Thank you for the opportuntiy to comment on the Proposed Guidelines for Federal Outdoor Developed Areas (U.S. Access Board Docket No. 2007-02).
The Forest Service has been very proactive in providing universal access and a range of opportunities to forest visitors. I ask the Access Board to consider my comments and continue to help agencies, such as the Forest Service, continue to provide a full spectrum of recreation opportunities.
I have directly commented to questions 2, 3, 7, 9, 11, 12, 14, 20, 25, and 26. I have also included a general comment at the end.
Thank you again for your time and consideration.
/s/ Eric Sandeno
Outdoor Recreation Planner
Hoosier National Forest
811 Constitution Ave.
Bedford, IN 47421
Question 2: The term “not feasible” is used in Condition 4 to specify what is “reasonably do-able.” It does not refer to the technical infeasibility or possibility of full compliance with the technical provisions. Should the word “practicable” also be used in this condition? That is, are there situations where it would be “reasonably do-able” to comply with the guidelines, but it is not “practicable” to do so? Should there be more guidance for determining what is or is not feasible or practicable in applying Condition 4? If so, what type of guidance should be provided? Should the guidance give specific examples of situations where certain provisions such as maximum running slope may not be feasible or practicable for a portion of a trail?
Comment: You have asked if “not feasible” or “practicable” should be used, but I am guessing you really mean if “not feasible” or “not practicable” should be used. By definition, these words are very similar. Of these two choices, I feel “not practicable” or “impracticable” fits slightly better. To me, “not feasible” means not capable of being done and “impracticable” means not capable as planned. I also feel “inappropriate” is another term that could be considered. In the example given in T302.1 Condition 4 of the Proposed Guidelines for Federal Outdoor Developed Areas, Providing a trail with a 1:20 slope or less up a 1,500 foot tall mountain using heavy construction equipment may be feasible, but the trail would be at least 5.8 miles long (rather than 2 miles long under a traditional back-country layout), and may cause inappropriate environmental and visual impacts, specifically states the project is feasible, but inappropriate. If you are going to use “inappropriate” to define your meaning of “not feasible”, maybe “inappropriate” is a better term in this case.
Overall, examples of situations will lead to a clearer meaning of the intent and should be considered for other circumstances.
Question 3: A newly constructed trail that complies with the technical provisions for trails would be considered an accessible trail and is required to display a symbol designating the trail as accessible. The committee did not reach consensus on what symbol should be displayed on the sign. Some suggested that the International Symbol of Accessibility that is used to designate accessible features in buildings was not appropriate to designate accessible trails because the technical provisions for trails differ from the technical provisions for accessible routes in buildings, and using the International Symbol of Accessibility for accessible trails may convey the message that accessible trails meet the same technical provisions as accessible routes in buildings. Others suggested that the International Symbol of Accessibility be paired with the International Hiker Symbol. Comments on this suggestion or other suggested symbols are welcome.
The committee also recommended that trail signs provide detailed information about the trails’ running slope, width, cross slope, and other characteristics. This would enable people to make informed decisions about using trails based on the characteristics of the trails. On the other hand, it was noted that this approach might result in signs that would be too elaborate and complicated and some hikers might not be able to distinguish between the various characteristics to make appropriate choices. The Board requests comment on this issue. Information is provided in the advisory note to T321.2 showing examples of signs and other details. Question 25 also requests further comment on trail signage.
Comment: Even if a newly constructed or altered trail meets the technical provisions, The International Symbol of Accessibility (ISA) alone does not convey needed information or may misrepresent what people have become accostemed to ISA meaning. ISA has mainly been used in a built environement. Trails offer a very different experience than the built environment and ISA does not properly portray a trail experience.
Providing brief written information to all users so they can make an educated decision if a trail is appropriate for their skill level would be most beneficial. All trailhead signs on the Hoosier National Forest currently provide the name and length of the trail as well as a short description about the trail. Recently, we installed a new sign for an interpretive trail, which describes the typical and maximum trail grade, typical and maximum cross slope, typical and minimum tread width, surface type and firmness, and obstacles. This information is concise and appropriate for all users and provides more details about the trail than just ISA would provide. Also, this is a trail that was built in the early 1960’s and has not been altered since that time. Due to terrain, it is not an accessible trail. Since it is not accessible, ISA would not be posted on the information board about this trail. However, we were able to post information (as mentioned above) about this trail so forest visitors could make a conscious decision about whether they were going to use the trail or not. Again, this shows that properly describing conditions on the trail is more universal to more users.
Question 7: Height of a grill’s cooking surface is required to be 15 inches minimum to 34 inches maximum above the floor or ground surface. Is the 15 inch minimum too low? If so, what dimension should be used?
Comment: Most cooking surfaces on grills or fire rings have several settings to adjust the distance of the cooking surface from the heat source. Most individuals prefer to cook over coals, which requires the cooking surface to be fairly close to the heat source. Since the fire building surface for a fire ring is required to be no less than 9 inches above the ground level, increasing the 15 inch minimum for the cooking surface would cause the cooking surface to be too far away from the heat source. No change is needed.
