General Comment: It is very helpful to have guidelines regarding accessible outdoor areas, especially trails. A future version applying to public areas owned and operated by state, county and local government agencies will be very useful.
Below are comments on specific sections of the draft.
Section T103.1.1 Construction and Manufacturing Tolerances — This has been used in previous guidelines. As with the public right-of-way guidelines, unless there are “conventional industry tolerances” identified in the guidelines by reference to a specific standard, then these tolerances do not exist and will be set by the agency preparing the specifications for the work. For example, for a 5% maximum cross slope, this could result in slopes that are at or below the guideline maximum, an additional 0.5% steeper for a cross slope of 5.5%, or 1% steeper for a slope of 6%, or even more.
Section T203 Trails — More about the distinction between a trail and a sidewalk is needed in this section. In some areas, there is not a separate sidewalk along the road and a separate shared use path, but just one shared use path running parallel with the road. Can this be considered a trail with its requirements that are less stringent than for sidewalks?
Also, in the second paragraph of the advisory, it says that trails covered by section T203 do not include (among other things) pathways between buildings on college campuses. This should be expanded to also include pathways between buildings in an apartment complex, and business or hospital campuses.
Advisory T206.2.2 Multiple Picnic Tables — The separation between picnic “areas” is a little unclear especially for small sites. For example, a small park might have a covered pavilion which is 100 feet from a river with picnic tables under the pavilion and outside the pavilion up to the river. Would this be one area, or two or three?
Section T214.1 Utility Sinks, General — On the second line, the word should be “sink” (singular) and not “sinks” (plural).
Advisory T303.3 Surface — In the third paragraph (and anywhere else it occurs) for decimal numbers less than one, there should always be a zero before the decimal point, e.g. 0.5 and not .5.
Section T303.8 Slopes, Exceptions: 1 — Please clarify what kind of open drainage structures are being referred to.
Advisory T306.1 Picnic Tables — Reconsider applying accessibility requirements only to fixed picnic tables. There are many picnic tables in federal outdoor areas that are not fixed to the ground (due to their size and tremendous weight); for some federal outdoor areas, none of the picnic tables are fixed.
Section T307.3 Fire Surface Height — Many fire rings do not include a fire building surface; they are just a metal ring encircling bare ground on which the fire is built. This requirement should perhaps be applied to a different fire facility such as a fire pit.
Dover, DE 19901