Washington Island Ferry Line, Inc., Richard Purinton
November 6, 2006 [Email]

Office of Technical and Information Services,
Architectural and Transportation Barriers Compliance Board
1331 F Street, NW, Ste. 1000
Washington DC 20004-1111

Comment to Docket Nos. 2004-1; 2004-2 ADA Guidelines for Passenger Vessels

To Whom It May Concern:

This letter includes comments and opinions about our vessels and the intended ADA Guidelines for small passenger vessels. In particular, we are commenting about our ferries that carry vehicles and passengers (150 and under capacity).

Our major points, with supporting comment to follow, are these:

1. Address ADA rulemaking separately for vessels 150 passengers, recognizing larger vessels of beam, length and multiple decks for larger passenger capacities have greater flexibility in design than do vessels of narrow beam, shorter length.
2. Recognize difficulties in design and ADA compliance where small vehicle & passenger ferries, to serve their intended purpose, devote a maximum amount of main deck space for the maneuvering, parking, and carriage of vehicles. These vehicles may include, besides autos, large trailers and trucks and heavy equipment, and vehicles with heavy loads.
3. Recognize and create workable changes in grade between vessel ramp and shore ramp, and grades between cabin floor and outer decks. Consider alternatives to the ½” maximum in levels, and in gaps.
4. Consider the practical difficulties and limitations for a vessel owner where a passenger ferry operates from a facility either owned or controlled by an entity besides the ferry company. (i.e., Washington State Ferries is an excellent example of what is possible, but it is not an example for many ferry companies or passenger boat operators.)
5. Wheel chair locations and companion seating sections need reworking to provide flexibility with inside vs. outside seating; any provision that requires mixing passenger seating with semi-trucks and other vehicular traffic on a main deck to come up with a necessary number of wheel chair locations.
6. Wheel chair and companion seating requirements should be considered that allow for best use of deck space, whether in a small cabin, or outdoors on a main deck, so that space considerations, which are always a consideration no matter what sort of seating is contemplated, will best utilize precious deck space to the maximum.
7. Head (public toilet room) configurations that allow for creative design, or an approved vessel head design standard, that permits something less than the 5-foot radius with commode and sink on opposing bulkheads (walls). Utilize the narrow beam, the restricted deck space found on small passenger vessels to best advantage for both disabled access and for the vessel’s primary purpose, which may include vehicular lanes.
8. Define what is a major alteration. Distinguish between “new” or “major” renovation. When does “new” occur?
9. Allow for disabled access and emergency egress aboard a small passenger ferry without sacrificing vehicle lanes, or construction of a larger deck platform to accomplish those goals. The smaller the vehicular ferry, the more difficult to provide for clear width aisles of 36”.
10. Recognize that protrusions aboard a vehicular ferry may occur with vehicles of odd shapes and sizes, motorcycle kickstands, boats overhanging trailers, etc. Work with owners to define a single safe path which doesn’t prohibit loading of vehicles in typical ferry roll-on-roll-off patterns, where passengers have access to that deck or by necessity must traverse that deck when parked vehicles are present.
11. Assign the U.S. Coast Guard, the regulatory agency currently charged with small passenger vessel design and oversight, as the responsible agency for enforcement of ADA Passenger Vessel Design rules.

Company Description

Washington Island Ferry Line, Inc. (WIFL) operates five small vehicle/passenger ferries on a route of 4.5 NM between the tip of the Door County Peninsula and Washington Island, Wisconsin, on protected waters connecting Lake Michigan and Green Bay.

These five ferries were designed and built for service on our particular route, using docks built for our service, with a customer base in mind that consists of year around residents as well as seasonal visitors. They are:

C.G. RICHTER - Built 1950; single diesel; 9 autos; 150 passengers. 65 x 25 x 9
This ferry was a primary ferry for many years, then used in later years only during the peak of summer tourism, and it was the sole winter ice ferry until 2003. Currently this vessel is not used and is for sale. Ferry has two decks: a main vehicle and freight deck, and an upper passenger deck with cabin and two heads. Loading is accomplished by attaching a 10 ft. wide steel plate to the port side of the ferry, or by two 30-inch gangplanks (no hand rails provided).

