State of California · The Resources Agency
DEPARTMENT OF PARKS AND RECREATION
ACQUISITION AND DEVELOPMENT DIVISION
Arnold Schwarzenegger, Governor
Ruth G. Coleman, Director
October 15, 2007
United States Access Board
Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street, NW. suite 1000
Washington, DC 20004–1111
Chief of Permits
Bay Conservation and Development Commission
50 California Street, Suite 2600
San Francisco, California 94111
Dear Access Board,
Attached are the California Department of Parks and Recreation comments on the Architectural Barriers Act (ABA) Accessibility Guidelines for Outdoor Developed Areas, June 20, 2007. We appreciate the opportunity to review and comment.
Associate Landscape Architect
Accessible Trails Coordinator
Suggestion: Requiring resting intervals at all significant changes in slope (e.g. between 1:12 max, 1:10 max and 1:8 max) in addition to requiring resting intervals at the maximum designated distance for each slope.
Section T203 states “When designed and constructed, an accessible trail is a trail that meets the technical provisions included within these proposed guidelines. It is also considered accessible where one of the exceptions within the technical provisions is used to address a specific condition. This is limited to certain exceptions, and does not include those that allow for departure from the entire provision based on the conditions in T302”.
If a condition for exception creates a situation were a departure from an entire technical provision is required accessibility would terminate at that location. The guidelines would require addressing accessibility beyond this point unless one of the General Exceptions T303.2 applied. If a Condition for Exception is used, but one of the General Exceptions does not apply, then addressing accessibility beyond the point of departure does not seem reasonable because any point along the trail beyond the point of departure would no be accessible, because it would not connect to any other accessible route.
Suggestion: Either clearly explain the rationale for this requirement or eliminate the requirement to address accessibility beyond the first point of departure for which it is a departure from the entire technical provision and therefore no longer accessible beyond that point.
General Exception 5) the trail is not required to comply with any of the technical provisions in T303 for more than 15 percent of the length of the trail, should apply to both new and existing trail alterations. This would undoubtedly signify a situation were it would not be reasonably doable to provide trail accessibility beyond the first point of departure, due to the large quantity of trail conditions meeting Conditions for Exception.
Suggestion: Modify existing guidelines such that 1) the combination of running slope and cross slope exceeds 40 percent for over 20 feet, 2) a trail obstacle 30 inches or more in height is across the full tread width of the trail 3) the surface is neither firm nor stable for a distance of 45 feet or more 4) a clear trail width is less than 12 inches for a distance of 20 feet or more only apply to existing trail alterations and not to new trail alignments.
Maintain the existing guidelines such that 5) the trail is not required to comply with any of the technical provisions in T303 for more than 15 percent of the length of the trail applies to both new trails and existing trail alterations.
The following comments are a discussion of Multiuse Trails and required Accessibility
Section T104 States the following: “A trail designed, constructed, or designated for pedestrian use may also have other uses, such as bicycling or in-line skating. It is recognized that pedestrians use all trails. However, these guidelines apply only to trails where travel on foot is one of the designated uses for which the trail was created. For example, a trail designated for mountain biking will not be considered a “pedestrian trail” whether or not pedestrians actually use the trail. However, a multi-use trail specifically designed and designated for hiking and bicycling would be considered a pedestrian trail”.
Historically many of the trails in California State Parks were established for use by both Equestrian and Pedestrian use. In more recent times trails have been established for both Mountain Bike and Pedestrian use. The following provides information on why the California Department of Parks and Recreation (DPR) feels multiuse trail accessibility should not be mandated in the proposed guidelines.
Under the proposed guidelines hikers with mobility impairments or using mobility assistive devices could be sharing a “multiuse” trail with equestrians. Under these standards both user groups would be occupying a minimum 36 inch wide trail tread surface with a minimum 5 foot wide and 5 foot long passing area every 1,000 feet. With these limited trail dimensions, the size and weight of the average horse, the size of the average mobility assistive device and the physiological and behavioral makeup of horses, this situation could lead to serious user conflicts and safety issues.
