JOANNE CODY: All right. Thank you, my name is Joanne Cody, I am a senior landscape architect at the Denver Service Center for the National Park Service.
My comments are based on using these guidelines for the past seven years as our Park Service standard, and since 2003, I’ve been the accessibility coordinator in the quality assurance group at the Denver Service Center, the DSC. In this capacity, I review all the projects that the DSC design and construction group administer, which are basically all the major projects in the National Park Service.
So we see a whole lot of this type of area every day. I come into work and I automatically put up the Access Board website because I use it every day, so… I get a lot of questions.
We are very excited to see the process the progress on the guidelines and we need them badly because right now people are using ABAS and judging outdoor environments based on ABAS and so it gets that difficulty between accessibility and environment is one that we struggle with every day.
So we really we need these, and, for the most part, they have worked very well for us. My comments are based on areas that I get questions on often.
The first one I’m trying to base them off the Access Board’s questions that they put in the “Federal Register.”
On the question 1, about the approach, I think the exceptions is a great way to go. It really helps organizations to balance access with environment. What I’ve seen, though, is that the exceptions are only for trails, is the way that we keep reading it, and we really need to get those exceptions for parking areas, at trailheads. If you have an overlook or a pullout and you’re going up a 6% road and you’ve got your 6% or 5% parking space, you can’t get it to 2%.
So we need to get some exceptions there, which are not covered in the guidelines at all.
And as much consistency this is from me as a reviewer. As much consistency with the layout of ABAS that we can provide with these guidelines, that would be really helpful. One of the areas that is the exceptions are in the technical part and not in the scoping part. It would be great to get the exceptions up into the scoping part like ABAS is.
We the NPS we also use feature based decision making to determine the level of access. If an element is one of the key interpretive elements at a site, the level of access to that feature, such as Old Faithful or the general Sherman tree, petrified tree or any world’s largest anything, we’re going to try and get as close to ABAS as possible.
However, if there’s four mountain lakes and they all have similar views and they’re in close proximity to each other, not all the trails will need to meet ABAS or the outdoor developed guidelines if they if the exceptions apply to those trails.
We don’t want to see heroic efforts in our parks to provide similar types of experience.
Another question I get all the time is on the term “feasible.” I receive many calls and questions on feasibility in trail construction. The dictionary definition is “capable of being done, effected, or accomplished. A feasible plan.” To designers that call me, they’re saying “does that mean that it’s possible to do?” Which is how we look at “feasible.”
With construction practices today, an accessible trail is possible in most situations, but not reasonable or environmentally sound. The definition of “reasonable” is agreeable, to reason, sound judgment, logical, not excessive.
We feel strongly that “reasonable” needs to get included in your definition for in the exception.
A comment on Question number 3 on the international symbol. We agree that the symbol should not be used for these areas unless those areas comply with ABAS. That that’s a should be a marker for people to know that that’s the level of surface quality they can expect.
Suggest using that symbol maybe on a steep triangular base to show that it’s steeper than the ABAS or ADA standard, allows and needs to be included at the parking spaces, again, in those areas.
Many of our outdoor recreation areas need accessible parking that doesn’t comply with ABAS standards, such as a boat launch ramps. You’ll see parking on the ramp itself. Those ramps are steep for a purpose. But we have elderly Fishermen and Fishermen with disabilities that want to park at the bottom of the ramp where their boat is. We don’t have a sign at this point that we can give them to say, “This is an accessible parking space, outdoor accessible parking space for you.” That’s going to be way over the guidelines.
And again, many trailheads and overlooks have the same thing where they’re in a steep section that we can’t flatten to meet the ABAS guidelines.
A question on number 4 and 5. Question 4 and 5. The beach access routes. That they should also have the same exceptions as the trails.
Also, we need to get a definition of a beach. Does it it’s is it every shoreline? Is it because specifically in the west, you have a lot of steep clips. Same on the east coast. Where access is going to be extremely difficult to the trail standards.
A comment on Question number 9 on firm and stable. We feel strongly that a beach should be linked to standard established construction testing methods such as compaction, testing that people are already doing. And it also really needs to get linked to that half inch maximum vertical change between materials, when you get to your ABAS or your when you get to different surfaces. That’s one that I use a lot with during construction is: Can you maintain that half inch change between materials?
Any material that can’t meet the compaction and vertical change requirements shouldn’t be used.
And materials such as binders typically function at the end of construction when the firmness and stability testing is done, but how is the material functioning after use and after seasonal change?
Shorter trails. I think in the guidelines, it says that they can be moderately firm and moderately stable. We feel pretty strongly that those trails should be the most accessible trails that we have, because they’re the ones that are available to the most visitors. So if you have a feature that’s a short distance away, that trail should be at a higher level of stability and firmness than a lower one, so you can get most visitors to that point.
A comment on Question 10. Increasing the number of accessible elements like the picnic tables. This one is one that we’ve actually changed on our website because we get the comment so often that the requirement for 20%, which is 50% of the 40% of picnic tables to be on the outdoor accessible route, what that does because the outdoor accessible route has to connect from the picnic table to the restroom to the parking spaces, so in effect, it raises the scoping for parking spaces to 20% as well, when you start connecting the dots.
So and that gets really excessive in our steeper parks, to be able to meet that requirement.
The ABAS scoping for parking is about 4 is 4 to 8%, so going up to 20% for picnic areas is very difficult for us.
