Dear Access Board,
I am pleased to present comments to the Access Board on behalf of the Washington State Recreation and Conservation Office (RCO)
formerly known as the Interagency Committee for Outdoor Recreation (IAC). We were one of the members of the Regulatory Negotiating Committee that worked to produce the Outdoor Developed Areas Report which is the basis for this new proposed rule.
Here in Washington, our state agency administers millions of dollars in different grant programs each year to other state, local, and federal agencies here. Many of the recreational types of projects that we fund would be covered under the proposed rule, if it applied to local and state governments.
We have used the 1999 Outdoor Developed Report for years here as our basis measure for access, to define if a project is accessible or not to a person with a disability. Agencies here have followed the scoping and technical provision as best practices and build new parks or renovated existing sites based on the report. While we know this isn’t going to be mandatory yet on most of our grant recipients, our office will continue to use it as our minimum measure of access.
The RCO has a long history of supporting access for all and have had a full time Recreation Accessibility Specialist since 1994 to help our grant recipients with access issues. Having a final rule to go along with the other access requirements here in Washington will be very helpful.
Please move this proposed rule along and continue to work to make this rule applicable for state and local governments covered under the ADA.
We agree with the proposed rule as written and would like offer a few answers to some of the questions asked.
Q 2. We agree with adding the word “Practical” and defining it better through examples.
Q 3. Do not use the blue ISA symbol on trails or areas not meeting the “built or existing” level of accessibility that is recognized now as accessible. We support using another similar symbol and in a color of green or brown and white. We support information on the signs as to the exact conditions of the access for trails.
Q 4. We support more beach route access.
Q 5. We support raising the minimum width to 60 inches and not requiring passing areas less than 1000 feet.
Q 6. We agree with providing more access to the other managed areas.
Q 7. Leave the height as written.
Q 8. Define “area” to help with applying it.
Q 9. We think that a surface “range” is Okay to consider depending on the numbers and how hard it is to define.
Q 10. Leave it as written in report. It was discussed for a long time and the outcome was fair.
Q 11. Leave it as written in report at 9 inches.
We support the proposed rule as written and with our answers to the questions asked. Thank You for the opportunity to comment.
and past member of the Regulatory Negotiating Committee
Rory D. Calhoun
Recreation Accessibility Specialist
Recreation and Conservation Office
Natural Resources Building
Olympia, WA 98504-0917