Tonto National Forest, Kim Vander Hoek, RLA
September 27, 2007   [email]

  1. The Access Board guidelines include a definition for “alteration” that only applies to buildings, not trails.  This needs to be clarified in the final Access Board guidelines.

  2. In the original Regulatory Negotiation Committee’s 1999 Report (page 6), there are definitions for “alteration” and “maintenance” of trails.  These are good definitions and need to be added in the definition section of the final Access Board guidelines.

  3. There needs to be an exception in the final Access Board guidelines for protruding objects below 80 inches that occur on a trail where placing a warning barrier would block passage down the trail.

  4. The final Access Board guidelines should not include the International Symbol of Accessibility on trail signs.  Instead, information should be posted that is helpful to all users such as maximum grade, cross slope, minimum width, etc.  The information in FSTAG 7.3.10 could be used as an example.

  5. The 2nd General Exception is confusing since it suggests that only 15% of the trail length doesn’t need to be accessible.  Since this is not true, it needs to be rewritten to match the original Regulatory Negotiation Committee’s 2nd General Exception.

  6. The final Access Board guidelines need to incorporate the Interagency Trail Data Standards terminology, definitions and trail management concepts of trail classes, designed use and designated use, including within the Conditions of Departure.  This will make them usable within the trail structure of federal agencies.

  7. Outdoor Recreation Access Routes (ORAR) should only be required in developed recreation sites.  In undeveloped areas, the trail specifications should apply to the route to the facilities instead of the ORAR specifications.  The final Access Board guidelines need to make a distinction between developed recreation areas and undeveloped areas where facilities are placed primarily for resource protection.

  8. The final Access Board guidelines need to make an exception for Outdoor Recreation Access Route grade/slope for alterations/reconstruction.  In existing sites that are altered or reconstructed, it often is difficult to achieve the required grades/slopes without making a negative impact to the natural environment.

Kim Vander Hoek, RLA
Forest Landscape Architect
Tonto National Forest
Forest Accessibility Coordinator
Tonto National Forest
2324 E. McDowell Rd.
Phoenix, AZ  85006  
602-225-5236, Fax: 602-225-5295