The final guidelines need to clarify “alteration” definition as it does not apply to trails.
Include definitions for alteration and for maintenance of trails in the definitions section of the guidelines.
No exceptions are provided for protruding objects below 80" in height when they occur on a trail but placing a warning can block passage down the trail. An exception needs to be made for this.
The IAS (wheelchair symbol) is not appropriate for trails. It has the connotation of a smooth sidewalk with little or no grade whatsoever. This is inappropriate for trails.
The second General Exception is confusing and appears to state that only 15% of the length of a trail need ever become accessible; this is misleading.
The final guidelines must integrate Interagency Trail Data Standards (ITDS). This is standard trail terminology, definitions and standardized management concepts including Trail Classes, Designed Use and Managed Uses.
Exception for Outdoor Rec Access Route (ORAR) grade/slope is needed for alterations or reconstruction. The ORAR specs work well in new campgrounds but often don’t in older; due to terrain or other it may be difficult without significant change to the environment. This exception should be allowed to maintain the setting.
ORARs should not be required in areas that are not developed recreation areas. The guidelines need to make a distinction between developed rec areas and undeveloped areas where facilities are placed mainly for resource protection.
Catherine Albers, PhD
Recreation Program Manager
National Forests & Grasslands in Texas
415 S. 1st St., Ste. 110
Lufkin, TX 75901