Coronado National Forest, Debby Kriegel
Dear Access Board:
Thank you for the opportunity to comment on the Proposed Architectural Barriers Act Accessibility Guidelines for Outdoor Developed Areas. I am a huge accessibility advocate and applaud the Access Board’s efforts to provide accessibility guidelines for the outdoor recreation environment.
I have been a Forest Service landscape architect for over 18 years. I am submitting this letter on my personal time, though my comments reflect professional experience applying accessibility guidelines to a wide variety of recreation facility design and construction projects over the years. I believe it is very important to make some changes to the proposed guidelines before they are finalized. My major concerns are related to the potential for these guidelines to significantly and negatively alter the natural environment, compounded by the fact that they would require expenditures of federal funds (taxpayer money) in a manner that is not responsible and would not maximize accessibility benefits for visitors.
Here are my comments, grouped into two categories: critical and recommended.
Critical changes needed:
- The guidelines provide no clear distinction between developed and dispersed sites. When developed campgrounds and picnic areas (i.e., places with facilities like roads and parking, restrooms, tables, grills, trash bins, etc.) are renovated, it makes sense to improve access as much as is feasible. In remote camping and picnic areas where the site is entirely natural except perhaps a simple fire ring is provided to protect resources, it does not. The guidelines must clearly define and differentiate between developed and dispersed sites. In fact, the title for this document includes the words “Developed Areas,” as does the first sentence in T101 Purpose. Dispersed sites are not developed areas!
- The guidelines would require Outdoor Recreation Access Route (ORARs) at all sites in developed sites, as well as in dispersed sites. On the Coronado National Forest, and in much of the west, outdoor recreation sites are in rugged, natural settings (mountains, canyons, etc.). The proposed guidelines provide no exceptions in locations where topography makes it difficult or impossible to create accessible ORARs. Requiring ORARs to every camp or picnic site would, in many locations, require massive earthwork, ramps, and railings, causing enormous negative impacts to the natural settings that visitors come to the forest to experience, and at an equally enormous expense. The limited Federal funds available for recreation site improvements should be spent at sites where accessibility is feasible, not wasting money fighting nature at difficult sites. Doing so will result in fewer accessible sites overall!
- The guidelines (T318.3.4) would require a 3" edge on tent platforms. Adding an edge to raised platforms would create an obstacle (making it difficult for users to transfer from a wheelchair into a tent). For at-grade tent pads, requiring an edge would create a tripping hazard (campers walking around in the dark don’t need extra manmade elements to trip over!). This item should be deleted, or modified to read, “Where tent pad edging is required for safety, it shall be 3" high minimum”.
- The guidelines do not include applicability criteria for trails. A flowchart similar to the one in Appendix A of the Forest Service Trail Accessibility Guidelines (FSTAG) would be extremely useful, and would help focus accessibility improvements on appropriate projects.
- The accessible trail signs shown in the first Advisory section T321.2 use symbols that have not been tested in the field and may confuse many visitors. I recommend omitting this first advisory and including only the other two Advisories in this section.
- It would be helpful to provide an illustration of a typical campsite, showing the facilities (table, grill, fire ring, etc.) and minimum dimensions between each item in addition to simply stating the clear space requirements around each item. This would also be a great place to use terms that would be helpful to designers and contractors such as driveway vs. parking space, camp living area vs. parking spur, etc.
- For the trail guidelines (T303), it would be best to move the information on running slopes and resting interval to the first part of this section (along with surface), since these generally are more substantial issues than some of the other items (such as width, openings, obstacles, and passing spaces).
- The layout of the document makes reading and finding topics difficult. A table of contents would be helpful. Headers should be much larger. And format the document so that a printer will not place a heading or the first line in a boxed item as the last line on a page (my document printed out with many of these problems).
Thank you for considering my comments.
/s/ Debby Kriegel
Forest Landscape Architect
Coronado National Forest