1 

### 600 Pax **Dinner Vessel**  **Case Study**  **(Private Entity)**

**June 25, 2013**



### Introduction The dinner boat was constructed in 2002 and carries a maximum of 600 passengers.

**Figure 1. Dinner Boat Profile**

**– Original Design**  The dinner boat has three passenger decks.

 Main Deck

– The main deck is approximately 4752 square feet and contains an enclosed dining area with dance floor. There is a serving pantry , bridal suite, and single

- user toilet room at the rear of the dining area. There are open deck areas at each en d of the vessel. There are two boarding gates at the front and rear on each side of the vessel. There is an exterior door at the front on one side of the vessel that leads from the open deck area to the dining area, and two exterior doors at the rear of t he vessel that lead from the open deck area to the dining area. The doors have 6 inch coamings that are required b y the US Coast Guard. There is a main interior stairway

in the rear centerline of the dining area, and exterior stairway s at the open deck a reas on each end of the vessel that connect to the second deck. There is a recessed swim platform at the rear of the vessel that is connected to the main deck b y two stairways.

**Figure 2. Main Deck**

**– Original Design** 2

 Second Deck

– The second deck is a pproximately 3465 square feet and contains an enclosed dining area. There are toilet rooms for men and women at the front of the dining area, and a bar/serving pantry wrapped around the main interior stairway at the rear of the dining area. There is a pi lot house and open deck area at the front of the vessel that is for employ ees onl y. There is an open deck area at the rear of the vessel with two exterior stairway s that connect to the third deck. There are two boarding gates at the rear on each side of the vessel. There are two doors at the front of the vessel: one leads from the top of the exterior stairway to the dining area; and the other leads from the dining area to the open deck area at the front of the vessel. There are two doors at the rear of the vessel that lead from the open deck area to the dining area. There are fire doors at the top of the main interior stairway . There are two exterior stairways at the rear open deck area that connect to the third deck.

**Figure 3. Second Deck**

**– Origin**  **al Design**

 Third Deck

– The third deck is approximately 1950 square feet and is entirely open.

**Figure 4. Third Deck**

**– Original Design**  The dinner boat has a lower deck that is for employ ees onl y and contains the engine room, galley , storeroom, and othe r equipment. There are stairway s leading from the galley to the main deck serving pantry and from the storeroom to the main deck dining area.3 **Figure 5. Lower Deck**

**– Original Design** 



### Methodology The Access Board contracted with a marine architect to review the original designs of the dinner boat and to identify passenger features that would not meet the draft accessibility guidelines. 1 The contractor proposed new designs for the passenger features that would meet the draft guidelines. The contractor chose designs that would have the lowest capital cost and still meet the functional demands of the vessel owner/operator. The contractor also examined the impact of the new designs on the vessel’s space, electrical power, fuel consumption, and stability

. The contractor did not evaluate boarding s ys tems for embarking and disembarking passengers from the vessel. The contractor prepared a report describing the new designs and their impacts on the vessel. The company that designed the dinner boat and the v essel owner/operator were given an opportunity to review and comment on the contractor’s report , but no response was provided

. The Access Board has updated the study to represent the requirements in the proposed passenger vessel accessibility guidelines. The 2005 costs recorded in the 2008 draft of the study (available on the Board’s website) that applied to the proposed guidelines were multiplied by 1.27 29 2 to produce 2011 values. The contractor involved in the initial draft of the study

was not involve d in the updates. The vessel cost approximately $4.5 million to construct in 2002. The contractor estimated the cost in 2005 dollars for constructing a new dinner boat based on the original designs, and a new dinner boat based on the new designs that wou ld meet the draft guidelines. The contractor used a parametric approach based on the contractor’s compan y data on passenger vessels to estimate the cost for constructing the new dinner boats. The cost estimates include labor hours, materials, a 15 percen t surcharge for materials, and a 10 percent contingency . The contractor estimated the cost for constructing a new dinner boat based on the original designs to be approximately $5.1 million , updated to $6.49 million in 2011

