Charlotte T. Minor
Dear Access Board Members:
I am writing both as a professional landscape architect with the Forest Service and as an outdoor enthusiast. Early in my career, I had the opportunity to attend a week long training session about accessibility. Included in the session were many people with disabilities as well as able bodied people. We spent a few days in a classroom setting, then spend four days camping, canoeing, cooking and living together in the backcountry of Minnesota. This was the most enlightening experience I've ever had, and it highlighted to me the need to make guidance we develop for accessibility meet everyone’s needs. By this I do not mean have everything the same. I mean letting each person be able to choose the experience and level of activity that we can manage. To acknowledge the differences between urban and rural settings, as well as those between a developed area and a dispersed or backcountry area.
In caring for my elderly parents, both of whom had mobility limitations as well as having vision impairments, I was well aware of the need to prepare differently for an urban setting or developed campground, versus a rural setting and “throw-down” camping area. We enjoyed both activities together, but we all would have been sorely disappointed if the rural settings were as highly developed as the urban settings. In the latter example, we were expecting rougher terrain, a campsite with limited facilities, walking across undeveloped ground to use a restroom, and having to choose hiking trails that met our needs. We were seeking nature and know that natural environments are not flat or paved, and don’t have a clearing width that accommodates every user. We wanted to make the choices, instead of having them made for us.
I am also voicing my support for the following technical items as they relate to the differences between the Access Board and the Forest Service Guidelines:
- The final Access Board guidelines need to clarify that definition of alteration does not apply to trails (it applies to buildings).
- The definitions for alteration and for maintenance of trails in the original Regulatory Negotiation Committee’s 1999 Report (page 6) must be included in the definitions section of the final Access Board guidelines.
- An exception is needed in the final Access Board guideline for protruding objects below 80 inches in height when they occur on a trail where placing a warning barrier would block passage down the trail.
- The final Access Board guidelines should not use the ISA on trails, but should require information be to be posted that is useful to all trail users in determining which trail best meets their skills and available resources, including maximum grade, cross slope, minimum width and so forth, as detailed in the FSTAG 7.3.10.
- The final Access Board guidelines must go back to the original Regulatory Negotiation Committee’s language for the 2nd General Exception. It is clearly written and understandable.
- The final Access Board guidelines must integrate the ITDS terminology, definitions and trail-management concepts of trail classes, designed use and designated use, including within the Conditions of Departure, in order for the final Access Board guidelines to be useable within the federal agencies trails structure. These provide the information required for people to make an informed decision.
- Outdoor Recreation Access Routes (ORARs) should not be required in areas that are not developed recreation sites. For example, in areas where facilities such as fire rings or portable toilets are placed primarily so that they protect national forest resources, the trail specifications should apply versus ORAR specifications.
- The final Access Board Guidelines need to make a distinction between developed and dispersed or backcountry settings. It is not appropriate, nor desirable, to have highly developed facilities in an undeveloped, rural setting.
- An exception for Outdoor Recreation Access Route grade/slope is needed that addresses alterations/reconstruction. In rural settings where the emphasis is on the natural setting, it is appropriate to depart from the guidelines and allow an exception so that grade/slope specifications do not have to be met.
- The final Access Board guidelines need to include an exception for ORARs in alterations of existing sites, so when a section of an ORAR in those alteration locations can’t meet the ORAR maximum-grade specifications there is an exception available. In most of these cases I think that good signing and information (in a variety of forms) helps users make decisions about what they are able and desire to do. Lets keep the choice up to the individual and respect that rural, undeveloped settings should remain just that, undeveloped.
Thank you very much for your attention, and for the opportunity to comment on the guidelines.
/Charlotte T. Minor/
Flagstaff, AZ 86001