Public Comments To Access Board

The US Access Board is accepting public comments on the draft guidelines for passenger vessels (cruise ships) through March 28, 2005. The mailing address for public comments is:

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

E-mail comments can also be submitted to pvag@access-board.gov. Comments sent by e-mail will be considered only if they contain the full name and address of the sender in the text.

Listed are below my comments, submitted on December 16, 2004.

Comments on Draft Guidelines for Passenger Vessels

As the editor of Emerging Horizons, I have a great interest in seeing access guidelines for passenger vessels drafted and implemented. I thank the Access Board for their work and progress on this matter. I have followed the progress of this project from day one and after reading the draft guidelines I think the Access Board did an excellent job of taking the PVAAC comments under consideration.

That said, there is one glaring omission in the draft guidelines that I must address on behalf of my readers. Although the guidelines are suppose to be based on the ADAAG, they do not contain a provision similar to ADAAG 224.1.2. In land-based facilities this provision requires 32-inch entry doorway clearances on all guestrooms. I feel this is an essential part of the ADAAG and I strongly encourage the Access Board to incorporate a similar provision in the final guidelines for passenger vessels.

This provision not only supports integration and visitability, but in the long run it will also make more accessible staterooms available to passengers who require access modifications beyond wide doorways (such as adapted bathrooms).

Emerging Horizons focuses on travel for slow walkers and wheelchair-users. In short, we cover accessible travel options. I get a lot of mail from travelers, and over the past five years cruising has greatly increased in popularity among our readers. Indeed, it is a very popular vacation option for wheelchair-users ,and with the aging of baby boomers I predict this popularity will only increase.

More and more slow walkers are also choosing to cruise these days. Unlike full time wheelchair-users, these passengers can walk a few steps but are unable to negotiate longer distances. In many cases these passengers use scooters and they don’t require any access modifications to their staterooms beyond wide entry doors. Herein lies the problem with cruise ships as they are configured today.

Because most standard (non-accessible) staterooms lack wide doorways, these slow-walker passengers have to reserve an accessible stateroom just to get their scooters inside the door. Scooters cannot be left in hallways due to safety regulations.

This results in accessible staterooms being used by passengers who don’t need most of the access modifications, thus making them unavailable to passengers who do need them. With accessible staterooms being in such short supply (and the demand continuing to increase), it only makes sense to save these adapted staterooms for passengers who physically need them. And in the long run, the cruise lines would be better equipped to do this if all staterooms had wide doorways. If that was the case then slow walkers could simply choose any stateroom, which would in turn free up accessible staterooms for passengers who require more substantial access modifications. Including a provision similar to ADAAG 224.1.2 in the final guidelines will make this scenario a possibility.

Of course the industry argument against widening all stateroom doorways is that it will force the cruise lines to decrease the number of staterooms on their vessels and in turn decrease their profitability. It is my contention that with proper design on newly constructed ships, the cruise lines would not have to loose any staterooms. In fact, designers may be able to incorporate this essential access feature into every stateroom by simply relocating the closets.

Yes, initially it would require the cruise industry to adapt a different general design for their vessels, but in this day and age of universal design all businesses are learning to adapt and make those changes. Why should the cruise industry be exempt?

In fact the cruise lines are quite capable of making changes to their designs. For example, in the past five years the number of balcony cabins (a feature that takes up more space) has greatly increased; as has the inclusion of features previously unheard of on the high seas, such as rock climbing walls and ice skating rinks. Indeed, change is possible.

In closing, I urge the Access Board to facilitate this change and make cruise ships more accessible to everyone by including a provision similar to ADAAG 224.1.2 in the final regulations for passenger vessels. It’s truly a change that needs to be made.