. The case study

estimates th e (updated) cost for constructing a new dinner boat based on

1 The contractor used the draft guidelines that the Access Board made available for public review in 2004. 69 FR 69244 (November 26, 2004). This report has been updated to reflect the proposed guidelines. 2 1.2728845384

new designs that would meet the proposed guidelines to be approximately $ 7.13 million. It is estimate d that the proposed guidelines would add $642, 2 00 to the (updated) construction costs of t he new vessel, or a 10 percent increase. The new designs proposed to meet the draft guidelines are discussed below , as updated to reflect the requirements of the proposed guidelines . The designs are identified as having significant impacts; incurring additional costs but not having significant impacts; or having minimal impacts. A design is identified as having a significant impact where the design would add more than 0.5 percent to vessel’s construction costs; would substantially

reduce the vessel’s usable space or necessitate an increase in the vessel’s size; or would present major operational issues. A design is identified as incurring an additional cost but not having a significant impact where a specific cost can be attributed to the design but i t does not meet the criteria for a significant impact. A design is identified as having a minimal impact where a specific cost cannot be attributed to the design and it will have little impact on new construction of the vessel.



### Designs That Have Signifi **cant Impacts**
**1. Accessible Route Between**  **Passenger Decks** The dinner boat has three passenger decks. The proposed guidelines require an accessible route to connect each passenger deck. V206.2.1. The guidelines permit vessels that are less than 10,000 I TC gross tons to use limited

- use/limited

- application (LULA) elevators to connect passenger decks. V206.6 Exception 2. LULA elevators are smaller and less expensive than standard size elevators. The dinner boat is less than 10,000 I TC gross tons, and the contractor proposed to use a LULA elevator to connect the three passenger decks. The contractor estimated the LULA elevator to cost $ 29 7 , 372

. The contractor proposed to locate the elevator adjacent to the interior stairway in the rear centerline of the dining areas. This location is in proximity to the general circulation path , and allows one side of the elevator shaft to share a steel bulkhead of the existing stair tower.

**Figure 6. Dinner Boat Profile**

**– New Design** 5

The elevator pit would be locat ed in the overhead of the engine room, in front of a major transverse watertight bulkhead. The elevator machinery would be located in a cage under the pit and not impact the space in the galley

. The contractor assumed that there is sufficient space withi n the engine room to fit the elevator machinery and that the elevator pit w ould not cause interference with running exhaust piping, ducting, or electrical cabling. 3 The contractor proposed to change the location of the door between the e ngine r oom and the galley

to the other side of the stairway leading from the lower deck to the main deck. The contractor assumed that the new door location w ould not adversel y impact the equipment arrangement in the galley

.

**Figure 7. Lower Deck** 

**– New Design**  On the m ain deck, the serving pantry counter on the side of the stairway where the elevator is located would be lost. The contractor proposed to increase the serving pantry counter on the other side of the stairway by moving the counter forward approximately 4 fe et in order to compensate for the loss of counter space due to the elevator. The case study estimates the additional counter space to cost $ 3,988

.

**Figure 8. Main Deck**

**– New Design** 

3 The company that designed the dinner boat commented that the size of the engine room should be increased due to the elevator pit and machinery.6

The elevator shaft would have minimal impact on sight lines for pa ssengers in the dining areas on the main and second decks. T he elevator shaft w ould create a substantial box on the third deck that would adversel y impact the appearance of the vessel and interfere with panoramic views. 4 The top of the elevator shaft is below the fixed portion of the vessel’s mast so the elevator shaft would not impact the air draft of the vessel.

