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The Access Board requested public comment by June 27, 2011 on Proposed Rulemaking to develop accessibility guidelines for shared use paths.


arrow See comments submitted by American Trails

arrow Read the Advance Notice of Proposed Rulemaking as published in the Federal Register March 28, 2011

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California State Parks Comments on Proposed Shared Use Path Accessibility Guidelines

From California State Parks, Jason Spann, Accessible Trails Coordinator

Comments on the Shared Use Path Accessibility Guidelines, March 28, 2011, Docket Number 2011-12


General Comments:

It would be helpful to add illustrations to the guidelines for clarification.

Question #1:

Does the draft definition of "shared use path" sufficiently distinguish these paths from trails and sidewalks? If not, please provide any recommendations that would strengthen this distinction.

Comment: CSP believes the definition should also distinguish shared use paths from recreational trails covered under the Draft Final Guidelines for Outdoor Developed Areas. The Shared Use Path Definition would be improved if written” A shared use path is a multi-use path designed for both transportation and recreation purposes, with a focus on transportation and designed to be part of a transportation system. Shared use paths typically are separated from motorized vehicular traffic by an open space or barrier, either within a highway right-of-way or within an independent right-of-way”.

The definition should not limit shared path users with disabilities to wheel chairs but be more inclusive such as “pedestrians using mobility assistive devices” or “shared path users using mobility assistive devices”.

Question #2:

What technical provisions, if any, should apply where separate unpaved paths are provided for equestrian use? Additional information and guidance on this issue is welcomed.

Comment: CSP does not believe there should be any accessibility requirements required for equestrian paths where separate unpaved paths are provided for equestrian use.

CSP also believes it is critical for pedestrians with disabilities and equestrians users to be located on separate paths based on the following.

Equestrian Conflicts:

Under the proposed guidelines hikers with mobility impairments or using mobility assistive devices could be sharing a path or trail with equestrians. With potential 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.

Physical and Behavioral Characteristics of Horses:
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.

User Protocols:
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 to 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 to soon may result in the horse attempting to kick the hiker. When a hiker using a mobility assistive device and a horse and rider meet on a trail who has the right away? If the trail is not wide enough for both users to safely occupy the trail at the same time who steps off of the trail? What side of the trail do they use? Regardless of who has the right away this situation can be dangerous to both users.

Question #3:

Are there conditions where a 5 percent maximum grade cannot be achieved on a newly constructed shared use path? If so, the Board is interested in a description of the specific conditions that might prevent compliance. The Board will consider providing additional exceptions where it may be difficult or impossible to meet the 5 percent maximum grade.

Comment: Given enough money and design effort any new shared use path could achieve a 5% maximum grade. However, the end result of the design solution (multiple ramps, etc...) could violate National, State, and Local Government laws, regulations and statutes aimed at protecting natural and cultural resources. The design and construction solutions could be completely impractical, unaffordable and non-compatible with the intended designed use for the trail (smooth transportation of pedestrians and bicycles). In addition such extreme design solutions could lead to safety issues along the trail. Locations were it would be “difficult “to achieve a 5% maximum grade should be allowed similar exemptions as provided in the Draft Final Guidelines for Outdoor Developed Areas.

Question #4:

Should the Board provide guidance on how to address steeper segments of shared use paths when they cannot be avoided? For example, would providing space for bicyclists or wheelchair users to move off of the shared use path in order to avoid conflict with other traffic be helpful?

Comment: Steeper segments should be designed to meet 5% as close as possible, and should not be allowed to exceed a maximum determined grade up to a specific length (e.g. 8.3% maximum grade up to 100 feet). The distance between slopes greater than 5% should be long enough to prevent multiple abrupt grade changes that could cause bicyclist and skaters to lose control. Because of increase bicycle speed in steep sections it could improve overall user safety if steeper segments were wider to ensure safe passing spaces if not already accommodated in the overall design width of the trail. Steeper sections could also require trail signage to state maximum speeds, increase grade warnings and reminders for bicyclist to watch and slow for pedestrians.

Question #5:

What would be considered a sufficient separation between a shared use path and a roadway, or outside border of a roadway, where it may not be necessary for the shared use path to follow the grade of the roadway?

