Dear Architectural and Transportation Barriers Compliance Board:
This is in response to your invitation for public comments to the Proposed Accessibility Guidelines for Outdoor Developed Areas published in the Federal Register on June 20, 2007.
I am writing on behalf of the Georgia Appalachian Trail Club (GATC). GATC was organized by the USDA Forest Service in 1930 as a volunteer group to construct and maintain the Appalachian Trail (AT) in Georgia. Today, that is the Appalachian National Scenic Trail. The southern most 75 miles of the AT is in Georgia, and that resides entirely in the Chattahoochee-Oconee National Forest (C-ONF). GATC manages, maintains and protects the AT in Georgia under what is now a 77-year-old agreement with the Forest Service. To those ends, we contribute 12,000-15,000 volunteer hours annually.
I currently serve as GATC’s Conservation Director. Among my responsibilities is receiving, reviewing and responding to proposed actions by government agencies and non-government entities which will impact the AT, and the AT experience. Generally those involve projects and special uses on the C-ONF. Occasionally, broader issues have been addressed. Forest Service Trail Accessibly Guidelines (FSTAG) and the National Trail Classification System are among those broader issues.
GATC is one of 30 AT volunteer maintaining organizations under the jurisdiction of the Appalachian Trail Conservancy (ATC), formerly the Appalachian Trail Conference. ATC is the non-government partner of the US Department of Interior’s Appalachian Trail Park Office (ATPO) that manages the entire AT. ATC participated on the regulatory negotiation committee that developed the accessibility guidelines now being addressed. As a consequence, GATC and the other AT maintaining organizations were made generally cognizant of these forthcoming guidelines.
Along the 2174 miles of the AT from Georgia to Maine, small, usually 3 sided, shelters can be found approximately one day’s walk apart. These shelters are traditional along the AT, and most predate National Scenic Trail designation. Twelve (12) such shelters exist on or near the AT (and an approach trail) in Georgia, all in the C-ONF. In the past 2 years GATC has retired the oldest shelter in this system and constructed a new one at a nearby, less environmentally sensitive, location. In recent years, GATC has constructed food container hoist systems (to deny animals, primarily bears, easy access to hikers’ food) and moldering privies at each of these shelter sites. All of this construction took accessibility criteria, as we understood them at the times, into account. The newest shelter and privy site also includes tent pads, a steel fire ring and a picnic table. ATC’s employee assigned to accessibility matters for the entire AT inspected the site, and signed off on our work.
A large amount, if not most, of that work, was done prior to the Forest Service publishing their final FSTAG.
All of my comments should be considered from the perspective of a hiker/backpacker involved with volunteer hiking trail construction and maintenance. All of my comments pertain to hiking trails in remote, natural settings. Those trails may not be exclusive to hiking.
None of the following should be construed to mean the writer’s or GATC’s complete agreement with FSTAG or Forest Service Outdoor Recreation Accessibility Guidelines (FSORAG). FSTAG is untested in our area. It is not completely objective, and it is sufficiently complicated as to be a source of controversy, when it is put to a practical test.
You have acknowledged FSTAG and FSORAG, indicating the Forest Service will revise both “as needed to incorporate the Board’s guidelines.” As I read FSTAG and FSORAG and the Board’s guidelines, I find several inconsistencies between the former and the latter. Three of these on which I will submit comment on below are:
Interagency Trail Data Standards
For reasons beyond my understanding, FSTAG applies only to Hiker/Pedestrian designated trails. The Hiker/Pedestrian designation is established in the Interagency Trail Data Standards (ITDS). (Also referred to as the National Trail Classification System.) Logically then, FSTAG is defined on the ITDS. The Accessibility Board does not even mention the ITDS in their guidelines. That would imply that FSTAG is totally non-compliant with those guidelines. The term Hiker/Pedestrian Trails, regardless of the intuitive understanding of the words, has no real meaning, in this context and relative to other designations, absent of the ITDS.
