1 

### 120 Pax **Small Cruise Ship Case**  **Study (Private Entity)**  **June 25, 2013** 

### Introduction Th e small cruise ship was built in the late 19 80s and carries about 1 20 passengers in 60 passenger guest rooms
. T he vessel has an overall length of about 302 feet and breadth of about 50 feet , and has six decks . D ecks two through six are passenger decks. With a draft of about 14 feet, the vessel travels to ports and areas of the world not navigable to larger vessels. Decks two through six are entry decks.

**Figure 1**  **. Outboard Profile -**  **Original Design**

 Deck 1

– The first deck is open only to crew members.

 Deck 2

– The second deck ( main deck) is approximately 302 feet long and 50 feet wide. Eleven staterooms are provided in the forward half of the deck, and a galley and restaurant is provided in the after half. Near the middle of the stateroom area, a stair tower connects decks one through six. Adjacent to the stair tower is the vessel’s hospital. Near the bow, an enclosed stair connects an op en bow area on the third deck. Between the galley and stateroom area, an elevator lobb y contains two multi

- user toilet rooms (one male and one female), and a stair connects deck two through six. The one elevator also connects decks two through six. From the restaurant, two aft exterior exit doors with 24 inch high coamings lead to an exterior stair which connects the third deck, and the doors also lead to the tender loading platform. The tender loading platform is about 24 to 30 inches below the level o f second d eck and is connected b y a short stair to the main level of the deck

. As the exit doors are for emergency use, the stair to the third deck is used by passengers when tenders are being loaded and unloaded.

**Figure 2**  **. Second**  **Deck**

**– Original Des**  **ign**2

 Deck 3

– The third deck is approximately 302 feet long and 50 feet wide. In the forward half of the deck, 19 state rooms are provided. Toward the bow, an enclosed stair connects the second deck and an open stair connects the fourth deck. These stai rs are only used b y passengers in emergencies. A third stair connects the enclosed crew area o n the second deck at the bow

. Near the middle of the stateroom area, a stair tower connects decks one through six

. Aft of the stateroom area, an elevator lobb y with two multi

- user toilet rooms (one male and one female ) and stair separate the staterooms from the lecture lounge near the stern. From the elevator lobb y, through two exterior doors with 11 inch high coamings, two open walkway s (one of each outboard s ide of the lounge) connect the lobby with the stern area which contains storage space for five inflatable 10

- passenger tenders . Also, from each walkway , an adjustable stair /gangway can deploy to connect a portable tender boarding platform located at the l evel of the second deck. At the after end of the lounge , two emergency doors (one on each side of the lounge) connect the open walkway s. At the forward end of the lounge, a curving stair connects the club /bar on the fourth deck. Near the stern area of the third deck, two open stairs (one on each side of the deck) connect the fourth deck , and a third open stair connects the second deck.

**Figure 3**  **. Third**  **Deck**

**– Original Design** 

 Deck 4

– The fourth deck is approximately 234 feet long and 50 feet wide. In the forward half of the deck , 15 state rooms are provided . An exterior walkway (jogging track) encircles the deck. At the bow, an open stair (used b y passenger s in emergencies) connects the third deck and near the middle of the stateroom area a stair tower connects decks one through six. An exterior door connects the stair tower to the exterior walkway

. Aft of the stateroom area, an elevator lobb y contains a stair that connects decks two through six, two single leaf doors (one on each side of the ves sel) connect the open walkway and two double leaf doors in series connect the club area located toward the stern. In the aft area of the club, a library is provided, and two doors (one on each side) connect the open walkway . A bar is provided in the club and a curving stair connects the lecture lounge on the third deck. At the stern, two open stairs (one on each side) connect the third deck and another open stair connects the Jacuzzi at the stern area of the fifth deck.3 **Figure 4**  **. Fourth**  **Deck**

**– Origin**  **al Design**

 Deck 5

– The fifth deck is approximately 218 feet long and 46 feet wide. At the bow, the pilot house is located, followed by officer cabins. Near the middle of the deck, eight staterooms with balconies are provided. Between the officer cabins and staterooms, a stair tower connects decks one through six. Aft of the stateroom area, a small elevator lobby contains two multi

- user toilet rooms (one male and one female), a stair which connects decks two through six , and one door connects a short ex terior walkway on the starboard side of the vessel . From the lobb y, an aft door accesses a passageway running past a small gy

m (on the port side) to the stern area. The stern area contains a buffet and an open deck area, about half covered b y an awning. At the aft end of this area, a Jacuzzi and open stair to the fourth deck is provided.

**Figure 5**  **. Fifth**  **Deck**

**– Original Design** 

 Deck 6

– The sixth deck is approximately 165 feet long and 45 feet wide. At the bow end, a large stateroom “owner’s suite” with a forward facing balcon y is provided. After entering the owner’ s suite, two steps connect the level of the suite. Aft of this stateroom, on the port side, a (narrow ) stair tower connects decks one through six. Aft of this stair, six staterooms with balconies are provided. Aft of this stateroom area, a small elevator lobby is provided which contains a stair that connects decks two through six. Adjacent to4

the elevator lobb y, the hair dresser’s space is located. All other spaces on this deck are no t open to passengers and principally contain air conditioning equipment.