Ferry size and difficulty of side-loading has rendered it obsolete for present day service.
Vessel speed, as with our other ferries, is approximately 9 knots.

EYRARBAKKI - Built 1970; twin diesel; 18 autos; 150 passengers. 87 x 36 x 8.5
The open deck on this ferry carries a load of either 18 autos or a combination of autos with trucks or trailers. Bow and stern ramps permit drive-thru for autos, but large trucks and trailers must be backed on or backed off. Passenger access is over the same 16-ft. wide ramps used for vehicles. The passenger deck with cabin and men’s and ladies’ heads is approximately 10-ft. above the car deck and is accessed by stairs to port.

ROBERT NOBLE - Built 1979; twin diesel; 19 autos; 150 passengers. 90 x 37 x 9
Similar in arrangement to the Eyrarbakki with slightly more passenger seating on upper deck.

WASHINGTON - Built 1989; twin diesel; 21 autos; 150 passengers. 100 x 37 x 9
Several features distinguish this ferry from the others, most notably a centerline pedestal which is a structural support that houses engine room access, heads, storage, and stairs for vertical access to the passenger decks; there is a “sun deck” or uppermost passenger deck, and a cabin and seating on the 01 passenger level. While this ferry has the most main deck vehicle lane length, the lanes are narrow. The upper two decks have generous open air seating.

ARNI J. RICHTER - Built 2003; twin diesel; 18 autos; 150 passengers. 104 x 38 x 10
Heavily built with a hull designed for ice breaking in winter, this ferry design compromise vehicle deck space for a cabin and unisex head on the same level as the vehicles. Engine room access is located within this structural trunk, and also fore and aft passenger stairways to the mezzanine deck (inside cabin) and from that level to the uppermost open sun deck which has bench-style seating. Accommodation for elderly and disabled passengers was made with a main deck cabin and unisex head, although they are not strictly designed to ADA standards.

Route, service and seasonality – WIFL ferries operate year around serving an island population of 700, many non-resident property owners, and a summer tourism trade.

Since ferries are the only means of access to Washington Island during winter, the ferry Arni J. Richter was specifically designed and built to standards suitable for ice breaking and cold weather conditions. Winter crossing takes generally 40 minutes; the same route is less than 30 minutes in summer. Operations are profitable May through October, when revenues are greatest, but not in the remaining months.

Improvements to our ferries have been incremental, generally when equipment changes such as new motors or pumps are required. Major modifications to hulls or cabin have never been made, given the short season and short peak to the tourism season. We also find there are advantages to operating smaller and therefore more efficient ferries in the slower “off” seasons. New ferries were built as vehicular traffic changed (more trucks and trailers, less freight carried on deck, etc.). Passenger volume has not appreciably changed over a fifteen year period.

Profitability and deck area – From a service standpoint, the ability to transport trucks and trailers of all sizes throughout the year is important to our customers: modular homes; lumber; bulk cement; oil, gas and LP; food products; hardware; farm products; logs; package freight such as UPS or FEDEX…….are examples of the types of commodities carried either on trucks or trailers.

Nearly 65% of all annual company revenue is earned in July and August, months in which it is critical to fill ferry deck lanes with vehicles. Loss of main deck vehicle space is critical to profitability.

Vehicle revenue is also tied directly to passenger revenue. We have approximately 8000 one-way trips per year. If we lose revenue by losing one car space in order to satisfy an ADA requirement (and assume that this car space would earn revenue 50% of those trips) we would lose $11.50 x 4000 trips, or $46,000. The resulting lost passenger revenue could easily equate to $50,000, if we figure an average of 2.5 persons per vehicle.

Our ADA Suggestions for small ferry vessels –

We offer a number of suggestions:

1. Program –
   Where the ‘program’ is getting from A to B, and the trip is short, standards ought to minimally impact key vehicle deck space.
   
   Horizontal pathways for emergency egress, for example, will complicate the loading of semi trucks or similar truck/trailer combination if they are considered “no park” areas. Can safe egress be provided elsewhere, by other means, or could a single route of egress be considered sufficient?
   
