Comments provided by:
Peter Axelson MSME, ATP RET
Beneficial Designs, Inc.
I am a rehabilitation engineer with 30 + years of experience as a wheelchair user. As a trail user I have had the opportunity to hike on outdoor recreation trails in my manual wheelchair, in my hiking chair, in the Permobil powered exterior wheelchair, in the Independence Technology IBOT, in an ATV and in an OHV. I have accessed water trails in a kayak and in a canoe. I have accessed snow ski trails on a cross country ski sled, on a back country ski sled, in a sit-ski, in a mono-ski, in a bi-ski and on a snow machine. My education is in Mechanical Engineering and Product Design. I have significant experience in the design of outdoor recreation products including adaptive sit-skiing and mono-skiing equipment, hand cycles that balance, wave skis and seating for mountain bike wheelchairs and all sorts of motorized mobility devices including the IBOT wheelchair. I serve RESNA as the chairman of their Technical Standards board where I also chair the RESNA Wheelchair Standards and Adaptive Sports Equipment Standards Committees. I also participate in the ASTM Playground Surfaces committee and the ANSI B-77 Ski Lift Standards committee. I had the privilege of participating on the Access Board’s Outdoor Recreation Committee on behalf of American Trails and the subsequent Regulatory Negotiation Process. Our company, with funding from the National Institutes of Health, National Center for Medical Rehabilitation Research, developed a wheelchair work measurement procedure and the rotational penetrometer, a portable device for measuring firmness and stability of outdoor recreation surfaces. NIH also funded us to develop the Universal Trail Assessment process and Trailware data processing software. We were also funded by the National Center on Accessibility to conduct research on the effects of grades and cross slopes on persons with mobility impairments in the outdoor environment. The Access Board also provided support for us to conduct human subject testing for a variety of Outdoor Recreation Surfaces. With this background and a passion for access to a variety of Outdoor Recreation environments I respectfully submit the following comments….
First off, this reviewer is in full support of all of the recommendations provided by American Trails. The one distinction between my own personal views and the comments which I contributed too for American Trails would be the priority that I would place on providing Trial Access Information over and above indicating if a trail meets the Trail Accessibility Guidelines or not.
Second, I am supportive of many of the comments provided by CA state parks. I do not have their submission draft however their recommendations on the following sections made sense to me in their 21 September 2007 draft…
Section 303.82 Running slope, Section 303.9 Resting Intervals, Section 303.2 General Exception Suggestions 1 - 4, Section 303.3, Accessible parking and FSTAG Classification issues.
And I do not completely agree with 100% of the language in the following comments: 302.1 Conditions for Exceptions, T104 Definitions, T303.6 Tread Obstacles and T321.2 Signage. However their comments have greatly shaped my concerns about multi-use trails that allow equestrians and mountain bikes along with pedestrian hikers. The trail professionals with California State Parks have designed and built some of the best accessible trail experiences in the United States. The training and education that they can provide to rest of our country on how to build good, fun, sustainable trails that happen to meet access requirements should be packaged for everyone to see and hear.
I believe that trail access information should be included at all trailheads regardless of trails meeting or not meeting accessibility guidelines. The information is generally more important for trails that do not meet access requirements so that as a hiker, I can determine where I can and can not go, given my own personal abilities, personal assistance I may have with me and the adaptive equipment I may be using at any given time. In my personal experience I can tell you that the work to negotiate a continuous 5% (meeting access guidelines) grade can far exceed the work to negotiate a trail with a 2 to 3% typical grade with short grades that are over 12% (not meeting access guidelines).
Trail access information should be provided at trailheads but also on publicly available websites and should include all of the following elements: Trail length, the user groups allowed and not allowed on the trail, typical and maximum grade, typical and maximum cross slope, typical and minimum tread width, typical and worst condition surface firmness and stability, the type of obstruction, magnitude, remaining tread width and location from the trailhead of the greatest obstructions on a trail. It is also important to disclose the date that the trails were assessed since conditions can change over time. For persons new to trail access information, it is important to include that a standard ramp is typically an 8.3% grade. Basic trail access information can be placed on a vertical signpost. An example of this basic information is provided as part of these comments. The format is similar to the Nutrition Food Fact Label. Remember, there was tremendous resistance to providing this information by food manufacturers that felt that the quantity of information required would take over the product packaging with labeling. Food labeling has turned out to be extremely valuable for consumers for their heath and well being. Signposts with trail access information have been created for posting on over 50 trail segments in Northern Nevada. Providing trail access information will allow people desiring to know the specifications of a trail to assess that information for their own personal needs and safety. Sure, some trail users may not care about trail access information and for others it will take some time for people to learn what the information means. Reference to a standard ramp being an 8.3% grade is always provided in trail access information. These comments also include a sample overview panel map (24 by 36 inch full size) for a system of trails in a park shows how trail access information can be provided in larger signs. These informative signage panels have been created for posting on many different trail systems in Northern Nevada and won an Accessibility award from the National Coalition of RecreationTrails.