**Figure 6**  **. Sixth**  **Deck**

**– Original Design** 



### M **ethodology** In providing estimate s on the cost s of implementing ( in new construction situations ) the provisions of the passenger vessel accessibility guidelines , vessels selected for case studies needed to be of recent construction

. Since newer vessels incorporate more access features as part of industry

practices, such vessel s provide a clearer picture o f the impacts the guidelines would have on current n ew construction practices. Because the number of existing newer small cruise ships is low and the willingness of vessel ownership to participate in this study is even low er , it was found necessary to use a small cruise ship built in the late 19 80s. Although the vessel is a foreign flagged vessel, the case study evaluated the impacts also based on the vessel being a US flagged vessel subject to international requirements. This study

was first made available on the Board’s website in 20 08 and was originall y based on the requirements in the 2008 draft guidelines. The Access Board has updated the study to represent the requirements in the proposed passenger vessel accessibility guidelines. The costs recorded in the 2008 draft of the study ( that applied to provisions in the proposed guidelines ) were multiplied by 1. 08 59 1 to produce 2011 values. In some places, cost ranges provided in the 2008 study are now based on average costs and have been rounded. The updates have not been reviewed b y the vessel representative. Since the vessel was designed and constructed before the Americans with Disabilities Act (ADA) went into effect, there was concern that if the original designs of this vessel were used in the case study, the guidelines would p roduce greater impact than if the cruise ship had been constructed in the 2000s. However, maybe because the vessel was constructed for a clientele which expected more luxury and space , many of the provided features are at least consistent with current pra ctices. Nevertheless, in three places (number of mobility guest

1 1.085857424 and results have been rounded.5

rooms, number with balconies, and public toilet rooms), the cruise representative believe s the features did not represent current practices and the applicable impacts were adjusted to reflect outcomes modified by current practice s. To determine the impact , the anal ys is went through three steps : Step 1

- A representative of the Access Board reviewed the original general arrangement drawings of the vessel with a representative 2 of the cruise compan y to identify passenger features that would not meet the draft passenger vessel accessibility guidelines 3

. Step 2

- T he cruise representative proposed new designs compl yi ng with the guidelines

. However , the designs only showed how the impacted f eatures were changed and the effect on surrounding spaces , but the surrounding spaces themselves were not in most cases further adjusted (for example, the enlarged elevator overlaps the adjacent stair, but the stair was not repositioned). In most situatio ns, the adjustment of bulkheads (walls) to provide necessary clearances for access were determined to not increase the cost of a new vessel, but did create noteworth y spac e (and operational) impacts summarized below and resolved in Step 3

. The issue numbe rs below correspond to the issue s ( and actions ) discussed in more detail in the section titled “Impacts and Other Outcomes”. The Board has provided update notes to reflect changes based on the proposed guidelines.



### S **pac e** **/Operational Impacts S**  **ummary**

 **1 .**  **G uest Rooms** 
- Provid ed three guest rooms equipped with mobility features, and provided balconies at 11 more guest rooms on the fourth deck

. o Outcome : Reduced the interior size by about 25 square feet (SQFT) ( about 10 percent reduction) for each of the three adjacent non

- accessible guest rooms , and removed a portion of external walkway (jogging track) which encircles the fourth deck to provide the 11 balconies. o Update Note : The proposed guidelines would only require three guest rooms to be equipped with mobi lity features. V224.2 Exception. A reduction in impacts on the new designs could not be determined due to this change . However, it is assumed for the updated study that the space savings regarding the number of mobility accessible guest rooms balances o ff the increased space needs required in the ship’s hospital (see issue 2 below). Therefore, no modification was made to the updated cost estimates.

 **2 . Hospital** 

- In crease d the footprint due to larger bath room and clearances at a bed.

2 Although the report notes decisions made by the cruise representative, it should be noted that the Access Board hired a consultant (acceptable to the cruise representative) to provide most impact information (including cost estimates) which was used by the cruise representative in the case study decision making process. 3 The draft guidelines, as am ended by Board action at the 2007 and April 2008 meetings. The first public version was based on the requirements in the 2008 draft passenger vessel accessibility guidelines (dated June 26, 2008) , and reflected 2008 costs

. The Access Board has updated th is study to reflect the proposed guidelines and 2011 costs.6 o Outcome : Occup ied about 110 SQFT of two adjacent officer cabins which have a total area of about 270 SQFT. o Update Correction : The proposed guideline s (and 2008 draft guideline s ) have no specific scoping for beds in medical care facilities, so the “general access” requi rement applies which means all bed in accessible spaces of medical care facilities must be accessible. V201.1. As only one patient room is provided, it therefore must be accessible in the new designs, and all beds in it must also be accessible. Itis no t known how much additional space would be needed for the hospital to provide more clear deck spaces at a second bed on both sides , but it is assume in the updated case study that an y increase in space needs would balance off the space savings mentioned ab ove (issue #1) due to the reduction in the number of mobility

accessible guest rooms.  **3 .**  **Accessible means of escape (AMOE)**

- Spac e impacts occurred generally in providing a second AMOE from spaces required to be accessible

. o Outcome : Discussed in issue s #4 and #5 below.  **4 . Doors (High Thresholds)** 

- Ramped 24 inch high threshold (coaming) at restaurant rear exit door to provide second AMOE out of the restaurant

