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Comments by American Hiking Society on proposed USFS Trail Accessibility Guidelines

Comments submitted to the U.S. Forest Service on draft Forest Service Trail Accessibility Guidelines, April 14, 2005

By Celina Montorfano

TO USDA FOREST SERVICE, WASHINGTON, DC

Thank you for the opportunity to comment on the USDA Forest Service's draft Forest Service Trail Accessibility Guidelines (FSTAG) and Forest Service Outdoor Recreation Accessibility Guidelines (FSORAG). We commend the Forest Service for its effort in revising the two sets of guidelines and continuing to engage critical stakeholders from the trails community in the process.

As the national voice for America's hikers, American Hiking Society promotes and protects foot trails and the hiking experience. With thousands of individual members as well as the volunteers and members of its 187 member organizations, American Hiking represents more than a half million outdoor enthusiasts and is the only national organization dedicated to establishing, protecting and maintaining America's foot trails.

As a long-time partner with the Forest Service, in addition to the substantial involvement and volunteer contributions of many our member organizations to Forest Service trail maintenance and construction activities, American Hiking and its constituents have a very strong interest and stake in the accessibility guidelines as they pertain to trails and recreation facilities on national forests and ultimately other public lands.

Although American Hiking Society did not sit on the Regulatory Negotiation Committee on Outdoor Recreation Developed Areas commissioned by the Access Board, American Hiking participated in most of the Reg Neg meetings in the late 1990s. One of American Hiking's larger and more prominent member organizations--the Appalachian Trail Conference--was and is a very active participant in the process to develop accessibility guidelines and served on the Reg Neg Committee. American Hiking Society endorses the specific comments submitted by the Appalachian Trail Conference on the FSTAG and FSORAG interim directives.

We strongly agree with the underlying principle that whenever a new trail is being designed or an existing trail is significantly rerouted or reconstructed, accessibility should be considered. However, we also urge the Forest Service to ensure the guidelines are reasonable, understandable to the trail organizations and volunteers who will help implement them, and that primitive, backcountry hiking trails retain their natural character in accordance with the purpose of the directives. We firmly believe there are plenty of trails and sections of trails, both already on the ground and others still on paper that could and should be made accessible to people with disabilities, where appropriate.

The majority of our comments pertain to FSTAG as these are the provisions most relevant to trails and commonly related elements or "associated constructed features" such as shelters, tent platforms, privies, and fire rings that are often provided at overnight camping areas along long distance hiking trails. Although associated constructed features are addressed in detail in FSORAG, we appreciate the inclusion of the relevant provisions related to those elements in Appendix B of FSTAG. Our general comments below are followed by more specific comments on various sections and provisions within FSTAG.

Although the FSTAG and FSORAG have been significantly improved during various iterations the last few years, we are still concerned that the guidelines are very complicated. While it is not stated in FSTAG or FSORAG, we understand the Forest Service intends to develop an illustrated, "plain English" manual in the near future and also plans to provide locally-based training opportunities for both Forest Service personnel and cooperators. In addition to a manual, the basics of the simplified guidelines should be included in a hand-held field card.

We strongly believe supplemental educational materials and training opportunities related to FSTAG and FSORAG will be essential, particularly if the Forest Service wishes to continue to engage nonprofit partners and volunteers in the trail design, construction, and maintenance process on National Forest System lands.

The most successful trails are those supported by a strong partnership between land manager and volunteer. The effect of volunteers on trail construction and maintenance varies regionally but must not be underestimated. In some areas, volunteer-based organizations have taken complete responsibility for trail-building, and in many cases, the volunteers are more knowledgeable than the thinly-stretched public land managers.

We are concerned that overly complex regulations could have the effect of reducing the contributions of trail maintaining organizations and volunteers.

In addition, although we understand that cost is not a factor in accessibility determinations, we are concerned about the serious maintenance and construction backlogs facing the Forest Service. Many trail organizations fear the costs associated with accessibility-based renovations will result in fewer or protracted trail projects and fewer volunteers willing to deal with the complex technical and legal requirements.

We believe it would be appropriate for the Forest Service to comment in FSTAG (and FSORAG) on the implications, if any, of the application of the proposed interim directives in relation to the serious maintenance and construction backlogs and with respect to the level of participation by Forest Service partners, including volunteers.

FSTAG Executive Summary:

We recommend that the next iteration of the interim directives include any relevant provisions from the Trail Business Rules and TRACS as an appendix to FSTAG for easier reference by readers.