And then if you use the same parking spaces, the same accessible spaces for several tables, then that means that you have to have your access aisle connect to your accessible route connect to your outdoor accessible route connect to…
So anyway you have to connect the dots back to the beginning. And if the road is used as part of your travel lane, in ABAS it’s required that you are outside the travel lane for that accessible route so you need to widen the roads, which is not something we like to see in an outdoor environment.
And again, this difficulty has come up so often that we changed the scoping requirements for picnic tables and associated elements to be the same as parking spaces and transient lodging, with the additional requirements for each type of space provided, such as a single table, family grouping, group area, and also dispersion requirements. So that really helps with scoping. That’s one reason why I have the website up so often is because there are so many different scoping tables and so many different situations, it’s very difficult. So the more that the board can streamline scoping, but add in those requirement for each type of space and also dispersion requirements, I think that will make it easier for us to scope, but also get more of the types of areas that we want.
PHILIP PEARCE (BOARD MEMBER): You’ll need to go ahead and wrap up.
JOANNE CODY: I’m sorry.
PHILIP PEARCE: Your time’s about up.
JOANNE CODY: Oh, no! Construction tolerances. Oh, I’ve got to do this one. All right. Construction tolerances are based on the construction material and not the location. The slope requirements for outdoor areas need to be relaxed for outdoor developed areas. The same slopes given for trails should be used for the trailhead parking area, picnic areas, beach access routes, everything that’s in the guidelines need to have those same slopes.
And what we’ve done at the Park Service is to say that we’re not going to do it’s not construction tolerances, but we have design maximums, so if you have an 8.33% maximum for a ramp that’s a constructed maximum. That’s where the construction tolerances come into play, and what you need to do is to give a design maximum. What we’ve done is 8% for ramps, 4.75% for walks, and 1.8% for cross slope. That’s where that’s what you need to do, and not do construction tolerances, because the industry doesn’t understand that. We need to build it into the design maximums.
And I will send off the rest of my comments for you, and look really forward to seeing this in print. We really need it. Thank you. Can we come back up afterwards if there’s more time?
PHILIP PEARCE: Yeah. Sure.
[Additional remarks made after all registered speakers concluded their testimony:]
JOANNE CODY: Thanks. I just want to Jean Cody again, and I just wanted to cover just a couple of more issues that we see very often.
One is that we’ve added standard contractor quality control specification to our standard specifications that we give out to our con to our A&Es to work with and to our contractors and what this does is that it requires testing and inspections just like every other inspection that the contractor has to do.
But for accessibility as well. So getting that somehow advisory or something so that we get that disconnect between design and construction closed.
I’ve given that, so you guys have a copy of that as well.
The other thing is the smart level. The smart tool. And I don’t know how many of you own one. I’ve got three that I give to parks. It’s the tool that everybody is using to see if we’re complying or not with ABAS, and I know that you guys went to Sprague Lake, I think, yesterday, and I took my kids, my smart level tool handlers with me, up there to Rocky Mountain, and even Sprague Lake, the accessible parking there, which looks very flat, is over 2%. And I take I don’t take just one smart level. I take two.
So that again, that tolerance and what we need to do in the outdoor environment is really important, to make sure that it’s buildable out there.
And as far as the smart tool, there needs to be someplace in the guidelines, I hope, that recommends a standard for how slopes are measured by people, because we’ve had in our specification, we require a 24 inch smart tool. We’ve had some complaints from people that are out well, not complaints from parks, but people are out checking the slopes with a 12 inch or just the electronic portion of the smart tool, and with those short levels you can’t get an accurate reading and so you’re getting areas that are out of compliance, we’re getting complaints for it, we’re having to go out and check it. So getting some kind of standard into these guidelines is going to be really important for us to be able to meet the guidelines.
Comment 14 on should elements be located on inaccessible trails be accessible.
It goes back to talking about the picnic tables and the access around them. It’s I think it’s great to show an accessible table, but a part of that is that you have to provide the 3 feet around that table for maneuvering space so it’s not just the table that’s accessible but it’s also the space around the table that becomes excessive, I think, on steep areas.
A comment on T211, overlooks and viewing areas. Overlooks are typically pull offs on roads and many are steeper than the 2% that is allowed for parking. The width of the ABAS requires is 13 feet which in a lot of winding roads, 13 feet is pretty wide to make a pull off. So getting some of those exceptions, again, available for pull offs, overlooks, to everything in there so that we can provide an example, in going to the sun road in glacier, there is a comfort station that there’s no way we can get it’s at 5% and they wanted to have the shuttle bus stop there for and for visitors to use the restroom, but there’s no way for us to get them there by ABAS or by the these standards and so we said, “We’ve got to build it someplace else” so they have to make a new restroom because it’s at 5% and not at 2%, so we just need to get some of those exceptions in there.
The 80 inch overhead clearance, there’s many areas at Sequoia I’ve got a photograph here that shows a log, a tunnel log that you go through that’s got a 6 foot 6 inch clearance and not 80 inches, and my question was: I don’t I don’t know, and I haven’t been able to tell people that ask me, “What does it mean for making a barrier to make people aware?” What we’ve done here is to change the trail surface, but I don’t know if that qualifies as a barrier or not, to change from trail surface to a boardwalk with a handrail so you know that something’s coming up.
The other comments I have were on the benches. That a lot of times we have historic benches that need to be included in an exception as well. Where you have, you know, Sequoia half log. And there’s also the requirement for the bench backs that a lot of trail benches are half logs that sit in a view space, so if you have a back on those benches, then you’re blocking the view for someone in a wheelchair. So getting that exception in there as well.
That covers all my comments. I thank you again for letting me come back up.