Wayne C. Lamson

The Woods Hole, Martha’s Vineyard and Nantucket Steamship Authority (the “Steamship Authority”) is pleased to have the opportunity to submit comments in response to your Notice of Proposed Rulemaking on Passenger Weight and Inspected Vessel Stability Requirements. Background: The Woods Hole, Martha’s Vineyard and Nantucket Steamship Authority is a public instrumentality of the Commonwealth of Massachusetts that was created by Chapter 701 of the Acts of 1960 to provide for the adequate transportation of persons and necessaries of life for the islands of Martha’s Vineyard and Nantucket. In 2007, the Steamship Authority’s vessels carried 2,692,000 passengers, 453,000 automobiles and 146,000 trucks between the mainland of Massachusetts and the islands of Martha’s and Nantucket. The Steamship Authority operates without any public operating subsidies. Our cost of service is covered 100% by the rate and fares paid by the users of our ferry service and any operating deficits, in excess of a statutorily-required reserve fund, must be assessed against the local port communities in which we serve. The Steamship Authority operates 9 U.S. Coast Guard inspected vessels. The vessels’ sizes and classifications are as follows: Vessel Vessel Length (ft) Gross Tonnage Subchapter Designation Iyanough 154 98 K Island Home 255 1,567 H Martha’s Vineyard 230 1,297 H Eagle 230 276 H Nantucket 230 1,148 H Governor 242 678 H Katama 235 99 T & I Gay Head 235 99 T & I Sankaty 220 749 H & I Comments on Proposed Rulemaking: In general, the Steamship Authority supports the proposed use of the higher average passenger weight (185 lbs.) for purposes of calculating vessel stability requirements. We object, however, to the concept of automatic future weight changes based on a recalculation of weight by the Center for Disease Control. Any future changes should be based on a demonstration of need and adopted through the normal notice of proposed rulemaking and comment process. The proposed implementation schedule for the revalidation of stability calculations for existing vessels within 12 months is unrealistic and is not feasible given the number of submission that would be required and the resources that are currently allocated to the Marine Safety Center. The process should be phased in over a longer period of time. No one has demonstrated that the previous average passenger weight led to any passenger ferry casualty. A five year period seems reasonable. The proposed revalidation of the vessel’s lightship characteristics every 10 years appears to be somewhat burdensome and unnecessary. Revalidation with calculations should be reserved for those situations involving cause. With a fleet of nine vessels, the Steamship Authority overhaul schedule does not allow sufficient time to perform this requirement and wait for the results from the Marine Safety Center. The proposed procedure would have to be submitted to the Marine Safety office for their approval. Review of the test results and comments from the Marine Safety Center could take another 8-12 weeks, at a minimum. These recalculations by a Naval Architect are expensive to conduct. Our records indicate that a dead weight survey would cost approximately $5,000 and an inclining would cost $12,000-15,000. It is respectfully requested that the U.S. Coast Guard issue a supplementary notice of proposed rulemaking that addresses the public comments that have been submitted. Thank you for the opportunity to submit comments in response to this proposed rulemaking. Wayne C. Lamson General Manager Woods Hole, Martha’s Vineyard and Nantucket Steamship Authority P.O. Box 284 Woods Hole, MA 02543