U.S. Department of the Interior, Office of Civil Rights; Sharon D. Eller
October 15, 2007   [email]

Dear Mr. Botten:

In response to the U. S. Architectural and Transportation Barriers Compliance Board’s (Access Board) Notice of Proposed Rulemaking (NPRM) for accessibility guidelines for outdoor developed areas, the Department of the Interior (DOI) requested its Bureaus to review the NPRM and provide comments for transmittal to the Access Board.  Comments were received from the National Park Service, the Fish and Wildlife Service, the Bureau of Land Management, and the Bureau of Reclamation. 

General comments about DOI’s review of the NPRM are highlighted below.  A summary of comments and recommendations based on those received from DOI staff are included in Attachment A.  In addition, we are providing bureau individual staff comments without edit in Attachment B.

General Comments:

• The document is applicable to and usable by DOI Bureaus.
• The NPRM should be reviewed for clarity because some responses received from DOI staff indicated that they misunderstood the requirement.
• The NPRM should be reviewed to ensure that the intent of the Regulatory Negotiation Committee (RegNeg) Report was not changed.  For example, the RegNeg Report calls for several elements (telescopes, viewing platforms, etc.) to be connected to an Outdoor Recreation Access Route but the NPRM does not include this requirement.
• The process of determining when and where you apply the technical provisions and the departures is reasonable and workable. 
• If a definition is used in several sections (such as cross slope, running slope, etc.), it should be added to the definitions section.
• There should be a requirement for documentation when applying the Conditions for Exceptions.  While this might be difficult to add as a requirement in the NPRM, it should at least be included as in the advisory notes section.
• The addition of the advisory notes in the body of the document instead of an Appendix makes the advisory notes more effective.

Thank you for this opportunity to comment on this important proposal.

Sincerely,

  /s/

Sharon D. Eller
Director, Office of Civil Rights,

Attachments

cc:  James E. Cason, Associate Deputy Secretary
  David Park, Department of the Interior Liaison

Attachment A

Overview of NPRM

Since Interior is one of the primary Federal land managing agencies that develop and manage the type of facilities covered by this NPRM, these guidelines will have significant implications for the design, construction, and operation of our facilities.  Dealing with the outdoor environment requires a sensitive balance between maintaining the fundamental nature of an outdoor experience and providing access to these areas by as many people as possible.  Outdoor recreation facilities bring many other unique challenges such as construction techniques, terrain, and degree of development issues.  Achieving this balance was a goal of the Regulatory Negotiation Committee and of these proposed guidelines. In general, we feel that these guidelines accomplish that goal.

In addition to providing provisions to increase accessibility at our outdoor sites, these guidelines also allow a process for departures and exceptions so that we do not unreasonably impact these areas.  Several of our DOI agencies, including the National Park Service, the Bureau of Land Management, the Bureau of Reclamation, and the Fish and Wildlife Service have already been designing facilities using the guidelines set forth in these proposals since they were first published in 1999.  Based on these experiences, we feel that these guidelines, in general, allow planners to design facilities that will not impact or alter the nature of the setting while allowing persons with disabilities the opportunity to share in the wonderful experiences that our sites provide.  We commend the U. S. Access Board and the Regulatory Negotiation Committee for this effort.

General Comments:

1. The NPRM should be reviewed for clarity.  Based on some of the comments that were received from DOI staff, there are several provisions that are not clear.  For example, we believe that the applications of the Conditions for Exceptions (T302) need to be clarified.  It was our assumption that the conditions in T302 would apply to all elements of this rule including outdoor recreation access routes, beach access routes, picnic areas and camping areas.  Based upon the way that the proposed guidelines are written in the NPRM, it appears that they apply only to trails.  We believe that the conditions in T302 should generally apply throughout the document.  This is particularly true in the alteration of existing facilities.  While we believe that invoking these exceptions in alterations to campgrounds and picnic areas should be the exception rather than the rule, we think that full compliance would be very difficult to achieve given the nature of various terrain.  The NPRM should be reviewed to make sure that the intent of the Regulatory Negotiation Committee report was not altered when the Board revised the format of that report to match the format of the Architectural Barriers Act Accessibility Standards (ABAAS).  One example is found in Section T303.2 Trails – General Exception.  While the Regulatory Negotiation Committee report lists four general exceptions, the NPRM includes the “15 percent threshold” as a fifth general exception.  As written, it is different from the original report requirement and implies that a trail does not need to comply with any of the technical provisions for more than 15 percent of the length of the trail.  Another example deals with connecting elements with outdoor recreation access routes.  The Regulatory Negotiation Committee report requires several elements such as telescopes and viewing platforms to be connected to outdoor recreation access routes while the NPRM does not include this requirement.
2. There has been some discussion among Interior staff concerning scoping requirements of picnic tables, benches, and camping elements.  Some staff feel that the number is too high, while others feel that, consistent with principles of universal design, 100% of these elements upon replacement should be accessible.  In general, we feel that the scoping requirements are reasonable and acceptable as written.  Accessibility coordinators within the Department of the Interior continue to remind designers and planners that these accessibility guidelines are minimum standards, and any agency can adopt higher thresholds if they choose to do so.
3. We believe that beach access routes should be provided to provide access to beach activities and accessible managed elements on the beach.  In addition, we feel that the “edge of the beach” does not constitute access to a beach.  We had varying opinions regarding the end point of the route and recommend that the Access Board contact experts and operators in this area to determine the appropriate end point.
4. We believe that the term Beach Access Route needs to be clarified.  It is unclear where a Beach Access Route begins.  In addition, the difference between “access from beach to water” and “access routes to the beach” is, also, unclear.  For example, are the steps built over the dunes part of an Access Route per ABAAS, or is it a Beach Access Route?
5. We believe that clarification between new construction and maintenance should be provided.
6. To ensure that the Conditions of Exceptions are used correctly and not as a means to avoid providing an accessible trail, route, or element, we recommend a requirement for documentation when applying the Conditions for Exceptions be discussed in the NPRM.  While it may be outside the scope of the Access Board to add documentation as a regulation (may be more appropriate for DOI and Bureau policy), we feel that discussion on documentation at least should be included as an advisory note.

Comments on technical provisions of the NPRM

1. We have two comments regarding the tent platform provisions (reference Section T318.3).  In our experience, we have found that most individuals with mobility impairments transfer from their wheelchair to the tent platform.  We believe that the edge protection requirement may create a barrier to the transfer process.  Perhaps allowing for openings (similar to openings in edge protection on docks) would solve this problem.  Also, we are frequently asked how high a tent platform should be.  This dimension should be provided in the technical provisions.  We recommend a height of 17 to 19 inches, similar to the height of a bench.
2. With regard to beach access route requirements, we feel the height requirement (6 inches or higher above the beach surface) in Exception 6 (T205.2.3) is too low.  We agree that this exception is needed for areas where there is an elevated platform.  However, we feel that meeting the technical requirements for an beach access route is not difficult to achieve from a platform 6 inches high, and this exception will probably eliminate a lot of sites where the opportunity to increase accessibility exists.  We recommend that 12 inches or higher be used instead of 6 inches to invoke an exception to this requirement.
3. We have a couple of comments regarding trail signage.  First, we feel that there should be some kind of signage that indicates this trail was designed to meet accessibility guidelines.  We recommend a sign that includes the international symbol of accessibility along with an outdoor recreation symbol similar to the lower two examples shown in Advisory T321.2 in the NPRM.  Second, while we feel that trail information such as surface information, slope, and trail length are useful for all hikers, we do not feel that this information should be a requirement in the final rule.  Instead, we feel that this should remain as an advisory, as it currently exists in the NPRM.
4. We feel that the requirement regarding operable parts for cooking surfaces and grills may not be reasonable (reference Section T308.4).  The feedback we have received from field staff indicates most of the permanent cooking grills used at picnic areas and campsites usually require two hands and more than five pounds of force to raise and lower the cooking surfaces. We recommend that the Board research this issue to verify this is a reasonable requirement before issuing the final rule.
5. We feel that the width requirement of 36 inches for beach access routes is too narrow.  Since the nature of construction makes it almost impossible to maintain the minimum width due to the movement of the native material over the route, we recommend that the width should be 48 inches as a minimum and preferably 60 inches.
6. The height of a bench, including a picnic table bench, should be provided in the technical provisions; we recommend a height of 17 to 19 inches, similar to the ABAAS requirement for the height of a bench.
7. In order to help designers and planners to better understand these guidelines, we hope the Board will prepare technical assistance materials and case study examples similar to those prepared a few years ago for the Recreation Facilities Guidelines.

Attachment B – General Comments

• The Notice of Proposed Rulemaking (NPRM) should be reviewed for clarity and consistency with the Regulatory Negotiation Committee Report dated 1999 (RegNeg Report).  For example, it was assumed that the conditions of departure listed in Section T302 would apply to all elements of this rule; as written, it appears that they only apply to trails.

  Another example can be found in Section T303.2.  The RegNeg Report only listed four general exceptions; the NPRM has listed five general exceptions.  The “15 percent threshold” is listed as an exception.  This implies that the technical provisions only apply to 15 percent of the trail.

• Numerous definitions are included in the advisory notes.  If these definitions are used in several areas, they should be added to the definitions section.
• The advisory notes are very useful and they be should be retained and expanded as needed.
• I found the guidelines to be well thought out and sensible.  The guidelines include technical specifications regarding the new construction and alterations to outdoor facilities.  There is no requirement to make changes to existing facilities during normal and routine maintenance.
• Great care is taken in the discussion to protect natural and cultural resources and provide exclusions or exemptions in situations where accessible design may damage resources.  There is also a sensible approach between what is technically feasible verses what is practical. (i.e., something may be technically possible to construct, however may not be actually practical to build or maintain in a given setting.)
• There was ongoing discussion concerning accessible trail signage.  Two schools of thought were discussed.  One defended a simple sign designating an accessible trail such as what is currently used on an accessible building (the International Symbol of Accessibility). The other approach opted for a far more complex sign indicating a range of technical data such as maximum running slope of trail, maximum and minimum width, cross slopes, and other characteristics.
• It is my feeling that the simple approach, the International Symbol of Accessibility, is preferable both from a sign construction and maintenance perspective and from the view of the trail user who may become confused or put off by too much technical information.
• As you know, Minuteman Missile National Historic Site is in our fourth fiscal year of operations.  Although we have been dealing with some accessibility challenges during these formative years, we have reviewed the proposed guidelines and have no specific comments pertaining to the subject memo.  We appreciate the opportunity to provide input and ask that you continue to “keep us in the loop.”
• Indiana Dunes National Lakeshore appreciates the opportunity to provide comments on the Proposed Architectural Barriers Act Accessibility Guidelines for Outdoor Developed Areas.  This document will have an effect on development in all parks.
• The vast majority of the proposed guidelines are a good, realistic approach for providing accessible trails, camping, picnicking, and development.  The recommendation for Beach Access (Ref: T305) falls short of what can reasonably be expected from park staff.  While it is possible to provide access to the water’s edge, it is not possible to guarantee that access on a daily basis.  Lake Michigan is an unpredictable body of water with possible daily fluctuations in the amount of wave action.  This action could easily change during the course of the day or over night and possibly destroy or remove any temporary means of access.  Permanent access routes would certainly not withstand the accumulation of shelf ice that is an annual event on Lake Michigan.  In addition, the severe spring and fall storms have the capability of causing massive erosion or complete reshaping of the fore dune area covering any structure with multiple feet of sand.
• We believe that the beach access situation should be accessed on a case-by-case basis depending on the history of the adjacent body of water.
• We have reviewed the proposed guidelines for Accessible Outdoor Developed Areas and have no comments.  Quite a thorough effort by those involved! 
• Committee did an extremely thorough job of looking at a wide arrange of outdoor activities.
• Rules allow for a wide variety of exceptions to accommodate the natural environment, localized building materials, practices and financials means.
• Rules allow the land manager/agencies to use its discretion.
• If the regulations are adopted, the NPS will need to develop training for trail crews, designers, etc for their proper implementation.
• The Outdoor Developed Areas Guidelines and the project requirements will need to be closely studied as there are many exceptions to the rules.
• It is very helpful to have a standard for the required amount of accessible camp spaces.  Prior, the amount was based on hotel rooms.
• When will the Board decide on trail sign requirements?
• Clear distinction needs to be given for when to use the November 8, 2005 Architectural Barriers Act Accessibility Standard (ABAAS) and Architectural Barriers Act Accessibility Guidelines for Outdoor Developed Areas.  For example, both guidelines cover the material in sections T309 through T317 of the Outdoor Guidelines.  Do we use the more stringent of the two requirements?
• Section T306.2 Picnic tables.  It would be difficult for parks to need to follow two sets of regulations for picnic tables. Will the Architectural Barriers Act Accessibility Guidelines conform to the Outdoor Guidelines?
• Will there be a grace period for these proposed regulations.  For example, in October of 2005, we started an accessibility project here in the park.  We have been using the Architectural Barriers Act Accessibility Standard, (ABAAS) November 2005 as the guide.  The project may not be constructed for several years; will there be a mechanism to allow us to use of the ABAAS standards rather then having to change all of the drawings to match the Outdoor Guidelines in the future?
• Overall the park commends the efforts of the advisory board tasked with providing agencies with detailed information about the process of considering and balancing proposed accessibility requirements with the potential outcomes at the park level.  However, the document raised a number of questions and we do have serious concerns regarding the practicality of some of the proposed guidelines.  We hope that review includes experts within the design and construction fields.

