FW: [MA-RPC] Draft copy or MARPC response to FSTAG/FSORAG

[Frank Bohn]

Kerry,

Excellent response.   Thank you.

Below is what I've drafted as my own response.  I'm currently circulating it
to the CVATC board to get their advice whether to reword it as a club
response rather than purely my own opinion.  I expect to submit it to the
forest service later this week.  Any comments for the rookie (me) are
welcome.

Frank

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This note is a response to the request for comments on the USDA Forest
Service Outdoor Recreation Accessibility Guidelines (FSORAG) and Trail
Accessibility Guidelines (FSTAG).

My comments are informed by my experience as the maintainer of a section of
the Appalachian Trail in Cumberland County, PA, as a member of two
Appalachian trail maintaining clubs, as a Board member of one of those
clubs, the Cumberland Valley Appalachian Trail Club (CVATC), and a
representative from CVATC to the Appalachian trail Mid-Atlantic Regional
Partnership Committee.  I mention these affiliations as an indication of my
interest in the subject, but I make these comments on my own behalf, not as
a spokesperson for these organizations.  I have no direct involvement with
maintenance of the Trail on Forest Service lands, but I want to comment
because the Forest Service guidelines may serve as models or precedents for
those of other agencies.  These comments will relate primarily to the FSTAG,
because my experience does not relate to the kinds of facilities covered by
the FSORAG.

In the FSORAG and FSTAG it is encouraging to see an earnest attempt to
balance worthy considerations which cannot all be fully realized in the same
time and place.  I would like to see the quality of the outdoor experience
more explicitly acknowledged as one of those considerations.  The guidelines
appear to have based the Conditions of Departure more strongly on technical
considerations than on recognition of the purposes for which these trails
were made.

I believe that the statement that "Maintenance does not constitute
alteration" is an essential clarification within these guidelines, along
with its associated definition of maintenance.  It is important that routine
and minimal surface-hardening or resource-conservation measures (such as
turnpiking or erosion control) remain within this categorization as
"maintenance."

I believe that the establishment of Conditions of Departure in Section 7.1.1
and General Exceptions in Section 7.1.2 are essential to the balance of
interests in these standards.  Hiking trails often follow the natural
contour of the land with minimal alteration of the surface.  An attempt to
hold to all the specifications of slope and surface would create an
appreciably engineered setting to the detriment of the natural qualities
desired for the outdoor experience.

The Appalachian Trail (and many others) have been built and maintained with
the enthusiasm and energy of many volunteers.  I urge the Forest Service and
other agencies to remember that the requirements and standards must also
allow the partner organizations to foster and build that enthusiasm and
energy.  They are essential to maintain these world-class resources for
present and future generations to enjoy.

Let me also state my agreement with the comments of the Appalachian Trail
Conference, which I have seen as a draft dated April 6, 2005 from David N.
Startzell.

Thank you for this opportunity to comment.

Sincerely,

W. Franklin Bohn
  -----Original Message-----
  From: ma-rpc-bounces at commerce-02.cilia.org
[mailto:ma-rpc-bounces at commerce-02.cilia.org]On Behalf Of Kerry Snow
  Sent: Monday, April 11, 2005 10:36 PM
  To: MA-RPC at commerce-02.cilia.org
  Subject: [MA-RPC] Draft copy or MARPC response to FSTAG/FSORAG


  I've attached copies of the draft letter to the Forest Service in Word and
pdf format.

  Kerry
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