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USFS proposed trail guidelines compared to draft ADA guidelines

Differences Between the draft FSTAG and the Access Board's draft 1999 Regulatory Negotiation Committee's guidelines (March 2005).

By Janet Zeller, USDA Forest Service

The Forest Service is seeking comment on the Draft Forest Service Trail Accessibility Guidelines (FSTAG) - Download the FSTAG in PDF pr Word formats and Questions & Answers on the FSTAG (75 kb). Read the notice in the Federal Register: February 17, 2005.

These guidelines and more information are available at www.fs.fed.us/recreation/programs/accessibility. Comments on the draft FSTAG can be sent electronically to rhwrtrail@fs.fed.us until April 18, 2005. The Access Board has announced plans to publish their 1999 Regulatory Negotiation Committee's Final Report (draft Reg Neg guidelines) as a Notice of Proposed Rulemaking (NPRM) in 2005.

Draft FSTAG draft Reg Neg guidelines
The following draft FSTAG provisions are higher than the draft Reg Neg guidelines.

These provisions are intended to be in the FINAL FSTAG. ...to ensure the Forest Service's continued application of universal design, as well as agency terminology and processes.

Constructed features: All new or reconstructed "constructed features" where provided, such as pit toilets, along trails are to comply with the applicable provisions in the draft FSTAG.

Process Overview. The Forest Service Process Overview, or flowchart, is provided to assist in the implementation of the guidelines on the trails.

Does not include flowcharts or other assistive tools

Separate document: At the request of trail designers and builders, the draft FSTAG is a separate document, a complete tool addressing the unique aspect of trails, with appendices that include a user-friendly flowchart for implementation, related applicable guidelines including pit toilets and tent pads and the details with graphics of all ABA Accessibility Guidelines referenced in the draft FSTAG.

Combines trails, outdoor recreation access routes and all other outdoor developed area facilities in one document.

Difference in Terminology: The draft FSTAG uses and defines the Forest Service terminology and the trail related terminology accepted by the trail programs of the Federal land management agencies: Accessible trail, associated constructed feature, trail constructed feature, cross slope, typical cross slope, designed use, hiker/pedestrian, managed use, point of deviation, prominent feature, protruding object, scoping requirement, surface, technical provision, trail, trail class, trail grade, trailhead (designated, developed), trail terminus, tread width (clear tread width, minimum tread width), wheelchair.

Maintenance and Alteration are defined per the references in the Reg Neg 1999 Final Report — page 5.

Only trail, designated trailhead and tread width are defined.

Trail processes. Uses the Forest Service's trail terminology, thus ensuring that all trail-related definitions used in the guidelines are in coordination with the Trail Business Rules and TRACS. TRACS information is available at the Forest Service Recreation Integrated Business Management website, www.fs.fed.us/r3/measures/TR.htm.

This supplement references the agency's trail classification system. The trail manager determines the trail class by referring to the Forest Service National Trail Management Class Matrix that is posted on the agency's trails website at www.fs.fed.us/r3/measures/Inventory/Trails.htm.

Order of provisions: Technical provisions appear in the order in which they impact the usability of the trail, trail grade and cross slope, resting interval, surface, clear tread width, passing space, tread obstacles, protruding objects, openings, and edge protection.

Does not address the technical provisions in the order in which they impact the usability of the trail.

Documentation: If a determination is made that the FSTAG technical provisions either do not apply to an entire trail or cannot be met on portions of a trail, a brief statement is to be drafted and retained in the project file documenting how that determination was made, which conditions of departure and exceptions apply, the date, and the name of the individuals who made that determination, in order to have information available if challenged in the future. There is no standard format for this documentation; each unit may develop its own format to meet its specific needs.

No documentation required.

Signs: Signs shall be posted at the trailhead of newly constructed or altered trails and trail segments designated as Trail Class 4 or 5, which are highly to fully developed trails. At a minimum, the information on these signs shall include the typical and maximum trail grade, typical and maximum cross-slope, minimum clear tread width, surface type and firmness, and obstacles. In addition, the signs should state that the information they provide reflects the condition of the trail when it was constructed.

