City of Lakeland, Eric Bridges
October 15, 2007   [email]

Mr. Botten,

Thanks for allowing me to comment on the proposed guidelines.  We have spoken in recent years about this topic and it is exciting to see the progress that has been made.  My comments are based mostly on outdoor trail accessibility guidelines but some may be universal in implication. 

I think the Board has done an admirable job at managing a complex issue among sometimes mutually exclusive competing interests. 

  1. I believe that “practicable” should be one of the considerations in addition to “feasibility.”  A specific example would be in our terrain where there is no bedrock for many hundreds of feet.  That is, even though the terrain is very steep it is very feasible to flatten the slopes (i.e. soft digging), however, it is not practicable to do so in most cases as the level of disturbance would destroy the character of the landscape and the outdoor experience.
  2. I believe that the proposed trail signage is appropriate and that until actual uses of this signage system indicate where changes are necessary it should be attempted as proposed.
  3. I believe it is important to have a clear definition of what an “alteration” is in terms of trails.  I foresee potential conflicts with routine maintenance being called into question.  I believe this was fairly well addressed in the 1999 RegNeg report.
  4. Terminology is a bit confusing.  I believe there is a consistent terminology in the ITDS that would make application of the new rules much smoother as federal agencies are already familiar with these definitions.
  5. In all cases, I believe an emphasis must be made on natural resources protection and the nature of the trail/outdoor experience.  In my limited dealings with this issue I have found that most mobility impaired trail users desire a challenge in an outdoor recreation setting.  I believe there should be a clear distinction in the regulations between “developed outdoor recreation” experiences and “undeveloped outdoor recreation” experiences.

Again, thanks for the opportunity to comment and congratulations on a commendable job.

Sincerely,

Eric Bridges, CF
Natural Resources Director
City of Lakeland
901-867-2717 x 412