Ice Age Park and Trail Foundation, Michael G. Wollmer
The Ice Age Park and Trail Foundation (Foundation) would like to express our gratitude for your efforts on developing the proposed Outdoor Developed Areas accessibility guidelines, and for the opportunity to comment on these proposed guidelines.
The Foundation is the non-profit partner working with the National Park Service and Wisconsin Department of Natural Resources. Our mission is to create, support and protect the Ice Age National Scenic Trail (NST) as a thousand-mile foot trail tracing Ice Age formations across Wisconsin. As one of only eight national scenic trails designated by Congress, the field work is done primarily by volunteers.
As an organization that represents where the boot meets the trail, we request you to seriously consider how these guidelines will be carried-out on the ground by volunteers. The simpler, more clearly defined, and less authoritarian, the greater the likelihood the federal and private partners will be able to reach the on-the-ground volunteers.
These recommendations by no means indicate a lack of interest or intent by this organization. On the contrary, and despite increased costs, workload and the difficulty of educating the average volunteer, the Foundation would like to have a set of well-constructed and logical guidelines. We have the distinct privilege of providing access for Americans with disabilities to the natural, cultural, recreational and scenic highlights of the Ice Age Trail NST.
Please find our comments attached. If you have any follow-up questions for the Foundation please do not hesitate to contact us. Again, thank you for your Committee’s solid work on these proposed guidelines.
Respectfully,
Michael G. Wollmer
Executive Director
The Ice Age Park and Trail Foundation strongly recommends the following changes to the Access Board’s proposed Outdoor Developed Areas accessibility guidelines. The guidelines must be more clearly aligned with the U.S. Forest Service’s Outdoor Recreation Accessibility Guidelines (FSORAG), the Forest Service Trail Accessibility Guidelines (FSTAG), and to be more relevant, applicable and interpretable to volunteers on the ground.
The following are the Ice Age Park and Trail Foundation’s (Foundation) recommended changes pertinent to the Access Board’s proposed Outdoor Developed Areas accessibility guidelines:
- Trail Definitions
The Foundation asks the Access Board to consider addressing the unique aspects of a footpath with regard to the guidelines. Unlike the 32 trail-related definitions within the FSTAG guidelines, there are only three trail-related definitions in the proposed Access Board Guidelines: “trail”, “tread”, and tangentially “designated trailhead”. For example, along the length of the Ice Age NST, there are several different Recreational Opportunity Spectrum (ROS) trail types. There are a variety of trail surfaces and environs through which the Trail passes. Therefore, further definitions and clarifications within the “trail” topic are requested. Our preference is that the final Access Board guideline’s “trail” definitions be consistent with those of FSTAG.
- Definition of Alteration
The definition of “alteration” added under T104 is viable for buildings, but not for trails. It is imperative the definition that appears in the proposed Access Board guidelines does not include trails as it is currently written (see next comment).
- Definitions for Alteration & Maintenance
It is essential that the definitions be accurate and straightforward. Two examples of definitions that require refinement are “alteration” and “maintenance”. These definitions need to be clarified and made applicable specifically to trails. The Foundation recommends the use of the Regulatory Negotiation Committee’s 1999 Report in defining “alterations” and “maintenance” in the final Access Board guidelines.
- Protruding Objects
The Foundation requests that there be an exception to the guidelines for protruding objects below 80 inches in height that occur on the trail. Adding an additional warning barrier could actually cause more of an obstruction and should not be the only remediation for such a situation.
- International Symbol of Accessibility (ISA)
Although the International Symbol of Accessibility (ISA) is certainly applicable to specific trails that meet these requirements, it creates a certain amount of expectations – as it should. However, because grades of up to 12.5% are appropriately allowed along trails in the proposed guidelines, it is possible that the trail will not meet the expectations put forth by the signage. To better inform the trail user of actual trail conditions such as grades, cross slopes, minimum width, distance to exception, turn-around, and composition (as detailed in FSTAG), the signage should contain such information, and the ISA symbol should be avoided.
- Second General Exception
Under the General Exceptions (T303.2), the Condition 1-5 is confusing. It seems to read that no trail is required to have greater than 15% of the trail accessible. We doubt that this is the intention of this exception, and request that a clearer definition be established. The Second General Exception in the Regulatory Negotiation Committee’s 1999 Final Report has such language.
- International Trail Data Standards
The Foundation works closely with its federal partners, the National Park Service and US Forest Service, on management of the Ice Age NST. We also share experience, trainings, and information with many private, state and federal trail partners. Interagency Trail Data Standards (ITDS) have been adopted by federal partners. The ITDS provides a consistent framework for communication. The Foundation requests that the Access Board integrate ITDS terminology, definitions and trail management concepts, including Conditions and Departures, in order for these guidelines to be consistent and usable among federal trails.
- Outdoor Recreation Access Routes (ORARs)
The Foundation requests that the proposed Access Board guideline be changed to specify that ORAR’s are not required in areas that are not an outdoor developed area. We recommend that there be a very clear distinction between ‘developed’ and ‘undeveloped’ recreation areas, and that there be differing guidelines for each. Our reasoning is that connecting undeveloped areas with ORAR’s could impact negatively the cultural, environment and natural features of an ‘undeveloped’ area, and, therefore, should have an exception.
- Exceptions for ORARs
Currently the proposed Access Board guidelines do not allow for any exceptions to the ORAR’s. It is imperative to provide an exception to the ORAR’s when certain terrain, historic, cultural or environmental factors pertain, especially in an alteration or reconstruction situation. The Foundation requests that the Access Board consider including exceptions to the ORAR’s during alterations of existing site and where other features prevent compliance.
In addition to IAPTF’s comments regarding the differences between the Access Board’s proposed Outdoor Developed Areas accessibility guidelines and the FSORAG/FSTAG, below we specifically address one question not addressed above that was raised by the Access Board in its Federal Register notice.
Question 19: Are open drainage structures the only drainage structures where cross slopes up to 10 percent should be permitted? If not, what other areas should be identified?
First of all, it is important to specifically define open drainage structures. There are a variety of structures, and many hybrid structures used for proper trail drainage. Also, different materials, such as rocks are used and should be addressed.
For trail sustainability and user safety, some drainages may be greater than 10%. There are special instances in which the tread itself is constructed in a way greater than 10% cross slope. This is not necessarily considered a structure per se, although still used for the purpose of drainage.