. Also ramped 11 inch high threshold at lecture lounge rear /side exit door to provide an onboard accessible route to the exterior areas of the third deck and a second AMOE. o Outcome : In the 1700 SQFT restaurant, a switchback ramp structure reduced the space by

about 160 SQFT ( 9.4 percent reduction) and caused the loss of three tables with a total o f 12 seats

. In the 110 seat , 1800 SQFT, lecture lounge, a ramp structure reduced the lounge b y about 90 SQFT (a 5 percent reduction) and caused the loss of eight seats, and created minor external appearance issues due to the raising of the exterior walkway and associated guardrails. o Update Note : The proposed guidelines allow protected waiting areas to substitute for a ramping structure bridging a door coaming. Advisory V207.1

. As the vessel owner could not be contacted to determine the feasibility of us ing the alternative to the ramping structure, no changes have been made regarding impacts identified at this door in the new designs.  **5 . Doors (Maneuvering Clearances)** 

- Provided maneuvering clearances at public doors which were part of an onboard accessible route or (principall y at stair tower doors) part of an AMOE. Three groups of doors in series were further separated. o Outcome : In general, increased the size of the center stair tower which impacted the layout of the hospital and other adjacent spaces and the size of the second deck bow stair enclosure which impacted entries to adjacent officer cabins

. The changes for doors in series impacted adjacent spaces and some entries to adjacent cabins/guest rooms.  **6 .**  **Elevator Enlargement**
- Increase d the foot print of the elevator. o Outcome : Reduced adjacent space, principall y the adjacent stair and lobb y area by about 10 S QFT on each passenger deck (50 SQFT total) to provide a larger elevator

.  **7. Tender Boarding Platform Access**

– Providing a platform lift connection from the third deck. o Outcome : The platform lift structure coming down from the third deck and the platform lift occup yi ng a portion of the tender boarding platform interferes with7 mooring and tender operations . In addition, the lift location on the third deck occupied space used to store inflatable tenders

. Step 3

- F rom a review of the spac e impacts , the cruise representative provided an estimate on how much the size of the original vessel must be increased to restore the spac e characteristics to that of the original vessel. Also, the cruise representatives provided estimates on applicable cost increases and comments on other outcomes

. Enlarged Vessel (Step 3 Results)

- T he cruise representative estimated that the original cruise ship would cost approximately $ 60 million to $ 70 million to construct in 200 8 , updated by

the Access Board to $70.58 million in 2011

. For a vessel enlarged to restore spac e characteristics , the cruise representative estimated that the new enlarged vessel would have to be 31 0 feet long, an eight f oot increase

. This increase in size would add $2 ,117,400 to the vessel’s (updated) construction cost. In addition, the enlarged elevator ($ 2,700 ), assistive listening s ys tem ($ 4,400 ), two ramp structures ($ 41,200 ), visible alarms ($ 48,900 ), and platform lift from the third deck to the tender boarding platform ($ 27,100 ) increased costs . Therefore, the case study estimated the cost of the vessel would increase b y $ 2.4 million , or an increase of approximately 3.2 percent. Be low, the case study

provides more details on the impacts and other outcomes

.8 

### Impacts and **Other Outcomes**  **1. Guest**  **R ooms**  **(State Rooms/Cabins)** The cruise ship has 60 passenger guest rooms
. N o rooms were designated as “ADA” guest rooms . The 2008 dra ft guidelines require d that four passenger guest rooms be equipped with mobility features (mobility guest rooms) and at least one be equipped with a roll

- in shower. V224.2. The guidelines require the mobility guest rooms 4 to be dispersed among the types (e.g., rooms with balconies) of guest rooms provided. V224.5. Update Note : The proposed guidelines would only require three guest rooms to be equipped with mobility

features. V224.2 Exception. A reduction in impacts on the new designs could not be d etermined due to this change

. However, it is assumed for the updated study that the space savings regarding the number of mobility accessible guest rooms balances off the increased space needs required in the ship’s hospital (see issue 2 below). Therefor e, no modification was made to the updated cost estimates. The remainder of the issue write up reflects the outcomes from the 2008 draft study which are the same outcomes due to the proposed guidelines

. As the cruise representative believes that at least one ADA mobility

guest room would have been provided based on current industry practices ( if the vessel was constructed in the earl y 2000s ) , the impact evaluation is based on the need to provide three additional ADA guest rooms, one with a roll

- in shower

. Another industry

practice was raised concern ing the number of guest rooms with balconies. Currently 15 guest rooms (on the fifth and sixth decks) have balconies , but industry practice would have much more

. T he case study calculated its impacts assuming 11 of the 15 guest room s on the fourth deck have balcon ies and the critical exterior jogging track which encircles the deck would be provided elsewhere in the enlarged version of the vessel (Step 3) , probably

on a seventh deck. This increased the number of balconies by 1 1 which

4 The proposed guidelines V224.4 would also require cruise ships with 51 to 75 guest rooms to have seven guest room s equipped with communications features (communications guest rooms). Per V224.5 , one communications guest room is required to be located in one mobility guest room. The other six communications guest rooms are not permitted to be placed in the “required” mobility guest rooms. Although these six guest rooms are not required to be equipped with any mobility features, such as clearances at doors, water closets, lavatories and beds, the rooms would still have to meet the protruding object requirements in V204. The case study assumes that to provide seven communications guest rooms, the impact would have an insignificant increase on the cost of a new enlarged vessel (Step 3).9

provide s a total of 26 guest rooms with balconies. Balconies were not provided on the port side aft of the center stair tower because this portion of the jogging track is part of a means of ( emergency) escape to the stern of the vessel. The cruise representative proposed in Step 2 to provide one mobility guest room with a balcon y on decks four through six (for a total of three guest rooms)