**Figure 9. Third Deck**

**– New Design**  The elevator and new design of the toilet rooms on the second deck would reduce the usable space in the dining areas. The contractor proposed to lengthen the dinner boat b y four feet to retain the same square footage of usable space in the dining areas. The case study estimates the lengthening of the vessel to cost $ 204, 467 , plus $ 8,90 4 for additional gene rator capacit y. The costs for lengthening the vessel and the additional generator capacity are discussed below in “vessel space impacts” and in the following section. **2. Accessible Route to Swim Platform** The recessed swim platform at the rear of the m ain deck is used occasionally for boarding passengers. The proposed guidelines require an accessible route to connect passenger entry points and accessible passenger features within a deck. V206.2.2 and V206.4. The swim platform is approximately 30 inch es below the level of the main deck. The contractor noted that designing a ramp to connect the main deck and the swim platform would increase the length of the dinner boat b y approximately 7 feet, and would be excessive given the limited use of the swim p latform as a tender boarding platform

.

4 The company that designed the dinner boat commented that the elevator shaft on the third deck w ould have an extremely negative impact on the a ppearance of the vessel. The contractor responded that the visual impacts of the elevator shaft could be mitigated by paint, fairings or other designs. The third deck is 1950 square feet. The proposed guidelines permit a platform lift to be used to prov ide access to decks that are less than 3000 square feet. V206.7. 1 . A platform lift would not have the same adverse visual impact on the third deck as an elevator shaft. The contractor considered using an elevator to connect the main deck and second deck , and using a platform lift to connect the second deck and third deck. The contractor chose to connect all the passenger decks with an elevator because the marginal cost of extending the elevator from two to three decks was less than the cost of an elevat or and a platform lift.7

Since the contractor noted that the swim platform lift would be regularl y exposed to waves, the proposed guidelines allow a manuall y powered boarding lift to be used to connect the swim platform, at a cost 5 of $15,000. V206.7. 6 Exception. To provide space for the boarding lift in the new designs, t he designs eliminate one of the stairway s connecting the swim platform and the main deck, and move d the swim platform approximately

18 inches to one side of the vess el and approximately 6 inches forward in order to fit the boarding lift where the stairway was located. **3. Doors with Coamings 6** 
The dinner boat has three weather tight exterior doors on the main deck with 6 inch coamings that are required by the US Co ast Guard 7

. One door is at the front of the main deck, and two doors are at the rear of the main deck. The proposed guidelines require at least one accessible route to connect passenger entry points at both the front and rear of the main deck, and the di ning area . V206. 2

. 2 and V206.4

. Where doors on accessible routes are required to have coamings, the guidelines permit ramps to be used. 8 V404.2.5 .2 . The contractor proposed the following designs to meet the guidelines. See Figure 8 for the Main Deck

– New Design.

 Door at Front of Main Deck. The contractor proposed to use a 1:12 ramp on each side of the coaming (i.e., double ramp access) and an automatic door opener for the door at the front of the main deck. 9 V404.2.5.2. 2 . The contractor estimate d the double ramp access to cost $ 4, 673 and the automatic door opener to cost $ 13,80 6

.

 Door at Rear of Main Deck Near Toilet Room. The contractor proposed to use a 1:10 ramp 10 on the side of the coaming that faces the open deck area (i.e., single

5 The 2008 draft case study had a platform lift connecting the swim platform ($24,695 in 2005) . In the proposed guidelines, a new exception (V206.7.7 Exception) allows a manually powered boarding lift at this location. The update d case study assumes the work needed in the new designs to install a platform lift wo uld be the same w ork to install the boarding lift but at a reduced cost of $15,000.

6 The proposed guidelines require thresholds at doors w ithout coamings to be 1⁄2 inch h igh m aximum, beveled. V404.2.5.1. The case study assumes that this requirement would have minimal impact in new construction.

7 The doors have a 32 inch minimum clear opening in the original design and meet the clear w idth requirement of the proposed g uidelines. V404.2.3.

