General Comment: Comments regarding the Access Board’s proposed Outdoor Developed Areas accessibility guidelines, Docket No. 2007-02:
I am providing my comments as a private citizen, but wanted to state that I am a Forest Service recreation/trail manager wanting to offer my personal comments based on my experience as a field manager.
The current FSTAG and FSORAG guidelines currently in use by the Forest Service are working just fine, and I see no need for change. They were based on the original Access Board’s 1999 draft and have proven to be successful. I disagree with a number of items that are changes from the 1999 draft, FSTAG, and FSORAG. I disagree because I fear these changes will alter the natural setting and experience that our forest users come for. I have concerns with the following specifics:
The proposal is not in compliance with the Interagency Trail Data Standards used by all the Federal land management agencies. This presents problems with terminology and confusion over what to apply under what circumstances.
The definition of alteration and maintenance is not consistent with FSTAG, again causing confusion.
Need an exemption for a barrier device for protruding objects less than 80" clear headroom, because caves and or other terrain features may make it impossible or unsafe install such a device.
Do not post the wheelchair symbol on trails because trails will not offer the same degree of accessibility found in developed areas (such as a downtown sidewalk). Also, do not create new symbols; people don’t seem to understand the international symbols that are out there now, much less new ones. Instead, post a simple description at the trailhead of what to expect.
The proposed definition of a trail is that of an Outdoor Recreation Access Route, which in FSATG are routes within developed recreation areas. Things are different in the woods (in setting and experience), and should reflect as much in the standards. Again, use the FSTAG definitions.
Fire rings: As a manager, I receive numerous complaints about accessible fire rings. I urge the Access Board to drop the height/reach requirement and implement my suggestion (described below). The designs that meet the current FSORAG requirements result in a fire ring that resembles a 55 gallon drum with a fire in it. There is not enough air circulation for the fire to burn well, and people simply can’t see the flame. A campfire is a very important part of the outdoor experience, and takes away a lot when people can’t experience the aesthetics of a flame. I’m all for facility upgrades when it benefits everyone or doesn’t deprive anyone. This is almost always the case with these guidelines. But, when a large majority of users are deprived of their experience for the benefit of a select few, you have now created another group of people who are being discriminated against. At the risk of sounding calloused and politically incorrect, is it the right to take away the experience of the vast majority of users for the accommodation of a minority of users with a disability? I suggest allowing agencies to have the option to provide two fire devices so both groups can be accommodated: provide a pedestal grill so a person with a disability can have an accessible cooking surface, and allow a ground level fire ring for those desiring a traditional campfire.
Thank you considering my comments.
Bloomington, IN 47401