Comments on U.S. Access Board guidelines (Docket No. 2007-02):
1. As a designer of outdoor recreation facilities with over 15 years experience, I feel the technical specification for ORAR’s in a reconstructed campground or day use facility is not reasonable. There needs to be an exception similar to the one the Forest Service put into their FSRORG. In the 9 reconstruction projects I have designed I have always strived to provide the greatest number of accessible sites as possible. However, when dealing with heavily vegetated steep terrain it is not always possible to construct a trail meeting the grade requirements of an ORAR for each unit without causing severe resource damage and/or completely changing the quality of the recreational experience. Clearing an entire slope in order to construct an accessible trail can look very unsightly and reduces privacy to the camp or picnic site. In most situations it takes a number of years before vegetation will re-establish and begin to soften the scar. Making the every single site accessible can destroy its character to the point that it is no longer a desirable place to camp or picnic.
2. Forest Service has undeveloped areas where we will place fire rings or pit toilets to control the location of use and protect the natural resources from damage. Because there is very little development and it is often at a “primitive” level we feel any trails in these areas should fall under the requirements of a trail not an ORAR. The guidelines need to differentiate between requirements of routes in developed areas vs. undeveloped areas.
3. The definition of alteration is not appropriate for trail alteration and needs to be clarified.
4. The language of the 2nd General Exception is vague and needs to be rewritten.
5. The standardized trail terminology of the Interagency Trail Data Standards needs to be adopted in to the Access Board guidelines.
6. It is not reasonable to require placing a barrier to warn of objects below 80" tall which extend into the trail if the barrier will restrict access down the trail.
I hope you will take these comments into consideration before issuing your final guidelines. The more restrictions placed on designers the harder it is to provide quality recreation experiences for all members of the recreating public.
Ann May, Forest Landscape Architect
Prescott National Forest
344 S. Cortez Street
Prescott, AZ 86303