. The fourth mobility guest room required b y the proposed guidelines is assumed in this case study to already

exist on deck two or three

. Deck four is proposed to have the guest room with a roll

- in shower, and decks five and six will have transfer showers (36 inches b y 36 inches). In making the three bath rooms comply with the proposed gu idelines, the size of the bath rooms increased from around 32 square feet to around 52 square feet for the transfer shower bath rooms (62 percent increase) and around 57 square feet for the roll

- in shower bath room (78 percent increase)

. Combined with n eeds for maneuvering clearances at the mobility guest room entry doors (which moved the room closet forward) and keeping the amenities and spac e needs the same as other similar guest rooms, the increase in bath room size necessitated over a 10 percent incr ease in the interior area of the guest room s .

**Figure 8**  **. New Bath Room Layouts**

**– Transfer Shower and Roll**  **- in Shower**  **5** Th ese action s are estimated in S tep 2 , for each of the three mobility guest room s , to reduce the size of one adjacent guest room by an average of about 25 square feet 6

. The use of drainage s ys tems at the three balcony doors is discussed below, in the door threshold section (issue # 4 below )

.

5 The plumbing chase was widened to support the shorter grab bar (see V608.3.2 Exception). 6 The case study did not evaluate if furniture layouts were impacted in the mobility guest rooms and corrections may require additional square footage from adjacent guest rooms and are assumed resolved in Step 3.10

**2 .**  **Hospital** The cruise ship has a small hospital with one patient sleeping room containing one bunk bed and one single bed. A bath room with a tub serves the patient sleeping room. The hospital also has an examination room with a portable examination table and a small waiting room. The hospital area wraps around a stair tower which connects d ecks one through six. Officer cabins are located forward of th e hospital and passenger state rooms are located aft and on the starboard side. The vessel is required to have three beds should passengers need isolation due to infectious diseases. The prop osed guidelines require that one bed have a clear deck space on both sides (36 inches wide) and a turning space be provided in the room. V223, V805.2, and V805.3. In addition, the bath room (and tub) must be accessible. V805.4. Update Correction : Th e proposed guideline s (and 2008 draft guideline s ) have no specific s c oping for beds in medical care facilities , so the “ general access” requirement applies which means all bed s in accessible spaces of medical care facilities must be accessible. V201.1 . A s only one patient room is provided , it therefore must be accessible in the new designs, and all beds in it must also be accessible. It is not known how much additional space would be needed for the hospital to provide more clear deck spaces at a second b ed on both sides , but it is assume in the updated case study that an y increase in space needs would balance off the space savings mentioned above (issue #1) due to the reduction in the number of mobility accessible guest rooms. Except for the bed discussi on, the remainder of the issue write up reflects the outcomes from the 2008 draft study which are the same outcomes due to the proposed guidelines. The double

- leaf doors which connect the outside passageway to the waiting room, to the exam room, to the sl eeping room, have a clear opening of about 48 inch es wide . The active leaf of each door has a clear opening of about 30 inches and the inactive leaf a clear opening of about 18 inches. The door to the bath room has a clear opening of about 27 inches. Th e proposed guidelines require all four doors to be accessible and have a clear opening of at least 32 inches at the active leafs (plus have maneuvering clearances on both sides). V206.5, V404.2.2, V404.2.3, and V404.2.4. The cruise representative propos ed in the new designs to have the hospital comply with the guidelines. T his action is estimated in Step 2 to cause the loss of about 40 square feet from one officer cabin (26 percent reduction) as shown below in the f igure . The majority

of the increase in the size of the hospital was due to the sleeping room needing clear deck space s (36 inches b y 48 inches) on both sides of the b ed s and the enlargement of the bath room.11

**Figure 9**  **. Hospital Im**  **pact**

**– Original Designs**  **and New Designs (stair unchanged)**  However, because the adjacent stair needed to be adjusted to provide a maneuvering clearance on the pull side of the entry door, the stair tower had to be lengthened b y about 20 inches. This action no longer allowed the bath room to be placed on the po rt side of the stair (as shown above) which required the cruise representative to propose a new hospital layout (see f

igure 10 ) . This new layout, in Step 2, caused the loss of about 110 square feet from two adjacent office cabins which have a total area o f about 270 square feet **Figure 10. Hospital Impact** (40 percent reduction) . As the side of the **New Design and New Stair Layout** vessel curves, the bath room could not be **(bed impact incorrect** 7 **)** positioned adjacent to the port side bulkhead (wall ). **3. Accessible Means of Escape** The cruise ship is subject to means of escape requirements from the International Convention of Safet y of Life at Sea (SOLAS) and , for purposes of this case study , US Coast Guard (USCG) regulations. In general, these requirements mandate at least two means of escape (MOE) paths from each passenger deck to the primary area of refuge (mustering station) in the third deck lecture lounge and to the secondary area of refuge at the open stern area on the fourth deck. From these two locations, two MOE paths are required to the primary life boat embarkation area at the side exterior walkway s located near the stern of the fourth deck and