  The proposed guidelines indicate that all major alterations or new installations of trails and boardwalks must be designed and constructed to be accessible.

  This is not achievable in areas where terrain is steep. Trail switchbacks would have to be widened to such an extent that the length of the trail would be more than doubled. New designs would be prohibitively expensive to construct. The consequence of these proposed changes may be that no new trails are constructed due to costs

• The guideline appears to be exhaustive and complex.  We are confident the subject has been diligently researched and documented by experts in the field.  We believe that organizing the final document to include clear charts and examples for referencing would aid in designing outdoor developed areas.
• This document was developed prior to the publication of the Americans with Disabilities Act and Architectural Barriers Act Accessibility Guidelines (ADAABAAG) in July 23, 2004; therefore, all referenced standards are still based on the Americans with Disabilities Act Accessibility Guidelines (ADAAG ) 1991 publication.  To be consistent with the currently adopted ADAABAAG, the proposed guidelines should be updated and referred to standards published in ADAABAAG:

  16.8.2:  Clear Floor or Ground Space: Incorrectly reference to ADAAG 4.2.2.2 .  However, it would be easier and more consistent if 48 inches by 48 inches clear floor or ground space is required (similar requirements for all other outdoor elements, except for Utility Sinks and Toilets).

  16.17.3.6:  Tent Pad and Tent Platforms – Connection: The requirement is unclear regarding how a connection to tent pad and platform will be provided since edge protection in 16.17.3.5 also calls for curbs, walls, railing, or projecting surfaces surrounding the pad and platform. 

• All have concurred with the proposed guidelines.  These standards have been applied to design for the Willow Beach Fishing Pier project, and the design of the River Mountain Loop Trail.  These proposed guidelines are very useful and should be adopted.
• Accessibility at Crater Lake National Park is currently addressed by an ad hoc interdisciplinary committee as time allows. It  is my hope that this Proposed Rule provide an impetus to address Accessibility at Crater Lake as a comprehensive issue through an Accessibility Plan of some kind- systematically working to correct current deficiencies and plan for future projects.
• It’s obviously a very difficult issue to define objectives, standards and compliance targets.  It looks like they have many unanswered questions that might best be addressed by another small committee rather than the whole DOI.
• I would suggest if possible they build these new guidelines off of the USFS published reference book called “A Design Guide Universal Access to Outdoor Recreation” ISBN 0-0944661-25-4 first published in 1993.  It is a very user friendly, excellent guide and has been a very useful tool for me over the years when grappling with questions regarding accessibility in outdoor areas such as trails and picnic areas.  They give great examples, illustrations and address all or nearly all of the issues raised in the link below.  I notice that Dave Park was the NPS contributor to the effort as well so it’s likely that he knows about it.
• Widths and clearances as shown in the guidelines which we have implemented, have been quite comfortable for all users.
• The future will be handling groups with mobility.  We need to work with them on arrival.  They need trail information.  Our park should develop a communication on paper, E mailed, or interpreted personally for all to use.  Parks need to focus on the mass amount of folks over 60 years old with health issues or with permanent disabilities.  We have a lot of them  show up daily.
• I do like the idea of not abusing the international access symbol.  You post that and open up a real opportunity for different opinions and assumed requirements.  Parking lots and restrooms are the best locations for them, but we should not modify the symbol.
• There is nothing that can beat a personal contact or a very well written / depicted publication.  I think parks should focus on informing people before proceeding into the park experience.
• Going line by line on the question narrative was too difficult for me to follow.  Many didn't pertain close enough to our park operations currently.
• Recommend training opportunities be provided by the access board that are specific to interpreting the finalized Guidelines for Outdoor Developed Areas when unusual circumstances or physical obstructions are present.
• These Guidelines provide a reasonable approach to a difficult problem.  Without letting folks off the hook for following through on providing accessible facilities, the rules allow for serious consideration of the overall effects to the environment that may occur in the placement of facilities and, in particular, trails.  The approach seems to require accessibility standards to be followed, but doesn’t require implementation that would adversely alter the overall setting of the facility in a drastic way.
• Recommend including a more defined description of “outdoor developed areas” in T101 and also in the definitions section.  The definitions section seems pretty skimpy and should include more items.  “Outdoor Developed (recreation) Areas,” to me, means more concentrated-use areas such as typical drive-to campgrounds, as opposed to dispersed (recreation) areas that might include constructed trails and other destination facilities that, for example, can not be accessed by passenger cars.  But outdoor developed areas may mean more or less to someone else.
• Overall, accessibility is extremely important in the recreation facilities arena.  However, they cannot always be met due to multiple facets, such as where each facility is to be located.  There are certain areas where recreation facilities are needed that cannot accommodate all, or even any, of the accessibility guidelines, present or future.

  It is important to remember that [many agencies] provide multiple opportunities for people in need of accessible facilities, and thus we should not be constrained by intensive guidelines for each and every facility we construct.  This is especially true in wilderness study areas and in remote, backcountry settings.  Again, the setting character of these areas is often such that every need related to accessibility guidelines simply cannot be met.  The setting character of a primitive area should not be sacrificed.

  That being said, in other areas where these types of constraints are not present, we should make every effort to provide accessible facilities to those who need them.  In those areas, guidelines should remain just that…guidelines and not become the only way to install specific facilities.  This is one area where some flexibility could and should pay huge dividends to both the user and to management. 

  Therefore, it is my opinion that while guidelines should be used in each case, there are times when stringent rules such as those suggested in the new NPRM Proposed Accessibility Guidelines,  should be used with a certain degree of flexibility to help maintain the character of the recreation setting.

• In the listing of Conditional Departures, these Departures should apply to all sections and applications in the document much like programmatic exclusions in the 106 (Compliance) processes.
• The current ration of picnic tables that are accessible seems to work well.  The new proposed ratio of 50% of all tables being accessible seems excessive and in many cases very difficult to achieve since they must be along an accessible path which again in many terrain conditions is unachievable.
• The ratios currently used under the existing guidelines for most trail applications picnicking and camping areas have worked well.  Again, I don’t see the necessity to change them. There is a practical reason for this as well, as Park’s have finally begun to use the current guidelines and changing them will cause many parks to fail to conform to the new guidelines.  The exception to this is of course if the guidelines pertain to trails.
• The issue of signage is very important and I fell that the International ID coupled with another symbol would suffice.  My recommendations would be a hiker or a tree (chosen from current options).  I feel this is simple and legible without being too complex or attempting to add too many distinctions.
• When the final rule is completed, the Access Board and the DCRs in the Bureaus and Department will need to make training available on-line, in publications, and in person.  The proposed rule is extensive, detailed and technical. Much of the work done on the facilities covered by the proposed rule making is done by volunteers, and they will need clear explanations of the final rule and what it means to the projects they maintain or plan  to construct.
• User-friendly language will be needed to describe the requirements as many volunteers work on the facilities covered by this proposed rule and may not understand the current language.
• Federal agencies need to get approval for exceptions to the rule from their regional engineers, and document reasons for using any of the exceptions in the proposed rule to their station files and file them with their regional Division of Civil Rights. 
• Need to expand exceptions to constructing accessible facilities to parking areas and trailheads.
• There are no scoping requirements, guidelines or technical provisions for hunting and photo blinds. These should be included.  The Service will be glad to work with the Department and the Access Board to develop them.
• Many of the proposed guidelines in draft form have been in use over the last five years on national wildlife refuges and fish hatcheries.
• The guidelines are thorough and cover all of the major components of providing universally accessible outdoor experiences for our visitors. Some of the items included do not apply to many of FWS field stations (camping, fire rings, showers, etc.).
• We are concerned that the guidelines, as written, are quite technical and may be difficult to use as a reference for our managers. We suggest that a more practical field guide that includes examples of universally accessible facilities be developed.
• The guidelines are a “stand alone” document.  This format could be interpreted as redundant due to information in the proposed Outdoor Developed Area Guidelines, the 2004 Americans with Disabilities Act, and the Architectural Barriers Act Accessibility Guidelines.  The proposed Outdoor Developed Areas Guidelines could be more “user friendly” if there were notes indicating where there is similar information stated in the 2004 Americans with Disabilities Act and the Architectural Barriers Act Accessibility Guidelines.
• The use of “Advisory” text was unclear.  Was it intended to be explanatory?  Was it intended to be an extension of the requirements?  Was it intended to provide helpful information?
• There are some differences between this set of proposed guidelines and similar guidelines.  The question came up of why benches, for example, were different in these proposed guidelines than in the guidelines for Recreation Facilities.
• The format used for these guidelines is not very user-friendly. To ensure that these guidelines are used, they must be simplified so that people at the field level can easily find the information they need. The current format requires the user to continually flip from one chapter of the guidelines to another to get complete information.  Following are some suggestions for simplifying the format.
  • Is there any reason why the scoping and technical provisions for a feature can't be in the same place? In other words, can all the information about trails be in one place? It would save the user from having to work so hard to find complete information on a topic. The current format is very frustrating to work with, and the fear is that many will give up before finding the answer to their accessibility question.
  • If scoping and technical provisions must be separated, it would help to list the element when cross-referencing.  For example, instead of saying, “…complying with T306…,” say “…complying with T306 Picnic Tables…”  This will make the document longer, but will provide a little clarity.
  • These guidelines would really benefit from having a introduction/user guide at the beginning of the document to explain things like the difference between scoping and technical provisions.
  • A table of contents for figures is needed.
  • An index would be very helpful
  • If the format remains as is, the online version will need lots of links. For example, when it says in the scoping chapter that trails need to meet T302.2, the text “T302.2” should be a hot link to that section.  Why are all the chapters T and then some number?  I don’t understand what the T does – is it because this is being added to another document?
  • It would be great to add diagrams wherever possible to help explain things such as cross slope, what an outdoor recreation access route looks like versus a trail, etc.  Section 4 has a number of diagrams, and they improve understanding.
  • The beach access requirements need to be extensively revisited with input from biologists as well as visitor services professionals and facility managers. As they are now written, if a refuge manager, or other federal land management agency unit manager with responsibilities for protecting threatened or endangered species in a beach environment, could determine that he or she cannot provide universal access to the high water mark, and therefore close access to all recreational or commercial users. This is clearly not the intent of the proposed rule. The high cost of constructing and maintaining permanent and temporary structures needed for universal access in the adverse and constantly changing  environments along bodies of water may also afford reasons for denying access to all by financially challenged public agencies at all levels.

Comments on Chapter T1 – Application and Administration:

T101 Purpose

• We were please to see the advisory statement that natural environments may not always be compatible with wholly accessible facilities. This has been point of misunderstanding and debate in the past.

T104.4 Defined Terms

• A definition for a “beach” and a “new beach” need to be provided.  Reclamation has many miles of shoreline most of which the public can access and it is unclear from the proposed guidelines, which areas along the shore would be considered a “beach” or a “new beach”.
• Definition of Outdoor Recreation Access Route requires accessible elements to be connected to accessible parking, restrooms…  The same exceptions provided for trails need to be applied to the outdoor recreation access routes and developed area elements they connect.

Comments on Chapter T2 – Scoping Requirements:

T202.3 Alterations.

• Exceptions: I and T204.3 Location.  – Define “circulation path.”  How does it differ from an Outdoor Recreation Access Route?
• Advisory T202.3 Alterations – In the last paragraph, it says “Although not required, resource managers are encouraged to maximize the opportunity to improve the accessibility of outdoor facilities through maintenance and repair activities.  Every time a facility is maintained, the opportunity to improve access is present.”  We agree with this, and think that maintenance is a good time to make improvements, but then when does maintenance that improves a facility become an alteration that triggers meeting all the requirements in these guidelines?  We think this is something folks will be concerned about when they are doing maintenance that also improves the facility.  Also, how does this balance out with the requirement to make Federal programs accessible.

