RAY BLOOMER: Thank you, my name is Ray Bloomer, I'm with the National Center of Accessibility as Director of Education and Technical Assistance. And I also want to thank both the members of the Board and staff members of the U.S. Access Board for including Indianapolis as a place for public comment.
I was also a member of the regulatory negotiating committee that worked toward the development of the report that was the basis for the notice of proposed rule in the outdoor developed area and in general I do support most of the guidelines as they stand right now. There are a few areas that do give me a little concern and a couple areas that I think we need clarification on. The first is the one that we just concluded some discussion on or at least added some discussion on and that is the area of the beach, since-inch height on the exemption, where it meets an existing, on an existing beach. And I also believe that that is way too low as far as having that as a threshold to exempt people from making that area accessible.
One of the reasons that I say that is that, first of all, I was also on the subcommittee on beaches that worked toward the development of those recommendations to the full committee. I don't recall at any time that that six-inch requirement was discussed or forwarded to the full committee. I also, since I saw that come up, when that information first came out, I did ask a few other members of the committee if they also remember that issue or discussion. The discussion was something that most people do recall, but not that six-inch height guideline. There was the concern, as Peggy just pointed out, that some areas where you have very high board walks may be a little bit more expensive for some areas to provide accessibility.
I wanted to get a little bit of a comparison. I went to the Department of Transportation's guidelines for curbs. Their curb guidelines vary from four-inch to nine inches. At any intersection, that can occur four to eight times. Between the half mile marks for reach access, that could occur six times, therefore eight times at each intersection. That idea of that being onerous, I don't believe that it is. I believe that for most beaches except for the few that have extremely high access points I think it's critical to provide criteria to enable at least once every half mile, people with disabilities, to access a beach, participate with their family. When you look at beaches on a Sunday afternoon, where the weather is good, up and down all of our coastlines, you see people, blanket-to-blanket-to-blanket and that's just too many people participating in that activity not to have it fully accessible to people with disabilities unless there is extremes that we're working with.
Couple other areas that I'm a little bit concerned with and that is while I fully support [---] the issues relating to trails, where I have concerns is where we have issues that are coming in combination. I know that we will have areas and the committee was very willing to extend what we are traditionally familiar with in typical areas of grades relative to the current built environment, the 1:12 that was discussed earlier. We know there will be areas in the outdoors where the expectation will be a little bit steeper. We looked at various areas and determined that there are going to be some areas for very short distance where you can go as much as a one in -- or 12%. That 12% is as much as 50% higher than what you typically find in the built environment. We also stated that you can have a cross slope on a continuous basis that can go as much as 1:20 which is 250% higher than what we're used to.
We also indicated that there's going to be some areas where you can have an obstacle that can go up as high as two inches. We did -- and where my concern is, we didn't indicate the fact that these things can occur simultaneously and that is a great concern. That while you're going up as much as a 1:8 area you also can be going up a 1:20 cross slope and as many obstacles that may occur because we never did define there should be a limitation on those. I recommend we revisit that at some point and add some clarification there.
I also think some clarification needs to be added into the areas where we might be considering things such as the outdoor recreation access routes, when they can occur, exactly what they are. I know they're supposed to be connectors but I think there are areas where more clarity needs to be added so that people know exactly what they are and when they can occur. I think in adding that clarity and also to trails, in terms of its definition, because an awful lot of people lay that term on a trail as being almost anything that they decide is no longer -- or just a plain old route. Many park areas applied the term "trail" to almost any pathway leading to various destination points.
Some of those destination points are absolutely critical that access be provided and it be provided in a way that most people may be accustomed to. And I think some definitions that would be a little clearer would be beneficial.
Where I say that clarity needs to be added, I think possibly using some examples such as a trail is not, and provide some examples of what a trail may not be, an access route, an access recreation route is not and provide some definitions as to what -- or examples, rather, as to what they may not be. I think that would also help people to understand what some of those concepts are.
