The Office of the Secretary of Transportation
Office of Environment, Energy and Safety
Environmental Engineering Division, DTS-72
Volpe National Transportation Systems Center
55 Broadway, Kendall Square, Cambridge, Massachusetts 02142
12 July 1996
1. Executive Summary
1.2 Access issues
.2 Dock and pier
1.3 Data issues
.1 Fleet societal costs
.2 Shore access societal costs
.3 Other cost bases
2.1 Government actions
2.2 Industry activities
2.3 The industry and ADA
.2 General considerations
3.3 Access solution sets
.2 Docks and piers
4. Vessel Onboard Access
4.1 Fleet population
.1 Approach to fleet characterization
.3 Fleet data
4.2 Access barriers
.1 Wheelchair access
.2 Sight- and hearing-impaired access
4.3 Constraints on solutions
.3 Space requirements
.4 Egress and evacuation
4.4 Access solutions
.1 Affected vessel population
.2 Description of access solutions
.3 Application to fleet population 4.5 Sample vessels
5. Vessel Access Costs
5.1 Fleet population projections
.1 Fleet replacement
.2 Fleet growth
.5 Installation schedules
5.2 New construction
.1 Unit costs
.2 Industry implementation cost
.1 Unit costs
.2 Industry implementation cost
5.4 Training costs
5.5 Fleet cost summary
6. Shore-vessel Transition Access
6.2 Physical barriers to access from land to vessel
6.3 Marine design requirements for access solutions
6.4 Classification of marine facilities
6.5 Proposed access solutions
.2 Proposed solutions
.3 Safety concerns
7. Shore-vessel transition Access costs
7.1 Unit incremental costs
.1 Unit component costs
.2 Unit solution costs
7.2 Industry implementation cost
.1 Sources of information
.2 Site surveys
.3 Development of baseline information
.4 Application of incremental costs to facilities
8. Cost Scenarios
9. Stability calculations
9.1 Assumptions and conditions
.1 Intact stability weather criterion
.2 Intact stability passenger crowding
.3 Damage stability
10. Additional Observations
.1 Increased business from persons with disabilities
.2 Insurance benefits
.3 Employee health benefits
10.2 Implementation issues
.1 Application of ADA precedents
10.3 Additional data needs
.1 Vessel population
.2 Dock and pier population
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|
|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 o f 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
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
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.
|All facilities, low|
|All facilities, high|
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
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.2.
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
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"
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
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
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
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 therefor 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:
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
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.
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.
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
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
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
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:
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:
|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:
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
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
*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:
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
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
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
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
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
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
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
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
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 pieces for safe evacuation
in an emergency.
4.4 ACCESS SOLUTIONS
The 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:
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:
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.
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:
Notes: 1) Elevators for ferries with separate vehicle and passenger
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
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
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.
|52' excursion boat|
|64' excursion boat|
|65' dinner boat|
|91' crew boat conv.|
|102' crew boat conv.|
|122' crew boat conv.|
|180' cruise boat|
|80' shuttle boat|
|100' crew boat conv.|
|105' dinner boat|
|106' dinner boat|
|183' dinner boat|
|192' excursion boat|
|200' excursion boat|
|80' paddle wheeler|
|198' casino boat|
|274' paddle wheeler|
|84' ferry, veh. dk. only|
|40' fishing boat|
|45' fishing boat|
|59' fishing boat|
|60' fishing boat|
5. VESSEL ACCESS COSTS
Fleet costs are developed in parallel for both new construction (5.2) and alterations (5.3) by the following steps:
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:
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
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.
Cost factors are calculated using Office of Management and Budget guidance11:
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
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.
Passenger vessels are assumed to undergo alteration of the primary
function area as follows, based upon evidence from interviews
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:
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
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.
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.
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
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
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.
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:
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.
"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:
|Other||1 @ $15K||1 @ $5K||2 @ $3.5K||1 @ $2.0K|
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.
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
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.
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
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