Section T203 Trails

• The determination that trail managers make for what makes a trail “accessible” does not necessarily align with what is actually accessible (or not) for persons with various types and levels of abilities.  When Mother Nature creates a set of obstacles to making a trail “accessible” (as reasonably practicable) according to our definition that is one thing.  But when federal dollars go into building toilets, bridges, and benches, those items should be as accessible as possible when they are scheduled to be constructed or replaced.  However, we should not prematurely replace something that still functions properly because of new guidelines that require it to now be accessible.
• In support of accessible recreation opportunities and universal design, one hundred percent of elements located along trails should be accessible even when the trail itself does not meet the definition of accessible.
• Advisory T203.1 General – 1" paragraph, last sentence, “Accessible elements…” What does this mean?  The elements are connected by a trail, but don’t have to be connected by an outdoor recreation access route?  The last sentence is unclear, “Where there are differences, the more stringent provision should be applied.”  Does that mean that on a trail that is both for pedestrian and bicycle use, the bicycle standards should be applied?

T205.3 Beach Access Routes-Where Required: Existing Beach

• The height threshold for Exception 6 is too low.  It is not difficult to meet the beach access route technical requirements from a pedestrian route (elevated platform or boardwalk) that is only 6 inches high.  This would eliminate a lot of sites where an opportunity to provide access exists.  We recommend that 12 inches should be used to trigger this exception.

T206.2.2 Multiple Picnic Tables, T207.2.2 Multiple Fire Rings, T208.2.2 Multiple Cooking Surfaces, and T213.2.2 Multiple Benches

• These sections require that 50% of these items be accessible.  Most of our facilities are in remote areas and the proposed 50% required to be accessible is excessive for the amount of use these areas get.  We suggest that no more than 25% and no less than two if there is more than one be required to meet the accessibility requirements.
• Using the concept of Universal Design, all picnic tables, fire rings, cooking surfaces, and multiple benches should be accessible.  We should not assume that persons with disabilities can only access elements located on access routes.  In addition, all users benefit from the accessible elements (accessible picnic tables provide a “buffet” area for food, benches with back supports and armrests provide support for all users, etc.)

T209 Trash and Recycling Containers

• Accessibility of trash containers to humans sometimes means to wildlife as well (i.e. bear-proof trash containers are not all conducive to accessibility standards).  Will this be addressed?

T213 Benches

• There is no standard provided for distance between benches or rest areas (Section 303).  Is there a minimum distance, even for flat, even terrain?  If so, it should be stated.

T213.2.2  Benches, Minimum Number, Multiple Benches

• Benches without armrests and/or backs are often considered the only appropriate type in more primitive or rustic appearing locales.  Even though some of these areas might be fully accessible, it would be a shame to fall short of the standards if the only failure was a lack of an otherwise awkward appearing armrest or back on a half-log bench.

T218.2  Camping Facilities, Minimum Number

• Standardizing the scoping for elements would greatly help designers.  If parking numbers are used as minimums and add minimum 1 for each type of camping space – tent, RV/tent, pull through RV, group, large family site, etc. provided in campground would simplify scoping questions.

Comments on Chapter T3 – Technical Provisions:

T302 Conditions for Exceptions

• See first comment under “General Comments”.
• These conditions for exceptions should be included in the scoping section to align with ABAAS layout.  The exceptions need to apply to the entire guideline, not just trails.
• These conditions for exceptions should include all outdoor elements; trails, outdoor accessible routes, picnic tables, campgrounds, overlooks, trailhead parking, picnic area parking and beach access routes; not just trails as written.
• The first sentence of each Advisory repeats the Condition that appears immediately above it on the page.  Is this redundancy necessary?

T303.2 Trails-General Exceptions

• See first comment under “General Comments”.
• The proposed guidelines require all trails from a trailhead to be accessible to the first point of exception unless the trail is less than 500 feet.  We don’t understand the benefit of this.  It would seem to be disingenuous to imply that the trail is accessible when by this standard it could be inaccessible after a short 500 feet.  Rather than making all trails over 500 feet accessible to the point of exception in T303.2, we suggest the alternative that if the entire trail length cannot be made accessible in compliance with T303, then no portion of the trail should be required to be made accessible.
• It appears that the proposed guidelines would require that any trail leading to a “prominent feature” less than 500 feet from a trailhead is to be made accessible in compliance with T303, unless exempted by T302.  A definition of a prominent feature should be added.
• This section is difficult to understand the way it is currently worded.  Consider adopting the wording in the USDA Forest Service Accessibility Guidebook for Outdoor Recreation and Trails.

  A trail must always be accessible from either end to the first uncorrectable environmental barrier if the distance from the end of the trail to the barrier is more than 500 feet.  A trail that goes past a prominent feature must always be accessible at least to the feature — no matter how far from the end of the trail — unless there’s an uncorrectable environmental barrier between the end of the trail and the prominent feature.

• This paragraph is very confusing.  At a minimum, it is unclear why it makes a difference whether the prominent feature occurs at less than or greater than 500' from the trailhead.

T303.3 Surface

• We also suggest that the description of T303.3 examples be redesigned to include a bulleted list with examples of common surface types and sieve sizes under each category.

T303.7 Passing Space

• Passing space should be much closer than 1000'.  Recommend 250' maximum distance.

T303.8.1 Cross Slope

• In many cases a trail cross slope of 1:24 is both easy to measure and adequate for many natural trail surfaces and environments.  Good trail design would correlate cross slope with running slope, with greater cross slope needed on steeper running slopes for proper drainage. Unfortunately, the maximum trail slope specified will become the design standard.  Allowing some flexibility by specifying a range of cross slopes from of 2 percent to 5 percent will make for better trails and encourage better trail design.

T303.8.2 Running Slope

• Specifying a running slope of a maximum of 1:16 for perhaps 400 feet, (and a slope of 1:14 for perhaps 300 feet) would add considerable flexibility to trail design to better fit topographic constraints
• How much space is required between sloped sections?  Is 5 feet sufficient?  Are rest areas intended to be at the top and the bottom of the slopes?

T303.9 Resting Intervals

• Refer the reader back to T303.8.2 for resting interval distances.
• If the trail is 32 inches wide, is a 32 by 60-inch rest interval sufficient?

T303.10 Trails-Edge Protection

• Curbs/edge protection should be a standard height for all facilities.  Since 1984 curbs have typically been 2 inches high minimum.  As the proposed guidelines are written it will be difficult to determine if you are constructing an Accessible Route or an Outdoor Recreation Access Route.  Now you will also have to determine if it needs a 2 inch or 3 inch high curb.  Why not make all curbs either 2 inches or 3 inches minimum!  The only logic we can see for having a 3 inch curb is the information provided for trails.  Same comment applies to Section T304.9.

T304.7.2.1 Outdoor Recreation Access Routes-Running Slope

• Are there no resting intervals required for a trail with a running slope of 1:20?  Resting intervals are still needed at this slope.

T304.7.2.2  Outdoor Recreation Access Routes-Running Slope

• Can an Outdoor Recreation Access Route be constructed at 1:12 for 50 feet without handrails, have a level resting area every 50 feet and continue the 1:12 slope for another fifty feet and so on and so on.  If the accessible outdoor Recreation route is 1 mile long can there be one 50 foot segment exceeds 1:20 or can the entire route be at 1:12 without handrails as long as there is a level resting areas every 50 feet?  Same question for the 1:10 exception (T304.7.2.3)

T304.8 Outdoor Recreation Access Routes-Resting Intervals

• Refer the reader back to T304.7.2 for resting interval distances.

T304.9 Outdoor Recreation Access Routes-Edge Protection: Advisory

• Debris is likely to accumulate on trails during certain seasons.  Is this section intended to be a maintenance requirement?

T305.3 Beach Access Routes-Location

• See comments below for Question 22.

T305.8 Beach Access Routes-Turning Space

• For consistency with the RegNeg Report, we recommend that this section should be called “Turning Space/Resting Space”.

T306.2 Picnic Tables-Wheelchair Spaces

• The last sentence regarding additional 5 inches minimum for knee clearance is not clear.  In addition, this figure does not match any measurement in T404.  Should it?

T306.4.2 Picnic Tables-Slope

• The slope called out in Exception 2 should be “1:50” instead of “1:33”.

T307.4 Fire Rings-Raised Edge

• This is unclear.  The fire building surface must be 9" above the ground, but 24" below the edge or curb.  That can’t be right.  A diagram would be helpful here.

T308.4 Cooking Surfaces, Grills, and Pedestal Grill-Operable Parts

• The operable parts for cooking surfaces, grills and pedestal grills are required to comply with T407.  T407.3 requires that the force to activate operable parts shall be 5 pounds maximum.  Cooking surfaces, grills and pedestal grill need to be exempt from complying with T407.3.  There are no materials available that cooking surfaces can be made out of that will withstand the high temperatures generated by fire and still be light enough to be lifted with 5 pounds of force or less.  The alternative would be to remove to remove the operable parts from grill and fire ring cook surfaces.

T309.4 Trash and Recycling Containers

• This guideline will be difficult to get compliance on, as federal agencies are dependent on commercial trash companies for cost-effective waste containers and service to discard the waste.  The cost for bear-resistant dumpsters would be cost-prohibitive for some units, and others may get them simply to take advantage of the exception offered.

T312.2 Telescopes and Periscopes-Clear Space

• An exception for areas where space cannot be provided because of conditions of exceptions should be added (similar to other elements).

T3.13 Fixed Benches

• Why would the standards outlined in this section only be required for fixed benches?  By “fixed benches” does the requirement mean mounted in concrete, or just mean located at the same place all the time.  Would the fixed bench requirement apply to amphitheatres?

T313.2 Fixed Benches-Clear Space

• Wheelchair clear space should allow transfer to bench.

T313.4 Fixed Benches-Back Support

• Many benches in outdoor environments are simple half logs on bases. This type of bench at overlooks, along trails … keeps view unobstructed.  Should be included in an exception.  These benches are typically fixed with rebar through base.

T313.5 Fixed Benches-Arm Rest

• Many historic benches do not have armrests; these areas should be included in an exception, same exceptions provided for historic buildings.

T316 Pit Toilets

• For consistency with the RegNeg Report, we recommend that this section should be called “Fixed Pit Toilets” since this provision applies only to permanent pit toilets.  Similar change should be made in Section T216.

T317.3 Utilities-Water Spouts

• If the water spout is centered in the clear space, wouldn’t it be difficult for a person in a wheelchair to maneuver?

T318.2.3 Camping Facilities-General Use Parking Areas

• This appears to be for recreational camping vehicle and trailer parking spaces that are NOT within a camping space or unit, but may be in other parking area within a campground – is this correct?
• This is a confusing section and may create difficulties in designing parking lots to accommodate large-space vehicles.
• Is this proposed for only a certain number or ? percentage of parking spaces as in Table 208.2 in the Americans with Disabilities Act Architectural Barriers Act Accessibility Guidelines (ADAABAAG) (minimum number of required accessible parking spaces)?
• Can the 8-foot wide minimum access aisle extending the full length of the parking space be shared with the adjacent parking space?
• Are these accessible designed RV parking spaces to be signed with the ISA?

T318.3.2 Tent Pads and Tent Platforms-Surface

• Change “securement device” to “securing device.”

T318.3.4 Tent Pads and Tent Platforms-Edge Protection

• The edge protection may create a barrier for individuals that transfer from a wheelchair to the tent platform.  We recommend that openings similar to those provided on docks should be added to this technical provision.

T321.2 Signs-Trail Signs

• Advisory T321.2 Trail Signs - Suggest adding “Average Time Needed” to the list of information to be provided on the sign.
• Happy Falls Trail (example sign) - This is a great example, but it has a number of typos that need to be corrected.  For example, in the intro paragraph, scenic is misspelled (sceinic) as is “snap” shots (sanp).  A space is needed between “in” and “front,” and the word “star” (following Falls) should be “start” (with a T).  And, if they’re going to capitalize Falls in the last sentence, they need to capitalize it in the first.
• The trail signs indicating that the trail is useable by both abled and disabled visitor are preferred.  In describing trail conditions the sign should also include any information about temporary conditions that may be present (soft mud after rains).

Comments On Chapter T 4 Supplementary Technical Provisions:

General

• Chapter T4: Supplementary Technical Provisions – Since Chapter T4 comes from the new ADA/ABA Accessibility Guidelines, we have no comments other than to say figures are very helpful.  The use of figures in Chapter T3 would help clarify some of the guidelines there.

T402 Turning Space

• This is an example of a section that is the same as the 2004 Americans with Disabilities Act and the Architectural Barriers Act Accessibility Guidelines, but is not referenced to indicate the duplication.