8 The proposed guidelines do not require landings at the tops of ramps at doors w ith coamings. V404.2.5.2 Exception 1.

9 The company that designed the dinner boat commented that ramps w ould add to the vessel’s tonnage. The c ontractor responded that the ramps can be designed so they are removable and not counted in tonnage.

10 The proposed guidelines would not allow a 1:10 slope at a door coaming where single ramp access is provided if the largest deck of a vessel is 3,000 s quare feet or greater (as in this dinner vessel). The case study has not been adjusted to reflect the outcomes of a 1:12 ramp but suspects the additional 12 inches of ram p length could be provided by moving the coaming door 12 inches toward the bow . This change in the8 ramp acc ess) and to raise the decking 6 inches on the other side of the coaming for the door at the rear of the main deck near the toilet room. V404.2.5.2. 1 . The raised decking would extend approximately 14 feet into the corridor adjacent to the toilet room and through the toilet room. The contractor proposed to use a 1:12 ramp at the end of the corridor where the raised decking transitions down to the dining area deck. The contractor estimated the single ramp access and raised decking for the door near the toi let room to cost $ 31,80 6

.

 Door at Rear of Main Deck Near Bridal Suite. Although the proposed guidelines do not require both exterior doors at the rear of the main deck to be accessible, the contractor proposed to use single ramp access and raised decking for the door near the bridal suite to make the vessel more functional. The raised decking would extend approximately 17 feet into corridor adjacent to bridal suite and through the bridal suite and serving pantry

. The contractor proposed to use a 1:12 ra mp at the end of the corridor where the raised decking transitions down to the dining area deck. The contractor estimated the single ramp access and raised decking for the door near the bridal suite to cost $ 39,2 30

. 

### Designs That Incur Additional Costs Bu **t Do Not Have Significant Impacts** 
**4 . Toilet Rooms on Second Deck** 
T he toilet room s on the second deck have four toilet compartments (stalls) in the women’s room, and three toilet compartment s and three urinals in the men’s room. The proposed guidelines require an accessible toilet compartment in each toilet room, and an accessible urinal in the men’s room. V213.2, V213.3, V213.3.1, and V213.3.3. The contractor proposed to increase the floor area of each toilet room by 27 square feet, increase the door width by 2 inches, and reconfigure the fixtures to meet the guidelines. The new design resulted in an increase in the number of toilet compartments in the women’s room from four to five, and a decrease in the number of urinals in the men’s room from thr ee to two. 11 The contractor estimated the new design to add $ 11,400 to the cost of the second deck toilet rooms.

new designs is assumed to produce insignificant cost increases beyond what is recorded in the study. 11 The proposed guidelines require an ambulatory accessible toilet compartment in toilet rooms with six or mo re fixtures. V213.3.1 and V604 .8.2. In the new design, neither the men’s room nor women’s room wo uld be required to have an ambulatory accessible toilet compartment because each toilet room has less than six fixtures.9 **Figure 10. Second Deck**

**– New Design**  **5 .**  **Emergency Communications** The dinner boat has a combined public address, entertainment, and emergen cy alarm sy stem

. 12 The proposed guidelines require an assistive listening sy stem because the public address s ys tem is used for entertainment. V219.2. 1. In addition, because public address s ys tem is assumed to be used to provide emergency information to p assengers, the proposed guidelines require that a vessel

- wide assistive listening sy stem be provided to serve passenger areas. V219.2.2. The case study estimates assistive listening s ys tems for all passenger areas on all three decks to cost 13 $ 9,800

. As the original vessel is reported to ha ve no audible general emergency alarm, visual alarms in passenger areas are not required in the new designs. V215.1. **6 . Signs**  The proposed guidelines require certain signs to have raised characters and braille, and/ or visual characters that meet minimum requirements. 14 V216 and V703. The contractor estimated signs meeting the proposed guidelines to cost $ 1,0 40

.