Preamble:

The technical provisions contained in FSTAG "apply to newly constructed or altered trails or trail segments with a managed use of hiker/pedestrian under the Forest Service Trails Design Parameters." "Designated use" is defined as "the intended use that controls the desired geometric design of a trail and determines its maintenance parameters;" the "managed use" is defined as "modes of travel that are actively managed on and appropriate for a particular trail." Those distinctions are largely irrelevant for trails such as the Appalachian Trail that are both designed and managed solely as a footpath.

However, those distinctions may be significant for other long-distance trails where multiple uses such as equestrian/hiker or bicycling/hiker uses may be permitted on certain trail segments.

We recommend that the interim directives apply solely to trails or trail segments with a designated use (as opposed to a managed use) of hiker/pedestrian.

Background: Our understanding of the Forest Service's application of its universal design policy is that the policy was previously applied solely to outdoor recreation sites classified as highly developed under the Recreation Opportunity Spectrum scheme. Through FSORAG, the Forest Service is seeking to expand the application of universal design by applying the relevant technical provisions contained in FSORAG to outdoor recreation sites both at highly developed sites and at remote or backcountry sites. We recommend that the wording in the Background section be revised appropriately to better clarify that the Forest Service now intends to apply accessibility requirements to a much broader spectrum of outdoor recreation sites, even those in remote or primitive settings.

As noted above regarding Trail Business Rules and TRACs, we recommend that the relevant portions of the Trail Management Class Matrix be incorporated as an appendix to FSTAG for ease of reference by the reader.

Wheelchair Access/Entrance Issues:

We support the special provisions in FSORAG 6.6.9 with respect to entrance exceptions. We generally support the exceptions prescribed in FSORAG for features (e.g. privies, tent platforms) situated in general forest areas (GFAs), since such areas are more closely aligned with the types of settings typically encountered along long-distance foot trails. Associated Constructed Feature: The provision indicating that "side trails or other routes to these associated constructed features" are not outdoor recreation access routes (ORAR) is critical. At many backcountry campsites along hiking trails, such as the Appalachian Trail, facilities such as shelters and privies commonly are separated by a considerable distance, often uphill or downhill, and it would be infeasible to connect such facilities with side or approach trails required to meet ORAR standards without significantly modifying the trail class and/or recreational setting.

We support the Forest Service's determination that side or connecting trails linking such campsite facilities as shelters, tent platforms, and privies in GFAs should not be required to meet the ORAR technical provisions prescribed in FSORAG 2.0. Without such an allowance, we could not support the universal design policy underlying FSORAG that requires all such facilities to be accessible.

Conditions of Departure/Exceptions:

The Forest Service links certain conditions for departure and exceptions from certain technical provisions to the concepts of "trail class," and to other Forest Service-specific concepts such as designated use, managed use, general forest areas (GFAs), and forest land and resource management plans.

We generally support distinctions based on trail class, in part because such classification systems may provide a more objective standard for evaluating changes in recreational setting. However, it is not clear to us how such Forest Service-specific terminology and classification schemes will be reconciled with the Access Board guidelines, which do not presently include such distinctions or terminology, and which will be applicable to all federal land-management agencies-- ;agencies that may or may not apply similar terminology and classification schemes in their respective approaches to outdoor recreation management.

Purpose of the FSTAGs:

We generally support the objectives cited under the statement of purpose. However, we recognize that many of them cannot be fairly evaluated or measured based on the language and provisions contained in FSTAG. Only through experience gained from on-the- ground application at the Forest level will it be feasible to determine if those somewhat competing objectives can be achieved.

Section-By-Section Analysis:

Section 7.1 Extent of Application:

We generally support the clarifications provided in this section regarding new construction, alteration, maintenance, etc., with minor reservations ( e.g. limiting application solely to designated hiker/pedestrian trails)

Section 7.1.1. Conditions of Departure:

We support the four described conditions for departure. Under condition #4, regarding prevailing construction practices, we suggest replacing the word "infeasible" with the word "impractical" to clarify the intent of this condition of departure.

Section 7.1.2 General Exceptions:

We support the first general exception, with the understanding that conditions such as those described in the "limiting factors" are commonplace along many sections of long-distance hiking trails.

We also support the second general exception. However, depending upon the frequency of sampling, the calculations necessary by the trail manager to make the 15-percent determination of deviations could prove quite labor-intensive.

