Appreciate your addressing this difficult and controversial subject. Accessibility and scenic/natural land characteristics are important as well as the practicality of implementation. As Landscape Architect I have to deal with many of the standards that you formulate so the nuts/bolts of the rules are important to me. Also, as recreationalist much of what your require shows up in my world there also. So, I appreciate the opportunity to offer the following limited comments.
Question 1. There should be a definite limit or strict boundaries on the application on accessibility requirements. Not all trails should not be required to be accessible; it is difficult, expensive, and not productive. Trails with accessibility requirements should be limited to highly used recreation trails generally associated with developed facilities in generally high use areas.
This is not to limit people, because those who do want to use wildlands use horses, mechanized aids and find the myriad of places they can go with a little bit of looking. There should be no need to modify areas outside of urban areas because with existing and coming technology it is easier to modify the mode of transportation than change the landscape. There should not have to be major modification in any trail to be made accessible; the earth need not be made flat to accommodate disabled people, better for disable people to prepare their modes to be suitable for the environment (i.e., track vehicles, OHV’s, etc.).
Question 2. Use of the word “Practicable” should be the rule. Most trails aren’t that heavily used to warrant modification for accessibility and solitude can be found most places about 50 ft off the beaten path and certainly by OHV if that is desired. We are on a threshold of change that will soon have technological devices that will allow disabled persons to navigate much of the world they have not been able to previously; it will soon be far cheaper to buy the devices for assisting the specific disability rather than modify the trail for accessibility standards.
There are not more people going to wildland recreation areas, outdoor recreational use is dropping and it is not a function of accessibility. Most people, including those with disabilities, prefer different activities, many can make it work without strict modification, and to make standards to modify every possibility does not mean it will be used. Some areas may be appropriate to be accessible and some may not; this should be a function of the initial assessment and there should latitude in that choice.
Question 3. In my opinion, the less signing in the natural outdoors the better. The only requirement should be to identify the trail. There are bulletin boards, brochures, books, travel books, accessibility advisors, web pages, etc. The public has never had access to more information than now. Signing a trail with more information than identification is an urban practice and urban character; make it occur there and get a guidebook for the great outdoors. Signs get vandalized, weather changes the trail daily, and there are so many ways to get the same info.
Suggest that the info be posted in an accessible place, such as an information board at a ranger station or the internet. People should not have to be hand fed every scrap of information. Also, it should not even be necessary to post the ISA symbol – that is part of the information gained elsewhere. Disabled person have the same responsibility for informing themselves as does everyone else.
Question 4: On a beach the raised area will be a problem for change in elevation of sand on either side due to weather wear. This artifact will be more of a problem than a cure because the ground level on each side will change due to heavy weather. Suggest use of temporary roll out walkways or use of the larger beach wheel chair supplied at the site.
Question 5: The request for comments on whether the passing areas are appropriate every 200 feet or more and should the size is sufficient is a good example of regulations that do not make sense in an outdoor setting and should be limited to urban environments. I crowded beach settings, possibly 200 feet are too far apart, and on a quieter secluded beach it probably doesn’t make any difference because there is a really good chance no one may be there with or without a wheel chair. Suggest that, if the strict distance limitation is necessary, that it only be applied to urban settings; more remote areas should be left out of the requirements or given the leeway to analyze the need for what is suitable or practical. What ever the application is stated in the regulations, it is most important to limit and definite to urban applications the boundaries or when the regulation is triggered.
Question 6: If the handicapped access to all areas are required outside of urban areas, these facilities probably will not be built in small use areas because of cost. Also, in smaller areas the facilities/concessions may change location frequently because they are often temporary. Again, the setting and volume of use should be defined or the regulation only should only apply to urban environments.
Question 9: It is difficult to apply the standard of penetration (sink only to ½") for firmness without defining a tire width and firmness. Surfaces are very difficult to control in wildland setting but not in urban environments. With a strict requirement of only ½" sinking of wheel, many new trails affected by these standards will not be built or be the trail changed from native soil to another substance that is uniform and firm; in many cases this will alter the character of natural trails. It is unreasonable to suggest that any non urban trail be changed to fit the character of an urban wheel chair.
By the limited responses I have given, I clearly think that you are extending into natural areas and low use faculties that are not necessary or that have little to be gained by anyone, especially those with disabilities. I suggest that that more consideration of applicability of regulations should be tied to amount of use expected of an area which in high use, falls back into urban standards thus confined to urban or high use areas as your application of these regulations and rules. Suggest more flexibility in your approach rather than blanket regulations.
Redlands, CA 92373