficulties of data collection, discussed below, make accurate projections of replacement rate of existing facilities and the construction rate of new facilities impossible. Therefore, the cost of implementation for existing facilities only will follow that of new construction and retrofits for vessels, i.e. a 40-year phase-in.
The shore facility industry cost calculation consists of the following steps:
- Analysis of available data, including validation by site survey information
- Development of facility baseline data base by linking to vessel population (Section 4.3)
- Linking access solutions to facility data base
- Industry costs found as a range defined by upper and lower facility/vessel ratios and three distributions of access solutions to the population
7.2.1 Data analysis
Only two sources for shore facility data were found, both from U.S. Government agencies. Descriptions of the available data follow:
- Army Corps of Engineer Port Series– The reports in the Port Series cover the principal United States coastal, Great Lakes and inland ports. There are 59 separate reports, which are updated on a regular basis. Each report contains a general description of the port area and a listing of port and harbor facilities. The general port description includes the tidal range of the port.
The port and harbor facility list includes all wharves, piers and docks in the port by category of use. The usage categories include separate listing for vehicular ferries and passenger ferries. There is a separate description of each pier, wharf and dock which includes physical dimensions, owner and operator.
- Federal Transit Administration National Waterborne Passenger Transportation Data Base-- This data base (abbreviated to NWPTDB) identifies 168 separate ferry systems operating in the United States. Each system is profiled separately. The profile contains information on the ferry system location, number of routes, and vessels operated. The NWPTDB covers those ferry lines and associated facilities that responded to the original questionnaire. The passenger fleet data development in para. 4.3.3 indicates that this survey gives excellent coverage of the national ferry fleet and its shore facilities.
- Field data– The practicability of the six access scenarios was confirmed by trips to a representative range of shore facilities in New England, San Francisco Bay, Chicago, Cincinnati, New York City, Oregon, and Cape May, New Jersey. The number of vessels at each facility was also observed for the purpose of calculating facility/vessel ratios. Figure 7-1 is an example of a multi-berth facility servicing multiple vessels. Detailed site visit results are in Appendix E (Figure E-1).
(Component #s indicated)
The Army Corps data base is far from comprehensive; it covers only large fixed facilities in the principal port areas. For these purposes, it is inadequate as a national model and no correlation can be drawn to our field data since so many smaller ports and facilities were visited. This data base does, however, give an excellent indication of the distribution of coastal and inland water height ranges (see Appendix E).
It shows that, except for Alaska, some parts of Maine, and some river sites, all normal ranges are less than the threshold values of ten and twenty feet. Seven sites with water height ranges in excess of the thresholds were visited (about 12% of the total), including six in the Cincinnati, Ohio/Covington, Kentucky area. This ratio is too high based on Army Corps data and is adjusted to 5% of the total population. The industry cost calculation, therefore, reflects higher unit costs for that portion of facilities.
Therefore national facility data will be characterized as follows:
- Ferry terminals– The number of ferry facilities is drawn directly from NWPTDB, a total of 357. Based upon field observations, all facilities are assumed to be in scheduled service (“+”), less than 10’/20’ tidal range (“+”), and non-restricted water sheet (“+”). Distribution between H/K and T service is proportional to the fleet distribution, that is 219 H/K facilities (“++++”) and 138 T facilities (“+++-“). All are therefore in Categories 4 and 3 (Table 6-1).
- Non-ferry terminals– This population is developed from field observations and extrapolation of facility/vessel ratios using developed fleet data. The distribution of vessel types, by Coast Guard subchapter, among the observed facilities is extrapolated to the entire existing fleet. Two ratios are applied in order to get a range of cost impacts since the confidence in the data is low.
The global ratio of 0.43 and a local (Boston) study ratio of 0.33 resulted from the field work. The Boston number is distorted by the presence of a single terminal serving eight passenger vessels. The global ratio could be influenced by a disproportionate number of facilities in large and medium sized cities relative to small port areas. A high end ratio symmetric to the low end number is probably reasonable. Facility-to-vessel ratios of 0.33 and 0.55 are, therefore, used to bound the range of industry implementation costs. The population characterization is summarized in Table 7-3.
The terminals with high water level changes are folded into the general population by a weighting factor of 1.5, based upon the unit scenario costs in Table 7-2. The costs for Scenarios 4, 5, and 6 are little changed, but are 50% higher for #1, 2, and 3, the high access solutions for intensive use terminals. The affected terminals, i.e. all H/K and scheduled service T facilities, are therefore accounted at 7.5% instead of 5%, by multiplying the total category numbers by 1.025.