Section 7.3 Technical Provisions:

While many of the technical provisions provide multiple exceptions (adding to the complexity of interpreting and applying the provisions), we believe these multiple exceptions are warranted, given the high degree of variability in the outdoor environment.

We also recommend that some guidance be included in FSTAG to caution trail managers to be mindful of the cumulative effect of their actions on the recreational setting and visitor experience.

7.3.1.1. & 7.3.1.2. Along trails or trail segments, such as the Appalachian Trail, which has been designed and constructed primarily as a ridgecrest trail, compliance with the technical provision related to slope and cross slope is likely to prove challenging and, in many cases, infeasible.

7.3.3. A continuous "firm and stable" surface condition will be difficult to achieve in many places, especially where thin or erosion-prone soils exist or where the footpath is situated on bedrock, glacial till, or outcroppings.

7.3.4. In favorable conditions, such as sidehill construction in areas possessing deep soils, the prescribed clear tread width may be feasible. However, the exceptions that permit narrower trail tread will be necessary to accommodate commonly occurring conditions such as roots, bedrock, outcroppings, and other impediments to a wider clear tread width.

7.3.5. Again, in favorable conditions, passing spaces may be feasible. However, the exception that permits deviation from this provision will be warranted in many cases.

7.3.6. This provision may prove to be among the most challenging for trails (e.g. Appalachian Trail) in areas where thin to nonexistent soils exist and the trail tread is often strewn with cobble-sized rocks (more than two or three inches in height), rock outcroppings, and bedrock, or may be threaded among many tree routes and other "obstacles."

7.3.7. We support the added exception to the technical provision regarding protruding objects that does not exist in the current iteration of the Access Board's guidelines. 7.3.9. We support the FSTAG provision, which does not require edge protection along accessible trails.

7.3.10. We support this signage requirement, in part because we suspect that more highly developed trails are more likely to attract use by persons with disabilities.

Forest Service Trail Accessibility Guidelines (FSTAG): Technical Provisions:

Most of our comments related to the extent of application (7.1), conditions for departure (7.1.1), and general exceptions (7.1.2.) have already been noted above. However, we offer the following additional comments relative to Definitions (7.2).

7.2. Definitions:

Typical Cross Slope.

While we support the notion that measurement intervals should be more frequent with more highly developed (or higher trail class) trails, we suggest further discussion about the recommended frequency of measurement.

Trailhead. The definition of designated trailhead is critical because it is one of the central elements in determining the overall applicability of FSTAG to a newly constructed or altered trail or trail segment.

We recommend that the language defining "designated trailhead" be modified to clarify that a designated trailhead requires some level of development to accommodate pedestrian access beyond minimal provisions such as an unpaved pull-off along the side of a road. We urge the Forest Service to replace the term "designated trailhead" with "improved trailhead."

Also with respect to trailheads, it is a common practice at entry points along hiking trails, such as the Appalachian Trail, to install boulders, gates, stiles, or other impediments to discourage illegal access by off-road vehicles and associated adverse impacts to resources. However, such barriers could serve as an impediment to access by disabled persons. This issue is not presently discussed in FSTAG.

We urge the Forest Service to address the potentially conflicting management objectives of discouraging incompatible use and facilitating access by disabled persons, including recommended modifications to barriers that can accommodate access by disabled persons while still controlling conflicting uses such as off-road vehicles.

Overview of the FSTAG Implementation Process:

We commend the Forest Service for developing the flow chart/decision tree for the implementation process; however, we urge the Forest Service to include the recommended frequency of measurement related to the exceptions.

Appendices:

We commend the Forest Service for including the most relevant trail-related provisions from FSORAG and including certain relevant provisions and illustrations from the ABA accessibility guidelines referenced in FSTAG for the convenience of the reader.

The proposed directives will have a considerable impact on hiking trails throughout the nation and will influence the manner in which volunteers and Forest Service staff approach trail and campsite design and construction. We appreciate the Forest Service's efforts to improve access for disabled persons and urge the agency to ensure the guidelines are reasonable, practical, and applicable in a manner that preserves the natural setting and recreational experience for current and future generations of hikers. It is particularly crucial that the guidelines be clear and understandable to the trail organizations and volunteers who will help implement them. These volunteers have become increasingly important to trails and trail managers. Without them, many trails would not have been built, nor would they continue to be maintained.

Thank you for accepting our input on draft FSTAG and FSORAG at this time.

Sincerely,

Celina Montorfano
Director of Conservation Programs
American Hiking Society

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