### Designs That Have Minimal Impacts

12 The draft case study noted the vessel had a general emergenc y alarm, but further discussion with the vessel designer indicated the vessel had no audible general emergency alarm. 13 The draft case study showed the 2005 cost as $4,349. Based on new inform ation for assessing assistive listening system (ALS) costs, th e cost was updated. As the original vessel spaces would probably be classified as assembly areas, the number of receivers, per V219.3, w ould be determined by the passenger capacity of the vessel which is 600. The ALS’s estimated cost is $9.800; it requi res 24 quality receivers with headseats/neckloops ($6,800), one FM transmitter with related support material ($1,400), and engineering, installation, and other expenses ($1,600). Maintenance of the system is estimated to be less than $120 per year. 14 Sig ns required to comply with the proposed guidelines include signs identifying permanent rooms and spaces, directional and information signs, and signs for means of escape. Where all the exterior doors are not accessible, the accessible doors are required t o be identified by the International Symbol of Accessibility, and the inaccessible doors are required to have directional signs indicating the location of the nearest accessible door.10

**7 . Accessible Means of Escape**  The proposed guidelines require the d inner boat to have at least two accessible means of escape (AMOE) from each passenger deck to an evacuation station based on US Coast Guard requirements for means of escape (MOE) . V207 .1. Two stair way s provide the MOE and connect the three decks

. The g uidelines permit MOE stairway s to be part of an AMOE , but do not establish any requirements for these stairway s. Advisory V207.1

. **8 . Toilet Room on Main Deck**  The proposed guidelines require the single

- user toilet room on the main deck to be accessi ble. V213.2. The toilet room meets the proposed guidelines except that the sink overlaps the clearance around the water closet. V604.3.1.2. The contractor proposed to locate the sink next to the door between the toilet room and the bridal suite to meet the proposed guidelines. 15 The contractor assumed that the design would have minimal impact on new construction. **9 . Maneuvering Clearances at Doors**  The proposed guidelines require maneuvering clearances at doors on onboard accessible routes and on acc essible means of escape. V206, Advisory V207.1, V402.1(b), and V404.2.4. The contractor proposed to change the location of several doors by 18 inches to 22 inches to meet the proposed guidelines. 16 The contractor assumed that the designs would have minim al impact on new construction. **10 . Bar Counter**  The proposed guidelines require a portion of the bar counter on the second deck to be lowered to 36 inches maximum. V227.3 and V904.4.1. The contractor assumed that lowering a portion of the bar counter w ould have minimal impact on new construction.


### Vessel Space Impacts The elevator and new design of the second deck toilet rooms would reduce the usable space in the dining areas. The contractor proposed to lengthen the hull of the dinner boat

15 The door betw een the toilet room and the bridal suite would not be r equired to meet the proposed guidelines because the rooms are connected by at least one accessible route and is not part of a required accessible means of escape . V206.2.2 and V206.5.2.

16 The contractor proposed to change the location of the two exter ior doors at the rear of the main deck; the doors to the bridal suite and the toilet room on the main deck; the door connecting the corridor outside the bridal suite and the dining area on the main deck; one exterior door at the rear of the second deck; an d the door at the exterior exit stairway at the front of the second deck.11

by two fra mes or four feet to retain the same square footage of usable space in the dining areas. The two frames would be added around the storeroom at approximately frames 24 to 26. The compan y that designed the dinner boat used a combination of tonnage frames be low the main deck and tonnage openings on the main deck to keep the vessel under 100 gross tons and subject to US Coast Guard regulation under 46 CFR Chapter 1, Subchapter K. The contractor proposed to introduce partial tonnage frames in the engine room a nd decrease the useable portion of the storeroom in order to keep the lengthened vessel under 100 gross tons. 17 The contactor also proposed to add a tonnage opening into the elevator trunk on the m ain d eck . T he elevator mechanism would have to be located so as to not interfere with the tonnage opening. Th e tonnage opening may severel y limit the selection of elevators. The contractor estimated the vessel lengthening (updated) costs as follows. 18
Hull and House Structure $ 69,459 Propulsion Machinery