7 Figure 10 is from the 2008 draft study and does not correctly show the clear deck space requirement for both beds. It only shows it for the non

- bunk bed.12

to the secondary

embarkation area at the side exterior walkway s near the stern of the fifth deck. Stairs are the components in the MOE paths which connect the decks. The proposed guidelines require that two accessible means of escape (AMOE) also connect the areas of refuge and life boat embarkation areas. V207. 1. The proposed guidelines allo w stairs to be components in an AMOE path. Advisory V207.1

. This means the two MOE stair towers are part of the AMOE from each passenger deck , since the vessel representative did not want to use the one elevator in place of one stair tower
. Because thi s vessel is protected by an automatic sprinkler sy stem compl yi ng with SOLAS, protected waiting areas are not expected at the stairs

. Advisory V207.1

. Although the proposed guidelines do not require changes to be made to the stair s , the door way s to the e xit stair tower s that are part of an AMOE are expected to be accessible. Advisory V207.1

. The AMOE impacts principally relate to door threshold s and maneuvering clearance issues and are discussed below in more detail

. **4. Doors -**  **High Thresholds** The cruise ship operates in international waters and, for purposes of this case study , is also subject to USCG requirements. Therefore under the International Convention of L oad Lines and USCG requirements, certain exterior doors must have coamings (e.g., high thresholds). The proposed guidelines require doors which are part of an onboard accessible route or part of an AMOE to have conforming (beveled) thresholds 1⁄2 inch high maximum. V206.5 and V404.2.5. However, where doors are required to have coamings, the guidelines allows higher thresholds for the coamings if ramps are provided. V404.2.5 Exception and V404.2.5 .2 Door Coamings

- Coamings are onl y required on decks two and three. To meet the requirements of the proposed guidelines, the cruise repres entative proposed the following actions.13

 Deck 2

- Two aft emergency exit doors from the restaurant to the stern area have 24 inch high coamings (thresholds). The cruise representative proposed to add a 41 foot long (including three landings) s witchback ramp to the starboard side exit door to provide a second AMOE from the restaurant to the base of the exterior stair connecting the third deck 8 , the path of the AMOE

. A 24 inch high platform which is at the height of the coaming would also be included at the base of the stair

. InStep 2, this action is estimated to require the removal of three tables and a total of 12 seats in the restaurant

. The ramp structure occupies about 160 square feet of the 1700 square foot restaurant (a 9.4 percent reduction). Access to the tender boarding platform is discussed below (issue #7). The ramp structure to the exit door is estimated to increase the cost to construct the enlarged new vessel to the new designs (Step 3) b y $ 14,100

.

**Figure 11**  **. 2**  **nd Deck**  **- Restaurant**  **Ramp to External Stair**  Update Note : The proposed guidelines allow a protected waiting area to be substituted for the ramping structure bridging a door coaming. Advisory V207.1 . As the vessel owner could not be contacted to determine the feasibility of using the alternative to the ramping structure, no changes have been made regarding impacts identified at this door in the new designs.

8 A platform lift could not be used as part of an AMOE from the rear of the restaurant because the AMOE runs first up to the third deck and does not run directly to the tender boarding platform. Therefore, V206.7. 6 cannot be used.14

 Deck 3

- On each side, toward the after end of the lounge, an emergency exit door connects the side walkways which lea d to two exterior stairs (one o n each side of the vessel) connecting the fourth deck. The cruise representative proposes to a dd an 11 foot long ramp and two five foot long landings to the port side exit door for the required second AMOE out of the lounge. In Step 2, this action would reduce the size of the 110 seat (1800 square foot) lounge by 90 square feet (a 5 percent reduction) and reduce seating by eight seats to a total of 102 seats. Also, this action would require the port side external walkway to be raised b y about 11 inches to provide a platform (with a grating) outside the door with ramps at each end. The guardrail would also be raised along this part of the walkway and would create a minor appearance issue. Forward of the lounge, the elevator lobby has two exterior doors with 11 inch coamings. T hese doors are not required to be ramped , since the ramped lounge exit door provides access to the external area s on that deck 9

. This action is estimated to increase the cost of the enlarged new vesse l by $ 27,100 . A majority of this cost increase was due to work on the external walkway

.

**Figure 12**  **. 3**  **rd Deck**  **- Lecture Lounge** 

 Vertical Clearance On Ramps

- As the distance between the surface of the second deck and third deck, and the surface of the th ird deck and fourth deck, is over 105 inches, both decks have sufficient vertical clearance available to ensure the ramp surfaces have at least 80 inches of head clearance. In providing this head clearance, Step 2 would require some overhead space removed to provide the necessary head clearance at the top of the ramps. Step 3 results do factor in the rerouting of ducting or other features in the overhead to other locations.

