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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
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 firstname.lastname@example.org
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.
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".
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,
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
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.
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 email@example.com.