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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 Read comments submitted by California State Parks

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

arrow Download the Advance Notice of Proposed Rulemaking in pdf format

American Trails Comments on Proposed Shared Use Path Accessibility Guidelines

From American Trails, Public Affairs Committee

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

 

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: Yes, the definition seems to be explicit and easily understandable.

Question 2.

What technical provisions, if any, should apply where separate unpaved paths are provided for equestrian use?

Comment: Generally, equestrian use may conflict with bicycle or motorized uses because of the fight/flight nature of equines. We recommend that the guidelines recommend a separate unpaved path for equestrian use.
We would recommend the attached design standards that the U.S. Forest Service has for equestrian use. They have been in place a number of years and seem to work well
Adequate signing informing users of the types of uses allowed should be required where equestrian use is allowed on shared use trails.
Trail width for equestrians is usually 8 feet and 10 foot overhead clearance, the 5 foot width minimum is too narrow for equestrian use.
Equestrian use shared use paths should be separated from adjacent roads

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.

Comment: Most of the time, the 5% maximum grad(e) can be easily met most places. In steep areas it would take a much longer trail with climbing turns and switchbacks to meet the 5% maximum. If there are land ownership or environmental issues that would not allow long trail segments between turns, this could prevent compliance.
Recommend that the Board follow the same exceptions as stated in 1017 of the October 19, 2009 Draft Final Accessibility 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: We recommend that the Board not provide guidance for steeper segments of shared use paths when they cannot be avoided.
Recommend that the Board follow the same exceptions as stated in 1017 of the October 19, 2009 Draft Final Accessibility Guidelines for Outdoor Developed Areas.

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: We recommend 25 feet to allow adequate separation for equestrian use.

Question 6.

Are there conditions where cross slope steeper than 2 percent is necessary in new construction?

Comment: We feel the 2% maximum cross slope is adequate on paved trails. We recommend 5% cross slope on unpaved trails.

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: Yes, warnings at trailheads and at junctions with other trails or roads should be required to inform users of conflicts with other shared use paths users. (I don’t think any signs should be required; this would mean signing thousands of miles of trails, more clutter, and actual hazards like a trail narrowing with sharp curves

Question 8.

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

Comment: Recommend that the Board follow the same provisions as stated in 1017 of the October 19, 2009 Draft Final Accessibility Guidelines for Outdoor Developed Areas.

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: Recommend that the Board follow the same provisions as stated in 1017 of the October 19, 2009 Draft Final Accessibility Guidelines for Outdoor Developed Areas.

 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: No, recommend that they be either issued as part of the Final Accessibility 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: How the guidelines will incorporate the March 15, 2011 Department of Justice (DOJ) revised rules allowing “other power-driven mobility devices” to be used by “individuals with mobility disabilities” should be addressed.

MORE RESOURCES

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

See DOJ ADA Website

 

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