9 The cruise representative proposed to not limit the ramped exit door to only emergency use but would use it as part of the onboard accessible route connecting the interior areas of the third deck to the exterior areas. Therefore, an on

board accessible route complying with V206.3 connects the lobby to the exterior areas of the deck and the lobby exterior doors are not required to be accessible.15

Drainage

- Coamings are not required on decks four through six, but the cruise representative was concerned about water from rain, sea spray and storm waves entering the exterior doors (including balcon y doors) with low thresholds due to ship movements and creating maintenance and safety problems inside the vessel. To address this c oncern, the cruise representative proposed in the new designs to add drainage s ys tems to the outside of the exterior doors which are required to be accessible on these decks and also to have thresholds which do not exceed a height of 1⁄2 inch beveled. These actions are estimated to have an insignificant impact on the cost of an enlarged new vessel (Step 3) and do not create head clearance issues on the decks below the drainage sy stems
. **5 . Doors** 

**– Clear Widths and Maneuvering Clearances**  The passageway s are at least 36 inches wide and have overheads which are 82 inches high with doors having 78.5 inch vertical clearances. Public doors along the passageway s have at least 32 inch clear openings

. However, many doors which would be part of an accessible route to public spaces or are part of an AMOE do not have sufficient maneuvering clearances, and some passageway doors are in series with other doors (which may onl y be fire doors held open b y magnets) and may not have sufficient space between the in

series d oors. The proposed guidelines require that each door used as part of a required onboard accessible route or an AMOE be conforming. V206.5, Advisory V207.1 , and V4 02. 1 (b) . Complying manual doors must have maneuvering clearances and compl y with the door s in series provision. V404.2.4 and V404.2.6. The cruise representative proposed in the new designs to provide the necessary maneuvering clearances at the public doors which created minor spac e impacts on adjacent spaces in Step 2

. However , the doors in the center stair tower (see Figure 10) created the greatest difficulty as maneuvering clearances were not provided on the side of the doors inside the tower. To provide these clearances, the tower needed to be widened b y a few inches on the fourth, fi fth and sixth decks, and increased in depth by about 20 inches on the second and third decks. In Step 2, the case study recognizes that additional refinement in the stair tower layout may

be necessary

to ensure16

clearances are provided and are factored int o the Step 3 results

. Providing maneuvering clearances at the stair enclosure at the forward end of the second deck also significantl y impacted surrounding spaces in Step 2, as the stair enclosure had to be enlarged which blocked entry

to adjacent crew ca

bins. At the forward end of the elevator lobb y, on the second through fourth decks and sixth deck, doors in series were proposed to be further separated in Step 2. At these locations, light weight lobby doors (with no latches which swing in both directio ns) separate the lobb ies from the forward passageway s . Pass these doors, toward the bow, magnetically held open fire doors ( more than 36 inches wide) are provided. Separating the doors to provide 48 inches between the lobb y doors and the swing of the fire doors had significant impacts on the adjacent spaces in Step 2, as the new location of the fire doors blocked the entry to spaces on one side of the passageway s. Maneuvering clearances however, created m inor spac e impacts in adjacent guest rooms and cre w cabins. On the sixth deck, also, the series door s to the hair dressers room w ere replaced with one door. **6 .**  **Elevator** A small elevator is provided which serves all f ive passenger decks (decks two through six) with a travel distance of about 36 feet

. The elevator car size is estimated to be 5 3 inches in depth and 45 inches wide

. In this new construction situation, two options were evaluated. Either use two limited

use/limited

- a

pplication elevator s (LULA 10 ) or one standard elevator to connect decks two through six. Although the guidelines recommend that elevators compl y with ASME A17.1 , the case study assumes the US Coast Guard would require ASME use in US Flag vessels

. Therefore, a LULA is restricted by ASME to a vertical travel distance of 25 fe et, thereby requiring that two LULAs be provided to connect the 36 feet travel distance between the five decks

. ASME does not restrict a standard elevator to a 25 feet maximum travel distance. The guidelines allow standard elevator s to use a number of di fferent dimensional sizes that include a minimum size of 60 inches b y 60 inches, and 80 inch depth b y 54 inch width. V206.6 and V407.4.1. The LULA is allowed to be smaller (e.g., 54 inches by 42 inches). V206.6 Exception 2 and V408.4.1. The cruise representative proposed in the new designs to use a standard elevator which is 60 inches by 60 inches to connect decks two through six . This action i n Step 2 would cause the footprint of the elevator to increase by 10 square feet an d overlap the adjacent st air and lobb y area b y l ess than a foot . In Step 3, the stair would have to be moved outside the footprint of the new elevator. The larger elevator is estimated to increase the cost of the enlarged new vessel by $ 2,700

. **7 .**  **Tender Boarding Platform**

10 As the vessel is assumed to be less than 10,000 ITC gross tons, use of a limited

- use/limit ed

- application elevator (LULA) is allowed. V206.6 Exception 2. The The US Coast Guard informally communicated to the Board that they would interpret ASME A17.1 as not prohibiting shipboard elevators from being LULAs.17

At the stern of the second deck a tender boarding platform is provided. The platform is about 24 to 30 inches below the main level of the second deck. A small stair of fi ve or more steps connect s these two levels. As discussed above, o n the second deck leve l, two exterior door s with 24 inch high required coamings connect the stern area with the restaurant. As the doors are for emergency

use, passengers embarking or disembarking the tenders use the exterior stair which connects the second deck stern area with the third deck. The proposed guidelines require that an onboard accessible route connect the boarding platform (which functions as an entry point). V206.4. The guidelines allow a platform lift to be used to connect the boarding platform. V20 6

