Gregory C. Jones
October 15, 2007   [email]

Dear Sir or Madam:

Time constraints prevented these minor & sometimes picky points being vetted through a formal organization so I am submitting them as an individual.

There are several specific points I’d like to suggest be revised in the Accessibility Guidelines for Outdoor Developed Areas.

  1. The definitions section needs to include a definition of “Access Route” as opposed to trail.
  2. A definition is needed for “pedestrian trail”.
  3. When specifying the removal of tread obstacles, does that include rocks & roots (which naturally recur despite removal)?  What about ground bees?
  4. The 2-inch rule for tread obstacles in T 303.6 conflicts with water bars for erosion control.
  5. The requirements under T 303.8 are completely untenable for most cross-country trails.  This could be appropriate for certain short distance access routes but cannot be done across the board.
  6. Many urban trails are not paved and paving them would change the experience & accessibility of these trails!
  7. Paving a trail to make it accessible to wheelchairs may make that same trail no longer accessible to other disabled persons who use equines to access that trail (and have done so for decades or longer).
  8. The rule regarding spaces in trails being no greater than ½ inch is fine for Board Walks but makes no sense for actual trails.
  9. There should be mention of the need for mounting ramps at some trailheads to help impaired individuals mount horses or motorized trail vehicles in those locations where those means of access are allowed.  Standards have been developed regarding such ramps which aid both wheel chair bound & non-wheel chair bound people.  You might get more info on this from NARHA (NARHA.org).
  10. T304.6 simply cannot be met within 1000 feet on many cross-country trails.
  11. There is no provision in Chapter T3 for exceptions due to extremes of cost.  Some allowance for reason should be made in a world of limited funds where using money for one purpose requires eliminating funding of something else.
  12. In Chapter T3 regarding Technical Provisions, Conditions 3 & 4 leave the impression that one could be required to put a culvert or bridge at every water crossing, but is murky.  Some will see this as not feasible.  Others see water crossings as part of the experience sought on trail, and these crossings are needed by equestrians to water & cool their mounts.  This provision as currently written guarantees future lawsuits!
  13. T 303.3 needs revision.  The term “prominent feature” is too vague for the 500-foot zone of no exceptions.  Perhaps “designated prominent feature” would be more appropriate.  This is also an invitation for lawsuits.

Thank you,

Gregory C. Jones, MD
[address]
Owingsville, KY  40360