Dear Members of the Access Board:
I am writing in behalf of the New York – New Jersey Trail Conference in response to the request for public comments on the proposed accessibility guidelines for outdoor developed areas designed, constructed, or altered by Federal agencies subject to the Architectural Barriers Act of 1968. The proposed guidelines appeared in the June 20, 2007, edition of the Federal Register.
The New York – New Jersey Trail Conference is a federation of 104 hiking clubs and environmental organizations and 10,000 individuals dedicated to building and maintaining marked hiking trails and protecting related open space in the bi-state region. Our constituent clubs have a combined membership of over 100,000. We maintain over 1,700 miles of trails, primarily in state and local parks as well as 160 miles of the Appalachian National Scenic Trail.
A growing number our trails include accessible sections. We expect our state and local partners to be referencing the Access Boards recommendations whose policies we will incorporate into our procedures. Thus we are concerned about the details of those recommendations, particular as they apply to management and construction by volunteers. Our corp of over 800 dedicated volunteers devote about 40,000 hours of labor annually on a wide range of trail, resource, and visitor-management issues.
Comments on Questions:
Rather than restate comments made by others, we would like to commend to you comments already submitted by several of our partners. We whole heartedly endorse these comments.
Thank you for the opportunity to comment on the accessibility guidelines. As noted at the outset of these comments, the New York – New Jersey Trail Conference shares the desire of the Access Board to improve accessibility for persons with disabilities to outdoor environments including along trails and in campsites. In the past several years, we have gained experience in applying many of the guidelines along new or altered segments trails in our area. We will continue to incorporate accessible design in our trail design and construction processes and to strive wherever feasible to provide for improved access along appropriate segments in cooperation with our many local and state agencies.
Chair of Board of Directors