To Whom It May Concern,
I feel the following issues need to be addressed when preparing the final Access Board Outdoor accessibility guidelines. If some of the specifications are not changed by the Access Board they will have serious impacts on the natural settings of Forest Service trails and recreation sites. Please review the following critical issues:
The proposed Access Board guidelines only address the routes to facilities in developed recreation areas. 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. Unless that distinction is made, the FSORAG will have to be changed so that facilities in undeveloped areas would be required to be connected to an ORAR and that would have negative impact on undeveloped areas.
However, the proposed Access Board guidelines do not permit any exceptions to the ORARs technical specifications, regardless of the terrain, historic, cultural or environmental factors, even in alteration/reconstruction situations. The final Access Board guidelines need to include an exception for ORARs in alterations of existing sites, so when a section of an ORAR in those alteration locations can’t meet the ORAR maximum-grade specifications there is an exception available.
If the final Access Board guidelines do not include such an exception, the FSORAG will have to be changed to not permit any exceptions to meeting the ORAR specifications in alterations of existing sites. That change would have a negative impact on incorporating accessibility while protecting the natural environment at existing recreation areas.
Sincerely,
Carlita Hallett