Comments To Questions Posed By The Access Board In The NPRM:

Question 1:

• We concur with the approach presented in the proposed rule.
• All NPS lands (especially urban parks, historic sites, and memorials) do not really fit the definition of ‘Outdoor Developed Areas’ because outdoor recreation was not the purpose for designation of most NPS lands, and since trails development could conflict with natural and cultural resource management.  For “trails and outdoor recreation access routes” the decision regarding where these proposed guidelines for Outdoor Developed Areas apply verses where the more stringent Architectural Barriers Act Accessibility Guidelines (ABAAG) apply, should be a management decision made by Park Superintendent in the NPS master planning process (or by amendment to existing Master Plans).  For example, on George Washington Memorial Parkway, the proposed Outdoor Developed Areas guidelines might be considered applicable to Great Falls Park (except for Visitor Center area), Teddy Roosevelt Island (except for Teddy Roosevelt Memorial area), Dyke Marsh, Potomac Heritage Trail, and the Mt. Vernon Trail (all or a portion).  But the more stringent ABAAG guidelines might be more applicable to historic sites, monuments and urban park areas such as Arlington Ridge, historic grounds of Arlington House (a proposed new trail through the old growth Arlington Woodlands), Glen Echo Amusement Park, and Memorial Avenue.

  This approach clarifies conditions in a park where the level of development and uses are similar throughout.  But in parks that have a mixture of uses (i.e., multi-use trails, hiking trails, campsites, stores/shopping areas, monuments/memorials, and administrative areas), it is difficult to know when to apply ABAAG rules or the Outdoor Developed Areas rules.  This is particularly evident in the need for handrails and guardrails.

  An approach would be to provide examples of mixed use areas and show what governs a particular area.  In the Manual on Uniform Traffic Control Devices, typical applications are provided to show how the rules are to be implemented.  We frequently modify the typical applications for atypical circumstances, but they do provide a foundation for determining which rules govern.  Several examples should be included.

• It is felt that consideration should be given to the experience the visitor gains along the trails in each park and the purpose of a particular trail.  Does one trail stand out among the other trails in a park?  Does it provide a complete experience of the parks natural and/or cultural resources? Does only one trail lead the park visitor to the “main feature(s)”?  If so, that trail which provides a greater opportunity for a visitor to experience uniqueness of a particular park should also be given consideration as the possible accessible route along with the other approaches.  However, the design and construction of a trail should never interfere with the protection of the resource.  A trail should lie lightly on the land and follow the natural terrain as closely as possible with the least amount of interruption to the resource.
• The board considered and rejected requiring only a certain percentage of new “front country” and “back country” trails meet accessibility guidelines.  The board may want to consider requiring that a percentage of new “back country” trails meet the proposed accessibility guidelines.  Generally, development of “back country” trails and facilities are more time consuming and costly than development of “front country” trails.  If all front and back country trails are encumbered with the same accessibility requirements, agencies may opt for the less costly, easier to construct “front country” trails.  Another way to view this might be to require an equal percentage of new trails be constructed in the front and back country, which meet the proposed guidelines.
• The committee should re-examine the settings approach.  It is felt; at the time it was being investigated, to be understandable.
• Front Country and Back Country.  Should the approaches that were rejected be considered?  Are there other approaches the Board should consider?  If so, please provide information on how the alternative approaches could be applied and their rationale.  No other approaches are suggested but make certain the decision is very clear.   
• The exceptions included provide adequate flexibility for designers, and place responsibility with the designers and agency to provide comparable quality of experience for all visitors – these exceptions need to be included for all elements included in the Outdoor Developed Area Guidelines including the parking area, trailhead, restrooms and all elements.  The exceptions should be in the scoping section of the guidelines, follow ABAAS organization.
• Feature based decision making to determine level of access for the trail should also be incorporated.  If an element is one of the key interpretive elements for a park; level of access to that feature (ie. Old Faithful, General Sherman Tree, petrified tree, worlds largest anything…) will be as close to ABAAS guidelines as possible.  If there are four mountain lakes with trails around them in close proximity that provide similar views and experience, not all of the trails will need to meet the Outdoor Developed Area Guidelines if the exceptions apply to these areas. 
• I feel that if the trail can be improved using the proposed system then it should be applied to all trails.  There are people in my area who feel that we should apply different criteria to back country trail.  These proposed rules will not please everyone, so in this case I would error on the side of accessibility.  I feel that by requiring the trail to be scoped simple obstacles will be identified that could be corrected.  I do feel that primitive areas and some trails in wilderness areas should be left alone even if the improvement would not harm the area because in many of these places people are escaping from design of any kind and want to return to nature.  If an area is designated as primitive then the trail should also be nothing more then a common area people travel. Perhaps these areas could be called routes to help avoid confusion.
• The approach used by the committee is reasonable, can be broadly applied in diverse situations, and is relatively uncomplicated.  The introduction of back country, front country, percentages, and settings unnecessarily increases decision-making complexity.
• The term “designated” trailhead could be better defined.  Is this a signed or mapped or … trailhead?  What is the difference between a “designated” trailhead and one that is not “designated”?
• Due to so much variability with public lands trails across the country, putting a percentage on the amount to be made accessible is unreasonable.
• The committee should not reconsider rejected approaches or consider other approaches.
• The exceptions proposed by the committee are reasonable and allow land managers appropriate flexibility to deal with the existing conditions in their areas.  However, when the exceptions to the rule are employed, they should be documented as part of the construction plans, be approved by the regional engineering office, and sent to the regional Division of Civil Rights. 
• The promotion of sustainable trail design and construction is a method to increase accessibility on trails.  Sustainable trail design and construction has been shown to make trails comply with many of the scoping requirements, and where trails cannot be made accessible they are more easily negotiated by users with disabilities with assistance from a companion. Sustainable trail design has been proven as the most economical method of trail construction because of its lower maintenance costs, and lower environmental impact.
• Photographs, interactive exhibits, or other multimedia may provide an alternative experience that is accessible.  (Want to include?)

Question 2:

• T302, Condition 4, is sufficient as written.
• Some design flexibility in applying the guidelines to site specific conditions and working out solutions is needed, at least initially.  Examples can be developed from site specific application, and exceptions might vary from region to region or park to park depending on different environmental, topographic and soils conditions.  The title says these are “guidelines”, but the text often refers to them as “rules”.  Application of guidelines as hard and fast rules could have unforeseen adverse environmental or cultural impacts.

  In this case a similar approach should be taken as shown above.  Examples will help to provide guidance for decision makers.

• The uniqueness of our National Parks is what set them apart from other public lands.  Therefore, the statement that “it would be reasonably do-able to comply with the guidelines, but it is not practicable to do so” is an important point to make.  The significance of a natural or cultural landscape within a National Park is something that all people should be able to experience, however if  access to the resource is compromised by making a trail accessible, than we disrupt the very environs that set it apart from all others and made it worth experiencing.  Because each park is different, more guidance for determining what is or is not feasible or practicable in applying Condition 4 may be worthwhile if detailed rather than broad based.
• The word “practicable” should be considered for inclusion in the proposed rule.  Any trail project could be considered “doable” or at least “reasonably do-able” if adequate resources are applied during the construction phase i.e. financing, labor, equipment etc.  The practicality of maintaining the constructed trail, or portion of, comes into play if adequate resources are not available to maintain it. Guidance should be given in determining what is feasible or practicable in applying condition 4 of T302. Examples would include use of mechanized equipment for maintaining the trail when this equipment is not generally available to the entity responsible for maintaining it.  Also, building of accessible trails, which to meet compliance standards, varies the natural setting beyond recognition, and creates an artificial simulation for the user.
• Yes, there should be some leeway or specific interpretation as to which is “practicable” noting all situations are not foreseeable on paper. The guidance should provide some specific examples to assist in evaluating “practicable”.
• Limit trail signage to the physical conditions of trails such as users, hazards, grades, widths, and composition. Other information such as scenic beauty can be covered in a brochure.
• The term “not feasible” is used in Condition 4 to specify what is “reasonably do-able”. Should the term also be used in this condition?  Employees can agree or disagree on what is “feasible” and “practicable”.  Will the regulations be clear and understandable?
• Comment – Agree that the international symbol should not be used for these areas unless they comply with ABAAS requirements.  Suggest using the international symbol on a steep triangular base to show area is steeper than ABAAS/ADA allows.  Needs to be included at parking spaces for these areas – see other comments that parking needs to be addressed in these guidelines with exceptions and slope requirements.
• Comment – Outdoor recreation areas have many needs for accessible parking that does not meet ABAAS requirements. At boat launch areas, parking is placed along side of ramp for fisherman; the ramps are steep for boat launching purpose – elderly fishermen want to keep accessible signed parking here close to their boats, however, no standard sign allows this.  Many trailheads and overlooks are pullouts along a road, if the road is in a steep section; there is no way to flatten the parking that is parallel to the road.
• We could spend forever debating the proper term.  I am not a big fan of the term “not feasible”;  I also do not like the term “practicable”.  I would provide examples that help define these terms.  I think this questions needs to be reviewed by a solicitor so a defensible term can be chosen.
• The Advisory T3022.1 Condition 4 needs no further explanation.  The terms reasonable and practicable are so similar, the inclusion of “practicable” it will require further defining and examples than are already provided.
• The term “practicable” or “feasible” may each be the best term to describe certain situations.  Recommend defining each in more detail and showing examples.
• We think the addition of different wording to this exception is unnecessary; there is no need to add another term and another definition.  We prefer the use of the existing term “technically infeasible.”

Question 3:

• We suggest using the International Symbol of Accessibility along with detailed information such as the trail length, slopes, width, surface type and known obstructions.
• We suggest using the International Symbol of Accessibility along with an “outdoor recreation symbol” similar to those shown in Advisory T321.2.  We do not believe that trail information such as surface information, slope, and length of trail should be a sign requirement; it can be provided in other ways.
• Confusion between use of the Intl Symbol used for buildings and having to combine with the Intl hiking symbol would lead one to believe that one special symbol created to convey an accessible trail could reduce clutter and clarify.  Additional trail information can and should be conveyed on a kiosk or sign at the trailhead and should not be necessary along the trail, except where changes in access exist.  In those situations, a simplified repetition of the kiosk message should appear.
• The symbol on the bottom left of Advisory T321.2 seems to provide a clear visual message for a trail that meets the technical provisions.  Trails that are considered accessible only by use of the exceptions could be identified using the same format but using a broken line for the trail.  See further sign comments at Question #25.
• If a symbol for accessibility must be used along accessible trails, it is felt that the International Symbol of Accessibility should be adopted for use.  Since the International Symbol of Accessibility is already used in the outdoor environment (i.e., accessible parking spaces), it seems appropriate to use the same symbol along accessible trails.  This symbol is easily recognized and understood by the public.  The concern that the symbol may be inappropriate to use on designated accessible trails because the technical provisions for trails differ from the technical provisions for accessible routes in buildings should not be of concern since most people are unfamiliar with such provisions and simply recognize and understand the basic meaning of the symbol itself.  Therefore, to avoid unnecessary confusion, one symbol should be adopted for use indoors as well as outdoors.  Extensive information regarding all the various characteristics of a trail should be placed in brochures, park maps, websites, etc. rather than on a sign.  Extensive information placed on signs would result in large, visually intrusive signage within the parks.  How much information is too much information?  Will the average user actually take the time to read all of that information before heading down the trail?  If so, it is likely that they will have investigated the park via the internet prior to their visit.  Thus, much of this information can be placed on the park’s website.
• International Hiker Symbol paired with the wording “Accessible Trail” might be an option for signage.  A variation of the “Happy Falls Trail” sign  example given might be used and show instead of averages for Grade, Cross Slope, and Tread Width, a range, such as “The Grade of the trail ranges from 6% – 14%, Cross Slope ranges from 6% -  12%, Tread Width varies from 24" to 69"”, for example.
• Signs which are universal should be installed along accessible trails and boardwalks or have handouts available at trailheads so visitors can make their own determination if they wish to use the trail.  Information on the sign or handouts should contain the degree of difficulty such as grade, trail length, surface information and obstacles they may encounter along the way (steps, benches, etc.) similar to the advisory T321.2
• A higher threshold of more than six inches would be recommended.
• Accessibility symbol for trails.  The park questions what does this mean?  Does it mean that someone in a wheelchair can use the trail?  Or does it imply more?  If it is a nature trail, must the trail have accessible signs and audio stations?
• If the symbol means accessible for visitors who use wheelchairs, the park prefers the sign with the symbol of the hiker first and the international accessibility symbol second.
• Other comments:  The example of the Lower Yosemite Fall Trail has information that all visitors could use.  Although a wayside is always “on duty”, many visitors would probably prefer to have a paper copy with the map information as well.
• I think that requiring the trail to be signed is a great idea.  My thought is to use the same symbols that ski lifts use and place that border around the international hiking symbol with the associated color (green, blue, black) the symbol would be in white as well as the boarder.  I know that people are color blind or blind but the sign could be in relief and also uses the circle, square, and diamond as a boarder.  These 3 levels would fit with the difficulty of the trail and would correspond with a simple definition of what easy, moderate and difficult accessibility means.  We have done this in our office and it has worked well.  I also feel that info such as distance, slope, elevation change, should be included in the sign and if done well will not be confusing.
• The hiker symbol should not be mixed with the International Symbol for Accessibility (ISFA).  A simple, separate symbol is needed.  Perhaps the ISFA can be placed within a large tree (or other outdoor related symbol) rather than the two separate elements.
• Prefer the international symbol with the rough terrain line below, showing the uneven surface.  It is the symbol located in the lower left corner of the options offered in T321.2.  Also, prefer to accept the recommendation as presented that trail signs provide detailed information about the trails’ running slope, width, cross slope, and other characteristics.
• The only time the International Symbol of Accessibility should be used at a trailhead is when the entire trail meets the provisions of whatever the final rule will be.  These trails will likely be relatively short and on level lands, or on former railroad beds.
• More definition of the symbols suggested in Advisory T321.2 needs to be developed and promulgated if they are going to be adopted.  The information suggested to be included with one of the signs is valuable to a wide variety of users, but adds to the cost and complexity of the signs, which may result in them not being read.  Perhaps a number of trails in all ranges of accessibility should be chosen a combination of signs and trailhead pamphlets giving trail characteristics should be piloted to find the best solutions.  Some variation on the ISA could be required until the pilot trails give a clearer idea of what the trail users find most valuable.
• Making the additional information accessible to visually impaired or totally blind users may create signs that are inappropriately large for a trailhead setting.