The limiting factor in the sharing of a common trail with these two user groups is the horse. Understanding their physiological composition and behavioral nature is critical to assessing the risks associated with this shared use.
Horses have developed their physical and behavioral characteristics through sixty million years of evolution. Even though they are quite large and powerful, they have been prayed upon by large carnivores since their existence. Being a pray species they have had to develop instincts that insure their survival. Humans have domesticated horses and enjoyed their use and company for thousands of years. However, their basic instincts have not changed significantly since they roamed the earth as wild animals. These instincts include caution when being approached by other animals (including humans) and flight when startled or threatened. This is why horses are often perceived as being nervous or skittish animals.
Horses have extremely large and wide set eyes. The combination of these large eyes and narrow face allows horses to have a field of vision of 350 degrees. The only direction that they cannot see is directly behind their head. However, only 65 degrees of this field of vision is binocular (seeing with two eyes). The remaining 285 degrees is monocular (seeing with only one eye). Although this allows horses to detect movement in almost any direction their depth perception is poor where they have monocular vision. Horse’s eyes are also elongated which inhibits their ability to quickly focus on objects both close and far. Their vision is generally poorer than humans and they can see about 60% as well and as far as humans. Because of this, horses may have difficulty determining if an approaching trail user is a human or a predator. Horses do have excellent night vision but their eyes have difficulty adjusting to abruptly changing light and dark conditions (normally occurring in a forested area). Finally, because of their long face and wide set eyes, horses have a blind spot directly in front of their feet. This condition can make it difficult for horses to identify other trail users that are directly in front of them and lower to the ground (sitting in a wheelchair).
Their sense of hearing and smell far exceeds those of humans. They often hear or smell approaching animals far before their riders do. Horses are also capable of feeling vibrations through their hooves. These sensory capabilities may result in horses becoming alarmed and startled without their riders knowing the cause.
The hooves of horses generally provide them with an excellent means of traction in a variety of conditions. The bottom triangular portion of the hoof (frog) is fleshy and susceptible to injury when stepping on sharp stones or rocky surfaces. This area can become bruised or injured with repeated exposure to these types of surfaces. Horseshoes provide additional strength and support to a horse’s hoof in rugged terrain or during prolonged riding periods. They do, however reduce traction in rocky or icy terrain. Developed or hardened surfaces such as wood, asphalt and concrete are slippery whether the horse is shod or not. Considering the average weight of a horse (800 to 1,000 lbs.) and the relatively small surface area of their hooves, these animals can generate considerable mechanical wear on trail tread surfaces.
Given the behavioral and physical characteristics of horses, hikers sharing trails with horses normally yield the right a way to horses. When approaching horses, hikers should make themselves as visible as possible and not approach the horse too rapidly. Hikers should speak to the horse or equestrian in a low and friendly voice to insure their recognition. Hikers should select a wide spot in the trail or an area with a gentle side slope and step off to the downhill side of the trail. Most equestrians prefer to have the uphill side of the trail during these encounters incase the horse bolts. When the horse approaches, the hiker should not make any sudden moves and maintain their conversation with the equestrian. The hiker should not step back onto the trail until the horse is its body length down the trail. Stepping behind a horse too soon may result in the horse attempting to kick the hiker.