Comment: This decision would be very site specific and would involve the analysis of multiple design factors including, but not limited to existing structures, existing topography and existing utilities. It may not be realistic to provide a generic width of separation where it may not be necessary for the shared use path to follow the grade of the roadway. If a width separation was provided it would have to be wide enough to account for potential site specific issues of a project. “Where the shared use path corridor is contained within a street or highway border, or located within 50 feet of a street or highway border its grade shall not exceed the general grade established for the adjacent street or highway, unless lesser grades can be obtained.”

Question #6:

Are there conditions where cross slope steeper than 2 percent is necessary in new construction? If so, the Board is interested in a description of these specific conditions and recommendations for appropriate allowances.

Comment: CSP cannot identify any conditions where cross slope steeper than 2 percent is necessary in shared use path new construction as long as the paths are surfaced with either concrete or asphalt. It should be noted that long term maintenance of 2% maximum cross slopes may be achievable on concrete shared use paths, but could be difficult to maintain on asphalt paths due to the flexibility inherent in asphalt material. Shared use paths which are surfaced with materials other than concrete or asphalt should be allowed cross slopes steeper than 2% but not to exceed 5%.

Question #7:

Is there a need to provide additional warnings or information to bicyclists regarding potential conflicts with other shared use paths users, including pedestrians with disabilities?

Comment: Possibly in sections that exceed a 5% maximum grade (see question #4. No other warnings would be necessary as people with disabilities are likely to be as visible as recumbent bikes, tricycles, and youth bikes also using the trail. As with most existing shared use paths, right of way protocols and speed limits should be posted. Speed limits should be determined by site specific criteria to include, user types, volume of users, path width, liner grade, turning radius and sight distance.

Question #8:

What technical provisions should apply where the shared use path overlaps a trail or sidewalk?

Comment: The most stringent guidelines should apply where overlap occurs.

Question #9:

Are different technical provisions needed when applying the draft technical provisions for shared use paths that "connect" shared use paths together or with other pedestrian routes (e.g., sidewalks, trails, accessible routes)? If so, please provide any additional information or recommendations.

Comment: Unless the shared use path and other pedestrian routes overlap or use the same route corridor (see question #8) the appropriate guidelines for those identified routes should be used up to the point where they connect to another pedestrian route.

Question #10:

Should the accessibility guidelines for shared use paths be included in the same document as the accessibility guidelines for pedestrian facilities in the public right-of-way?

Comment: These are two separate issues and should be kept in separate documents. Shared use paths could be incorporated into the guidelines for Outdoor Developed Areas.

Question #11:

Are there other issues that need to be addressed by the accessibility guidelines for shared use paths? If so, please provide specific information on any additional areas that should be addressed in the guidelines.

Comment: The shared use guidelines should also state or reference accessibility guidelines for shared use path trailhead parking, routes from parking to shared use paths, outdoor facilities (e.g. picnic areas, restrooms, overlooks), site amenities, outdoor constructed features (e.g. benches, drinking fountains, trash cans)

Question #12:

The Board requests commenters to provide information for the regulatory assessments, including:
Number of existing and planned shared-use paths at the state or national level; 1
Number of shared-use paths constructed each year (on average) within your jurisdiction; 0
Typical cost for a new shared-use path on a per-mile basis; Cost not available for CSP. Cost varies by site conditions, design prescriptions and level of construction required.
Sources of funding for the construction of shared-use paths (e.g., Federal highway funds, other Federal grant programs, state funds, local funds); Recreation Trails Program, Environmental Enhancement and Mitigation, Transportation Enhancement Act.
The extent to which the AASHTO Bicycle Facilities Guide, or other design guides and standards are used for shared use paths; Shared use paths would currently use the Caltrans Design Manual or AASHTO Bicycle Facilities Guide.
Whether any of the draft technical provisions would result in additional costs for design work, materials, earthmoving, retaining structures, or other items compared to current construction practices or design guides and standards currently followed; Additional expenses could be substantial to comply with 5% maximum grade guidelines.
What, if any, unintended consequences (positive or negative) could result from an agency adopting the guidelines, and Additional cost and potential resource impacts associated with achieving 5% maximum grades could reduce shared use path development possibilities.
What impacts will the draft technical provisions have on small entities and are there alternatives that would minimize those impacts? Small entities may have a difficult time affording and achieving 5% maximum grade guidelines. Modifying grade guidelines could minimize impacts.


American Trails index on accessible trails, outdoor recreation, and the Americans with Disabilities Act

See DOJ ADA Website

Aditional information and comments on the “power-driven mobility device" issue:

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