Questions 4:

• See comment for T205.3 Beach Access Routes-Where Required: Existing Beach above.
• Boardwalks are typically elevated more than 6 inches above beach sand to keep drifting sand off the boardwalk.  Where boardwalks provide pedestrian steps down to the beach, a ramp or beach access route should also be provided.  A higher threshold than 6" should be adopted, such as 12" to 18".
• The committee proposed that a beach access route be required where pedestrian routes are provided to or along the edge of a beach.  Several exceptions to this general requirement are included in the proposed rule.  Section T205.2.3 Exception 6 provides an exception for pedestrian routes that are developed along the edge of an existing beach, such as a boardwalk.  Under this exception, beach access routes would not be required if the pedestrian route or boardwalk is elevated 6 inches or higher above the beach surface.  The Board is concerned that this exception will not provide sufficient access for persons with disabilities, especially where lengthy elevated boardwalk systems are provided.  In view of this, the Board requests comments on whether a higher threshold than 6 inches should be used.  We agree with the finding that beach access routes would not be required if the pedestrian route or boardwalk is elevated 6 inches or higher above the beach surface.
• It is not practical to have structures built where frequent erosion, storm surges or other extreme natural weather conditions such as hurricanes are common. At Canaveral National Seashore, many of our elevated wooden boardwalks crossing over the dunes from the parking lots are 10 or more feet above the sandy beach terrace below. A series of ramped switchbacks meeting ADA criteria are constructed to provide for ADA access.  It is fairly common that these boardwalk switchbacks receive some degree of damage during periods of extreme high tide and almost total destruction during hurricane storm surges.
• If a beach access route is provided, the general public will naturally gravitate towards using this route since it is marked, established, and a surface more easily traversed.  Width should then be determined by anticipated traffic that the route will generate.
• Beach access comments on threshold higher than 6 inches.  Comments and Questions?   Does this imply that if a beach access route is over 6 inches it does not have to be accessible?  Because of endangered sea turtle nesting requirements, seasonal changes in visitation, and potential boardwalk replacements, could alternatives to an elevated boardwalk be considered?
• Beach access routes need to include the same exceptions provided for trails.
• A higher threshold than 6" should be required for an exception.  If there even is a height exception, it should be at the height where it is no longer “reasonable” to achieve an accessible entry.
• Agree that a higher than 6 inch threshold should be used.
• The threshold should be raised to at least 12 inches, preferably 18 inches, for elevated boardwalks.  If the boardwalk is only 6" off a beach, an accessible route leading from the boardwalk to the beach seems a “do-able” thing.

Question 5:

• The 36-inch minimum width with a 60"×6"” passing space every 200 feet should be the standard so that these types of pedestrian access are consistent with the requirements for walkways and outdoor recreation access routes.
• Beach access “boardwalks” over protective dunes are typically 4' or 5' wide, because 3' is too narrow.  If 3' is adopted, the passing space interval should be reduced to 100' due to often heavy pedestrian group traffic.  If beach access is at grade, parts of the route will be constricted in width by drifting sand, and a minimum of 5' to 8' will reduce routine maintenance costs.
• An accessible path to the beach will most likely be used by a large number of beach goers who will be carrying large items such as coolers, beach chairs and umbrellas, strollers, etc.  Therefore, the minimum width of beach access routes should be increased to minimum width of 60 inches (5 feet) and passing spaces should be eliminated.  However, it is believed that access routes to the beach will require intense maintenance on a daily basis if not more often because of shifting and blowing sand.  Sand that is allowed to accumulate on the accessible route will prevent people with disabilities from maneuvering along the path.
• Canaveral National Seashore has set a design standard which utilizes a constant 60" minimum width for boardwalk access to the beach.  Years of observing our park visitor patterns show that many of our users are not just simply transversing over the boardwalk with a beach towel but are toting beach chairs, coolers, wheeled fishing carts, etc. across the walkways.  When these types of users meet midway traveling in opposite directions, passing becomes difficult. This is the main reason why a constant 60" minimum width is utilized in lieu of passing space located at 200 foot intervals.  With the above said, a wheel chair may have a difficult time trying to back up when on the down hill slope of the boardwalk even when the slope is within the required grade for accessibility.
• It is felt that an accessible route should be provided if these elements are combined in a specific area to group them in a more highly developed setting.
• Should be the 36" inch width of beach access route be increased?  Should passing spaces be provided more frequently than every 200 feet?  Yes, if it makes it easier not just for the wheelchair user or for someone with mobility situation (a walker) but the family with him or her and visitors behind or in front of him or her.  As far as natural resources, a path would protect more of the beach.  Every 200 feet is enough with a bench to rest.
• The width for beach access routes should be increase to a min of 48".  This is because the nature of construction makes it almost impossible to maintain the min width due to the movement of the native material over the route.  This is hard enough when you are dealing with stable materials to maintain let alone sand.  I am fine with the passing zones as they are proposed.
• Passing spaces should be every 200 feet, unless beach usage numbers show that passing spaces are needed more frequently to prevent backups on the access routes

Question 6:

• Elements on the beach such as first aid stations and concessions should be on some type of accessible route.  It could be a beach access route, outdoor recreation access route or other walkway.
• Extension of beach access routes to the water must account for tidal, estuarine, and lacustrine level changes.  In areas of Alaska, tides of over 22 feet exist.  Development in hydrologically active zones is and will continue to be a problem.
• It appears the intent of beach access is to not only access the beach, but also reach the water.  There are many NPS areas (in Alaska and other places) where visitors may want to access the beach, but not necessarily the water.  Requiring the beach access to extend to the water per T305.3 in all cases seems excessive.
• “Wet or damp” beach sands are typically firm enough to be accessible.  The typical accessibility problem for beach access is getting across the soft dry sand to the firm wet sand.  Some beach access devices (both manual and motorized) have been developed to address accessibility on soft sand.  If existing concessions, first aid stations, and rental equipment facilities are permitted and set in dry sand areas they should be made accessible, but new facilities should be located on the land side of a beach and not where drifting sand poses daily maintenance problems.
• Yes, beach access routes should connect to managed elements and spaces.
• First, we are of the opinion that a boardwalk extending to the beach shoreline will not last past the first major storm, which generally causes severe erosion and undermining of the boardwalk structure and is likely to compromise the structural stability of the boardwalk.  Maybe the first aid stations, concession stands, volley ball courts, etc. should be located closer to the point of beach entry where accessibility may not be a major issue.
• Should connected managed elements and spaces often located on a beach such as a beach volleyball court, first aid station, beach rental equipment facilities, and concession stands be accessible?  Yes, and also lifeguard stations should be one of the accessible beach routes.
• My answer to this question is yes.  There is no reason that all of the facilities listed could not be located along an accessible outdoor route.  As long as the route allows reasonable access to the general area for activities such as volleyball I feel that that should be sufficient, but the service areas such as first aid should all be located along accessible routes.  This should not be a problem for a designer.
• Beach access routes should connect “accessible” managed elements and spaces located on the beach.  The beach environment and its elements should be treated similar to a forested or other outdoor setting that provides accessible managed elements (such as picnic tables, fire rings, benches, etc.)
• Yes, any managed elements available to some should be available to all.
• Accessible beach access routes should be located in the same areas as the general circulation flow of most site users, including access to the areas mentioned in question six.  To not do so would unfairly restrict the opportunities of disabled beach visitors.

Question 7:

• The minimum height should be 15 inches.  Most fire rings have a cooking surface.  The 15-inch height allows the wheelchair user to easily access the cooking surface yet still use the fire ring for campfire purposes.
• Fifteen inches is the new revised low reach standard.  Setting grills higher than 15 inches in environments such as a dry forests could greatly increase the fire hazard – lowering the grill to 9”in high fire hazard areas should be permitted (with fire building area on ground).  Some flexibility in adapting the accessible grill height to different environmental conditions is needed.
• A cooking surface for a grill seems to be too low.  There is concern that it would be necessary for the user to bend or lean too far over the fire in order to prepare food and reach for items.  Such motion could throw ones balance off and topple the person into the fire.  A minimum height of 18 inches minimum to 34 inches maximum would reduce the extent of leaning and reaching over the fire and hot grill.  Also, a firm and level surface should be provided adjacent to the grill so that the user doesn’t lose their balance or tip a wheelchair while cooking.
• The Preserve is currently using combination accessible fire ring/cook-tops.  The cook-top has a four level height adjustment ranging from 19"-24"
• The 15" height for a cooking surface of a grill appears extremely low and may pose a tripping hazard.  A 24" to 34" height would be more appropriate.  Additionally, on windy days there would be less chance of wind blown dust or sand landing on your food as it is being prepared.
• Leave to interpretation.
• The height of the cooking surface of a grill is from 15 to 34 inches above the floor or ground surface. Is the height 15 inches too low?  Depending on the type of fire ring cooking surface, 15 inches could be appropriate.  Otherwise raise the height to 20 inches.
• 15" is too low.  In many states the fire code is going to require the fire ring to be at minimum 7" high above the fire surface to prevent the fire from spreading.  If the fire building surface is required to be a minimum of 9" off the ground then that only leaves 6" which is 1" short.  This dimension needs to be considered in conjunction with fire grills because most grills are connected to a fire ring.  I would recommend that the minimum height be 17".  The max of 34" is fine.  These dimensions fit exactly with the accessible fire rings we have been ordering from Pilot Rock.
• A 15" height cooking surface is not too low.
• The 15" minimum height above ground level is appropriate.

Question 8:

• The explanation provided in Advisory T206.2.2 adequately explains how the term “Area” should be applied.
• A possible definition of area might be “consisting of facilities associated by use in a discreet geographic location or physiographic setting”.
• Some flexibility for management/designers in interpretation of definition of “area” is needed to adapt to different terrain, and environmental conditions.  A definition of an area could also be described as, “A distinct location separated by natural features such as topography, vegetation and bodies of water; the built environment including buildings, roads, fences, and walls; or by user groups including individuals, small groups, or large groups.”
• The term “area” does not need to be defined.  The opportunity to explain site features of a park in detail can easily be addressed in park maps, brochures, leaflets, at park kiosks and on the park’s website.
• The definition of “Area” does not seem as important as to describing the intent of T206.2.2 & T206.3 that accessible tables be dispersed at a ratio of 1:1 to non-accessible, but not less than 2 and that they be intermingled amongst the various types of picnic settings.
• Physical conditions of a trail should be posted for the user to determine if the trail is accessible to them.
• Request for a definition of “area” in regards to picnic tables.  The term “area” is not confusing; the word “fixed” is definitely more confusing and has stopped accessibility projects in parks and in some cases only the minimum number of tables has been placed in picnic areas.  This park has considered purchasing only accessible picnic tables.
• I would use the term connected area, or something that shows that the site is linked or managed as one site in a larger area.  This needs to have an example so that it is not abused.
• The Advisory T206.2.2 Multiple Picnic Tables needs no further explanation.  Is it easily understood as most recreation areas are specifically designed with separate picnic areas.
• Yes.  Area can be defined as a cluster or node of related elements in close proximity to one another.
• The explanation given for “area” is sufficient to explain to federal outdoor recreation designers and planners the intent of this definition.