Shore terminal population
Access Categories shown parenthetically
|Terminal type and||H/K sched.||T sched.||H/K un-sched.||T un-sched.|
|Ferry ++||224 (4)||142 (3)||NA||NA|
|Other(0.33) x ++||209 (4)||989 (3)||10 (3)||168 (2)|
|Other(0.33) x +-||27 (3)||345 (2)||0 (2)||61 (1)|
|Other(0.55) x ++||348 (4)||1648 (3)||16 (3)||281 (2)|
|Other(0.55) x +-||45 (3)||576 (2)||0 (2)||102 (1)|
7.2.2 Population/solution linkage
Six industry cost scenarios establish the range of industry expense for shore facility upgrade. Two facility/vessel ratios, established in 7.2.1, are crossed with three access solution distributions. High access facility categories are linked with the high access solutions, i.e. Categories 4 and 3 are solved by Solutions 1, 2, 3, and 4. Low access facility categories 2, 1, and 0 are addressed by Solutions #4 and 5.
The available data do not support any particular distribution of access solutions to the facility population; therefore three distributions are chosen to show a range of costs with different proportions of high and low cost solutions. Table 7-4 describes the linkages and distributions. Note that Solutions #1 and 2 are most costly and that #3, 4, and 5 are much cheaper solutions.
Access Solution Linkages
|S O L U T I O N S|
|High access||Low access|
|1 ($138K)||2 ($114K)||3 ($37K)||4 ($18K)||4 ($18K)||5($13K)|
The industry implementation cost is calculated separately for ferries; the facility/vessel ratio is not varied since the facility population is well documented. Ferry operations are, by the study’s definitions, all high access terminals. However, many T ferry facilities consist of simple roll-on/roll-off arrangements for short runs, including those for ferry barges. Three ferry facility industry-wide costs only are calculated, for the cost scenarios in Table 7-4. Only Solutions 1-4 apply, with the caveat that 25% of T ferry facilities need no access features.
Tables 7-5 and 7-6 summarize the results of the industry cost calculations. Table 7-5 is the societal cost, that is, the present value of capital outlays over a 40-year replacement and construction period, with no amortization costs. Table 7-6 shows the present value of business costs, which include capital costs amortized at 7.9% over ten years, resulting in a cost stream of 50 years.
The “raw total” values come from the detailed industry implementation cost sheets, presented in Appendix E (pp. E-9 and E-10). These actual costs in 1996 dollars are estimated to range from $79.5 million to $263.8 million.
Industry-wide terminal access implementation costs ($millions)
|Raw Total||Raw annual||PV 1||PV 5||PV 10||PV 20||PV 30||PV 40||PV Total|
The costs in Table 7-5 and 7-6 may be apportioned along the lines of vessel size by Coast Guard Subchapter. The apportionment is asshown in Table 7-7, per industry implementation spreadsheets, pp. E-9 and E-10 in Appendix E:
- Ferry terminals– H/K account for 67% of the total cost and T for 33% of the total.
- Non-ferry terminals– H/K accounts for 17-19% of the total and T for 81-83%.
Industry-wide terminal access implementation costs ($millions)
Business costs, amortized
|Raw Total||Raw annual||PV 5||PV 10||PV 20||PV 30||PV 40||PV 50||PV Total|
Terminal access cost summary, 1996 present value ($millions)
|Society costs||Business costs|
|Distribution||Facility/vessel ratio (R)||H/K facilities||facilities||Total||H/K facilities||T facilities||Total|
8. COST SCENARIOS
This chapter is a brief examination of the impact of access requirements on individual businesses; five examples, mostly representative of small concerns, are provided. They are the following:
- An operator of two Subchapter K dinner/excursion boats who will retrofit one in 2005, replace the other in 2010, and refurbish the dock in 2010 (Scenario 1).
- A T ferry operator who will retrofit one vessel in 2000, replace another in 2010, and replace his dock in 2005 (Scenario 2).
- A T commuter boat operator who will replace the vessel in 2005 and the dock in 2010 (Scenario 4).
- An operator of two T fishing boats who will replace them in 2005 and 2010 and rebuild the dock in 2005 (Scenario 4).
