203 Governor Street
Richmond, Virginia 23219-2010
State Parks • Soil and Water Conservation • Natural Heritage • Outdoor Recreation Planning
Chesapeake Bay Local Assistance • Dam Safety and Floodplain Management • Land Conservation
L. Preston Bryant, Jr., Secretary of Natural Resources
Joseph H. Maroon, Director
Date: October 18, 2007
To: Office of Technical and Information Services, Architectural and Transportation Barriers Compliance Board
From: Robert S. Munson, Planning Bureau Manager, DCR-DPRR
Subject: Comments — Docket No. 2007-02
The Department of Conservation and Recreation, Division of Planning and Recreational Resources has reviewed 36 CFR Part 1195 accessibility guidelines and would like to offer the following comments:
Question 1 – More experience constructing trails using the existing rule at the local level should determine whether another approach may be needed.
Question 2 – As long as not feasible specifies what is “reasonably do-able,” the term practicable is not needed.
Question 3 – A green color is preferred, top left sign on page 35. Land managers should be provided with examples of different approaches to signage that can be adapted as appropriate to help users determine if a trail meets their skills and desired experience.
Question 9 – The description of T303.3 should include a bulleted list with examples of common surface types. Firmness and stability should be based on intended use.
Question 12 – The same special conditions provided for trails should be provided for alterations and maintenance in beaches, campsites and picnic areas. Use the definition of “alteration” from the original report instead of the current version, which applies to buildings but is not appropriate for trails.
Question 15 – The requirement for an access route for every one-half mile of linear feet of new beach is not appropriate, and may kill some public access projects.
Question 16 – Some reports predict that 25 percent of coastal land in Hampton Roads may be underwater within this century. Low-lying coastal areas should be exempt from these requirements, so limited federal funds can address other more pressing needs.
Question 18 – State and federal lands designated for conservation management or species protection should be exempt from these requirements.
Question 19 – More experience constructing trails following this rule at the local level is needed to determine if additional drainage structures should be allowed this departure.
Question 20 – The conditions for departure should also be applied to Outdoor Recreation Access Routes. Make a clear distinction between accessibility requirements in developed recreation sites and those that are not developed. ORARs should not be required in areas that are not developed recreation sites. Trails that connect accessible amenities should not be required to meet the standards of an ORAR.
Question 21 – Apply conditions in T302.
Question 26 – Support retaining the application of the four conditions for departure with regard to protruding objects.
Definitions of trail-related terms should be consistent with accepted practice such as those included in the Forest Service Accessibility Guidelines and Federal Interagency Trail Data Standards.
The Access Board guidelines should include a decision-making flow chart (as in the Forest Service Trail Accessibility Guidelines) or similar process diagram that illustrates how the general exceptions and conditions of departure can be applied in the trail design and construction process.
We appreciate the opportunity to comment.