Jefferson County Open Space, Ralph Schell
October 10, 2007   [email]

Dear Sirs:

As a steward of lands of scenic, natural, cultural and historic value, Jefferson County Open Space has followed the evolution of guidelines for accessibility in outdoor-developed areas and for trails with great interest.  We have adopted modified versions of the Forest Service Trail Accessibility Guidelines and the Forest Service Outdoor Recreation Accessibility Guidelines as guiding documents to help us evaluate accessibility issues on our parks.  We feel that the current proposed rulemaking is likely to be detrimental in its application and a step backwards from both the Regulatory Negotiation Committee recommendations and from the Forest Service Guidelines. 

At the most general level we feel that it is essential that accessibility guidelines provide some level of reasonable exception to the most rigorous design criteria for accessibility.  There must be some recognition that the need for protection of natural and cultural resources can in a defined, rational way be balanced with the need to provide access to those resources. 

Some specific issues within the proposed Access Board guidelines that cause the greatest concern for Jefferson County Open Space are:

• The proposed guidelines do not permit any exceptions to the technical specifications for alteration and reconstruction of facilities in a restricted natural environment.  The net result might be a choice to remove facilities and therefore provide less access to the natural environment.  There should be exceptions provided for these situations.
• The proposed guidelines should not require Outdoor Recreation Access Routes in areas that are not developed as recreation sites.  Facilities that exist primarily for purposes of resource protection (such as pit toilets) should not trigger accessibility requirements beyond those that can be accommodated within the facility itself.
• The proposed guidelines have a definition for the term “alteration” that is applicable to buildings, but does not work for trails.  The definition for “alteration” and “maintenance” of trails from the Regulatory Negotiation Committee’s 1999 Report (page 6) should be included in the final Access board guidelines.

Thank you for your consideration of these comments.  We request to be involved with further comment opportunities and are available to answer specific questions on these issues.

Sincerely,

Ralph Schell
Director of Open Space

Jefferson County Open Space
700 Jefferson County Parkway #100
Golden, CO  80401

RS/kb

cc:  Board of County Commissioners
  Jim Moore, County Administrator
  Open Space Advisory Committee Members
  Amy Ito, Manager of Planning & Development
  B.J. Ellison, Planner