Rocky Mountain Region’s Center for Design and Interpretation, Glen France
October 17, 2007   [email]

Comments on U.S. Access Board Proposed Architectural Barriers Act Accessibility Guidelines for Outdoor Developed Areas (Docket 2007-02)

  1. The definition of alteration provided for buildings is not appropriate for trail alteration.  Include the original Regulatory Negotiation Committee’s 1999 Report definitions for alteration and the maintenance of trails in the guidelines.  This gives those working with the guidelines, a much better understanding of the intent of the guidelines.

  2. As stated, the 2nd General Exception is unclear and needs to be rewritten to clarify the overall intent. Stating that only 15% of the trail needs to be accessible is unreasonable.

  3. Incorporate the Interagency Trail Data Standards into the guidelines.  Their inclusion will strengthen the guidelines and continue the use of standardized terminology between the federal agencies which are utilizing this integrated data structure.

  4. It is not appropriate to require placing a barrier to warn of objects below 80" tall which extend into the trail if the barrier will restrict access down the trail.

  5. The final Access Board guidelines should not require the International Symbol of Accessibility to designate a trail as accessible.  Providing appropriate information, such as minimum width, maximum grade or cross slope would be much more helpful to the user in matching his skills and abilities to the challenges faced on a specific trail.

  6. Clarify the differences between developed and dispersed sites in the guidelines.  This will differentiate how the guidelines apply to each of these areas.

  7. An exception is needed for ORAR’s, to deal with the conditions encountered when modifying or reconstructing recreation sites.  Without an exception, it will be difficult to provide access to many natural areas without negatively impacting the resource.

Thank you for the opportunity to comment on the guidelines.  I appreciate the many collaborative efforts contributed by the Access Board, individuals and other groups assisting with the development of the guidelines.

/s/ Glen France

Glen France, Landscape Architect / Regional Accessibility Coordinator
Center for Design and Interpretation (CDI) Rocky Mountain Region (2)
Phone: (303)275-5176   Fax: (303)175-5170   [email]