- An operator of two T whalewatcher and excursion boats who will retrofit the whalewatcher in 2005, replace the excursion boat in 2010, and refurbish the dock in 2005 (Scenario 5).
Table 8-1 summarizes the costs that would be incurred by the sample businesses. Capital costs are given first in 1995 dollars and then amortized ten years from the build year and present valued to 1995. Operating expenses for a thirty year period from the build year are present valued to 1995.
Operator scenario costs
|Boat 1||Boat 2||Dock||TOTAL|
|Capital $||Oper. $||Capital $||Oper. $||Capital $|
|Description||Raw ‘95 $||10-yr. APV||30-yr. PV||Description||Raw ‘95 $||10-yr.APV||30-yr. PV||Description||Raw ‘95 $||10-yr.APV|
|1||Alteration 2005||$102,000||$73,832||$352,226||Newbuild 2010||$88,250||$50,530||$72,950||Replace 2010||$138,300||$79,188||$628,725|
|2||Alteration 2000||$87,500||$80,067||$422,877||Newbuild 2010||$89,500||$51,246||$150,469||Replace 2005||$113,700||$82,300||$786,959|
|3||Newbuild 2005||$12,000||$8,686||$4,834||NA||$0||$0||$0||Replace 2010||$12,700||$7,272||$20,791|
|4||Newbuild 2005||$19,500||$14,115||$1,731||Newbuild 2010||$19,500||$11,165||$1,283||Replace 2005||$12,700||$9,193||$37,487|
|5||Alteration 2005||$27,250||$19,725||$214,254||Newbuild 2010||$69,750||$39,937||$74,767||Replace 2005||$12,700||$9,193||$357,876|
PV = present value
APV = amortized, present value
9. STABILITY CALCULATIONS
Elevators installed for the purpose of providing multi-deck access for persons with disabilities are the single access feature which may significantly impact the stability of a passenger vessel. The weight (in excess of two long tons) and the high location imply basic design issues for some vessels beyond the economic considerations of direct cost and deck space losses. A sampling of five passenger vessels is the object of a brief analysis to see how the addition of elevators affects stability.
9.1 ASSUMPTIONS AND CONDITIONS
The analysis proceeds on two sets of data: 1) the signature of the vessel and the particulars of the elevator retrofit; and 2) the Coast Guard’s statutory stability parameters for passenger vessels. The following address the first point:
- The samples chosen are existing domestic passenger vessels, known to satisfy all stability regulations in their present condition, i.e. with no elevators19.
- Elevator is assumed to serve all passenger accommodation decks.
- Elevator is placed in the most favorable position stability wise, amidships and on the centerline.
- The elevator’s center of gravity is assumed with the car in its topmost position .
Stability requirements are the following:
Coast Guard weather criterion, 46 CFR 170.170, specifying that vessels sustain heeling moments due to transverse wind loads on exposed surfaces. The unit area wind load varies with the service area of the vessel, e.g. exposed, partially protected, and protected waters. The latter generally correspond to open ocean, areas within 20 miles of safe refuge, and lakes, rivers, and harbors, respectively.
Coast Guard passenger heeling moment criterion, 46 CFR 171.050, specifying that vessels sustain heeling moments due to passengers crowding to one side.
Coast Guard adopted version of the International Convention for the Safety of Life at Sea rules for passenger vessel damage stability, 46 CFR 171.080. These specify, for given damage situations, minimum range of positive stability, minimum righting energy, maximum heel angle, and minimum righting arm relative to heeling moments induced by wind and passenger crowding. Positive range and righting arm are indexed to operating areas, similar to the weather criterion.
Elevator access was modeled as for retrofit to existing vessels, due to constraints of available data. The models did not include extra deck space as would be likely for a new design. The following provisions were part of the analysis:
- All vessels are assumed to operate in “partially protected” waters. Instances of failure to comply with the weather criterion resulted in a second iteration at the more benign “protected” standard.
- Weather criterion compliance is checked for four conditions: departure, fully loaded, with and without the elevator; and arrival, with stores and liquids “burned out”, with and without the elevator. Wind heeling moments are per the calculations of ref. 19.
- Required metacentric heights for passenger crowding in the intact conditions are calculated directly from the Coast Guard formula and compared directly to found values in the critical condition: arrival, with elevator. At arrival, the vessel’s center of gravity is highest and its stability is consequently the least robust.
