This is a public comment on Docket 2007-02 regarding the Proposed Architectural Barriers Act Accessibility Guidelines for Outdoor Developed Areas. That was published in the federal registrar June 20, 2007.
This proposal leaves a lot of ambiguity for individual park managers to interpret regarding mobility devices. The accessibility board needs to provide a specific definition of a mobility device. In one area of the document you discuses a “mobility enhancement device” and refer to ATV and OHV. This is confusing language. I would like to see the document identify a “mobility device” as defined and approved by the Food and Drug Administration. The way this is written, it sounds as if ATV’s are considered a “mobility device.” ATVs are not an approved mobility device as per FDA guidelines. I would hate to see ATVs forced upon parks, forests, or refuges as a means of letting those with disabilities out on an otherwise non-motorized trail.
Also regarding mobility devices, Segways are not addressed. These machines are not approved by the FDA as a mobility devise, but as per FDOT should be considered on federal trails and transit. This is confusing the public as to how to classify a Segway. For this reason, the accessibility board needs to write a clear definition of a mobility devise and leave it up to individual field stations to approve for general use and not as means of access for someone who can’t walk very far. They should not be considered a “mobility devise” until FDA approves them as such.
As for the section on new beaches. I think that a “paved” access to the waters edge every ½ mile on a natural beach is very disturbing to Sea Turtle nesting habitat and nesting shorebirds, etc. The maintenance of these facilities would also be outrageous and therefore not practical at all. Some beach access is warranted, but every ½ mile is excessive. At many National Seashores, you have a regular pedestrian access at a mile interval. It would be more appropriate and universal to identify a percentage of beach accesses per beach unit designated as accessible. This would be similar to parking lots where a percentage of spaces must be designated disability parking.
Thank you for accepting my comments and look forward to seeing the final product.