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Summit Independent Living Center, Inc. An Advocacy & Resource Center for Montanans with Disabilities Serving Western Montana since 1981 700 SW Higgins, Suite 101, Missoula, MT 59803 • (406) 728‐1630 TT/Voice • Fax (406) 829‐3309 • www.summitilc.org May 19, 2010 Donna Gaukler Director Missoula Parks and Recreation 435 Ryman Street Missoula, MT 59802 Dear Donna Gaukler, Thank you for the opportunity to provide comment regarding Missoula Parks and Recreation’s intent to pave the Riverfront Trail from Orange Street to the Van Buren Street footbridge. July 26, 2010 marks the 20th Anniversary of the Americans with Disabilities Act (ADA), a comprehensive federal civil‐rights statute protecting the rights of people with disabilities, and so, we are thrilled to see the Parks and Recreation Department continuing to move forward in its goal to ensure that all Missoulians have full access to and are able to utilize the many outdoor recreational opportunities that our community has to offer. We applaud the Department’s efforts to ensure that those opportunities meet the standards set forth in the ADA’s Accessibility Guidelines at a minimum. We commend and fully support the Department’s decision to pave this portion of Missoula’s trail system. This portion of Missoula’s trail system is one of the most scenic and widely used portions due in large part to its location and its connectivity to various primary destination hot spots throughout Missoula including Osprey Stadium, McCormick Park, Orange St., Caras Park, Higgins St., the Downtown area, the Madison St. Bridge, and The University of Montana. The trail serves as a convenient and enjoyable route for commuters who prefer an alternative mode of transportation to driving. For commuters with disabilities, however, it isn’t always about choosing an alternative mode of transportation. Oftentimes people with disabilities do not drive themselves and sometimes do not have access to other means of transportation and so must rely on Missoula’s extensive trail and sidewalk network to walk, wheel, or ride from point A to point B and back. The concerns with the accessibility and the need for this improvement on this portion of the trail system are not born out of mere “convenience." While the accessibility problems on this portion of the trail system are most evident when there is inclement weather, there have always been barriers that have prevented it from being fully accessible and, as a result, at times difficult and/or impossible for some people with disabilities to navigate safely or at all. The trail is often resurfaced using crushed gravel that is typically laid down in a 2 to 3 inch layer that covers the entire width of the trail and it is left up to the traffic utilizing the path to compress the gravel so that it creates a firm and compacted surface. This creates a substantial barrier for individuals who use manual wheelchairs as well as walkers and even makes it very difficult for users of power wheelchairs to navigate. Furthermore, it does not provide a "firm, stable, and slip resistant" surface as is required by the ADA and, therefore, this type of gravel surfacing could arguably be in violation of federal law. Add this to the fact that we live in Montana and there always has been and always will be inclement weather, and what you have is a recipe for an inaccessible trail. Not only do the rain and snow affect the gravel surface of this trail during their ---PAGE BREAK--- occurrences, but, because the gravel surface is also harder to maintain, they also have lasting effects that contribute to the trail's unevenness and create potholes and other obstacles that are not conducive to a qualified accessible path of travel. It only makes sense to ensure that this vital connective link in Missoula’s trail system be brought up to full accessibility. Bicycles as well as foot traffic also tend to kick up loose gravel even on a trail that has been specifically designed with accessibility in mind, and without ongoing maintenance, any accessibility is quickly lost. Paving this section of the Riverfront Trail will not only enhance its accessibility and usability but it will also increase its durability and make it easier for the Parks and Recreation Department to maintain and ensure that it is continuously accessible to and usable by all. It is our strong opinion that paving this section of trail is the only long‐term solution to ensuring accessibility for people with disabilities and seniors now and into the future. Sincerely, Travis Hoffman Advocacy Coordinator