Epic Adventure Cruises
July 27, 2005 [Email]

EPIC ADVENTURE CRUISES

Daniel Vaccaro
Chief Executive Officer
Epic Adventure Cruises
401 East 34th Street
New York, NY 10016 USA

RE: Accessibility and Expedition Cruise Ships

Dear Members of the United States Access Board:

My company is in the process of finalizing financing to build the first in a series of new ships for the expedition niche segment of the cruise market. As most of the companies in the expedition segment are operating old tonnage and are not pursuing the construction of new vessels, I thought it imperative that this segment, with its unique operating requirements and passenger base have a voice.

A. Segments of the Passenger Cruise Industry

Passenger shipping includes three very distinct segments:

• Ferries – where transport from one destination to another is the motivation
• Mainstream Cruising – where passengers sail on floating mega resorts, geared for mass consumer markets, competing with land based vacation alternatives
• The Expedition/Adventure Niche Cruise Market – where passengers use small cruise ships to access remote corners of the globe for the purpose of visiting areas of the world which are only suited for rugged adventure, with distinct physical demands

B. Virtually No Demand for Expedition Cruising by Persons in Wheelchairs

Only two ice class expedition vessels have a total of three cabins which can be used by people in wheelchairs.1 These wheelchair accessible cabins are frequently used by staff because there is no demand among the expedition passengers for these types of cabins.

The lack of demand for expedition cruises by disabled passengers is no surprise. The focus of expedition cruising is the frequent landings in remote and uninhabited locales, such as Antarctica, the South Pacific and High Arctic for the purpose of hiking, diving and getting a close look at the wildlife and the wilderness. Expedition cruising is expensive and no fun if one is not physically able to participate fully in the landings. The process of getting to the wilderness destination is physically demanding because the locations typically do not have pier facilities. Landings are characterized by:

• Walking down an exterior stair on the ship and boarding rubber zodiac landing crafts (which hold 10 passengers).
• Holding on to ropes, as the zodiacs bounce atop the waves.
• Swinging over the rubber sides of the zodiac and wading in deep water to get to the wilderness site or to reach shore.
• In Antarctica and the Arctic, which make up to one half of our planned schedule, walking on uneven ice and through snow drifts
• Even in warmer climates, climbing over slippery rocks and boulders to reach the shore.

C. Compliance Is Not Commercially Feasible for Expedition Cruising

Practically speaking, compliance with the cruise ship construction requirements to accommodate passengers with disabilities and in particular, those passengers in wheelchairs is not simple or particularly reasonable for the expedition cruise segment for the following reasons:

• Expedition ships are necessarily much smaller than ferries or mainstream cruise vessels and do not benefit from economies of scale like big ships.2
• Our narrow vessels are only wide enough for a single cabin on each side of a single hallway.
• The cost of building a small expedition ship is enormous due to the extreme weather and navigation conditions encountered by the expedition ship in reaching the wilderness destinations.
• The physically demanding nature of expedition cruising appeals to a limited but devoted group of intrepid passengers.
• The price of an expedition cruise is extremely high. While one can easily sail on a big cruise ship for a whole week for $599, our average rate PER DAY is above $600.

For your information, our proposed design will be for a vessel, approximately 439 feet long and 59 feet wide. The ship will have 112 passenger cabins, of which 9 will be designated for staff and guest lecturers. Of the remaining 103 cabins, while all can accommodate 2 persons, we will accept numerous singles, for a targeted load of about 165 passengers. While we think that bookings from disabled passengers will be few and far between, we planned to make the ship friendly in general for those who have challenges in getting around:

• Access to all passenger decks by elevator at two locations
• No steps to navigate within a given deck, including lounges and dining room
• One or two cabins designed for wheelchair access and mobility features

However, to gear up the ship, devoting lots of space and capital, for passengers who have shown little interest in our style of travel and whom we will rarely see is unrealistic. It puts us at a competitive disadvantage for no reasonable purpose and may force us to eliminate features of the vessel, because building handicapped access would prove too costly or use up too much space. Some examples follow (a complete discussion can be provided upon request):

• V224.2- As we are planning to sell 103 of our 112 cabins, the chart indicates we would need to have 7 cabins with mobility features. However, since we might get only one disabled expeditioner ever year or two, having seven cabins available at all times creates a hardship. Such cabins are wider by necessity and will reduce revenue space, forcing us to reduce the number of cabins for single passengers, who are much more interested in sailing with us. Handicapped cabins are less marketable, because of their sub-optimal layout and are hard to sell. With our limited number of cabins, having 7% unmarketable is a hardship that makes us uncompetitive. Having to disperse such cabins among all grades creates further hardship, as verandah cabins are already cramped, based on reduced floor space. Two cabins (essentially suites) in our minimum category with picture windows should more than suffice.
• V224.4- 12% of cabins with communications equipment is excessive. Big ships, that are more likely to attract disabled passengers, only require 3%.
• V231.1- Unlike on big ships, the exercise room for expedition ships is quite small. If duplicate equipment (which could not or would not be used by other passengers) were required, other passengers would end up getting less than half the projected machines.
• V214- More than a single accessible washer/dryer is excessive in light of the likelihood of having more than one disabled passenger on a cruise is minimal.
• V208- As noted above, most stops are not alongside land. Usually the beginning and ending point of a cruise will be at a port where we will come alongside a pier. As these are remote, most will not have accessible gangways, like major ports might. It is unlikely that a ship of our size (or even a mega ship) will be able to carry a gangway several hundred feet long to meet the changing tides.
• V224- As stated in the guidelines, room width prevents 32 inch doors. Space on expedition ships is at a premium, as only outside cabins (with windows) can be sold. The notion of hospitality rooms is not workable for the same lack of space. Surely passengers can be invited to the cabin of the person requiring accessibility.
• V235- Expedition ships have very limited space for a pool and hot tub. Space, expense and maintenance issues in extreme climates for accessibility equipment may make it impractical, resulting in these facilities being lost for all passengers.
• V304- Due to the ship’s narrow beam of 59 feet, it may not be possible to provide turning space of 60 inches at all places
• V404.2.5.2- Access to the forecastle deck must have a weathertight door for vessel safety, there will be no room for ramps
• V211-Luxury expedition vessels do not have drinking fountains, which serve to spread germs and are hard to maintain under the extreme climate conditions faced by expedition cruise ships.

In conclusion, the very nature of expedition cruising and its purpose attracts only those passengers seeking a physically challenging vacation. While an expedition cruise line can expect to have an occasional mobility impaired or disabled passenger, it does not seem to be commercially reasonable to require the expedition segment to design their vessels around accommodating persons who are not likely to ever want to be passengers on an expedition vessel.

Sincerely,

Daniel Vaccaro

1. A team member and former expedition staff member and expedition leader aboard the two ships with cabins for the disabled reports that in several years of sailing those ships, she can only recall having a wheelchair passenger aboard once.

2. Our ships will be less than 10,000 GRT or one-sixteenth the size of the new generation of cruise ships Expedition ships must be small and narrow if they are able to fit into the natural harbors and undredged shores of the wilderness destinations sought by expedition passengers. Because expedition ships are focused on adventures ashore, recreational activities and entertainment found aboard mainstream cruise ships are generally lacking or significantly reduced, as passengers eat and rest up for the next day’s landings.