Wirin g $ 1,204 Electrical S ys tem Wiring $ 5,623 Electronic Equipment Wiring $ 6,229 Auxiliary S ys tems (HVAC, Potable Water, Bilge Piping) $ 11,806

Outfitting & Furnishings $ 100,195 Deck Fittings & Deck Machinery $ 9,948 T otal $ 204,467



### Electrical Power, Fu **el Consumption, and Vessel Stability Impacts** The dinner boat has two diesel generators rated at 170kW each that are sized to handle the electrical load for the vessel. 19 The contractor calculated that the elevator, platform lift, and additional lighting a nd HVAC loads due to the lengthening of the vessel would require an increase in the generator capacit y to 190 kW. 20 The contractor estimated the

17 Without adjusting the tonnage frames, the lengthened vessel w ould be over 100 gross tons and w ould be subject to US Coast Guard regulation under 46 CFR Chapter 1, Subchapter H. The change in regulatory category would significantly increase the vessel’s capital and operating costs.

18 The company that designed the dinner boat commented that the engine room length should be increased by t wo feet. The contractor responded that th e engine room size can be increased in the new design and estimated that adding two feet to the length of the engine room wo uld cost $3,712 for additional structural fire insulation in the overhead of the engine room.

19 The vessel is not required to have an em ergency generator or final emergency power source under US Coast Guard regulations. 46 CFR 120.312.

20 The contractor assumed that the assistive listening systems would demand no more electricity than the existing public address system. The contra ctor also assumed that the main switchboard has sufficient capacity to handle the larger generators. The company that designed the dinner boat questioned the switchboard assumption. The contractor estimated that a switchboard w ith a higher capacity to c ost an12

increased generator capacity to cost $ 8,903

. A ssum ing the vessel operates 2,000 hours per year , the contractor calculated the annual fuel consumption for the 190 kW generator s w ould be approximately

30,600 gallons, an increase of approximately 3,200 gallons from the 170 kW units in the original design. The dinner boat is propelled by two diesel engines rated at 440 hp . Each engine driv es a fixed

- pitch propeller via a reduction gear. The contractor calculated that the elevator, platform lift, and lengthening of the vessel would add approximately 9 long tons to the weight of the vessel for a full load displacemen t of 394 long tons. The contractor calculated that the power demand based on vessel resistance would decease by 0.7 percent from 273 hp to 271 hp per propeller; and the power demand based on maneuvering would increase b y 2.3 percent from 774 hp to 792 hp per propeller. The contractor determined that the existing engines have ample power to handle this slight change in demand. A ssum ing the vessel operates 2,000 hours per ye ar at an average engine load factor of 60 percent, the contractor calculated that t he annual fuel consumption for the engines w ould be approximately 55,300 gallons. Depending on the ratio of time maneuvering to time underway at speed , the contractor calculated that the elevator, platform lift, and lengthening of the vessel would affect the annual fuel consumption by

- 387 gallons to +1,272 gallons. The dinner boat in original design is reported to have good margins for both intact and damaged stability , but is marginal for subdivision. The contractor noted that lengthening the hull at the aft part of the storeroom may cause the vessel to fail subdivision due to the increased volume of the storeroom if the watertight bulkhead at Frame 13 is damaged. The contractor noted that the problem could be corrected b y relocating the watertight b ulkhead at Frame 13, adding an additional watertight bulkhead, or increasing the hull depth by an additional 6 inches. The preferred solution would depend upon the actual shape of the floodable length curve. The contractor assumed that adjusting the bulk head location would have minimal impact on new construction.