Also, where possible, it would be helpful to keep numbers similar. There are times when exceptions are needed (such as fire rings) at that is understandable, but it would be easier for field administrators to adhere to the technical provisions if they are similar for fixtures found in an outdoor setting, when appropriate. For example, in this instance why would you change the 15 inches? As mentioned above, most cooking surfaces have several settings. If 15 inches is too low for someone, then can move it up one setting. Don’t arbitrarily create a maze of numbers that will be hard to remember.
Question 9: Extensive information is included in the advisory note to T303.3 (Table A) on the degree of firmness and stability of a trail surface. The Board is seeking comment on whether the recommendations for the degree of surface firmness and stability should be based on the length of travel, the intended use, or the direction of traffic. For example, surfaces that are moderately firm or stable may be appropriate in areas where a cushioned surface is preferred (e.g., for a multi-use trail that includes equestrians).
The Board requests comment on the concept of having a range of requirements for what will qualify as firm and stable. For example, is it acceptable for a trail under .5 miles in length to be only “moderately” firm? Is it acceptable for a trail less than .1 miles in length to be only “moderately” firm and “moderately” stable? Further, is it appropriate to consider a surface firm if the wheel of a wheelchair sinks into it by .5 inch? And, is it appropriate to measure both firmness and stability by the same wheelchair penetration test? While this information is only advisory, the Board requests comments on whether it should be included in the advisory at all.
Comment: No, the advisory note is complicated and does not take into account changes due to weather. Forest Service Trail Accessibility Guidelines (FSTAG) and Forest Service Outdoor Recreation Accessibility Guidelines (FSORAG) each contain definitions of firm and stable which have been easy to follow and should be used instead of the advisory note.
Question 11: The 2004 Architectural Barriers Act Accessibility Guidelines changed to the technical provisions for reach ranges. The low reach was changed from 9 inches to 15 inches minimum. Should the low reach for the fire building surface on fire rings be changed?
Comment: No! Campfires are a key component to the camping experience. Forest visitors enjoy the warmth provided by a campfire and especially the sight of their fire as they sit around it in the evening. Currently, the Hoosier has been replacing old in-ground fire rings with fire rings that stand 18 inches above the ground (9 inches filled in with gravel to provide a fire building surface and 9 inches to contain the fire). Forest visitors have commented that they feel as if they were sitting in front of a burn barrel and not an aesthetic campfire, because the fire can’t be seen as well anymore. Adding additional height to the walls (24 inch tall fire rings instead of 18 inch tall fire rings) would completely obstruct the fire, which would have a negative affect on the camping experience.
Question 12: The committee recognized that the distinction between alterations and maintenance activities is as critical to picnic areas, campgrounds, and beaches as it is to trails. Although the previous discussion specifically refers to trails, the examples could be extrapolated to include other outdoor elements. How should alteration and maintenance activities be defined for picnic areas, campgrounds, and beaches, including outdoor recreation access and beach access routes?
Comment: The defenitions found in T104.4 are lumped for both recreation facilities and trails. The definition of alteration in T104.4 also includes information about maintenance, which should be removed and addressed separately. Separate definitions need to be included for recreation facility alteration, recreation facility maintenance, trail alteration, and trail maintenance. Defenitions for some of these activities can be found in various sections in the Proposed Guidelines for Federal Outdoor Developed Areas, but need to be centralized in the “defined terms” section of the document.
Alteration of a recreation site, building, or facility: A change to a recreation site, building, or element or portion thereof that affects or could affect the usability of the recreation site, building, or element or portion thereof.
Maintenance of a recreation site, building, or facility: Routine or periodic repair to a recreation site, building, or element to restore them to the standards to which they were originally designed and built.
Trail Alteration: An action that changes the original purpose, intent, or design of the trail.
Trail maintenance: Maintenance is routine or periodic repair of trails or trail segments to restore them to the standards to which they were originally designed and built.
Question 14: Where trails are not accessible, the committee could not agree on whether elements such as benches, picnic tables, or toilet rooms located on a trail should be required to be accessible. For example, an element such as a picnic table may be located on a trail too steep to be accessible. The committee considered how future and existing technology will allow assistive devices to get over more difficult terrain. The committee discussed options to minimize scoping (e.g., one of each element) requirements or limit the requirement to certain elements such as sanitary facilities. Should elements located on inaccessible trails be required to be accessible?
Comment: Yes! The Architectural Barriers Act requires access to facilities designed, built, altered, or leased with Federal funds.
Question 20: The committee was unable to decide whether there should be exceptions from the technical provisions for outdoor recreation access routes based on the conditions in T302. Currently, departures from the technical provisions are permitted for specific elements, (e.g., picnic tables, camp sites) but not for the outdoor recreation access routes that connect those elements. Should exceptions be permitted for specific elements on the outdoor recreation access routes leading to those elements?
