As a national non-profit organization with a staff and membership dedicated to championing public lands access for responsible recreation and multiple-use purposes, BlueRibbon Coalition is expanding its efforts to increase accessibility for disabled members of the American public. It sometimes feels like anti-access organizations have unlimited resources to enforce discriminatory restrictions against those with disabilities. For a growing number of public land users, motorized access is the only way for those with mobility impairment physical disabilities to access public land. We believe that the goals of conservation stewardship and recreational use can be responsibly and equitably harmonized and champion the responsible use of public lands for the benefit of all recreationists, including those whose only means to outdoor recreation is through the use of an OHV due to disability.
In one of his first acts as President, President Biden signed and Executive Order Methods and Leading Practices for Advancing Equity and Support for Underserved Communities through Government. The Office of Management and Budget solicited public comment on this action, and in response to this invitation, BlueRibbon Coalition submitted a public comment highlighting the importance of OHV access for the equitable access of disabled persons to public lands. You can read our comment here:
We hope OMB takes our comment seriously, and we would like to highlight several guiding principles that we believe should form the basis of any reform that results from implementation of this Executive Order or any other policy that advances access equity for those with mobility impairment disability.
- Federal Agencies that manage public land should be required to perform organizational assessments to gather a baseline understanding of the level of discrimination that exists among agency staff towards those with mobility impairment disabilities.
- Once a baseline understanding is achieved, education and training programs should be required for agency decision makers to help them recognize and eliminate any tendencies they might have to discriminate against those with mobility impairment disability.
- Land management agencies should be required to also perform an institutional analysis to facilitate the assessment of systems, institutions, departments and programs to identify problem patterns and assumptions that lead to discrimination in agency routines – such as administrative requirements and policies, misguided internal memoranda and legal opinions, shortcomings of administrative processes such as NEPA reviews, employee training, and mechanisms for soliciting and reviewing feedback from the public.
- Land management agencies should look for ways to eradicate administrative policies that force agency staff to neglect and ignore those with disabilities or reductively claim through boilerplate legal disclaimers that active discrimination is “not discriminatory.”
- Grant programs such as the Recreation Trails Program and the Land Water Conservation Fund should prioritize projects that create more equitable access for those with mobility impairment disabilities.
- Land Management processes such as the creation of travel management plans, resource management plans, and forest plans should require authentic engagement with the mobility impairment disability community through a process similar to how they are required to analyze impacts to cultural resources.
- Local, State, and Federal lawmakers should find ways to promote equitable access on public land for those with mobility impairment disabilities.
We will keep you updated about any response we get from OMB. However, we aren’t interested
- Under President Biden’s Inauguration Day Executive Order 13985, the Federal Government is directed, “to pursue a comprehensive approach to advancing equity for all, and explicitly with respect to persons with disabilities.” As lands designated for public use become increasingly restricted due to so-called environmental concerns, access for disabled persons who enjoy outdoor recreation is becoming increasingly limited. This constitutes a form of discrimination against persons with disabilities in our public lands policies.
- The problem stated above may be reasonably addressed by a basic requirement to consider disability access when analyzing travel management. While we recognize that OHV access cannot and should not be permitted on all terrain and in all areas, current travel management restrictions are significantly tighter than necessary and hamper disability access to public lands.
- OHV access can be appropriately balanced with ecological concerns through not only travel management restrictions, but also through responsible recreational practices as promoted by those already engaged in OHV recreation. Many groups which advocate for OHV access simultaneously go to great lengths to educate their members on appropriate, responsible use and to assist in maintaining trails, signage, and other amenities that serve to maintain and protect wildlife, vegetation, and other resources.
Please click on the following link to submit your comment: [insert link]
Following the comment submission period, should the Federal Administration fail to implement procedures and guidelines which protect disability access on public lands, BlueRibbon Coalition intends to move forward with a plan to propose legislation to the same effect.
We thank you in advance for your efforts to work with us to advocate for disability access to public lands and hope that our joint voices will have an impact for generations of disabled OHV users to come.