. 7. 6

. As a platform lift would be exposed to waves, the guidelines also allows use of a manually powered boarding lift to connect the boarding platform. V206.7. 6 Exception. The cruise representative evaluated three options in providing access to the tender bo arding platform. All options will experience maintenance difficulties due to potential storm wave actions in following seas at the exposed stern location and create complications and obstructions for crew in operating the tender boarding platform and oper ating mooring equipment and running mooring lines

. Option 1 ( 54 In ch High Platform L ift)

– A hydraulicall y operated platform lift (36 inches by 60 inches), approached from the side, would connect an onboard accessible route by an elevated walkway to the restaurant’s 24 inch high coaming door at the base of the stair to the third deck

. This option is estimated to increase the cost of the enlarged new vessel (Step 3) by $ 13,000 to $ 23,900 11 . As the 24 inch high raised walkway cuts across the mooring equipm ent area and needs guardrails, it creates an obstruction to crew member use of the mooring equipment and some operations related to the tender boarding platform. Also, a second small stair would be needed for passengers (who would not be using the platfor m lift) to provide a path from the raised walkway down to **Figure 14. Tender Boarding Platform** the other small stair

. **Onboard Accessible Route** In an enlarged vessel design (Step 3), a grate d deck surface at the height of the 24 inch coaming s could be provided with raised mooring equipment. This would remove the need for the raised walkway and the 24 inch coaming s would still protect the doors to the restaurant, but the drop

- off to the tend er platform would increase and therefore increase the size of the small stair.

11 The platform lift uses the hydrauli c power unit used by the mooring equipment which reduces the potential cost of the platform lift which is estimated to be $5,000 to $15,000, and the elevated walk from the restaurant exit door is estimated to be around $7,000.18

Option 2 (1 44 Inch High Platform L ift)

– A h ydraulically operated platform lift would be provided running from the third deck down to the tender boarding platform. As the li ft platform and most of the operating mechanisms can be stored on the third deck, the platform lift has less exposure to waves , but the lift and the onboard accessible route occupies spaces on the third deck used for inflatable tender storage

. However, th e raised walkway ( elevated accessible route ) from the restaurant’s 24 inch high coaming door to the platform lift is not required and the elevated maneuvering clearance on the outside of the coaming door is less of an obstruction for crew members working i n the stern area of the second deck

. In this option, a lthough there is no platform lift shaft, the structure to support the lift ’ s decent from the third deck could interfere with mooring operations and some tender operations. This option is estimated to increase the cost of the enlarged new vessel (Step 3) by $ 27,100 with hydraulic power coming from the mooring equipment hydraulic power source

. Option 3 ( 54 Inch High Manually Powered Boarding Lift)

– A manually powered boarding lift would be used instead of the h ydraulically operated platform lift used in option 1. This option is estimated to increase the cost of the enlarged new vessel (Step 3) by $ 10,900 to $ 16,300 but (due to the raised walkway) create the same crew problems as noted in option 1

. Add ed to this expense is the cost of the raised walkway which is estimated to be $ 7,600 , for a total increase of $ 23,900 for this option

. In evaluating the options, the cruise representative selected option 2 , as the raised walkway created a greater obstruct ion to crew members

. **8. Public Toilet Room**  **s** The second, third and fifth decks each have two multi

- user toilet rooms (one male and one female) in the elevator lobby . The cruise representative believes that current industry practices would have produced clusters of two single

- user (uni

- sex) toilet rooms on these three decks with at least one on each deck being accessible. The proposed guidelines onl y require one toilet room in a cluster of two single user (uni

- sex) public toilet rooms to be conforming. V213.2 Exception 4. Therefore, as sufficient space is available to convert the multi

- user toilet rooms into two single

- user (uni

- sex) toilet rooms (with space to spare), one of which complies with the guidelines, this outcome is determined to have no imp act on the enlarged vessel designs (Step 3)

. **9 .**  **Assistive Listening System** The cruise ship has a lounge in which amplified lectures are held. The lounge has a seating capacity of 1 10 seats. Because the lecture lounge is an assembl y area where amplif ied communication is provided that is integral to the use of the space, the proposed guidelines require the lounge to be served b y a permanently installed assistive listening s ys tem (ALS)

. V219.2. 1. For a seating capacity of 1 10 seats, the guidelines require five receivers , two of which must be hearing aid compatible. V219.3. I t is estimated a permanently installed AL S19

and the necessary

number of receivers would increase the cost 12 of the enlarged new vessel by $ 4,400 (Step 3 )

. Since passengers are ass igned designed muster stations to go to in an emergency , a ship

- wide AL S is not required. V219.2.2 Exception. **10. General Alarm**  When getting underway , the crew i nstructs the passengers on what actions to automatically take when the general (audible) a larm sound s and passengers are given a practice alarm drill. Therefore, an audible emergency alarm is provided for passenger use and passengers know the meaning of the alarm and take immediate actions without crew direction. The proposed guidelines requi re in US flagged passenger vessels (which is applied to this ship) that vis ible notification appliances must be provided in public areas and guest rooms equipped with communication devices

. V215.1 and V224.4

. The cruise representative proposed to provi de in the new enlarged designs (Step 3) , visible alarms (strobes) complyingwith NFPA 72 (2007) in the public passenger spaces and in the seven guest rooms required to be equipped with communications features