- Damage stability is checked for the critical condition only: arrival, with installed elevator. Passenger crowding heel moment is the critical requirement19 and is the only criterion checked.
The analysis shows a compliance with stability regulations among the vessels sampled, except for the 91 foot excursion boat. In the four cases which pass the criteria, the addition of an elevator lessens the margins of compliance somewhat, but in most cases the residual margin is ample. Detailed results of the analysis appear in Appendix F.
9.3.1 Intact stability weather criterion
The modified, and more stringent, version of the Coast Guard weather criterion was employed, i.e., allowing no more than half the heel angle needed to submerge the deck edge. Four of the vessels passed easily, and the 91 foot excursion boat passed barely (see Table 9-1). In the latter case, the addition of an elevator would cause much greater heeling under wind loads and probably result in significant passenger discomfort.
Compliance with 46 CFR 171.170
|Vessel||Wind load area (ft2)||Maximum allowed||Resulting|
|80’ shuttle boat||1175||9.67o||2.76o|
|91’ excursion (ex-crew) boat||1388||12.75o||10.72o|
|105’ dinner boat||2803||6.81o||1.91o|
|192’ dinner boat||4314||6.16o||3.40o|
|274’ paddle wheeler||9827||5.33o||0.66o|
9.3.2 Intact stability passenger crowding criterion
This calculation requires a minimum metacentric height, found formulaically and depending upon passenger capacity, beam of the vessel, and vessel displacement. Table 9-2 shows the results, in all cases for the “arrival, with elevator” condition. The 91 foot excursion boat fails by a narrow margin, although it passes in the “departure, with elevator” condition.
Compliance with 46 CFR 171.050
|Vessel||Passenger capacity||Req’d. GMt (ft)||Attained GMt (ft)|
|80’ shuttle boat||200||2.21||7.90|
|91’ excursion (ex-crew) boat||250||2.91||2.69|
|105’ dinner boat||600||3.35||16.50|
|192’ dinner boat||600||2.04||11.32|
|274’ paddle wheeler||1200||1.90||42.76|
9.3.3 Damage stability
The Coast Guard standard requires each vessel to survive certain “extents of damage” which may occur over its entire length, under the influence of several external forces such as wind loading and passenger crowding. The result for each craft is multiple damage cases, each involving one or more watertight compartments below the main deck.
All sample vessels except the 91 foot excursion boat comply with the requirement in the arrival with elevator condition. In five of its eight damage cases, the 91 footer fails to sustain the required passenger crowding loads. Quick examination of the results indicates that this vessel would also fail the less stringent “protected waters” criterion.
The results show a clear correlation of success with size, the only failure being one of the two smallest sample vessels. The size trend can also be observed by examination of the changes in safety margins when the elevator is added; the relative change is smaller with progressively larger size.
It is probable that designers of new T boats, or conversions as in the case of the 91 foot excursion boat, will have weigh carefully the options of stair lifts and elevators. Stair lifts minimize weight and engineering impacts, but will likely require extra stair wells and particular attention from crew members. Elevators of course add substantial weight and maintenance burdens, but offer convenience for the passengers with a minimum of crew involvement.
10. ADDITIONAL OBSERVATIONS
The implementation of ADA in the passenger vessel industry suggests three possible benefits. This study can only address them qualitatively since available data does not allow for a valid quantitative estimation of the benefits.
It should be recognized that these potential benefits represent a narrow view of access opportunities, neglecting the much wider monetary and societal benefits of greater inclusion of persons with disabilities in employment, commerce, and leisure activities. It is likely that “universal design” concepts will evolve to successfully accommodate an aging population, people with disabilities, and users of all shapes and sizes. This bright future is beyond the scope of this study.
10.1.1 Increased business from persons with disabilities
It is probable that improved access will result in more patronage of the passenger vessel trade by customers with disabilities. Measurement of the benefit would require data on: 1) annual industry revenues; 2) present use levels of marine passenger service by persons with disabilities; and 3) revenue increment data from other industries and transport modes due to access improvements. With these data, revenue enhancements could be estimated with reasonable certainty on the expected increased frequency of visits by persons with disabilities. Information on items #2 and 3 is only available in anecdotal form.
10.1.2 Insurance benefits
The marine environment is unfamiliar territory for many of the millions of passengers who board each year. Moisture, motion, spatial limitations, and tripping/climbing obstacles can make for a hazardous environment on the dock and vessel. There is evidence that the majority of insurance claims by passengers against carriers is for “slip, trip, and fall” incidents. A major marine insurance broker reports that 40% and 22% of all claims are for mishaps on the decks and on ramps/ladders, respectively.