Multiple use trails combining both mountain biking and hikers with mobility impairments or using mobility assistive devices have some inherent conflicts. These conflicts are more subtle than those encountered with equestrian use. The key element in mountain bike trail design is reducing the speed of the mountain bikers. Higher rates of speed lead to increased user conflicts (even with other mountain bikers), safety, resource degradation and trail sustainability issues. One method of reducing speed is to avoid laying out trail segments that have long, straight and uninterrupted sight lines. If the mountain biker can see a clear route ahead (particularly on downhill runs) that has no turns or natural features to maneuver around they will accelerate through that segment. Usually when they come to the end of that segment and encounter a curve in the trail, a natural feature to maneuver around or another trail user they will apply their brakes hard. This breaking action can cause the bike to go into a skid. As the tires skid across the trail tread they dig into the tread surface and push it towards the outside edge of the trail. This action when repeated over a period of time will result in an entrenched trail tread and the development of a berm on the outside edge of the trail. Once these conditions develop the trail can no longer effectively sheet overland runoff and becomes a ditch that collects and diverts water. At this point, the trail becomes a liability to the resources and is unsustainable. This mechanical wear also can cause the tread surface to deviate from the firmness and stability requirements of REGNEG and increases the potential for user conflicts and accidents.
Generally multi use trails are designed to have wider tread surfaces (minimum of 48"), longer sight distances, and wider turning radius to reduce user collisions and conflicts. These design criteria are not inconsistent with REGNEG except for the tread width however, experience with these types of trails has indicated that mountain bike use will quickly degrade non paved trail surfaces to the point where they no longer meet REGNEG firmness and stability requirements or provide adequate sheet drainage. This has been the case with trail tread comprised of native soils, crushed rock, soil stabilizers, or combinations of these various surface types.
Suggestion: Only require trails were foot travel is the only use to address accessibility unless the trail is designated a shared use path or similar and conforms to AASHTO level or similar design standards.
Suggestion: Remove references to shared use paths needing to meet proposed guidelines until the Access Board, AASHTO and possible FHA coordinate to provide consistency of trail access information.
Conduct research and studies to see if paved shared use paths should follow the proposed guidelines. It may be possible that given a hard paved surface that the same level of accessibility could be provided with different slope criteria.
Suggestion: Limit the obstacle height to one inch with an exception of two inches when the running grade and cross slope is 5% or less. Limit the width of tread obstacles to a maximum of 25% of the trail tread and their density to a maximum of 10% of the tread surface where they occur. Fields of obstacles (several tread obstacles in a section of the trail) should not constitute more than 10% of the trail’s total tread surface. If for some reason it would not be possible to comply with these standards it would seem that the reason for non compliance would fall under one of the four conditions for departure.
Suggestion: The definition and associated guidelines developed by the U. S. Forest Service (FSORAG) should be added to the proposed guidelines. In addition there should a definition of trailhead parking and associated guidelines. These guidelines should account for the existing conditions, resources, and aesthetics of the area.
Alterations to existing non-paved parking areas should not require paved accessible spaces and associated ground striping and symbol, but should require a firm stable surface less than 3%, and a min width of 16 feet. These accessible parking spaces could be signed with 2 ISA signs and associated arrows delineating the 16 foot accessible parking area and could include a blue bumper or similar to assist in accessible parking delineation. Mounting ISA signs would require a min mounting height of 36 inches.
Guidelines would need to be established to determine if proposed (new) parking areas would require paved accessible parking spaces. All parking associated with exterior routes of travel would require paved parking. Accessible parking spaces connecting to an Outdoor Recreation Access Route or Trail would have the option to provide paved or non-paved accessible parking spaces, based on individual project needs, and would be required to follow applicable guidelines based on that decision (e.g. non-paved parking standards as described above or ADAAG and building code requirements).
Suggestion: Access Board to consult with US Forest service to revise FSTAG.
Suggestion: Recommend that only Accessible Trails provide access information signs. Keep those access information signs simple to include the only the most useful information to a visitor (Trail Name, Accessible Length, Cumulative Elevation Change, Typical Grade, Typical Width, Typical Surface). Recommend that in some cases it may be appropriate to provide access information on non-accessible trails, but only when it would be considered desirable and useful for the majority of users.
Suggestion: Allow the use of an Outdoor Recreation Access Route, T204, for recreational boating from parking spaces to ramp area or the start of the gangway system. This is similar to the outdoor recreation access route that connects accessible elements within a picnic area, camping area, or designated trailhead.