. The vessel will take approximately 11 0 alarm points to cover the applicable spaces. The total cost of the visible alarm sy stem will be approximately

$ 43,400 to 54,300 (average of $48,900)

. There might be some cost savings if the visible alarms were integrated into the SOLAS audible general alarm sy stem 13 , but that would be hard to quantify. The visible alarm strobes themselves draw about 250 watts. Adding in the alarm control sy stem and monitoring, the total will be on the order of 500 to 1,000 watts. This power need is not estimated to impact the size of the emergency generator
. Providing visible alarms is estimated to be not significantly more expensive than just the audible alarms, nor is the power requirement significantly larger. **11. Storage Facilities**  No storage facilities are provided for passengers outside their guest rooms. L ife jacket storage lockers are intended to be used onl y b y crew members, in handing out life jackets to passengers, and are therefore not subject to the guidelines. V203.2.

12 The assistive listening sys tem (ALS) cost has been updated from the 2008 draft study. The ALS’s new estimated cost is $4,400; it requires 5 quality receivers with headsets/neckloops ($1,400), one FM transmitter with related support material ($1,400), and engineering, installation, and other expenses ($1,600).
13 US Coast Guard has indicated informally that in their reading of SOLAS, SOLAS would not prohibit a visible alarm system from being attached to the SOLAS required general alarm. In addition, the consultant hired to provide impact costs contacted the American Bureau of Shipping and they confirmed that in their opinion SOLAS would not prohibit a visible alarm system from being attached to the SOLAS required general alarm.20

**1 2**  **. Spa (Jacuzzi)** The ste rn area of the fifth deck contains one raised spa (Jacuzzi) . The proposed guidelines require either a means of entry which is a swimming pool lift, transfer walls, or transfer sy stem. V234.4. The cruise representative proposed in the new designs to prov ide a transfer **Figure 1 5**  **. Transfer Wall** wall (see figure 15 ) which is connected to an onboard accessible route . This action is estimated to have an in significant impact on the enlarged new vessel costs (Step 3)

. **1 3**  **. Electrical**  **Power, Fuel Consumpt**  **ion, and Vessel Stability Impacts**  The vessel has four 1 , 000 KW generators . Two run off the vessel’s propeller shaft and two run off motors. O ne 240 KW emergency generator is provided

. The larger elevator 14 , platform lift, and assistive listening s ys te m have an insignificant impact on the normal power supply of the vessel. For emergency

power, the larger elevator has a very similar power draw to the original elevator , within a few horsepower , and is estimated to have an insignificant impact on the eme rgency

power supply. I f the platform lift to the tender boarding platform was required to be part of an accessible means of escape, it would be expected to have emergency power . Advisory V207.1. Therefore, a separate h ydraulic power unit (HPU) on emerge ncy power would be needed (instead of using the larger mooring equipment HPU). This smaller HPU would likely

not drive the emergency

power over its current limit

. Inaddition, the 500 to 1,000 watts needed for the visible alarm s ys tem (issue #1 0 ) is esti mated to not have a significant impact on the capacity of the emergency

generator. **1 4**  **. Passenger Boarding System**  Passenger boarding s ys tems were not addressed in the case study

.

14 The consultant noted that the e levator is required t o have emergency power for half an hour to bring passengers to a deck. In practice, the elevator will be on emergency power.21 

### Summary The cruise representative estimated that the original cruise ship would cost approximately $ 60 million to $70 million to construct in 200 8, updated b y the Access Board to $70.58 million in 2011. For a vessel enlarged to restore spac e characteristics (Step 3), the cruise representative estimated that the new enlarged v essel would have to be 31 0 feet long, an eight foot increase. This increase in size would add $ 2,117,400 to the vessel’s (updated) construction cost. Plus, the following table summari z es other costs which would add $ 124,300 t o th e above amount. Therefor e, the case study estimated the cost of the vessel would increase b y $ 2. 2 million , or an increase of approximately 3.2 percent
. **120 Passenger Small Cruise Ship** 2008 Estimates 2011 Estimates (rounded/average) Construction Cost (original vessel) $60 M
- $70 M $70.58M 8 Foot Lengthening (due to space impacts) 1.8M

- 2.1M 2,117,400 Elevator Enlargement 2,500 2,700 (revised) Assistive L istening Sy stem revised 4,400 Restaurant Ramp Structure 13,000 14,100 Lecture Lounge Ramp and Raised Exterior Walkway 25,00 0 27,100 Platform L ift From Third Deck to Tender Boarding Platform 25,000 27,100 Visible Alarms 40,000

- 50,000 48,900

**Total (% increase) $1.91M**  **- $2.23M**  **(2.7% -**  **3.7%) $2,241,700**  **(3.2%)**22 

### Attachment

**– Other Case Study Notes**  **(from the 2008 draft which we**  **re retained)** 1) The cruise representative believe d that the cost increases due to the 2008 draft guidelines to provide a 310 foot vessel (Step 3) are not unreasonable. 2) The cruise representative does not see as unreasonable that four mobility guest rooms are required for a 60 guest room cruise ship (as required in the 2008 draft guidelines) . With the aging of the US population, market forces are creating a greater demand for mobility guest rooms. 3) The cruise representative sees no problem i n selli ng the four mobility guest rooms as many passengers seek larger accommodations even if they are not disabled.