COMMENTS OF THE
UNITED SPINAL ASSOCIATION
Submitted to the
UNITED STATES ACCESS BOARD
Notice of Proposed Rulemaking
Architectural barriers Act (ABA) Accessibility Guidelines for Outdoor Developed Areas
[DOCKET NO. 2007-02]
United Spinal Association
75-20 Astoria Boulevard
Jackson Heights, NY 11370-1177
October 12, 2007
United Spinal Association applauds the efforts of the Access Board in developing the proposed access specifications for outdoor developed areas. These draft guidelines provide a better understanding of what accessibility requirements would apply to various outdoor areas and amenities.
United Spinal Association has recently created a travel department that specializes in accessible travel. Many of our members enjoy taking vacations that include camping, beaches and other outdoor areas. The Board’s draft guidelines will help to ensure that our members will be able to enjoy outdoor areas where access and inclusion is not an issue.
Throughout the proposed rulemaking, the Access Board asks a series of 26 questions, United Spinal has drafted responses and inquiries to several, but not all of, the questions.
Question 3 – asks what symbol should be displayed to identify the trail as accessible. Since an accessible trail does not necessarily meet the requirements of an accessible route and may widely vary on acceptable standards such as slope, cross slope, surface, etc.; we do not believe the International Symbol of Accessibility should be used as this already has a distinct meaning. Thus, we believe new symbols, such as those found in Section T321.2, must be created. These new symbols should convey the level of access provided on the trail. This rating system will address the Committee’s other recommendation that the sign provide detailed information about the trail’s characteristics, such as slope, without having to list them. The signs would simply contain the appropriate symbols to designate the level of accessibility. Each symbol would convey the level of accessibility based on slope, width, and other characteristics outlined in the proposed guidelines. This system would work as most hikers familiarize themselves with the area they will be hiking so this information on what each symbol means would be placed on the park’s website and in printed guides and materials.
Question 4 – asks whether 6 inches should be the threshold to be used when a pedestrian route, such as a boardwalk, is developed along the edge of an existing beach. United Spinal does not agree with Exception 6 as there are many situations that could result in access even if the pedestrian route or boardwalk is elevated 6 inches or higher above the beach surface. Ramps could be constructed parallel to the board walk to allow for easy access for wheelchair users or the boardwalk itself could be sloped in certain areas to achieve access to the beach. United Spinal believes that the 6 inch threshold is too limiting.
Question 5 – asks if a minimum of 36 inch wide route is sufficient as long as a 60 inch wide passing space for 60 inches is provided every 200 feet. United Spinal believes this is sufficient.
Question 6 – asks if beach access routes should connect to manage elements and spaces, such as first aid stations and beach rental equipment. United Spinal believes that beach access routes should be provided to such spaces. We believe that such items could be provided from a central location, such as the parking lot and not necessarily be on the most direct route so as not to completely cover the beach with materials sufficient to make the route accessible.
Question 7 – asks if the minimum height of 15 inches above the ground is too low for the height of a cooking surface. We believe the 15 inch height is too low. To cook for a prolonged time and to have to reach across the cook surface would limit many people who use wheelchairs and have balance problems from using the cooking surface. One option may be to look at the work surface heights in the ADA/ABA guidelines Section 804.3.2 which provides that a kitchen work surface shall be 34 inches maximum above the finish floor or ground with an exception for adjustable surfaces to go as low as 29 inches minimum.
Question 8 – asks if a definition of area should be given. United Spinal believes a definition should be provided in order to avoid confusion in large parks and open spaces.
Question 9 – asks if a range of requirements is necessary to define firm and stable. We agree in the outdoor developed areas that a broad range of firmness and stability is necessary and would be a factor in determining the level of access for a trail.
Question 10 – asks if scoping for the number of accessible elements such as picnic tables, fire rings, and benches should be increased from 50%. We believe the scoping provided in Chapter T2 is sufficient.
Question 12 – asks for clarification on alterations and maintenance activities for picnic areas, campground and benches. Maintenance should include painting and minor repairs that are done in place. Alterations are if the element, such as a bench, picnic table, grill, fire ring, etc., needs to be replaced because it is in such disrepair it can not be fixed.
Question 13 – asks if construction tolerances for outdoor areas should be different than for indoor areas. The tolerances should not vary as the difficulties and nuances in dealing with outdoor areas have already been dealt with in the actual scoping and technical guidelines.
Question 14 – asks if elements should be made accessible where the trail to the element is not accessible. We believe that elements should be made accessible at time of construction or installation so that they would be usable if/when they are connected.
Question 15 – asks in the construction of a new beach if a beach access route should be constructed every ½ mile. We agree that such a beach access route should be constructed every ½ mile.
Question 17 – asks if a beach access route should be triggered by construction of a parking lot or spaces. We believe that such construction should trigger a beach access route.
Question 18 – asks if a beach nourishment activity or project should trigger the inclusion of a beach access route. We believe that a beach access route should be provided if the nourishment project affects more that 50% of the beach.
Question 25 – asks if the signage shown in Section T321.2 is sufficient. We believe the signs depicted on page 38 (generic signage) and page 39 (trailhead signage) conveys appropriate information to allow the person to make an informed decision of whether of not they are able to traverse the trails and area.
United Spinal would like to take this opportunity to thank the Access Board for allowing it to comment on some of the questions it proposed in the ABA Accessibility guidelines for Outdoor Developed Areas.