Question 9:

• We concur with the proposed rule as written.
• Firmness and stability need to have distinct measurability, but must also be combined with traction.  Compacted clay, for instance, is especially firm and stable, even when wet.  However, self-propelling a wheel chair across such a surface is next to impossible due to lack of traction.
• Multiple use trails require some compromise by various different users.  Setting the degree of firmness and stability should be based on the intended use.  While joggers and equestrians typically prefer a cushioned surface, hikers and bicyclist prefer a firmer surface.  However, equestrian use will quickly reduce surface firmness.  Firmness may have to be increased to make a trail more accessible.  Equestrian use of some multi-purpose trails may not be permitted for safety, erosion or heavy pedestrian use.  Keeping the firmness and stability information “advisory” is recommended to allow for some trail management flexibility.
• The Board request comment on the concept of having a range of requirements for what will qualify as firm and stable.  For example, is it acceptable for a trail under .5 miles in length to be only “moderately” firm?  Is it acceptable for a trail less than .1 miles in length to be only being “moderately” firm and “moderately” stable?  Further, is it appropriate to consider a surface firm if the wheel of a wheelchair sinks into it by .5 inch?  And, is it appropriate to measure both firmness and stability by the same wheelchair penetration test?  While this information is only advisory, the Board requests comments on whether it should be included in the advisory at all.
• What weight parameter would be used to determine the wheelchair penetration test as weight would be variable between users?
• Firmness needs to satisfy the use regardless of the trail distance.
• It is felt that 50 percent is excessive.
• Should information in the advisory include degrees of firmness for trails under half a mile?  If the information would assist park staff- add to the advisory.
• Yes, I feel that the degree of firmness should be based on the length and type of use, especially if a trail is designated as shared use.
• The advisory information is needed.  Surfacing has been one of the most confusing and complicated issues for accessibility.  The stated guidance for trail length with specific types of surfacing firmness and stability is adequate, but could be improved by developing a matrix.  An example is shown below:

  Trail Length	Grade	Firmness	Stability
  < .1 miles	< 3%	Moderately Firm	Moderately Stable
  > .1 but < .5 miles	< 3%	Moderately Firm	Very Stable
  > .5 miles	> 3%	Very Firm	Very Stable

  The matrix above becomes more complicated when different users are added e.g. equestrians and bicyclists.  It may be that equestrians and bicyclists may not be compatible users on the same trail, requiring separate trails.
• Only need to have firm and stable defined.  Table A does not need to define levels of firmness or levels of stability
• The definitions and explanations of these terms and determinations is good; However, determining the firm & stable class using a rotational penetrometer is not a "reasonably practical" way to determine if a trail or access route is "accessible." This seems like a conflict of interest since there is basically one source for a penetrometer, Beneficial Designs, and it is expensive (>$2,250). This instrument also needs to be calibrated in order to obtain accurate readings and this may be problematic.
• We also suggest that the description of T303.3 examples be redesigned to include a bulleted list with examples of common surface types and sieve sizes under each category

Question 10:

• See comment for T206.2.2 Multiple Picnic Tables, T207.2.2 Multiple Fire Rings, T208.2.2 Multiple Cooking Surfaces, and T213.2.2 Multiple Benches above.
• Whether or not the areas containing picnic tables, fire rings, etc. are accessible is beside the point.  Manufactured products such as tables, benches, fire rings, regardless of where they are placed can and should be universally used.  First, there is no reason to design and manufacture site elements that are not in compliance because of the many years invested in upgrading facilities it has been determined that universal design is good design.  Second, even though access to areas with the aforementioned site elements may not be accessible, the use of those elements should not be predicated upon mobility impairments only.  Why not provide an accessible picnic table to someone who is not restricted to a wheel chair, but may have other physical limitations or even be the picture of perfect health?  Maneuvering in and around the table seats, for example, is not only possible but also an accommodating experience for all?  Finally, why should a facility manager invest in a multitude of furnishings when a goal of accessibility is met by cost efficient and sustainable operations and maintenance?  Bottom line, determining a certain percentage of site elements that are deemed accessible does not make sense.
• Accomplishing the goal of providing adequate accessible picnic tables is difficult.  If we assume that all picnic tables are fixed, then scoping of 50 percent of outdoor elements as accessible and 40 percent connected by an outdoor accessible route is probably excessive and should not be increased.  If very few are fixed, then it is low.  Most picnic areas are near parking areas and percentages should double or triple the accessible parking spaces to allow for some choice.  Picnic tables in many areas are not fixed, and any picnic tables required to be on an accessible route should be required to be fixed or they will be relocated by users.  In our park, the determination of whether or not to make tables fixed is a maintenance/resource management decision and less than 5 percent are fixed.  The rule should be written so that the number of accessible places at picnic tables meets the need.  Using a method similar to determining the number accessible parking spaces might be a better way to accomplish the goal.  If we determine that 5 percent of all seats be accessible, it could then be further written that a number of those tables should be fixed to make sure they remain in an area that is accessible.  This will give designers the flexibility to provide a variety of seating options and not allow maintenance decisions about fixing tables to significantly influence the number of accessible seats.
• The number of required accessible outdoor elements and those that are connected by an outdoor recreation access route should not be increased.
• A requirement of 50% of the elements provided to be accessible seems high in comparison to the requirements of the Americans with Disabilities Act, for example, indoor restroom facilities do not require the minimum number of toilets in a restroom to be at 50% of the non-accessible toilets. That is, unless recent amendments have changed this requirement?  The 50% ratio in the proposed rule seems more than adequate. 
• OK as written.
• If all outdoor elements such as picnic tables, fire rings, and benches are 100% accessible, no one is excluded. 
• The requirement to connect 20% of all picnic tables and other elements by an outdoor recreation access route is excessive.  This requirement means that these tables need to be connected to restrooms, accessible parking spaces and other accessible elements in the area.  This effectively raises the scoping for accessible parking spaces at picnic areas to 20% as well to meet this requirement, where ABAAS scoping for parking spaces is 4-8%.  If the same accessible parking spaces are used for several tables, this requirement means providing an access aisle from the parking to the outdoor recreation access route the picnic tables are located on.  This route needs to be out of the travel lane, if the road is part of the access route, it needs to be widened.
• Recommend the scoping for picnic tables and elements be the same as for parking spaces with the additional requirements for each type of space provided in the picnic area (single table, family table, group area) and dispersion requirements.
• No.  I feel that 50% is a good percentage.  I also feel that 40% is good.  I do feel that in many cases designers should be able to reach 75% but in difficult terrain this would only happen by dropping potential sites.  It would be my hope that if the facility is not difficult to make fully accessible then it will be.  I know the Forest Service has made this decision.
• The proposed rules are adequate to serve accessibility needs while moderating expenditures.  In some cases, designers will need to be creative and diligent while designing accessible routes, but should be able to accomplish these modest goals.
• Two part answer:
  • Agree with the numbers stated (50 percent).  See no need to increase the percentages but would like to strive whenever possible for higher numbers.
  • Do not see the need to increase the numbers on connecting accessible routes.  Agree with the numbers stated (40 percent).
• The increased number of accessible elements, such as picnic tables, should be 100 percent not 50 percent.  If the outdoor accessible route has to be 100 percent accessible that connects the picnic tables, to the accessible restrooms, to the accessible parking spaces, then, in effect, it raises the scoping of all elements to 100 percent, when you connect the dots.  Visitors with and without disabilities should be able to recreate together in the setting they choose.

Question 11:

• The proposed reach ranges should not be difficult to maintain.  There are fire rings, grills and other outdoor items available that already meet these ranges.
• A fire building area at 9" is needed if a grill is to be at minimum of 15". Raising the fire building area may increase the fire hazard in environments such as dry forests – lowering the fire building area to ground level to minimize fire hazard in hazardous area or dry conditions should be permitted.  Some flexibility in adapting the accessible fire building height to different environmental conditions is needed.
• There is concern that the minimum height of 15 inches for a cooking surface is too low for the average adult and should be raised to 18 inches minimum to prevent toppling onto the hot grill or into the fire when preparing food or reaching for items.
• Maintenance and visitor use inevitably causes shifts in site features.  It is felt that rulings should not stipulate the very minimum and should allow for change in use by stipulating requirements that are above the minimum.
• The park has no comment on this question.
• I have already commented on fire rings earlier.  My question concerning this issue is that if the min reach for a fire building surface is remaining at 9" (which I agree with) then what other elements in the outdoor environment outside of cook surfaces would raising the min height to 15" change.  I have already explained that the cooking surface is going to need to be 17" because of fire code and safety.  I would just leave the min reach at 9" except for cooking surfaces to avoid confusion.
• Make the reach 9" for the fire building surface on fire rings an exception to the standard reach ranges of 15" to 48" as shown in figures T406.2.1 and T406.3.1.
• Keep the fire-building surface at 9" minimum and the revised 15" minimum for the operating mechanisms and various controls.  This falls in line with the cooking surface minimum height.

Question 12:

• Examples of alterations for picnic sites and campgrounds include:
  • Addition of new features.
  • Replacement of features such as tables, benches, fire rings, and RV parking pads.
• Examples of maintenance of picnic sites and campgrounds include:
  • Cleaning and removal of debris, such as leaves branches, and fire ashes.
  • Painting, removal of graffiti.
  • Replacement of broken parts, such as table tops, fire grates, roofing, and signs.
• The NPS already defines trail maintenance and maintenance of picnic areas, campgrounds, etc., and distinguishes alterations as repairs, rehabilitation or new construction.  The level of maintenance or “alteration” should be a park management decision and is dependent on budget appropriations.

• The distinction between alteration and maintenance should be clarified as they relate the resurfacing of a trail with the same material.  This seems to be a maintenance function but the wording in the advisory for T202.3 cites as an alteration, “Installation of a new trail tread surface…”  It is not clear if this is meant to include a new surface of the same material or a new material.  If it means the same material, then it should be considered maintenance because it still would not change the original purpose.  Suggest rewording to say “Installation of a new material on the trail tread surface.”
• The definition of trail maintenance versus alterations seems to work as a definition for other types of elements as well, such as campgrounds, picnic areas etc.
• Deferred comment.
• Similarly to the statement:  Every time a trail is maintained, the opportunity to improve access is present, should be the guidance. 
• The same definitions should be used for all elements covered in the guidelines
• I feel that the examples for defining what is an alteration and what is maintenance should be for campgrounds and other developed areas and not trails.  Designers can extrapolate the examples into trail.  Maintenance on trails often requires changing the natural environment with very few man-made elements.  This is different then performing maintenance on man made structures or elements such as tables, campsites, accessible outdoor routes etc.  I would have all of your examples that define alterations and maintenance come from campsites/picnic sites and accessible outdoor routes and not trails.
• The Advisory T202.3 Alterations needs only one or two examples of maintenance beyond those shown for trails.  Example:  Repair of outdoor elements, including painting and replacement of deteriorated, damaged, or vandalized parts of such elements as picnic tables, benches, tent platforms, and fire rings.
• Alterations for picnic areas, campgrounds and beaches, including outdoor recreation access and beach access routes should be defined the same as trails under T202.3.  Maintenance would be defined the same as trails under T202.3
• If the activity being planned significantly changes any of the elements of the original site design or purpose, then it is an alteration. If it is a repair that brings an element back up to the original design standard, then that would be a maintenance activity. For example : Adding a fishing pier at a lakeside recreation area is an alteration if that pier was not previously there and in that same location.  Accessibility improvements could be triggered when maintenance exceeds a certain percentage of the currently estimated value of the outdoor recreation facility.

Question 13:

• Construction tolerances should not be different for the outdoor environment, especially for elements other than trails.
• Construction tolerances for outdoor environments should obviously be different, and are dependent on materials (natural or manmade), labor (skill level, machine, power or hand tools used), management directives, distance from roads, etc.  Construction tolerances achievable in an urban park cannot be met and are inappropriate in a back country, primitive or wild area. Some flexibility appropriate to different environments, man made or natural materials, labor & tools available, proximity to roads, management philosophy, etc., is needed to retain/sustain the “outdoors” in varied outdoor environments.
• Weather factors should be carefully considered when considering construction tolerances in an outdoor environment.
• OK as written
• Tolerances will need to be greater by stipulating requirements that are above the minimum as explained in Question 11.
• The park is not certain about these questions. Do these questions mean that trails, picnic areas, and camping facilities would be utilized by more people than interior accessible routes?  If so, more attention and funding should be obligated where more visitors will benefit.
• Construction tolerances are based on the construction material, not the location.  The slope requirements for outdoor developed areas should be relaxed for outdoor developed areas – the same slopes given for trails should be used for trailhead parking areas, picnic areas, beach access routes and campgrounds.  2% maximum slope is unreasonable for accessible parking spaces and cross slopes in outdoor environments.  The 5% cross slope maximum identified for trails should be used for all elements including parking (tent pads, table pads and RV pads should be 2%). As written, parking areas and routes to restrooms, etc. are based on ABAAS.  This guideline needs to allow these areas the same flexibility as the trails they serve.
• There should be an advisory included to identify construction tolerance issues and advise that percentages identified in the guidelines are constructed maximums. Advise that design maximums need to be less than the constructed maximums identified in the guidelines to allow for paving material construction tolerances provided in project specifications.
• We added the following design standard to our website and design scope of services:

  To meet the requirements of the Architectural Barriers Act Accessibility Standard (ABAAS) for accessible routes, the DSC has developed the following standard for design maximums:

  	Construction Maximums (ABAAS)	Design Maximums (DSC Standard)
  Ramps	1:12 = 8.33%	1:12.5 = 8%
  Walks	1:20 = 5.00%	1:21.0 = 4.75%
  Parking	1:48 = 2.00%	1:55.0 = 1.8%

  These design standards assure construction contractors can meet the ABAAS requirements while allowing for paving material construction tolerances provided in project specifications.  Example of bituminous concrete pavement specification tolerance and implication on design:

  Bituminous Concrete Pavement Specification:

  Surface Tolerance:  The variation between any two contacts with the surface shall not exceed 3/16 inch in 10 feet.  Correct all humps or depressions exceeding the specified tolerance by removing defective work and replacing it with new material at no additional expense to the Government.