Another issue that I think is really important, and that is we have recognized the fact that you're not going to get slip resistance in the outdoor areas. So we did not include that as part of the report to the Access Board from the regulatory negotiating committee. However, in trying to define what is firm and stable, I think the values there either need to be changed or we need to come up with a measuring device that is simple to attain, something that the majority of maintenance staffs or trail builders can easily get and not have something that is either expensive or complicated given the number of resource management individuals that are either part of trail maintenance or trail building or trail designing that need to be able to define and measure firm and stable and all different outdoor areas.
I also wish to add support to the fact that in the picnic areas and the scoping for the number of accessible picnic tables, I do wholeheartedly support the fact that at least 50% should be provided, and I also lend support to the fact that if it's able to be pushed to 100% I do support that. I believe if a person with a mobility device can get to a picnic area there shouldn't be a challenge with at least having the ability to participate in the activity of having a picnic.
Two other areas: That is clarity as to what is a picnic area. There are many, many different areas of parks where picnic tables are scattered off the side of the road. The only access to them is the fact that people can drive their automobile right up to the picnic table. And where they're scattered like that, I think that we really need to be able to define what amount and where accessibility requirements for those picnic tables should be and if they are all over the place and there's not a defined picnic area then I think all of those areas or all of those picnic tables should also be considered accessible. Thank you.
PHILIP PEARCE [BOARD MEMBER]: I'm not going to let you loose.
RAY BLOOMER: I didn't think I'd get away too easily.
PHILIP PEARCE: Because I want to raise the questions with you and obviously you have a disability that -- a sight disability. And so I want to particularly ask you questions about the signage issue. And I know that you didn't address that but I would like to hear what you think are ways that signage can be used to provide access and guidelines, way-finding, possibly, for persons who are blind or have low vision.
RAY BLOOMER: I think in the area of signage -- and this is a very, very difficult question -- but I think in areas of signage, first of all, if there's trail head information, I think it's important that at the trail head, information that may be provided such as maps, that type of information, can be and should be easily provided in a tactile way so that a person can get an understanding using a combination of scale and other tactile information, how long the trail is, and also what direction the trail may go in. It's going to be very difficult to provide extensive information that may be needed for an individual with a mobility impairment because using Braille, Braille will use up an extensive amount of physical space on a sign. I think the practicality of that, to have that extensive information, is probably not feasible. But limited information in Braille I think can be provided, such as the fact that the trail is a certain degree of length or possibly some -- some areas where a trail may have certain heights that might be difficult. But I think, in general, it's going to be really difficult for extensive information on a trail head sign.
I also believe the trail head sign is probably the only place where it's practical for a sign to be available for individuals who have visible impairments. The reason why is the sign has to be easily found. And if you don't have it in a consistent way, then that's not going to be reasonable.
One of the reasons why the signage requirements in the built environment is where rooms are permanent and they're always at a particular height on a particular side of the door, et cetera, and that's going to be very, very difficult to achieve in an outdoor setting.
PHILIP PEARCE: OK, I appreciate that. Let me ask you about nontraditional signs. And things like infrared signage and information systems and that sort of thing. Do you think that that is something that technology improves, that that could help resolve some of those issues? And I'm equally as concerned about not just information at the trail head but way-finding once you're on the trail. Are those opportunities or options that maybe will be available and how effective do you think they'll be?
RAY BLOOMER: I think that they can be extremely effective. And where I find they would be most effective, I believe, is going to be where you've got trails of an interpretive nature where the development of those trails has already been established. Where you've got way-side information, I think with GPS information and technologies that are being developed I think it's almost -- it's probably more difficult to keep up with the degree of technology right now. And I think it's almost difficult to say that it is infeasible. I think right now almost anything is truly becoming feasible. And I do believe that with the combination of GPS technology, infrared, and other technologies right now, I think it's getting very close to an individual being able to completely and independently utilize many trails, if designed well.
PHILIP PEARCE: OK. And as management of those trails, do you think that maintaining and durability of those systems is becoming something that would be as feasible as well?
RAY BLOOMER: I think it's working in that direction right now, yes, I do.
PHILIP PEARCE: OK, all right, I appreciate that. Thank you very much, Ray.
RAY BLOOMER: Thank you.