The information needed to create trail access information can be collected using the Universal Trail Assessment Process (UTAP) or another comprehensive trail measurement system. Beneficial Designs and American Trails have provided UTAP training to over 800 trail professionals. Florida now requires that trail project sponsors assess their Recreation Trail Program projects using the Universal Trail Assessment Process and submit the information to the Office of Greenways & Trails. The office provides funding to cover the cost of UTAP and Trailware training and funding to purchase UTAP tool kits and Trailware software for all project liaisons. For larger agencies with significant amounts of trail mileage to assess, a High Efficiency Trail Assessment Process is being Beta testing for commercialization that allows a single person using a sensor package attached to a wheeled device (roll-a-wheel, jogging stroller, ATV or OHV) to collect data on all types of trails at a speed of 1 mph or greater. The development of this technology is being funded by the USDA Small Business Innovation Research Program and measures grade, cross slope, distance, GPS position and trail images along a trail.
I do not think that signage should be required on recreation elements (campsites, picnic areas, etc.). If symbol signage is used to indicate where a recreation element is located then a sign would be relevant and should be used. However, I think that the use of the ISA could cause confusion in the trail and outdoor recreation environment. Occasionally it is necessary to indicate the direction to a facility that provides access from one that does not, in which case use of the ISA would be appropriate. From a universal design perspective the ISA should not be necessary. However if symbol signage is used, I would recommend the use of a variation of the trail or other element symbol itself to indicate access. This would allow signage that communicates which elements are and are not accessible when there are multiple elements in a campground for example. Currently trail signage by companies like Rockart, Guidepost and Voss have dark backgrounds and the symbols inside the signage are white and there is also a white border around the signage. In some cases printed information uses a white background with a dark symbol with a dark border around the symbol. Leaving off the light or dark border (barrier) could be a communication tool to indicate that the element meets accessibility guidelines. Another communication tool could be to insert a horizontal line beneath the symbol inside the border of the sign. This slight variation of signage that could be applied to every recreation element symbol and would indicate that the element complies with access guidelines. A sample of this concept is included with these comments.
There will be many comments submitted about the difference between Shared Use Paths and Outdoor Recreation Trails and the need to create definitions and separate requirements for each. This reviewer would propose that there only be one definition for an Outdoor Recreation Trail that includes Shared Use Paths. However, this reviewer would propose that there be a distinction between Outdoor Recreation Trails that are paved and Outdoor Recreation Trails that are not paved. The reason that this is being proposed is that surface firmness and stability is such a dramatic factor for accessibility that we need to allow for another set of design standards for Outdoor Recreation Trails, but only when the surface is paved.
This experts proposal, in summary, is to harmonize the Outdoor Recreation Trail Standards with the ASHTO standards for grade for paved trails only. The reasoning for this is that the guidelines for Outdoor Recreation Trails specify that we require firm and stable surfaces which allows non-paved surfacing of trails. However, a non-paved surface that is firm, stable and level will cause a typical user of a mobility device to have to exert the same energy as rolling up a 3% to 4% slope. Therefore for the same grades, Outdoor Recreation Trails with paved surfaces should be able to allow slightly longer distances than Outdoor Recreation Trails with non-paved surfaces that are firm and stable. This is being proposed because a paved surface requires so much less energy to negotiate than a non paved surface.
This expert would propose that for paved surfaces only, that we follow the ASHTO Shared Use Path grade standards for access which generally allow longer distances for a given grade. Therefore, for Paved Outdoor Recreation Trails, use the AASHTO Guidelines with the following additions:
This would also mean that Shared Use Paths without paving would still have to meet ASHTO Shared Use Path Standards but would also be required to meet the Outdoor Recreation Trail Guidelines.
After extensive discussions with trail experts from California State Parks, this expert recommends maintenance exceptions for Access Guidelines on Outdoor Recreation Trails. The exceptions for maintenance would be triggered if equestrian use is allowed on a trail or if mountain bike use is allowed on a trail. In addition, standardized equestrian and or mountain bike user conflict information should be drafted and communicated using signage that shall be provided on all trails that are designated for equestrian and/or mountain bike use along with pedestrian use. This signage should explain what actions to take, how to act and how to respond when encountering a horse or mountain bike while on a recreation trail. The signage should also explain the potential hazards and risks that could occur when encountering horses or mountain bikes on a recreation trail. I am not recommending an accessibility design exception for multi use trails that allow equestrians and mountain bike use. Trails can often later be designated for use by different user groups so it makes no sense to design and build any type of trail that does not meet access guidelines. Where trails are designed only for use by equestrians or mountain bikes and where alternative trails are provided for pedestrians, access guidelines should not be required.