While it is possible that access improvements will make the industry safer for able passengers and reduce such claims, such a benefit may be offset by claims increases from passengers with disabilities using newly accessible facilities.
A quantitative estimate of this benefit would require: 1) claim data from marine insurance companies; and 2) data from other industries and transportation modes showing improved safety and reduced incidence of injury. These data are not presently available.
10.1.3 Employee health benefits
Improved access for wheelchairs may result in fewer job-related injuries for operator personnel since crew assistance for the lifting and moving of wheelchairs is reduced or eliminated. The Casco Bay Island Transit District has reported that fewer and less costly employee injury claims have resulted from a thorough health and safety program which includes job function analysis, employee training, ADA hiring practices, and capital improvements18. The report cited access features on vessels in the fleet as a key factor in reducing high stress lift situations on board.
10.2 IMPLEMENTATION ISSUES
The research for this project has identified an array of questions specific to the passenger vessel industry. Some involve application of the myriad provisions of ADA to the marine sector (a number of assumptions have been made for the access solutions proposed herein); other issues are simply beyond the scope of the cost study. The following points will need clarification:
- Definition of the ADA notion of “alterations” for the marine industry, for vessels and pier/dock facilities, referring to current ADA definitions for vehicles and facilities.
- Application of the many other provisions of ADA and ACAA to the marine industry, e.g., exceptions such as “one-car-per-train” and “equivalent facilitation”, (see 9.2.1).
- Investigation of trigger mechanisms. How does construction of or alteration to accessible “parts” affect the whole marine operation, e.g. is the dock part of the accessible path of travel to a new or upgraded vessel?
- Investigation of emergency egress and evacuation situations for people with disabilities. The study has made assumptions relative to the cost impact of lifesaving appliances (none) and leaves completely aside the issue of crew manning for the evacuation of large numbers of persons with disabilities.
- Provision of “event” related access features by vessels in certain services, e.g. gambling machines for motor impaired people on gaming boats or narrative reading cards for the hearing-impaired on tour boats.
10.2.1 Application of ADA precedents
The following are brief descriptions of ADA and other regulatory provisions as they have been applied to transportation modes and how they might be pertinent for marine access. A broader and more detailed discussion is provided in Appendix G.
- Air Carriers Access Act (ACAA)– The Act is significant for marine passenger service because it 1) recognized situations in which carriers and loading facilities are differently owned, requiring provision of access by all stakeholders, and 2) permitted different access treatments for different sizes of airplanes.
- Railroad access– Precedents in this mode are probably analogous to marine public transport assets such as ferries, but not excursion and other leisure vessels. One level of access on two-level commuter and dining cars is acceptable, as is “one car per train” access.
- Undue burden– Transportation providers may not claim undue burden relief when acquiring new or remanufactured vehicles.
- Elevator exemption– Some private entities are exempted if the building is less than 3 stories or 3000 ft2 per story. Transportation facilities, among others, cannot be exempted, indicating the importance placed by Congress on transportation access. There is an analogy, if not exact, to public accommodation passenger vessels, depending on the cost and technical issues acknowledged by the regulation.
- New construction– Access must be provided unless it is technically infeasible, for which the standards are very high (cost is generally not a factor). The solutions proposed herein generally follow this guideline, i.e., they assume feasibility of providing access. There is flexibility for installing elevators, depending on size and service of the vessel.
- Alterations– Alterations must generally meet the new construction standards “to the maximum extent feasible”, based on technical, not cost, considerations. ATBCB and DOJ have consistently ruled that adding elevators is not required. No vessel alteration requires more than proposed solution “Access 2”, and that only for large public accommodation vessels, only in cases where needed to provide full services. Technical feasibility of access accommodations, especially elevators, will be more problematic than for new construction.
- Small vehicles– Surface vehicles carrying less than 16 people are not required to have lifts or ramped access. For this reason, we have excepted water taxis and crew boats (forms of public transport) from the study.
- Fundamental nature– ADA states that accessible accommodations are not required in cases where they would alter the “fundamental nature” of the business or activity. An example in the marine environment would be handrails around a dock where boats tie up. Other such exceptions are not contemplated in this study, but may indeed be argued by some operators after implementation.