2. Ocean Liner vs. Small Passenger/Vehicular Ferry
   At one end of the passenger vessel continuum are the large ocean liners with generous deck space. At the other end: water taxis that are currently exempted from this rulemaking, acknowledging both lack of space, brevity of route, and frequency of stops.
   
   Somewhere between these two vessel types are the small passenger vessels carrying fewer than 150 passengers. We believe our vessels, our service, and our clientele, more closely parallel water taxis than ocean liners. ADA guidelines should adjust requirements with vessel size and service.
   
   Experience tells us that larger is not always better. The smaller ferries we operate are an advantage in certain weather conditions, allowing us to operate when high winds might otherwise shut down service offered by a larger ferry with greater sail area and less maneuverability. Because of smaller engines, there is less fuel burn, and the vessel deck capacity more closely matches the traffic loads of the “off-season.”
   
3. Create a public toilet space (head) appropriate to the vessel size - Floor space is premium when a vessel’s working deck width is 35 feet or less. While a 5-foot turn radius for a wheel chair is the ideal, design modifications that permit toilet room access for the disabled is still possible whereby both disabled and non-disabled can be adequately served. Bear in mind, once again, vessel size, route length, and the intended service, and compare an ocean liner with an 18-vehicle ferry.
   
   We think an economical arrangement that extends to the location of wash basin, commode, soap dispenser, hand dryer, etc., is possible with the completed space still serving as a functional and safe space for the disabled. Are there existing designs available such as those available on passenger rail cars, for example, that take into account the similarly restrictive beam of a small passenger vessel?
   
   Creative design could utilize a 4-foot designed toilet room width, for example, which could be integrated as part of a vessel’s vertical structural section between decks, also functioning for necessary vertical access to upper deck, or for crew access to machinery spaces below decks, and for the stowage of small freight, luggage, or life jackets. This would be a sensible and economical compromise, especially for vessels that have less than 35-foot beams to begin with.
   
4. Clearance height for uneven surfaces -
   ADA standards cite a maximum of ½” in surface differences, or in gap.
   
   This standard is most easily followed ashore where structures are level, square and there is abundant floor space….and where surfaces do not move.
   
   Boarding our ferries takes place over a steel ramp that overlays a second, adjustable steel shore ramp. The outer edge is constructed with a 1 ¼” steel bar where top and bottom plates are joined. There are both horizontal and vertical gaps between ramp sections and between vessel and ramp.

   These ferry ramp sections and ramp ends are designed to slide back and forth with sea motion, or articulate like fingers when the ferry has a list (such as with a heavy deck load). A fine ramp edge would have the potential of cutting tires, wearing over time to a knife-like taper. Overlaying a light plate to cover these gaps for passenger access is possible but not feasible, as the plate would either bend or break with usage.

   (See enclosed photos showing truck tires on ramp edge….. )

   Challenges in deck levels occur at doorways to heads or cabins, where ice and snow can build up and water sloshes against the threshold. A steel plate was welded to the deck rather than a threshold, but it is over ½” in height.

   Is ½” change in level aboard a vessel an absolute, or is there an opportunity here for Flexibility? Unlike an ocean liner with miles of interior corridors (and little threat of water or snow), a small passenger ferry has maybe one or two points of access for passengers, plus perhaps a choice of two doorways into/from a cabin space, and where all access points are generally open to weather decks.

5. Wheelchairs and companion seating arrangement -
   The configuration of a small passenger ferry cabin is limited by both the vessel beam and by vehicle lanes on the main deck.
   
   The ferry Arni J. Richter’s main deck cabin, for instance, is a rectangular-shaped box that runs fore and aft. Seats face inward with an aisle between them.

   Current ADA wheel chair and companion seating requirements assume the person in the wheelchair and his/her companion always wish to face in the same direction, shoulder to shoulder, as if watching a movie. No allowance has been made for the companion to sit anywhere other than shoulder-to-shoulder, even though the objective
   is for the two persons to travel from point A to point B, rather than focus toward a theater stage, etc.

