Alisa Mitchener
October 16, 2007   [email]


On Proposed Rule for Accessibility Guidelines for Outdoor Developed Areas

There is difficulty fitting natural settings into a measurable standard of compliance.  Nature is constantly changing; trails need to be redirected due to natural disasters, beach access installations are destroyed by storms, seasonal sand shifts along coastlines creating different environments within the same shoreline depending on the time of year.  Access and preservation are linked and affect all people that value our natural environment.

Trails:

Hawaii trails are not easily made accessible due to slope.  It will be difficult to measure the slope of entire trails.  Some public pathways or trails are not linear paths; in some areas trails disappear and become broad or open areas with approximate landmarks to show the way.  Creating geographically logical turnaround spaces may be more practical rather than mandating turnaround distance intervals.  Researching local surfacing materials and new products may be important for Hawaii’s more civilized paths as surfacing material may need to be shipped here.  We don’t have the same aggregate that is readily available on the mainland.

I would support good faith efforts that included choices for degrees of challenge on trails, detailed signage and accessibility information in brochures and online, and access routes to family and communal areas with accessible features (fire rings, picnic tables, outdoor showers, etc).  I also think program access could be used creatively making parts of trails or outdoor environments accessible to create the general experience without engineering entire trails or natural features where accessibility is technically unfeasible.  Added interpretive exhibits and educational programs could enhance the experience if the whole trail wasn’t completely accessible.  Visits to culturally significant sites could be enhanced with interpretive programs for better accessibility and historic preservation.

Beach access:

I support beach access into the water for aquatic activities and would include the development of other areas beyond a straight path to the water. The standard for beach access to the high tide line is a concern.  The high tide line can be as far as 75 feet from the water’s edge.  This standard would not necessarily provide access to the water.  Basic access along the beach could be enhanced with temporary mats to the water’s edge as needed.

Many of our beaches change drastically in the winter:  storm surf and migrating sand cycles create different beaches depending on the time of year.  A beach may be accessible during the summer and inaccessible and dangerous in the winter.

I would appreciate more exploration of boat ramps, access ramps and rails to the water for swimming, and chair lift options where appropriate.  Activities in the water provide opportunities for exercise that are not available on dry land.  People with wheelchairs also need to be able to find a spot along an access route to “lounge” in a way that their chairs would not block the access path to the water.  Beach access should consider coastline routes, accessible “cul-de-sac” areas (sand and shade) for lounging off the main access route, and access to the water’s edge for swimming, canoeing, and snorkeling.

Expectations of accessibility:

The USDA Forestry Service uses the “Recreation Opportunity Spectrum” (ROS) to categorize and define outdoor recreation environments and experiences.  Classifications assigned to each area by the ROS are useful generalizations of what may be expected within that area.  As outdoor environments become more developed and civilized expectations for accessibility increase; more primitive wilderness settings illicit less expectation of access and comfort as challenge and risk increase.  Quality outdoor recreation provides diverse opportunities and choices.  The goal is not to develop all outdoor environments equally.  Development and accessibility must compliment natural settings.

Question 10 states 50% of outdoor elements need to be accessible (picnic tables, fire rings, and benches), and 40% of those are required to be connected by an accessible route.  Question 14 asks whether elements located on inaccessible trails should be required to be accessible.  It was suggested that improvements in technology in the future might improve access to difficult terrain so when improvements are made to access routes accessible elements will be in place.  People with disabilities do find their way to extreme sites, sometimes via other means of entry (helicopter, by canoe along shorelines, etc).  Choice and the dignity of risk are important.

Maximizing Funds:

It is essential that an increase in federal funding be attached to this effort to increase access to natural outdoor environments.  Increasing federal funds for interpretive exhibits, manpower for restoration of access routes damaged by natural disasters, and for water safety features will improve accessibility.  Structural access goes hand in hand with program access.  Provisions for funding the “people“ part of making sites accessible and responsive to individual needs is equally important to creating specs for trail surfaces and fire rings.  Developing transition plans for program access, supporting improvements and incentives for caregivers and personal assistants, creative problem solving for inaccessible areas, staff training, and consideration for cultural protocol are connected to better accessibility and will be different for each site.  Federal recognition and funding for program access would support access innovation.

Conclusion:

Maximizing access while protecting and maintaining nature, striving for clarity, describing access conditions in detail, and beach access connected to infrastructure to the water’s edge are useful goals.  It will be important to educate people about expectations for access to outdoor developed areas. Consider developing the ROS system further to categorize and define outdoor experience (from urban/rural to wilderness).  Providing detailed information for informed choices, providing creative program access, and increasing funding for accessibility is as important as creating specs.

Respectfully submitted,

Alisa Mitchener
[address]
Keaau, HI  96749