  Implication on design:

  Accessible maximum = 2% for accessible parking.  If designed at 2% = elevation change of .40' in 20'.  If tolerance is added 3/16" in 10' = 3/8" in 20' = .03125' + .40' (2% design) = .43125 in 20' actual with construction tolerance added.  = 2.16% as built.

  3/16 inch in 10 feet equals 16% tolerance in grades.  Needs to be added to design grades = 2% – .16% = 1.84% Design maximum allowed to build to 2% max.

  If 1.8% max design allowed:
    = elevation change of .36' in 20'.  Add tolerance of .03125' in 20' = .39125' in 20'.
    = 1.956%.

  We also added a contractor quality control specification to make sure construction contractor meets the requirements of ABAAS (will need to be updated for outdoor areas).  Advisory to recommend quality control specification should be included in the guidelines.

• No.  With the possible exception of beach access.  I feel that the technical aspect of outdoor accessible routes is already different due to the exceptions.  Beach access is very difficult because the water and material are always changing in most cases daily.  Many people with disabilities visit water areas and beaches with assistance, and I feel that the slope requirement should be raised just like boat ramps to accommodate access especially along rivers, and especially where they can receive assistance to and from the waters edge.

  The issue of shared use is best solved by the agency who administers the trail identifying what the trail is designed for.  Instead of using the term “trails” the term pedestrian should be added.  If it is a bike trail that does not mean that people can’t walk on it but it is not intended to be designed as a pedestrian trail.  I feel this issue is best dealt with by asking the question what is this trail designed to do?  If it is a bike trail that also allows pedestrians then the bike aspect of its design should take precedence.  If it is a pedestrian trail that allows bikes then the pedestrian and the accessible laws that come with it should take precedence.

• Yes, construction tolerances for the outdoor environment should be greater than interior accessible routes.  They should also have more flexibility by allowing for a range of tolerances guided by minimums and maximums.  The current proposals for maximum trails grade lengths is a good example of this, which can be applied to other areas such as picnic, camping, trailhead parking, etc.
• No; there should not be different construction tolerances for the outdoor environment.  There already exists in place, exceptions to cover deviations from the standards in conventions T103.
• We suggest that construction tolerances in outdoor environments be greater than standard practices.

Question 14:

• See comment for T206.2.2 Multiple Picnic Tables, T207.2.2 Multiple Fire Rings, T208.2.2 Multiple Cooking Surfaces, and T213.2.2 Multiple Benches above.  In addition, it is asked if these elements should be required to be accessible in the event that technology will someday allow access to non-accessible trails with assistive devices.  There is no way to adequately predict what those conditions and circumstances will be and to base a requirement on what may or may not occur at some unknown time in the future may not be reasonable.
• Accessibility requirements are not waived on inaccessible 2nd or 3rd stories of new buildings without elevators.  Based on this analogy, some built elements such as toilet rooms, pit toilets cabins, shelters, and any doors should be accessible (readily fitted with grab bars for example) regardless of whether the trail to the area is inaccessible.  If you make built facilities accessible some people with disabilities and the elderly may eventually get there and use them.  Accessible design is good design and many aspects are universal.  New buildings/ facilities in currently “inaccessible” areas may eventually be accessible or may be accessed by senior citizens.
• The definition of an Outdoor Recreation Access Route versus a trail would benefit from looking at examples because the differences are unclear.
• No, it should not be a requirement to include accessible elements on trails that are not accessible.  As technology changes and allows for greater access, the elements can be updated to reflect the need.
• Don’t see the need for requiring accessible elements on trails deemed “not accessible” If future modifications would make the trail “accessible” then this should be considered an alteration and accessibility requirements would then apply.
• Trail toilet facilities should all be accessible.  For example, a companion assisting a wheel chair person along a non accessible trail and the wheel chair person needs to use the restroom.
• All trail construction shall be accessible as environmentally possible including accessible site features
• The park understands the difficulty in providing specific guidance on dividing trails into different categories.  Accessible benches, picnic tables, and toilet rooms can be used by all visitors.
• The requirements for trail width and maneuvering space around accessible tables will cause more environmental damage than the benefit of the additional accessible tables.  In many steep areas, picnic tables are placed on small pads with narrow access.  Making these tables accessible would create a much larger footprint in these natural areas – exceptions should apply to picnic areas and scoping should be the same as transient lodging or parking areas as a minimum with dispersion and type of picnic site added.
• I feel that Pedestrian trails should be rated into 3 categories.  Easy, Moderate, Difficult or Circle, Square, Diamond, Green Blue Black.  This should not necessarily be based on distance but more so elevation change, terrain, natural conditions.  I feel the backcountry issue could be addressed by calling these areas in the law “routes”.  Many of these backcountry routes the primary goal is to keep people from getting lost as they attempt to reach a destination.  Many of these routes are marked with cones or small signs.  I feel that it would be wrong to try and apply technical specs to these routes.
• I feel that in order to avoid confusion that even if a table or facility is not located along an outdoor accessible route it should be built to the technical standard.  I feel that facilities that are built to this standard serve everyone better with a particular benefit for older generations.
• I feel that all (100%) of tables, fire rings and cooking surfaces should be accessible.  This will make things much easier to monitor and implement.
• Yes, some elements should be accessible.  The board is moving in the right direction by considering what are the most important elements that should be accessible on an inaccessible trail e.g. restrooms vs. benches and picnic tables.  Since the life span and cost of a restroom facility is far greater than that of benches, picnic tables, and other small amenities, it is likely new assistive devices will exist during the restroom’s life span.  Benches and other amenities can be made accessible as alterations at the end of their life span become necessary.  This makes the transition to accessible faster once technology becomes available.
• Yes; elements located on inaccessible trails should be required to be accessible because it benefits everyone and may reduce the future costs of alterations.
• In support of accessible recreation opportunities and universal design, one hundred percent of elements located along trails should be accessible even when the trail itself does not meet the definition of accessible.

Question 15:

• The requirement for a beach access route for every ½ mile along a new beach is appropriate.
• On a long beach front ½ mile is probably reasonable, but the appropriate distance should not be the question.  The policy should be all new beach access construction should be accessible and existing beach access routes should be made accessible (i.e. universal access).  A possible exception would be existing heavily developed beaches with very small parking areas and restricted narrow access ways between buildings to beach, where opportunities for “universal” beach access route locations might be very limited due to very expensive private lands.  The distance and spacing of beach access routes should be a management decision based on environmental concerns, and the overall level of development (or lack thereof) behind or along the beach.
• Constructing permanent beach access routes every ½ mile along a new beach seems excessive.  However, the construction of temporary beach access routes every ½ mile is less likely to require ongoing maintenance and may be less likely to interfere with the way other beach goers use the beach.  The ½ mile close proximity of permanent accessible routes would begin to interfere with the way other beach visitors use the beach.  For example, it is customary for people to walk or run parallel to the ocean for long distances.  Accessible trails that run perpendicular to the ocean could become a barrier due to sand erosion or wind blown sand mounding along the hard surfaces of the trail.  They could also become a tripping hazard if the sand adjacent to the hard trail surface is not flush with the top of the pavement.  Also, extensive maintenance will be required on a daily basis or several times a day to keep accessible trails passable to people with disabilities.  One accessible beach trail should be considered as the norm along new beaches. 
• A percentage of access routes should be standard and the distance between should be according to the impact to natural resources and terrain but, ½ to 2 miles would be OK.
• The half mile distance between beach access routes for parks that have miles of coastlines would not always be appropriate for many reasons including safety of all park visitors.  This park has designated bathing beaches which are usually guarded during busy seasons.
• This distance is arbitrary and may lead to unnecessary access routes.  T205.4 is all that is necessary with one caveat.  50% of all access points to the beach (access point perhaps defined as a parking lot) should have accessible beach routes no matter the size of the beach.
• Recommend constructing a beach access route every ¼ mile because the individual experience would be improved and it would benefit everyone.
• The requirement that accessible routes need to extend to the high water mark of ocean, river and lake beaches needs to be revisited.  The construction and maintenance costs for these facilities, impacts on threatened and endangered bird and turtle species were not sufficiently considered in the NPRM.
• This requirement to construct a beach access route every ½ mile might warrant exceptions.  Maybe it would be better to require access where there are parking areas or other amenities.  If the area is otherwise unimproved, access routes every ½ mile are

Question 16:

• We suggest providing an exception for beaches with excessive slopes similar to that provided for trails.  In a reservoir with fluctuating water levels, the slope on the beach can vary greatly depending on where the waterline meets the beach.  Reservoir locations are typically picked because the locations have steep slopes.  Beaches naturally follow the original contours of the land which could make it difficult to meet the slope requirements in many areas.
• All beaches are not wide gently sloping sand, and topography or environmental concerns including ground nesting birds, may require year-round or seasonal closure or restricted public access.  All beaches are not public (varies by state & historic settlement patterns) nor accessible to the general public by land or water.  Environmental concerns should govern where beach access routes are provided.
• Shifting of the shoreline from one day to the next.
• Conditions on barrier islands are always changing including beaches after major storms.  For the safety of all visitors, it is recommended that visitors swim at life-guarded beaches.  Rough sea conditions can easily destroy boardwalk beach access; beach barriers could impact nesting sea turtles and colonial shorebirds which do not nest in the same places from year-to-year.  The park recognizes that visitors enjoy walking the beaches and enjoying solitude. 
• Need to include a definition for beach in T104.4.  Does it include all of the natural shoreline?  Many of these areas have steep cliffs adjacent to them.  Many are protected areas.  The same exceptions provided for trails need to be applied to beach access routes.
• No.
• Yes; reservoirs are not specifically spelled out.  It seems that departures would be covered under T302.1 Conditions for Exceptions in chapter T3: Technical Provisions.
• Yes, there might be steeply sloping conditions or uneven surfaces that make the provisions in T305 unfeasible.

Question 17:

• The construction of parking spaces adjacent to a beach should not trigger the need for a beach access route.  The purpose of the parking may not be for access to the beach but could be intended to provide parking for other facilities in the area such picnic sites, buildings, boating facilities, etc.  If the parking space does serve access to the beach, then a beach access route or a pedestrian route which connects to a beach access route should be required.
• See answer to question 15.  If new parking is constructed accessible parking spaces should be provided and enforced, and an accessible beach route provided.  If an existing parking area is large (or the sole point of beach access), then a “universal” beach access route is warranted.  For small frequent existing parking lots that provide direct access over sand to a beach, the parking lot (not water) should be considered the extent of a beach access route.  For persons with disabilities providing their own assistive device to traverse sand to water, “universal” beach access routes to the water should be provided at intervals of up to perhaps ½ mile.
• No, the provision of constructed parking spaces adjoining the beach should not trigger a beach access route.  However, the number of parking spaces would be a more appropriate method of triggering the need for an access route.  Constructing one or two large parking lots rather than numerous smaller lots scattered adjacent to the beach would be preferred.
• The provision of a constructed parking lot or parking space should not trigger a beach access route.  At Canaveral National Seashore, some of our boardwalks provide ADA accessibility up to the top of the dune to a vista point overlooking the ocean, but, because of site conditions, the construction of an ADA switchback ramp down to the beach was not practical.
• Beach access should be provided if it is not over sensitive terrain. Access routes would encourage traffic to traverse over specific areas and reduce impacts.
• Yes, if there is a constructed parking lot, regardless of the number of parking spaces, there should be a beach access route.  Boardwalks funnel visitors in specific routes keeping them off vegetation and dunes.
• I think adding the provision of constructed parking adjoining the beach is a good idea, adding a minimum number of parking spaces is important, consider 10 or more spaces.  The same exceptions provided for trails need to be applied to beach access routes.
• Yes, beach sites with constructed parking spaces or a lot should trigger the provision of an accessible beach route with the provision stated in Question #15 above.  Not every access point should be required to provide and accessible route, but requiring at least 50% is not unreasonable.
• Yes, the provision of constructed parking spaces adjoining the beach should trigger a beach access route.  The trigger should be based on the proximity to existing beach access routes within ¼ mile and as defined in the scoping requirements T205.2 and T205.3.
• It is better to place access routes at parking areas than at an arbitrary interval.  It would create routes used by all people.  It could reduce impacts on the resource.  And yes, the number of parking spaces would be a good trigger.

