To Whom It May Concern,
It has come to my attention that some of the proposed Outdoor Recreation Accessibility Guidelines may seriously impact our natural environment and possibly rob persons with disabilities the opportunity to experience the outdoors in ways that would give them a sense of adventure.
I am a designer who is very familiar with the requirements to make a facility accessible. The standards are perfectly applicable on flat, highly altered environments. I live in a very mountainous forested area. In order to meet the proposed requirements for grade for ORAR’s and trails the forests would either have to be decimated or have no facilities constructed or reconstructed. This will rob all of the public (including persons with disabilities) from enjoying the great outdoors. Please see the specific comments below:
The proposed Access Board guidelines have a definition for alterations that is fine for buildings, but will be disastrous to trails. Please clarify that the definition will not apply to trails. Please include the definitions for trail alterations and maintenance that were included in the original Regulatory Negotiation Committee’s 1999 Report (page 6). The International Symbol of Accessibility (ISA) is proposed to be used for trail signs. This is very unfortunate because there are different design standards associated with the ISA symbol that would be impossible to apply to trails. The public is used to seeing the ISA symbol to denote accessible parking spaces. Parking spaces are required to not exceed 2% slope, have no obstacles and a large area for maneuvering. Trails in the mountains cannot meet these requirements nor is it desirable. Trail signs that identify the slope, width, surface and length, etc. will give users of all abilities the opportunity to assess if the trail is right for them.
Please include this type of trail sign in the final outdoor guidelines instead of the ISA symbol. Please include the federal Interagency Trail Data Standards (ITDS) which include terminology, designed use, and Conditions of Departure into the final Outdoor Accessibility Guidelines. This will support a range of trail experiences for users of all abilities.
It is imperative that Outdoor Recreation Access Routes not be required at sites that are not developed. It is important to be able to keep some areas more primitive and undeveloped in order for the public (including persons with disabilities) to experience a wide range of recreation experiences in an outdoor environment. Sometimes primitive restroom facilities and tables may be put in to protect the natural resources. It would be remiss to make all of the outdoor sites similar to highly developed urban environments.
It is also extremely important to include exceptions for ORARs for alterations and new constructions in regards to terrain, historical, cultural and other environmental factors. If there is not an opportunity to have exceptions then existing facilities in mountainous areas will fall into disrepair may be a safety hazard for visitors. In mountainous areas, the only way to meet the design criteria for ORARs in new construction is to bulldoze the existing terrain which removes the trees and all other vegetation. Most people go to the forested mountains to have an experience in nature and not a shadeless parking lot.
Thank you for considering these suggestions. It is important that we keep a wide range of outdoor experiences for visitors of all abilities.
Forest Landscape Architect
Shasta-Trinity N. F.