10.3 ADDITIONAL DATA NEEDS
The approach suggested herein is the product of study of the industry and its pertinent safety regulations, the requirements of ADA, and the availability and reliability of data. Industry data was gathered both for the vessel population and shore facility population, with mixed results. Future refinements of the cost study, if desired, would require the acquisition and analysis of better, more complete data.
10.3.1 Vessel population
There is a clear picture of the present disposition of the passenger fleet regulated by the Coast Guard. Historical data have two deficiencies: 1) a gap between 1965 and 1987 when little sorted data of any kind exists; and 2) the period of time before 1965 when good global fleet data were compiled, but not sorted in any useful way to reflect vessel sizes and services. Coast Guard and Army Corps data comprise a good basis for the fleet’s last five years, but retrieving better historical data is probably not possible. The statement of data needs will, therefore, be limited to more feasible aims. These are:
- Enhancements of service life expectations. A rigorous data gathering effort involving owners, designers, and the insurance industry could establish a better foundation for the assumptions needed to conduct the industry cost calculation.
- A survey of non-Coast Guard regulated vessels, i.e. those on non-navigable waters regulated by state marine agencies and other non-inspected vessels such as those carrying six or fewer passengers.
10.3.2 Dock and pier population
Available data are by no means complete. The link between vessel and shore populations was made based upon a very limited sampling. Extensive field work would be needed for a better grasp of this linkage, especially given the wide variety of operations and physical configurations.
11. CONCLUSIONS AND RECOMMENDATIONS
The completed and planned work on the passenger vessel access cost study can be summed up as follows:
- This study has significantly advanced the knowledge in the area of waterborne access for persons with disabilities. More work is needed to improve the industry’s understanding of access needs and to form the basis of informed decision making at the Department of Transportation.
- Much of the data necessary to complete a detailed cost and benefit analysis was not available. A good snapshot of the current fleet has been developed, without, however, a strong historical basis on which to analyze long term industry trends. Shore facility data is quite weak; a snapshot was developed by site visits, linkage to the fleet data set, and validation by the limited data in the Army Corps Port Series.
- Unit costs include both the generic elements of ADAAG specifications and the unique aspects of marine transportation. The solution sets are limited to feasibly handle the cost analysis. They provide realistic outcomes but cannot anticipate all access designs.
- Onboard access requirements should provide for flexible solutions in a fleet that is diverse in terms of size, service and design, operating in a unique environment with a unique set of safety issues.
- There should be allowance for innovative solutions by industry, particularly for mobility access from land to the vessel, where large height barriers must be overcome, and for mobility on the vessels, both between decks and in doors and passageways on the decks.
- Operating and revenue costs comprise more than half the total cost of fleet access. About 85% of these are projected revenue losses caused by loss of deck space from alterations of existing vessels; this amount is sensitive to many factors such as design of access features and frequency of full capacity sailings.
- Revenue losses due to alterations of existing vessels would be during peak operating capacity times. This may substantially affect profits for some operators who make most of their money during peak seasons.
- Fleet capital expenses are based on a rather rigid application of the proposed full access solution set. The fleet-wide cost of some features , such as elevators, may be overstated since innovative designs and operating practices may reduce the need for such installations. Other costs which are more difficult to ascertain for a large population, such as upgraded auxiliary power plants, are not included. The results are unit and fleet costs which are a valid first approximation, useful for the purposes of decision making by the Department.
- Unit costs for operators of small passenger vessels (T boats) are lower, but the burden may nonetheless be more onerous for those small businesses. The fleetwide cost for T boats is the highest because of the preponderantly large size of that fleet sector.
- Costs of access across the docks and piers were difficult to estimate because of weak industry data. A limited set of five solutions, which were found to be sufficient for all of a wide variety of facilities visited, yield a useful estimate of unit costs. The industry implementation cost is a range estimate since data were insufficient to characterize the size or the nature of the population.
- The needs of access over the docks and piers can be satisfied in most cases by the set of five solutions developed for the study, which include no mechanical aids or devices. It is likely that such devices will appear as technology addresses industry’s needs for improved access.
This study has advanced the knowledge of watercraft access but also served to identify several areas where more work is needed to fully understand implementation of ADA. They are the following:
- Integration of access features with safety design as required by the Coast Guard. More research involving industry, access advocates, and the Coast Guard will lead to a comprehensive and detailed treatment of access on passenger vessels. Particular attention must be given to alternative elevator design, practicability of lifts, head design (particularly for state rooms), the details of sill/ramp design, several ADAAG/Coast Guard (Title 46 CFR) harmonization issues, and generally how to craft the standards for the variety of vessel types affected.