### Summary The contractor estimated the cost for constructing a new dinner boat based on the original design to be approximately $5.1 million , updated to $6.49 million in 2011 . The contractor es timated the cost for constructing a new dinner boat based on a new design that would meet the proposed guidelines to be approximately $ 7.13 million. The case study estimates that the proposed guidelines would add about $642, 2 00 to the vessel’s (updated) c ons truction costs, or a 10 percent increase. 21 About 80 percent of the additional costs are attributed to the elevator and the lengthening of the vessel. The cost estimates are summarized below.
additional $2,500

21 The company that designed the dinner boat agreed that the draft guidelines w ould increase the vessel’s construction costs by 10 to 12 percent. The updated cost increases costs by 10 percent.13



### 600 Pax **Dinner Vessel**  2005 Estimate 2011 Estimate (rounde d) Construction Cost (original vessel) $5.1M $6.49M Protected Waiting Area (updated attachment) 7 00 Elevator & Additional Serving Pantry Counter 3

- deck LULA: $233,618 ($297,400 in 2011) serving pantry

counter: $3,133 236,751 301,40 0
Vessel Lengthening & Incr. Generator Capacit y 4 feet lengthening: $160,631 generating capacity : $6,995 167,626 213,400
Ramps, Raised Decking & Automatic Opener at Doors with Coamings (auto door: $1 3 ,8 00 in 2011 ) 70,323 89, 500 Access to Swim Platform revised 15,000 Second Deck Toilet Room Additional Space 8,982 11,400 Assistive L istening S ys tems revised 9,800 Signs 817 1,0 00 **Total (% increase) $513,543**  **(10.7%) $642,**  **2 00** 

**(9.9%)** Note: Unable to get ownership to review a nd comment on the report.



### Dinner **Vessel Case Study Attachment**  After the May

4, 2006, draft was completed, it was identified that the vessel was not protected b y an automatic sprinkler s ys tem. Therefore, the accessible means of escape (AMOE) requireme nts for the second deck stairs needed further evaluation. **Forward Exit Stair** ($ 700 In crease)

- The forward stair on the second deck to be part of the forward AMOE needs one 22 protected waiting area (PWA) having two clear deck spaces (CDS), one at least 30 by 48 inches and the other at least 30 by 60 inches . By moving the port side stair landing entry door aft, flipping the hinge and latch sides of the door, and the widening of the landing to hold the two CDS, the landing can contain a PWA . This increase in landing size would move the toilet rooms toward the starboard side, such that the starboard side entry to the toilet room is about 42 inches wide instead of 60 inches. Costs related to fire and smoke protection for the PWA (e.g., A

- 60 bulkheads) is est imated to increase the cost of the new vessel by $ 700 23

.
22 No door is provided for the stai r on the main deck and the bottom is open to the weather, so no PWA is expected even though (due to the main deck evacuation plan) an AMOE runs up the stair. Advisory V207.1. As the proposed rule has no non - pool stair requirements (excluding general prot ruding object re q uir e ment s in V204) , no adjustments to the stair is required in the ne w designs. 23 Estimate 11 feet of A

- 60 bulkhead needed at $60/linear foot ($605 in 2008 and $660 in 2011). According to the vessel designer, as the main deck has an inter nal area of refuge and the US Coast Guard does not require it to be equipped with a ventilation system to provide smoke projection, it is assumed the14

**Stern Exterior Stair** 24 (No I mpact)

- It is understood from the evacuation plan that the internal stair connecting the main and second decks is not required for escape purposes, as the stern stair satisfies the need for the stern area MOE . Therefore, the stern stair can be used as part of the second AMOE. Advisory V207.1. Excluding the protruding object provisions in V204, no requirements in the proposed guidelines appl y to these stairs.

Protected Waiting Area ( PWA ) on the second deck would also not need a ventilation system and the estimated ventilation cost in the 2008 draft is not included in the updated study. To remove the requirement for a PWA, the vessel would need to be protected by an automatic sprinkler system which is roughly estimated to cost $150,000 in 2008. 24 The stern stair ru ns parallel with the beam of the vessel and is betw een two stairs on the sides of the vessel which connect the second deck to the third (sun) deck.