Apalachicola National Forest, Cathy Briggs
I have long been and continue to be a supporter of allowing people of all abilities access to the many wonderful opportunities on the National Forests. We construct our trails to be as barrier free as possible. However, I am very concerned about our ability to comply with the new Proposed Access Board Guidelines. As written, compliance could mean substantial alteration and potential destruction of the natural resource, and we are not allowed to do that. That means that if a trail cannot be fully accessible, it may not exist at all. (Please note that I am on a National Forest in Florida where the terrain is flatter than most other National Forests, and yet this issue effects this forest, as well.)
Please make the following changes to the proposed Guidelines:
- Please use the definitions for alteration and maintenance of trails in the original Regulatory Negotiation Committee’'s 1999 report (page 6) in the new Guidelines. Do not use the same definition for alterations for trails, as was used for buildings.
- Please include an exception for protruding objects below 80" in height.
- Please do not use the ISA on trail signs. Instead provide factual information (maximum grade, cross slope, minimum width, etc. from the FSTAG 7.3.10) which will allow all users to make their own decision about which trail best meets their abilities.
- Please use the original Regulatory Negotiation Committee’s language for the second General Exception.
- Please use the Interagency Trail Data Standards (ITDS) in the new Guidelines.
- Please do not require Outdoor Recreation Access Routes (ORARs) in areas which are not developed recreation sites.
- Please provide an exception for ORAR grades and slopes for alterations and reconstruction in situations where they cannot be met.
Thank you for your consideration.
Cathy Briggs
Recreation Manager
Apalachicola National Forest
57 Taff Drive
Crawfordville, FL 32327
850-926-3561 ext. 6509