The rationale for providing signage is that equestrian use of a recreation trail conflicts with pedestrian usage. The physical characteristics of horses and the behavioral characteristics of horses create safety hazards for hikers and mountain bike user groups when operating on a narrow Outdoor Recreation Trail. Historically horses are a prayed upon species that are cautious when approached by other animals and “flight” when startled or threatened because they are unable to differentiate humans from predators. The physical characteristics of horses must be considered as well. The have poor depth perception, with 285 degrees of monocular vision and only 65 degrees of binocular vision and a blind spot at their feet. At the same time they have an acute sense of hearing and smell and are startled by vibrations we cannot feel and sounds we cannot hear. Furthermore, the fleshy portion of their hooves is susceptible to injury, and while horseshoes help they reduce traction on hardened surfaces. The shear weight of an 800 lb to 1000 lb animal on a small footprint causes extensive wear on the trail surface. Because of the behavioral characteristics of horses, hikers should ideally move off of the trail to the lower side of the trail to ensure recognition and the hiker should speak in a low and friendly voice to horse or equestrian. For pedestrians that are unable to get off to the side of the trail, it is often not safe to have a pedestrian and horse on a 36-inch wide trail. This passing interval space is not wide enough for safe passage. More frequent passing intervals would be recommended on a multi use trail with equestrian users. Safety issues exist for mobility device users that cannot step off to the lower side of a trail. The desire for a firm and stable surface for one user group also conflicts with the desire for a softer surface for horses.
With regard to mountain bikes, the maneuvering characteristics of mountain bikes generally exhibit higher speeds in downhill sections of trails and they use lots of braking at turns which causes skidding and subsequent rutting of the trail tread. Mobility device users generally are not moving at a high rate of speed, which creates a user conflict with mountain bike riders. Generally mountain bikes trails have the following characteristics, they have berms on the outsides of turns due to skidding, they have entrenchments in the center line of the trail, the trail tread surface quickly degrades, the surfaces is often not firm and stable and the trail is often narrow with reduced sight distances. These characteristics are all in conflict with maintaining a firm and stable recreation trail surface.
This expert feels that exceptions to the technical provisions should only apply to existing trails and that the technical provisions should always apply to new trails without exception. New trails should not be designed and constructed that cannot meet the technical provisions, period. Trail classifications, should not allow a condition for departure for access. Use classifications can be used to establish maintenance standards or to establish a hierarchy. Classifications should never be allowed to exempt accessibility!
Trail Gate Barriers are important for land mangers to restrict access of motorized trail vehicles onto Outdoor Recreation Trails to prevent environmental damage to the trail and to reduce the hazards of this user conflict with non-motorized trail users. However, Trail Gate Barriers must allow hikers, including those that use personal mobility devices, to access Outdoor Recreation Trails. Currently, Trail Gate Barriers include bollards and other structures with minimum clearance widths that restrict many mobility device users from accessing Outdoor Recreation Trails.
Trail Gate Barriers for Outdoor Recreation Trails should be allowed to reduce the minimum clearance width to a minimum width of 24 inches, but only at heights above 34 inches. The anthropometric data shows that the 24 inch width at the shoulders will allow all ambulatory hikers of all body dimensions to negotiate the proposed Trail Gate Barrier profile as noted below.
Source: Henry Dreyfuss Associates (1993) ‘Anthropometry’ in The Measure of Man and Woman, New York: Whitney Library of Design
Source: <1988 Anthropometric survey of U.S. Army Personnel: Summary Statistics Interim Report>
Source: <Man-Systems Integration Standards, NASA-STD-3000> By National Aeronautics and Space Administration
Small-Shoulder width of 16-17" and chest size of
Medium-Shoulder width of 17-18" and chest size of 38-40"
Large-Shoulder width of 18-19" and chest size of 42-44"
Extra Large-Shoulder width of 19-20" and chest size of 46-48"
2X Large-Shoulder width of 20-21" and chest size of 48-50"
3X Large-Shoulder width of 21-22" and chest size of 50-52"
4X Large-Shoulder width of 22-23" and chest size of 52-54"
5X Large-Shoulder width of 23-24" and chest size of 54-56"
The proposed dimensions also allow manual and powered mobility device users, as confirmed by extensive data collection with mobility devices. A proposed illustration of a Trail Gate Barrier shows that the lower portion of the Trail Gate Barrier restricts the minimum clearance width to 32 inches for a distance of 24 inches and that the upper portion provides a gradual overhang of 4 inches on each side to restrict the upper portion of the Trail Gate Barrier while providing detection by persons with visual impairments. The illustrations are included with these comments.
The firmness and stability of all outdoor recreation surfaces should be objectively measured using a Rotational Penetrometer (RP). The RP is a precision tool for measuring the firmness and stability of ground and floor surfaces. To measure firmness, the Penetrometer has a calibrated spring that applies a downward force on a standardized indenter and a precision caliper records how far the indenter penetrates into the surface. Rotating the indenter and then reading the precision caliper again indicates the surface stability. The RP is capable of measuring all types of outdoor surfaces, from concrete to sand. It is specifically designed for portable use in the field. There is a report entitled Accessible Exterior Surfaces, with recommendations on firmness and stability readings on the Access Board website at http://www.access-board.gov/research/Exterior%20Surfaces/exteriorsarticle.htm
Respectfully Submitted by Peter Axelson MSME, ATP, RET
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