- Investigation of unusual vessel types. The Department’s decision making must include passenger vessels not specifically covered herein, including passenger sailing vessels and the emerging new class of passenger submarines. Additional work may be needed to determine the potential impact on vessels beyond the scope of this study, such as state regulated craft, small boats carrying less than six passengers, and cargo vessels carrying passengers for hire.
- Cruise ships. The legal issue of extra-territorial jurisdiction of the United States in the matter of internationally flagged cruise ships operating from U.S. shores has so far prevented field work in that industry. Future research on the provision and impact of access may be needed if a legal understanding is achieved with the cruise lines.
- Dock and pier access. Further investigation to improve knowledge of mobility solutions and to build a more reliable industry data base would lead to more accurate cost estimates and a better technical basis on which to build access requirements.
- New technology.Both government and industry must be aware of the possibilities offered by innovative solutions to access problems in the marine environment. A technology assessment would identify promising new approaches, e.g., in lift equipment and evacuation and lifesaving appliances.
- Documentation. Two documents would be very helpful for Government and industry: a “best practice” guide for onboard access features and a training manual for emergency situations.
- Bers, Steven E. “The Americans with Disabilities Act and the Passenger Vessel Industry”, briefing for the National Association of Passenger Vessel Owners, Jan. 1992.
- Pilsch, Martin C. Jr. “The Impact of the Americans with Disabilities Act on the Waterborne Passenger Vessel Industry”, FA-MA-06-0197-01-02, Feb. 1993.
- Recreational Access Advisory Committee :Recommendations for Accessibility Guidelines: Recreational Facilities and Outdoor Developed Areas”, for the ATBCB, 13 Jul. 1994.
- McGuiness et al, “Marine Facilities Access”, final report, 30 Jun 1992.
- Corrado, Hikida, and Trostel “The Feasibility of Applying the Americans with Disabilities Act to Passenger Ves0sels”, 14 Dec. 1994.
- U.S. Coast Guard “Small Passenger Vessel Inspection and Certification” 46 CFR Parts 170, 171 and 173 and Chapter I, Subchapter K and T, Federal Register, Vol. 61, No. 7, 10 Jan. 1996.
- Woods Hole, Martha’s Vineyard and Nantucket Steamship Authority “Access Regulations for Licensed and Operated Vessels”, no date.
- Port of San Francisco “Guidelines for Access Design of Floating Structures in San Francisco Bay”, draft version, no date.
- Anthoney, Kevin M. “Cruise Guide for the Disabled”, Cruise Travel, Jan.-Feb. 1993.
- Department of Transportation, Appendix A to Part 37- Standards for Accessible Transportation Facilities, “ADA Accessibility Guidelines for Buildings and Facilities”, Federal Register, Vol. 56, No. 173, 6 Sep. 1991.
- Office of Management and Budget “Discount Rates for Cost-effective Analysis of Federal Programs” Federal Register, Vol. 60, No. 33, 17 Feb. 1995.
- Army Corps of Engineers “Port Series”, various dates of issue.
- Pilsch, Martin C. Jr. “National Waterborne Passenger Transportation Data Base”, FTA-MA-06-0197, Jan. 1995.
- U.S. Coast Guard NPRM Evaluation for “Small Passenger Vessel Inspection and Certification”, 1989.
- U.S. Treasury Department “Merchant Fleet Statistics”, 1940, 1945, 1950, 1955, 1960, & 1965.
- Water Resources Support Center, U.S. Army Corps of Engineers “Waterborne Transportation Lines of the United States”, 1990 & 1993.
- Coppens et al “Development of a Level Change System for Federally Subsidized Vessels”, Transport Canada publication #TP10376E, March 1990.
- Christian, Patrick, Casco Bay Island Transit District “Impact of the Americans with Disabilities Act on Casco Bay Lines”, October, 1995, unpublished at time of report.
- Dyer, Michael G., Volpe National Transportation Systems Center, U.S. Department of Transportation “Passenger Vessel Damage Stability Study for 1990 Safety of Life at Sea Amendments”, USCG-M-1-94-1, DOT-VNTSC-CG-94-5.1, September, 1994.