Florida Trail Association, Deborah R. Stewart-Kent
October 17, 2007   [email]

FLORIDA TRAIL ASSOCIATION Building, Maintaining, Promoting and Protecting Florida’s Footpath Forever 5415 SW 13th Street Gainesville, FL 32608 352-378-8823 or 877-HIKE-FLA
16 October, 2007

Office of Technical and Information Services
ATTN: Docket No. 2007–02
Via Email to: outdoor@access-board.gov
and
Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street, NW, Suite 1000
Washington, DC  20004-111

RE:  Proposed Guidelines for Federal Outdoor Developed Areas

Greetings:

On behalf of the Florida Trail Association (FTA), thank you for the opportunity to participate in the planning process for the proposed accessibility guidelines for accessible trails and associated outdoor facilities.  The FTA is the primary partner with the USDA Forest Service for planning, building, maintaining and protecting the Florida National Scenic Trail (FNST), a 1,400 mile long hiking trail that traverses the length of Florida.

The Florida Trail Association requests you please consider our comments for the identified questions:

Question 1 Response:  The FTA supports the use of the exception based approach similar to those established in the Forest Service guidelines.  We recommend a revision of T202 to clarify that new and altered trails only need to be meet accessibility standards if that segment is connected to accessible trails or trailheads.  We encourage the Access Board to adopt guidelines that may be readily understood and followed by the volunteers who build and maintain primitive footpaths such as the national scenic trails.

Question 2 Response:  Condition 4 provides for the exception from the technical provisions when compliance is not feasible due to terrain or the prevailing construction practices.  We support this exception with further clarification.  This condition should specifically exempt primitive settings in which compliance may be technically possible but not practical considering the adverse effects compliance would have on the trail builder, visitor expectations, or the environment.

Question 9 Response:  This question addresses the firmness and stability of the trail surface.  Stability and firmness should be addressed as an advisory notice rather than be a requirement for accessible trails.  The varying trail surfaces would make measurement of trail surfaces impractical for volunteers and land managers.  The guidelines on this topic should be written for practical application without equipment or advanced computations by trail volunteers who likely would be responsible for these measurements.

Question 14 Response:  While it may be appropriate to recommend access compliance of trail facilities along non-accessible trails, we believe it would not be prudent as a requirement.  Accessible facilities on non-accessible trails would not provide utility for users and would make it increasingly difficult for volunteers and land managers with ever eroding resources to work towards access compliance on non-accessible trails.

Question 25 Response:  Signage requirements for accessible trails should not exceed those of the Forest Service access guidelines.  Burdensome requirements would exacerbate the demands for ever eroding resources available to land managers and volunteers resulting in the display of inaccurate visitor information.

The Forest Service trail access guidelines (FSTAG) provide a good model for applying accessibility guidelines for primitive trails on all Federal lands.  The proposed guidelines should be edited to include an expanded definitions section.  The definitions section provided in the FSTAG adequately clarifies trail related terms and is useful in the implementation of these guidelines.

Thank you again for the opportunity to comment.  If you have any questions, please contact me at (352)378-8823 or dstewart-kent@floridatrail.org or FNST Liaison, Kent Wimmer at (850)523-8576 or kwimmer@fs.fed.us.

Until next our paths cross, I wish you

Happy trails,

Deborah R. Stewart-Kent
Executive Director

Cc:  Peter Durnell, President, Florida Trail Association
  Vernon Compton, Vice President for Trails, Florida Trail Association
  Kent Wimmer, FNST Liaison
  Michelle Mitchell, Trail Manager, USDA Forest Service, National Forests in Florida
  Gary Werner, Partnership for the National Trails System

A volunteer non-profit association dedicated to developing, maintaining, promoting and protecting a continuous public hiking trail the length of Florida; providing opportunities to hike and camp; and educating others to appreciate and conserve the natural beauty of Florida.