I believe that the Rulemaking proposed by the U.S. Access Board is a step backwards from both the Regulatory Negotiation Committee recommendations and from the current Forest Service Guidelines. Although technically applicable only to Federal lands and facilities, these new guidelines may arguably be perceived as “best available knowledge” and thus become de facto standards for accessibility.
It is essential that accessibility guidelines provide some level of reasonable exception to the most rigorous design criteria for accessibility. There should be included in the new guidelines some recognition that protection of natural and cultural resources can be balanced in a defined, rational way with the provision of public access to those resources.
Regards,
Jim Daus
Land Acquisition Officer
Boulder County Parks and Open Space
5201 St. Vrain Road
Longmont, CO 80503
303-678-6264
fax: 303-678-6179