Question 18:

• Beach nourishment should be considered routine maintenance and exempt from triggering the requirement for a beach access route.  This would be consistent with the exemptions for meeting requirements for routine maintenance of other outdoor features such as trails and campsites.
• In general beach nourishment is routine maintenance.  However, if a new or different experience is created by the beach nourishment, then a beach access route should be added
• Beach nourishment projects are typically undertaken by a governmental agency.  If federal funds are involved, then these projects should be taken as an opportunity to provide for access route(s) and should be a required part of any beach nourishment project.
• Beach access should be limited to redevelopments or additions of architectural construction such as hard surfaces and buildings rather than beach replenishment.
• It has been the experience of this park that beach nourishment is a temporary fix for a long-term problem.  This park currently has only one beach nourishment site that is adjacent to a boardwalk.
• Yes, certain beach nourishment activities should trigger the provision of an accessible route.  The trigger occurs when the beach nourishment is no longer a “maintenance” activity vs. an alteration activity.  This can be defined similarly as other maintenance and alteration activities.  For example, if a beach needs to be completely “re-established” because of storm damage, the provision of an accessible route should be part of the re-construction activity.
• This appears to fall under the maintenance category.
• As with other types of projects, a percentage of cost or value might be used to trigger accessibility requirements.

Question 19:

• The departure from the technical provisions should also include natural drainages.  In a lot of areas the land will provide adequate drainage without the need to have physical “structure” constructed.  Trails are typically to provide a “natural experience”.  As written, it creates a requirement that in order to have a 10 percent cross slope a structure must be installed which takes away from the “natural experience”.
• Trails in “closed” drainage structures, except for possible short distances with a day lighted end clearly visible, are probably not desirable from a safety viewpoint.  A cross slope of 10 percent is probably only appreciated by skateboarders.  Many people with an assistive devices are likely to tip over on a steep cross slope of 10 percent, and any trail segment with a 10 percent cross slope should be limited in length.  But in some areas open drainage structures may be the only trail option.
• Yes, open drainage structures should be the only drainage structures where cross slope up to 10 percent are allowed.
• Anywhere that water may naturally cross a trail with or without an open drain.
• The park has no comment.
• Yes; but could also explore water-bars.  A definition of an open drainage structure would be helpful.  Make sure technical provisions define the exceptions to tread obstacles and openings.
• We agree with the written guidance that a cross slope up to 10% is permitted at the bottom of the open drain where the clear dread width is 42 inches minimum.  However, since cross slopes greater than 5% can be hazardous, they should not be permitted in other situations.

Question 20:

• Exceptions for specific elements on outdoor recreation access route as well as exceptions for outdoor recreation access routes should be permitted when any of the conditions of T302 are met.
• Concentration rather than dispersion of accessible elements may be appropriate where topography or soils necessitate exceptions.  However, the “best” picnic or camp sites (view, proximity to water, trees, and setting) may not be readily accessible by an outdoor recreation access route.  All the accessible elements should not be restricted to readily or easily reached sites, and a few of the best camp or picnic sites should be fitted with accessible elements even if outdoor recreation access route requires an exception.  Persons with disabilities and senior citizens should have some choice and variety in selection of camp or picnic sites.  Eventual movement toward more “universal” accessible design of camp and picnic sites is preferable.

  Rather than create conditions for the Outdoor Recreation Access Route (ORAR), would it be possible (due to topography) to locate some accessible elements (picnic tables, benches and campsites) adjacent to this area that meets the criteria for trails?  An example is showing one site where part meets the ORAR and the rest meets the trail criteria.  This would allow the designer to concentrate construction in one area to reduce resource impacts while still providing a fully accessible area and a potentially/partially accessible area.

• Yes, exceptions should be permitted to avoid significantly altering the nature of the setting.
• Yes, exceptions should be permitted for outdoor recreation access routes if one or more of the conditions in T302 apply.
• Yes.
• In some parks this is not an issue such as one with a relatively flat topography where a slope is not significant.
• The same exceptions provided for trails need to be applied to all outdoor developed area elements.
• No, I would not allow exemptions for the outdoor accessible route or the facilities.
• Allowing outdoor recreation access routes the same exceptions based on the conditions in T302 would not provide the desired accessibility.  Access routes by their very nature are linking multiple accessible elements in an area.  We expect areas such as these to receive heavy use and should therefore be design to accommodate the greatest variety of users including the disabled.  Designers have an obligation to location these areas in sites providing the best accessible conditions.
• Exceptions should be allowed as stated.  T302 should apply to outdoor recreation access routes, beach access routes, elements, and trails.
• 100% accessibility should be the stated policy goal for all federal land in outdoor recreation access routes as with the elements they connect.  Exceptions from the technical provisions should be permitted for outdoor recreation access routes based on the conditions in T302, but the same documentation should be required of them as for the exceptions for the trails as noted in the comments for Question One above.

Question 21:

• The proposed guidelines are adequate as written.
• See second bullet in Question 20.  Allow for exception under T302.
• Apply the conditions in T302 to the technical provisions for the slope of an outdoor recreation access route.
• Apply the conditions in T302.
• It is felt that the indicated requirements for running slope may be imposed if the requirements have no adverse impact on existing conditions.
• In some parks this is not an issue such as one with a relatively flat topography where a slope is not significant.  Based on our local conditions, this park defers to parks that have greater variances in topographic conditions.
• I would not add exemptions to the outdoor accessible route.  Exemptions would only make these standards harder to apply.
• Follow the guidelines proposed for trails to eliminated confusion between trails and outdoor recreation access routes (T303.8.2).
• Agree with second option – apply the conditions in T302 to the technical provisions for the slope of an outdoor recreation access route.
• The Service prefers the second option, as in the natural outdoor environment, a maximum of 15% of the total length of the outdoor recreation access route should be allowed to exceed the 1:12 slope.  If that is not reasonably practical, then one of the conditions for exception would most likely take effect, however that exception will need to be documented as noted in the responses to Questions One and Twenty above.

Question 22:

• Using the normal recreation water level as a marker for reservoirs is a marker that cannot be determined and therefore its use would be inappropriate.  Reservoir levels for Reclamation facilities are maintained for flood control and power generation and not for specifically for recreation.  The water levels vary greatly depending upon the time of year and the water conditions (drought) at the time.  Recreation occurs year-round at all various water levels.  We suggest using the maximum flood pool, which is an established level or allow agencies to determine on a case-by-case basis what will work best for the area.
• Markers suggested are appropriate and easily determined on most beaches, with the exception of some very low slope beaches or following storms, floods, high water (or drought for rivers, lakes and reservoirs).
• It is appropriate to use the high tide level, mean river bed level, or the normal recreation level to determine the terminating point of a beach access route.
• We find that the high tide mark for termination of fixed structures is not appropriate.  Storm surges can and will severely damage any fixed structures beyond the normal high tide mark.  We say this in light of the fact that our boardwalk access currently terminates well above the high tide mark and as close as possible to the dune edge and are frequently battered by surf conditions let alone wiped out during hurricanes which seem to be fairly common every season.
• Where high tide can be considered constant, with or without storm activity, an accessible route can be appropriately managed.  Conditions where the shoreline can change drastically, an accessible route will not be able to be managed even at high tide.
• Beaches are not stable; high and low tides vary from place to place and season to season.  Beaches previously flattened by storms can be over washed from minor storms or even high tides.  Because of these local conditions, high tide marks are not appropriate.
• Appropriate as stated.
• High-water markers are neither necessary nor appropriate.

Question 23:

• There should be no technical provisions for sloped entry into the water.  Erosion and the natural contours of the land often will not allow for control of the slope under water.
• Sloped entry into pools is artificial, and quite different than various natural underwater dynamic environmental conditions.  Any access into water should match the natural slope of the beach but recognize littoral dynamics that will change the exact configuration.  The high and low tide lines naturally fluctuate with lunar and seasonal cycles and are changed by storms.  Flexibility is needed to make periodic adjustments at the waters edge (and any underwater segment) of beach access route to maintain accessibility and avoid creating hazardous conditions for all people using the beach, especially from storms or floods.
• Technical specifications should be provided to prevent other bathers from being harmed by the intrusion of a firm surface into the water.  Strong surfs or water currents could easily throw swimmers into or onto the structure creating a life safety concern.  Also, strong currents could easily erode the ocean floor from around the fixed in place structure, creating a significant drop off where the path ends at the water.
• Swimming pools are controlled environments that are conducive for accessible routes into bodies of water.  The changing conditions of natural bodies of water will make a constructed accessible route difficult to conform to changing conditions and may enforce a false confidence that entering a natural body of water is perfectly safe.
• This park has no general comment.  However, one recommendation is to provide a beach wheelchair during the off-season
• Edge protection on beach access routes causes drifting sand to collect making boardwalk impassable for wheelchair users.
• We have provided access below the water line.  I would leave everything alone just to keep things simple.  These guidelines are already complicated enough.
• No technical specifications should be required if an entity decides to provide the route into the water.  Technical provisions for sloped entry into pools should not be applied.
• There should not be any technical specifications required for providing a route from the high-water mark into the water.  People who wish to enter the water will most likely have the specialized adaptive equipment they would need to enter the water.  The constant maintenance needed to keep an accessible route into the water up to standard, especially on tidal beaches, would probably result in very few sites choosing to provide a route into the water.

Question 24:

• We are not aware of any controls and operating mechanisms or of any modifications that could be made that will allow for fireplaces and woodstoves to meet the provisions of T407.
• Operable parts of many fireplaces with raised hearths and woodstoves will meet the reach requirements of T407.2.  The 5 pound operation requirement of T407.3 may be a problem for woodstoves.
• The park has no comment.
• No; not aware of any.
• Contact with manufacturers would provide this information.

Question 25:

• See first bullet Question 3 above.
• In general the rules seem to mandate an extensive amount of signage.  In some parks, view shed considerations call for small signs if at all.  To reduce the number and size of signs, the following is recommended:
• If the trail is accessible without exception, there should be no need for a costly trail “characteristics” sign.  The information about slopes, tread width and elevation can be inferred from the use of the symbol.  Trail length and surface could be simply stated in a text format.
• There should also be no requirement for a trail characteristics sign if the access trail is not an accessible trail.
• Temporary information on bulletin boards should be an acceptable alternative to signage.  This would reduce costs and increase compliance.  Trails that are undergoing reconstruction are usually done in phases which can span several years.  In these circumstances it would be more cost effective to use temporary information until the entire trail is done.
• The first example shown in the advisory for the trail signs shows a very complicated drawing that may not answer the questions a user may have about the accessibility of the trail.  The second is a better example in that it shows, in plan view, where the exceptions occur.  It can also be combined with information about the features of the trail.
• The International Symbol for Accessibility is recognized by the general public and easily understood.  It is currently in use in the outdoor environment in such places as parking lots, street parking and on parking meters and signs.
• Provisions requiring trail signs identifying accessible trails could lead to sign proliferation in compact urban areas.  Do identifying accessible trails or areas on maps serve this function?  90 percent of the National Mall is accessible and we need to get that message out.  NPS policy 9.1.1 is to maximize accessibility and universal design.
• This should be included as a physical condition of a trail on a sign. If overhead clearance is an issue, then represent that at the beginning of the trail by a marker indicating expected reduced clearance by physically representing the reduced clearance.
• If the symbol means accessible for visitors who use wheelchairs, the park prefers the sign with the symbol of the hiker first and the international accessibility symbol second.
• I have commented on signs in an earlier comment.
• The proposed signs provide too much information.  Do users understand the differences between a 3% cross slope and a 5% cross slope to make informed decisions about their ability to use the trail?  A simplified system could be used (at least alternatively) such as the standard symbols green circle for “easiest,” blue square for “more difficult,” black diamond for “most difficult,” and double red diamond for “extreme.”  Each symbol would have qualifying criteria (slope, cross slope, grade, etc.) to determine its difficulty level.
• Prefer the international symbol with the rough terrain line below, showing the uneven surface.  It is the symbol located in the lower left corner of the options offered in T321.2.
• See comments for Question Three.

Question 26:

• We do not have any suggestions to offer as we do not have any trails where the minimum requirement for overhead barriers cannot be met.
• The only options for locations where sufficient space is not available to go around the obstruction are to create a general exception in T303.2 (which could limit access to sites for people with visual impairment) or to provide a warning surface about “low head room” similar to provisions in ABAAS.
• Refer to Question 2.
• I did not fully understand the question.  I would sign an obstacle that can not be avoided.
• It is hard to keep the minimum overhead clearance maintained with living vegetation growing along a trail.  People of all abilities recreating in the outdoor natural environment should be aware of and vigilant of these obtrusions.  Many trails only receive maintenance once per year, so that may be the time when the 80" minimum is achieved.