Comment: Yes! Many of the campgrounds on the Hoosier National Forest were built in the early 1960’s. The Forest has gone to great length over the past seven years to modify elements to make them more modern and more accessible. We have been very successful in making elements in the campgrounds, picnic areas, beaches, more accessbile with outdoor recreation access routes, however, we must work with the existing terrain. We will continue to make every effort for outdoor recreation access routes to connect elements. However, it may not always be “feasible” due to existing terrain without altering the setting. In such cases, exceptions to the technical provisions for outdoor recreation access routes must be be permitted in alterations.
Question 25: Some examples of proposed signs designating accessible trails are included in an advisory note. The committee did not reach a consensus on a particular sign. Comment is sought on these signs and other options. The proposed guidelines for trails require a sign on trails that meet the provisions and exceptions of T303.
Comment: None of the signs in the advisory note are appropriate. Trailheads, bulletin boards, information kiosks, etc. can easily become polluted with information to the point visitors will not even look at them. Adding another sign will just add to the potential sign pollution issue. Also, ISA or or a modified version of ISA will not adequately provide information to the trail user. It would also take a significant amount of public education for forest visitors to understand what a modified ISA sign meant.
See response to Question 3.
Question 26: The committee could not reach consensus on allowing a complete departure from this provision if the minimum overhead clearance could not be provided along a trail. Providing such a warning along a trail in the outdoor environment may have the effect of creating a barrier for all trail users. What other options are available on trails, specifically where there is a lack of sufficient space to move around an obstruction without significantly impacting the natural environment or setting?
Comment: In some cases trails do pass through narrow winding corridors, under ledges, or through caves which would prevent 80 inches of clearence. These permenent features are part of the natural setting and can’t be removed. A warning on the trail could block the trail for other trail users or become a safety concern. Horses may become spooked by an object on the trail and toss their rider or it could be run into by mountain bikes.
Information such as protruding objects of a permanent feature in which a warning can not be provided on the trail is a good example of an obstacle which can be identified on a trailhead sign, but a posted ISA symbol would not provide adequate information to the user.
General Comment: The Forest Service, National Park Service, Bureau of Land Management and the U.S. Fish and Wildlife Service have all identified and are implementing the Interagency Trail Data Standards (ITDS). The ITDS include standardized trail terminology and definitions, and standardized management concepts including Trail Classes, Designed Use, and Managed Use. Because the proposed accessibility guidelines will apply to these federal agencies the termnology and definitions identified in ITDS must be incorporated in the final Guidelines for Federal Outdoor Developed Areas.
For Example, T104 page 10 of the Proposed Guidelines for Federal Outdoor Developed Areas states the following:
A trail designed, constructed, or designated for pedestrian use may also have other uses, such as bicycling or in-line skating. It is recognized that pedestrians use all trails. However, these guidelines apply only to trails where travel on foot is one of the designated uses for which the trail was created. For example, a trail designated for mountain biking will not be considered a “pedestrian trail” whether or not pedestrians actually use the trail. However, a multi-use trail specifically designed and designated for hiking and bicycling would be considered a pedestrian trail. Trails include, but are not limited to, a trail through a forested park, a shared-use path, or a back country trail. Trails do not include pathways such as sidewalks, pathways in amusement parks, commercial theme parks, carnivals, or between buildings on college campuses. These exterior accessible routes are already covered by the Architectural Barriers Act Accessibility Guidelines issued in 2004.
The accessibility guidelines for trails apply to those which are designed and constructed for pedestrian use. These guidelines are not applicable to trails primarily designed and constructed for recreational use by equestrians, mountain bicyclists, snowmobile users, or off-road vehicle (ORV) users, even if pedestrians may occasionally use the same trails. People use these categories of trails by means of transportation other than foot travel or personal mobility device. Design and construction requirements for equestrians, mountain bikes, ORVs, and snowmobiles are based on the specific requirements for the intended mode of transportation. For the safety of trail users, pedestrian use may not always be permitted on these trails in order to minimize conflicts between motorized and non-motorized recreation. These trails do not preclude use by a person with a disability since it is planned that all trail users would be using the one or more alternative means of transportation for which the trail is designed and constructed. The design and construction of pedestrian trails without consideration of these proposed guidelines, by contrast, could present barriers to some trail users because the intended use is by foot or personal mobility device. For these reasons, the committee intentionally limited the application of the proposed guidelines to pedestrian use trails.
The underlined sections seem to contradict each other. To me, both are examples of a multiple-use trail. If the final Guidelines for Federal Outdoor Developed Areas adopts termnology from ITDS such as designed use and managed use, confusion on implementing the technical provisions may be alleviated.
Modes of travel that are actively managed and appropriate, considering the design and management of the trail.
There may be more than one Managed Use per trail or trail segment.
Managed Use indicates a management decision or intent to accommodate and/or encourage a specified type of trail use.
The intended use that controls the desired geometric design of the trail, and determines the subsequent maintenance parameters for the trail.
There is only one Designed Use per trail or trail segment.
Although the trail may be actively managed for more than one use, and numerous uses may be allowed, only one use is identified as the critical design driver. The Designed Use determines the technical specifications for the design, construction and maintenance of the trail or trail segment. For each Designed Use and applicable Trail Class, a corresponding set of standardized construction and maintenance technical specifications or Design Parameters can be identified and applied.