PUBLIC SUBMISSION

Docket: DOT-OS I:2007-2682
ADA - Passenger Vessels Comment On: DOT-OST-2007-26829-0 1 77 U.S. DOT/OST - Transpo(ation for Individuals With Disabilities: Passenger Vessels Document: DO'f-O.S l"-1007-26829-0 I 87 Lake Michigan Carferry
9

As of: lune I7, 2009

Trzcking No. 80523424
Comments Due: April23,
Late comments are

Submitter Information
Name: Robert Manglitz
Addrrcss:

701 Maritime
P.O. Box 708

Ludington, MI, 49431 Submitter's Repr€sentative: faurie B ialochowski Organization: Lake Michigan Carfeffy

General Comment
Aplil22,2008
Passenger Vessel Operational Requirements under the

ADA Act

Ladies and Gentlemen: Lake Michigan Carferry is a small business and a member ofthe Passenger Vessel Association. The following comments are in Iesponse to your effotls to impose operational requirements to all passenger vessels for the DOT ADA rule. Lake Michigan Car-ferry operates the s.S. Badger. The Badger was built in 195253 by the Christy Corporation in Sturgeon Bay, wI and put into service in March of 1953. Since 1992, the Badger has been in service transporting leisure travelers, their vehicles and commercial trucks between Ludington, MI and Manitowoc, WI Lake Michigan Carferry is a tearr ofdedicated people committed to expanding our I 00-year car ferry heritage by providing a unique travel experience enhanced by superior customer sewice. The Badger is a R€gistered State Historic Site in both Michigan and Wisconsin. The coal fir'ed steam engine propulsion system is designated a Mechanical Engineering Landmark by the National Sociery of Mechanical Engineers. The Badger is a continuation ofa vital maritime tradition, and we celebrate that heritage by offering a rare opportunity for our passengers to errjoy a litt le h istoq - and a lot of fun. Our sailing season is from mid-May to mid-October. At the peak of our season, we ernploy up to 23 0 employees, half of which hold positions on shore in Ludington and Wisconsin. Aside from approximately 25 employees that work through the winter in the corporate office or winter work aboard the Badger, the rest ofour employees are summer workers. Our sailing season fits so well with college and high school schedules, a large majority ofour employees are students between the ages of 18 and 22. The Badger transports approximately I 00,000 passengers, 30,000 autos and 1200

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commeraial trucks per season. The route from Ludington, MI to Manitowoc, 60 miles, approximately four hours en route. We have 50-60 crewmembers
aboard for each trip.

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Potential requiremeDt for training in ADA and accessibility. The crew ofthe Badger consists ofboth licensed and rated personnel, pursuant to the requirements of the Coast Guard. Outside of our Navigation and Engine crewmembers, all other employees do not attend formal courses fot maitime training. The students that are hired for the summet season have the most interaction with our passengers. We conduct mandatory safetytraining sessions each season for all crewmembers. CPR training is required for all crewmembers in a supervisory position. Customer Service training is required for all new hires. A formal ?ADA training course? with ceftification is not in keeping with our current schedule of training sessions. As a large majority of our employees are students, the longevity oftheir emplolment is, at the most, one or tu,o seasons. Due to scheduling restraints and the small window of opportunity of time that we have with our employees, additional training would create a hardship for our company and extra burden to the preparation ofour season. TTY aDd other Lrformation Serviaes The reseryation s,stem that we have does not currently provide this service. When a reseryationist receives a call from a hearing impaired customer, the customer will make the call using operator assistance. This allows the hearing impaired person to use a TTY phone on their end. This has proven to be a successful way of communicating with the hearing impaired customer and has never been a deteffent or a point ofconcern. Historic Vessels The S.S. Badger and her sister ship the S.S. Spartan were tlle last ? and largest ? coal fired, steam engine carferries bttilt in the U.S. The Badger being the only one ofthe two that is operational offers an authentic historical experience to our passengers. The engines are two Skinner Unaflow 4cylinder steam, rated 3,500 hp at 125 rpm. The boilers are four Foster-Wheeler ?Dt),pe?, burning domestic bituminous coal. The seryices and activities that are ot'fered on each voyage are unique to the history ofthe Badger and have grown to
be expected by each and every passenger. The proposed modifications would be ?unduly burdensome? and would ?require a fundamental alteration? to the natule ofthe services and activities that we provide. Should Company ADA Complaint Resolution Officials and Vessel ADA Complaint

Resolution Officials be mandatory? With everytrip across the lake, our passengers are handed a ?customer comment catd? and encouraged to comment on the services they received and suggestions they may have. We value what our passengers have to say and take stock in their suggestions. Complaints are handled in a tinrely manner by the Cruise Director that is on duty during that vo1,age. We believe that the perconal attention our passengers receive from the LMC staff is one ofthe many unique aspects of sailing on the Badger. Any questions or concerns regarding ADA issues would be handled by the personnel with the most knowledge on the subject. To date we have had very few, if any, ADA complaints. Propriety ofCrew Assistance in Boarding/Deboarding Our crewmembers are not only expected to assist passengers when necessary but they are encouraged to assess every situation for the possibility of slips, trips and falls whether the passenger is disabled ol not. We provide a chair-lift for passengers that are wheel-chair bound and we offer the chair-lift to any passenger who feels they are
unable to use the stairs to board the Badger. Thank you for this opportunity to participate and vo ice our opinions in this rulemal<ing process,

Respecttully, Bob Manglitz Don Clingan Plesident/CEO V.P. Marketing & Shore Customer Service

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