Please consider the following technical specifications regarding impacts on the natural settings of Forest Service trails and developed recreation sites concerning the Access Board’s proposed Outdoor Developed Areas accessibility guidelines.
- The definition of alteration should not be applied to trails – it does not fit when applied to something in a natural setting.
- The definitions for alteration and for maintenance of trails should be included in the definition section of the Access Board guidelines, just as they are in the definitions section of the Forest Service Trail Accessibility Guidelines.
- Include the exception in the guidelines for protruding objects below 80 inches in height when they occur on a trail where placing a warning barrier would block passage down the trail.
- Do not include the International Symbol of Accessibility in relation to trails. Instead, post useful information to all trail users in determining which trail best meets their skills and available resources, including maximum grade, cross slope, minimum width, etc.
- Rewrite the 2nd General Exception to include language from the Regulatory Negotiation Committee Report. As it is currently written it is confusing.
- Integrate the Interagency Trail Data Standards terminology, definitions and trail management concepts of trail classes, designed uses and designated use, including within the conditions of departure. The final Access Board guidelines should be useable within the federal agencies trails structures.
- Outdoor Recreation Access Routes should not be required in areas that are not developed recreation sites. The final Access Board guidelines need to make a distinction between developed recreation areas and undeveloped areas where facilities are placed primarily for resource protection.
- An exception for Outdoor Recreation Access Route grade/slope is needed for alterations and reconstruction of recreation sites. Without an exception (regardless of terrain, historic, cultural or environmental factors) the change would have a negative impact on incorporating accessibility while protecting the natural environment at existing recreation areas.
Outdoor Recreation Planner