   Narrow cabins often found on passenger vessels limit ‘bump-outs’ for wheel chairs and beg for a creative seating solution. We submit that seating arrangements where two people face toward one another might actually be superior where conversation and eye contact is desired. Allowing for greater flexibility in wheel chair/companion
   seating arrangements would not reduce the requirement for wheelchair spaces, nor detract from the experience of the disabled passenger.

[*** end of expanded comment section ***]

ADA Nine Questions - [Although some of the answers to the Rulemaking “Nine Questions” are found in the above text, following are brief replies to the questions posed in the Revised Draft Passenger Vessel Accessibility Guidelines.]

1. Alterations to our ferries are minor, not major, and generally relate to replacement of a mechanical part, motor, or an electrical panel and not modifications to the basic vessel hull, cabin or deck plan. We have never lengthened a vessel, although we have considered and then rejected the idea when costs seemed prohibitive.
2. Not applicable to our ferries.
3. No tender platforms. Our hydraulic, adjustable shore ramps, and ferry ramps lowered to meet those shore ramps, are means of access for all ferry traffic, vehicular and pedestrian.
4. Our ferry vessel emergency plans include directing passengers to the uppermost decks as a refuge area when necessary. We do not have passenger lifts.
5. On the subject of wheel chair spaces and companion seating please refer to my earlier comments. Flexibility in seating arrangements is desired. Are companion seats, especially for short-haul routes, really necessary, or can we utilize some of the existing seating where it is in an “L” or “across-aisle” configuration? Must wheel chair locations be identified in a main deck outdoor space, when on that same deck semi-trucks (carrying logs, building materials, solid waste, etc. ) and other motorized vehicles are parked? Is this reducing safety?
6. No sliding doors used.
7. We do not use “cleats” as such on a passenger gangway, but we did weld metal diamond plate to our shore ramp as a means of providing better footing during wet and icy conditions. Plate is ¼” with raised diamond plate and can be seen in the photos provided of the truck wheels. This is necessary for both wheel traction in wet snow, and for passenger footing during slippery conditions.
8. No ‘tenders’ used, but we are interested in flexible seating arrangements to utilize space, create aisles, etc., for maximum benefit to all passengers..
9. a. Need more, varied case studies, especially within the smaller (150 and fewer) passenger vessels.

a. Yes.
b. Yes.
c. Case studies assume application of many shore-based guidelines, but do not account for down-scaled in size of vessel, especially vessels less than 150 passengers.
d. Don’t know, but it appears that the future designs we look at, in order to comply, would have to be substantially different, larger in size, and more costly to construct, than anything we have previously built.
e. Does not apply.
f. Does not apply.
g. This is a key problem, and one to which we need to be sensitive, for the needs of the disabled as well as for the general public. A single, approved means of emergency egress should suffice for small ferry, short route, small ferry. Crossing a vehicle deck with emergency egress paths restricts parking patterns. There is cost, either in sacrifice of useable vehicle space on deck, or in the increased ferry size needed to accommodate disabled access paths.
Work toward solutions that are an advantage for all passengers, and all types of vessels including vehicle ferries, without requiring increase in vessel size.
h. An increase in the range of 2-4% would be considered minimal and not a
discouragement to construction. Steel cost increases alone, or increases in main engine & transmission costs could easily exceed 2-4% due to other factors. However, that estimate seems low, given projects we’ve undertaken in the past. Changing vessel beam is even more problematic than length (although from a landsman’s point of view this may seem the easiest solution.
i. Larger vessels generally require larger power plants, which may result in greater fuel costs in the long run, possible dredging costs as draft keeps pace with length, or adjustments to docks and loading platforms as the vessel deck height changes relative to shore facility. The bottom line is this: we would consider it good business to have an ADA fully-accessible ferry, but the current limitations on small ferries as proposed don’t seem reasonable, and they offer few options in meeting the guidelines.

Respectfully,

Richard Purinton
President, Washington Island Ferry Line, Inc.
Encl: photos of each ferry; photos of ferry ramp and vehicle tires during boarding

[Note: Six non-digital photos provided with these comments were added to the rulemaking docket but not included in this web document.]