Does not specify the placement or content of signs.

Draft FSTAG provisions are NOT higher than the draft Reg Neg guidelines.

These provisions will NOT be in the FINAL FSTAG UNLESS added to the Final Access Board guidelines.

Condition 2 for trails. The draft Reg Neg guidelines cite a change in the nature of the setting as a condition for departure from the guidelines. However, two years of informal public comment on the Forest Service's draft accessibility guidelines for trails highlighted that more specific, objective criteria were needed to apply this condition of departure to trails. A trail's class, designed use, and managed use are determined by evaluation of many quantifiable aspects of the nature of the setting. These quantifiable features can serve as tools for evaluation of any change in the nature of the setting. The Forest Service's condition 2 for trails is as follows:

Trails, Condition 2. "Where compliance would substantially change the physical or recreation setting or the trail class, designed use, or managed use of the trail or trail segment or would not be consistent with the applicable forest land and resource management plan".
The change of trail class is not a condition for departure from the guidelines.

Condition 2 states only: "Where compliance would substantially alter the nature of the setting or the purpose of the facility or portion of the facility".

General Exceptions.

Grade: a general exception any trail that has a combination of trail grade and cross slope that total 20% for 40 ft.

Width: a general exception for any trail that is less than 18 inches wide for a length of 20 ft.

a general exception any trail that has a combination of trail grade and cross slope that total 40% for 20 ft.

a general exception for any trail 12 inches wide for 20 ft.

Protruding Objects: The draft FSTAG recognizes that in the outdoor recreation environment there are some areas, such as walkways through caves or specific types of trees where the natural environment will preclude both the 80" clear head room and the placement of a warning barrier. The draft FSTAG provides an exception allowing for the reduction in the clear head room if a warning barrier is placed.

However, on a narrow walkway through a cave or through specific types of trees, conditions may make it impossible to both place a warning barrier and permit passage. In those situations the draft FSTAG permits an exception from the placement of a barrier when such a condition of departure occurs.

The draft Reg Neg guidelines require the same placement of a barrier in the ORAR if there is less than 80" of clear headroom.

No exception is provided to this requirement regardless of such conditions as narrow pathways through caves, certain type of trees, etc.

Tent pads and platforms (where provided): Edge protection, where provided is to be at least 3 inches high. However, edge protection is not required. The designer determines the use of edge protection - where it should be provided for safety and where it should be eliminated because it would preclude access. Although this provision is addressed in the FSORAG it has potential significant impact for trails and so tent pads and platforms are also included in the draft FSTAG appendix.

At least 20% of the tent pads or platforms that are provided at a developed recreation site shall be accessible and connected to an ORAR. 5% in a GFA shall be accessible. Connection to an ORAR is not required.

Minimum of 3 inch high edge protection is required around tent platforms,, no exceptions are provided.

 

Tent pads and platforms

Chart provided based on total # elements

If 1 =accessible,

2-25 = 2 accessible

26-50 = 3 accessible and so forth

Pit toilets:

Through comments from trail facility designers the following specifications were added:

Placement of the riser on the side wall is specified in order to maximize the access.

Privacy screens are addressed as they are commonly used in remote areas rather than walls.

Recognizing that some pit toilet floors have to be located above the ground because of operation and maintenance requirements of the pit toilet system design, where the entrance is not at ground level a trail/ramp is to be provided from the ground to the entrance. Where a trail/ramp is not feasible and there is no other alternative is possible because of one or more conditions of departure exists, transfer steps meeting the specifications detailed (similar to those for play areas in Chapter 10 of the ABA accessibility guidelines), may be provided.

Although this provision is addressed in the FSORAG it has potential significant impact for trails and so pit toilets are also included in the draft FSTAG appendix.

 

 

 

Not specified

Not addressed

 

No exceptions to a level entrance are provided.

This document was developed in order to assist commenters in defining the differences between the two sets of draft guidelines. Any questions concerning this summary document should be directed to Janet Zeller, Forest Service Accessibility Program Manager, at jzeller@fs.fed.us.

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