6. SHORE TO VESSEL TRANSITION ACCESS

6.1 APPROACH

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.

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.

Note 1: Water height limits shown for tidal/non-tidal facilities.

6.5 PROPOSED ACCESS SOLUTIONS

6.5.1 Criteria

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

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
• Signage
• 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.

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.

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).

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.

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.

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.

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%.

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:

1. 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).
2. A T ferry operator who will retrofit one vessel in 2000, replace another in 2010, and replace his dock in 2005 (Scenario 2).
3. A T commuter boat operator who will replace the vessel in 2005 and the dock in 2010 (Scenario 4).
4. An operator of two T fishing boats who will replace them in 2005 and 2010 and rebuild the dock in 2005 (Scenario 4).
5. 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.

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:

• Intact stability

- 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.

• Damage stability

- 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.

9.2 APPLICATION

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.

9.3 RESULTS

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.

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.

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.

9.4 DISCUSSION

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

10.1 BENEFITS

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

11.1 Conclusions

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.

11.2 Recommendations

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.

1. Bers, Steven E. "The Americans with Disabilities Act and the Passenger Vessel Industry", briefing for the National Association of Passenger Vessel Owners, Jan. 1992.
2. 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.
3. Recreational Access Advisory Committee :Recommendations for Accessibility Guidelines: Recreational Facilities and Outdoor Developed Areas", for the ATBCB, 13 Jul. 1994.
4. McGuiness et al, "Marine Facilities Access", final report, 30 Jun 1992.
5. Corrado, Hikida, and Trostel "The Feasibility of Applying the Americans with Disabilities Act to Passenger Vessels", 14 Dec. 1994.
6. 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.
7. Woods Hole, Martha's Vineyard and Nantucket Steamship Authority "Access Regulations for Licensed and Operated Vessels", no date.
8. Port of San Francisco "Guidelines for Access Design of Floating Structures in San Francisco Bay", draft version, no date.
9. Anthoney, Kevin M. "Cruise Guide for the Disabled", Cruise Travel, Jan.-Feb. 1993.
10. 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.
11. Office of Management and Budget "Discount Rates for Cost-effective Analysis of Federal Programs" Federal Register, Vol. 60, No. 33, 17 Feb. 1995.
12. Army Corps of Engineers "Port Series", various dates of issue.
13. Pilsch, Martin C. Jr. "National Waterborne Passenger Transportation Data Base", FTA-MA-06-0197, Jan. 1995.
14. U.S. Coast Guard NPRM Evaluation for "Small Passenger Vessel Inspection and Certification", 1989.
15. U.S. Treasury Department "Merchant Fleet Statistics", 1940, 1945, 1950, 1955, 1960, & 1965.
16. Water Resources Support Center, U.S. Army Corps of Engineers "Waterborne Transportation Lines of the United States", 1990 & 1993.
17. Coppens et al "Development of a Level Change System for Federally Subsidized Vessels", Transport Canada publication #TP10376E, March 1990.
18. 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.
19. 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.