Prineville Reservoir State Park, Steve Memminger
October 17, 2007   [email]


Comments regarding Docket No. 2007-02 – Guidelines for Outdoor Developed Areas
Prineville Reservoir State Park, Oregon Parks and Recreation Department

Question #1

No comment

Question #2

This section is confusing.  The terms “not feasible, reasonably do-able, and practicable make no sense in this example.  The definition of “feasible” means capable or able.  Not feasible would mean incapable or unable.  If something is not feasible, I would assume it is not reasonably do-able yet they are used as the same meaning.  The word “practicable” means feasible.  It makes more sense to use possible and feasible as in:  Yes it’s physically possible to put an ADA trail in this location but it would not be feasible due to the cost of construction.

To answer the question, I think most land managers can determine based on their budget and resources what is feasible and reasonable to accomplish.

Question #3

Use of the international symbol would be appropriate along with additional information as to maximum slope or difficulty of the trail.  Some trails are only accessible for a portion of the distance before the terrain becomes too steep.  This information should be conveyed along with the symbol.  For example: the first one quarter mile is within the required slope, at the end of that portion another sign would indicate the end of the ADA portion along with a wide turn around area.

Question #4

Each beach pedestrian route is probably different due to surrounding terrain.  A higher threshold may be possible in some locations but not in others due to local conditions i.e. rocky shores, wet lands or dunes.  If a higher threshold is used, there may need to be exceptions based on the above terrain elements.

Question #5

The passing space is adequate.  The distance of 200 feet could be too long especially if the view down the trail is obstructed requiring people to back up to the next passing area.  Every 100 feet may be more reasonable on a 36" wide trail.

Question #6

Not all existing beach elements are located close enough to be connected by beach access routes.  Where it is feasible they should be connected to as many elements as possible.

Question #7

15 inches seems reasonable.

Question #8

The examples of “areas” are clear enough.

Question #9

Firmness of surfaces can be relative to the weight of the person using the trail.  A child being pushed in a wheel chair can go over softer surfaces than a heavy adult.  The only consistent surface for all sizes of people and mode of transportation would be asphalt, concrete, or paver bricks.  Compacted gravel is the next best surface but needs to be compacted annually as it loosens up.

Question #10

Having 50% of all elements within the same area is unreasonable.  Some Oregon State Parks can  have over one hundred tables in an area.  To have 50 of those to be accessible is not reasonable due to the fact that it would not be feasible to connect accessible trails to all of them.  If they cannot be accessed by people with disabilities, what would be the point in having so many of them out in the park?  Two percent is more reasonable.

Question #11

The new reach distances seem acceptable.

Question #12

Each alteration should be assessed individually based on necessity and cost.  Whenever possible, an alteration should be made for ADA standards if the facility is lacking in that area.

Question #13

Most construction tolerances for the outdoor environment are adequate.

Question #14

Elements on inaccessible trails should not be accessible.  If the trail is made accessible at a future date, the elements would have to be made accessible as well.

Question #15

This should be based on the local conditions and terrain of the beach.  Requiring access routes every half mile would require parking every half mile which might not be possible or feasible.  Locating the beach access route near existing facilities such as restrooms should be the first priority.

Question #16

On Bureau of Reclamation reservoirs, the water level fluctuates seasonally from high pool in the spring to low pool in the winter.  The “normal recreational water level” changes daily.  Providing access to the water’s edge throughout the high use season is not reasonable.  Providing access to the high pool level would be appropriate.  As the water level draws down, access would be limited.

Dune areas are another difficult terrain to place trails.  Many dune areas are usually very steep with numerous hills.  Providing access routes through these areas would require moving large amounts of sand.  An additional problem of dune areas are that they shift constantly and trails can easily be covered up over time.

Avoiding areas where endangered species of plants and animals, such as the Snowy Plover nesting site on the Oregon Coast should also be considered.

Question #17

Only if the section of beach offers a significantly different experience or feature than other beach areas.  If there is a unique feature that can be feasibly connected from the parking area, the managing agency should attempt to do so.

Question #18

No comment

Question #19

No comment

Question #20

Yes, there should be exceptions.  If the facility in question is not accessible due to the exceptions listed, then the access route may not need to be ADA accessible or it may not be possible due to the same conditions for the exempt element.  It wouldn’t make sense to lead people to a facility that is not accessible for them when they arrive.

Question #21

The second option is more reasonable because each area may have different conditions that could qualify it for an exception to the technical provisions.  Locking in a percentage for all trails may not be possible if the area meets the conditions for an exception.

Question #22

The high tide or high pool markers are usually known within a given recreation area.  Existing facilities are usually above those markers.  Natural features and vegetation are good indicators of water levels with the exception of 100 year flood zones.

Question #23

Paths or trails that lead into the water may not be visible under the water especially if they change direction.  Some form of curbing, buoys, or railing may be necessary to keep people from straying off the trail into soft sand or mud.  If a flat level surface is provided under the water line for people to move about, it should probably be marked in the same way.  Technical specifications would have to account for shifting sands, wave action and erosion.  Routine maintenance would be necessary to ensure the route has not settled, split apart or has become obstructed by rocks, sand or drift wood.

Question #24

Unsure

Question #25

Could not find the Advisory note related to signs.

Question #26

A sign at the beginning of the trail (including Braille) to alert users of the type of obstacle and its distance from the trail head would be appropriate.  The sign could also indicate that trail surface indictors (bumps) for the visually impaired would warn them that they are approaching the obstacle.  If the obstacle is not passable by all users, a proper turnaround would be necessary.