National Association of State Trail Administrators, Stuart H. Macdonald
Dear Members of the Access Board:
These comments are provided on behalf of State Trail Administrators based on discussions at our annual meeting in September, 2007. We provide funding, both federal and state, for local project sponsors to build, improve, and maintain trails of all kinds on land managed by federal, state, and local jurisdictions. We want to be able to promote accessibility while providing clear definitions of accessible trails and outdoor recreation access routes. We also want to ensure that project sponsors can evaluate the feasibility of accessible trails under vastly differing circumstances, and to provide for accessibility in cost-effective ways.
Our comments on the Accessibility Guidelines are:
- The guidelines for accessible trails and developed outdoor recreation areas in the Regulatory Negotiation Committee’s 1999 Report, have three essential strengths which should be retained. First, the Technical Provisions make specifications for accessible trails and routes fairly clear and quantifiable. Second, the four Conditions for Departure from the guidelines also provide a clear methodology to ensure that new trail construction will be appropriate to their use and setting. Third, the trail terms and definitions for alteration and for maintenance of trails are clear and comprehensive.
- Keep Conditions for Departure as written in the original Report.
- The applicability or scope of the proposed guidelines must apply only to trails or trail segments connecting to designated trailheads or to other accessible trail segments. Make sure this is clearly stated.
- Make a clear distinction between accessibility requirements in developed recreation sites and those that are not developed recreation sites.
- Accessible Outdoor Recreation Access Routes should be required in areas that are developed recreation sites, but not required in areas that are not developed recreation sites. This follows the Condition for Departure which does not require an accessible trail to be built if it does not connect to an existing accessible trail or recreation site.
- Include these same Conditions for Departure for Outdoor Recreation Access Routes in alterations of existing sites to allow for routes that cannot meet accessibility requirements.
- Accessible elements may be provided or encouraged, even where the access trail is not accessible, but the trail connecting such elements should not be required to meet the standards of an ORAR. The original Report clearly states that “elements located on trails shall not be required to be connected by an outdoor recreation access route.”
- Hardening of trail surfaces should be clearly defined as trail maintenance, and not a trigger for requiring compliance with accessibility guidelines. Improvements to trails will generally increase accessibility, but it may not be feasible to decrease slopes, remove steps and obstacles, or reroute existing trails.
- Use the definitions of “alteration” from the original Report instead of the current version which applies to buildings but is not appropriate for trails.
- Definitions of trail-related terms should be consistent with accepted practice such as those included in the Forest Service Trail Accessibility Guidelines and Federal Interagency Trail Data Standards.
Stuart H. Macdonald
National Association of State Trail Administrators
701 Ivanhoe Street
Denver CO 80220