I do understand that the ITDS was developed jointly by the Forest Service, the National Park Service, the Bureau of Land Management and the Fish and Wildlife Service. These are the federal government agencies that have trails. They have a lot of experience managing trails. The classification system seems to be an evolved inventory and management tool developed by the knowledgeable persons from those agencies. Your guidelines would be better presented, and eventually implemented, if they were integrated with ITDS.
Outdoor Recreation Access Routes
When the Forest Service was inviting comment on FSTAG, they pointed out that those provisions of FSORAG applicable to trails in General Forest Areas (GFA) were included as an appendix to FSTAG. GFA is differentiated from developed recreation areas such as campgrounds with improvements intended more for convenience than for resource protection. All 12 of the shelters along the AT in Georgia with their associated moldering privies and food container hoist systems are in GFA. Improvements at these sites are intended for resource protection, not convenience. That would be generally true along the entire length of the AT. In the 8 national forests through which the AT passes, there may be some shelter locations outside GFA, but not many.
The Accessibility Boards guidelines require ORAR everywhere there are “accessible elements”. The 40% criteria for like elements is not a limiter when the elements are so few so as to always require rounding up to unity. The clear implication is that the Forest Service will be required to revise, or rewrite entirely, FSTAG and FSORAG to mandate ORAR everywhere, including shelter sites along the AT in national forests.
This ORAR requirement also would extend to the two national parks through which the AT passes.
The shelters and any associated resource protection facilities at those locations were established with minimum site preparation and disturbance. The locations are usually remote, natural places on uneven, mountainous terrain. The specific sites at those locations for any of the resource protection facilities, that is privies, tent pads, fire rings, food container hoist systems etc., were chosen for reasons that were unique to the facilities’ requirements and the natural character of the location. Those include, level or sloping terrain, locations of trees, distance from and orientation to water sources, and sometimes which way the prevailing wind blows. Considering these as “accessible elements”, there may be no physical way to connect them with a firm and stable surface path, and also with a grade that meets the criteria of an ORAR, without using materials and methods of construction that are, at best, inappropriate for the setting. At worst, it may be impossible, given terrain and location of the “elements”, relative to each other, and the general remote location. Somewhere in between is getting path surface hardening material and/or sufficient ramp lumber to the location. That amount of that material may be several times the mass (weight) of the material used to construct the shelter and facilities. These locations are generally not accessible by motorized, wheeled utility vehicles, trucks. Methods to move material to these locations have been by helicopter (when available and affordable), packhorse trains, and on volunteers’ backs. It will usually be volunteers that will have to handle the material, on the front and back ends, and do the construction work. Construction of these ORAR could easily eclipse all previous work at the location, over all of its history.
An unavoidable compliance option may be to abandon the shelters or the resource protection facilities. None benefit from that. This is not to imply any cost-benefit consideration beyond motivations of volunteers, who likely will see no value in the work. The Forest Service has it right on Outdoor Recreation Access Routes in General Forest Areas.
