As a steward of lands of scenic, natural, cultural and historic value, Jefferson County Open Space has followed the evolution of guidelines for accessibility in outdoor-developed areas and for trails with great interest. We have adopted modified versions of the Forest Service Trail Accessibility Guidelines and the Forest Service Outdoor Recreation Accessibility Guidelines as guiding documents to help us evaluate accessibility issues on our parks. We feel that the current proposed rulemaking is likely to be detrimental in its application and a step backwards from both the Regulatory Negotiation Committee recommendations and from the Forest Service Guidelines.
At the most general level we feel that it is essential that accessibility guidelines provide some level of reasonable exception to the most rigorous design criteria for accessibility. There must be some recognition that the need for protection of natural and cultural resources can in a defined, rational way be balanced with the need to provide access to those resources.
Some specific issues within the proposed Access Board guidelines that cause the greatest concern for Jefferson County Open Space are:
Thank you for your consideration of these comments. We request to be involved with further comment opportunities and are available to answer specific questions on these issues.
Director of Open Space
Jefferson County Open Space
700 Jefferson County Parkway #100
Golden, CO 80401
cc: Board of County Commissioners
Jim Moore, County Administrator
Open Space Advisory Committee Members
Amy Ito, Manager of Planning & Development
B.J. Ellison, Planner