Q&A (Perceived pertinent to ORAR)
| Your ? # | Response |
|---|---|
| 1 | Yes, you should reconsider approaches rejected earlier. There is more than frontcountry and backcountry that should be considered. Remote backcountry and wilderness should also be in the categories. |
| 2 | Condition for Exception 4 is very important to these guidelines being credible. There are many, many miles of trails in extremely remote areas of federally owned lands. It truly will not be feasible for most of these ever meeting your guidelines. Inclusion of the word “practicable” strengthens Condition 4, and we would welcome its inclusion. |
| 9 | Firm and stable surfaces on totally natural trails are going to be very difficult to achieve. They will vary with weather. Your reference to equestrian needs is interesting. In our region, if it has been raining, horse traffic can turn a natural surface trail into mire. Stringent tests for surface conditions should be avoided. |
| 10 | In the ORAR discussion above, an effort was made to explain what might be required to connect accessible elements at a remote trail shelter/camp site on the Appalachian Trail. Backcountry, remote backcountry and wilderness campsites everywhere would be similar. Where there are accessible design elements at these locations, picnic tables fire rings, privies, tent pads, shelters, etc., they are so few in number, that putting a percentage requirement on connecting them is pointless. There should be some minimum number of accessible elements at a single location before this stipulation is in effect. |
| 13 | Yes, there should be different construction tolerances in different outdoor environments. In backcountry, remote backcountry and especially wilderness, natural materials from the immediate area are frequently used. Minimum, often vintage type, hand tools are employed. When construction material is brought in, it is often of an unfinished type, rough sawn lumber for example, so as to be compatible with a rustic setting. This may be an actual architectural requirement of a governmental agency. |
| 14 | As mentioned above, our organization has, under the Guidance of ATC, strove to comply with accessibility guidelines, as we understood them, in the construction and reconstruction of certain structures located at sites along the AT where primitive shelters are located. These locations are remote, on or near existing hiking trails that have little to no possibility of ever meeting accessibility criteria. Our experience with this has included modifications, redesigns, and reworks at the direction of the Forest Service. Volunteer time and toil was diverted from other activities to accomplish this. (Again, cost-benefit evaluation is only at the level of the individual volunteer. It is a motivation issue.) If the Forest Service is soon be required to revise FSTAG so that accessible elements at a GFA location, remote sites in a National Forest, be connected by ORAR, far more volunteer time will be necessary to comply, at many locations, than was ever expended over their entire history of those locations. The conflicts this presents could simply be avoided if the elements were not regarded as accessible. Please consider designating these “elements”, regardless of design, as accessible, if and only if they are on or near an accessible trail. This is logical, and it does not preclude the designs of the “elements”from being accessible. |
| 19 | Open drainage is fundamental to even the least developed of maintained trails. Flowing water, from rain or snowmelt, can rapidly erode treadway if water is allowed to remain in it. Water diversions are employed as part of trail construction and ongoing upkeep. Their purpose is to direct water on treadway flowing downhill off of the trail. Obviously, the slope of the diversion has to be greater than the cross slope of the trail. Dips are one form of water diversion. Another is what is commonly referred to as a “waterbar”. These are formed with natural materials such as rocks and logs found in the immediate area. Both forms of diversions are organic to the trail itself, and any outflow slopes are dependent on trail slopes. |
| 20 | Yes, exceptions should be allowed for ORAR. Where a small cluster, 1-8, of accessible elements exists along a remote, non-accessible criteria trail, and those are present as resource protection, accessible paths should not be required to connect them. The elements are sited so as to least disturb the environment. They may be separated horizontally and vertically so as to require paths much longer than the straight-line distance between them to connect them, and also meet slope requirements. The long paths are damaging in themselves, but there is a prevalent tendency for people to short cut these types of paths, and that does additional damage. |
| 21 | Of the 2 options presented, the set of exceptions under T302 is the preferred option. |
Signage
Your guidelines would require the International Symbol of Accessibility at trailheads. This symbol is so familiar with the public and understood to mean something that even the most stringent of your guidelines cannot universally provide. It will present a message that ultimately will be misunderstood by many. As a consequence it will be regarded as misinformation. That is all ways bad, but particularly so in the natural, outdoor environment.
Q&A (Perceived pertinent to signage)
| Your ? # | Response |
|---|---|
| 3 | The handicapped symbol you refer to should not be used at trailheads except those suitable for use by all handicapped people, without question. It is too familiar a symbol and conveys the concept of non-difficult. Everyday, somewhere, people set out on backcountry trails and soon find that they are more physically challenging than they expected. Except for purposes of safely, no one should be discouraged to take to a trail. But, they should not be falsely encouraged either. The symbol will almost certainly do that for some. |
| 25 | Same comments as for question number 3. |
The opportunity to participate in this process is a great privilege that needs to be acknowledged. Our continuing social-political experiment that respects the rights, the interests, and the opinions of all of our people is something we should be continually thankful for and proud of.
Yours truly,
Denny S. Rhodes
4360 Laurel Brook Drive
Smyrna, Georgia 30082
770-435-2445
Conservation Director
GEORGIA APPALACHAIN TRAIL CLUB
Ours is a Friendship of the Trails That Lead to Far Away Places