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Proposed guidelines for trails under Americans with Disabilities Act trail released

By Stuart Macdonald, Chair, National Association of State Trail Administrators

The Americans with Disabilities Act (ADA) requires us to make trails accessible, but doesn't specify how. New regulations being finalized will, however, affect all of us who plan and design trails.

The final report of the Regulatory Negotiation Committee on Accessibility Guidelines for Outdoor Developed Areas includes soon to be proposed ADA Accessibility Guidelines (ADAAG) for trails, outdoor recreational access routes, beach access routes, and picnic and camping facilities.

Currently the report is undergoing a regulatory assessment by the Access Board, an independent federal agency responsible for developing minimum accessibility guidelines under the ADA. Next will be a review by the federal Office of Management and Budget. Eventually, the proposed guidelines will be published in the Federal Register with an invitation for public comment over a 90-day period.

The following questions and answers cover the highlights of the trail guidelines:

First, what exactly is a trail according to the proposed ADA accessibility guidelines?

A trail is "a route that is designed, designated, or constructed for recreational pedestrian use or provided as an pedestrian alternative to vehicular routes within a transportation system."

What kinds of trails are subject to the proposed ADA accessibility guidelines?

The accessibility guidelines apply to those trails which are designed and constructed for pedestrian use. They are not applicable to trails primarily designed and constructed for recreational use by equestrians, mountain bicyclists, snowmobile users, or off-highway vehicle users, even if pedestrians may occasionally use the same trails. However, a multi-use trail specifically designed and designated for hiking and bicycling would be considered a pedestrian trail.

Then is an urban bikeway a "pedestrian trail"?

Accessibility guidelines apply to trails used as nonmotorized transportation facilities for bicyclists and skaters as well as pedestrians. However, transportation routes for bicyclists and skaters have design needs which exceed the minimum guidelines for trails. In some cases, the AASHTO Guide (1999) may requires a greater level of accessibility than the ADA trail guidelines. The appendix of the Access Board report compares the AASHTO guide with the ADA trail guidelines.

Will we have to bring existing trails up to ADA standards?

The proposed guidelines apply to all areas of newly designed or newly constructed and altered portions of existing trails. However, for entities covered by title II of the ADA, "program accessibility," may require accessibility to be provided on existing trails. Program accessibility means that the major elements in a recreation program need to be accessible. Clearly, though, trails involve an "experience" that is more complex than typical park facilities.

Must we improve accessibility when trail maintenance is done?

The proposed guidelines state that "routine or periodic maintenance or repair of existing trails or trail segments does not trigger the accessibility guidelines." Examples include removal of debris, reshaping the trail bed, erosion control, etc.

What about new trails that are nowhere near a road or an accessible trailhead?

The proposed guidelines apply only to trails that "connect to an accessible trail" or "designated trailhead." Where new trails connect to an existing trail that is not accessible, the technical provisions do not apply. Nor do they apply where the new or altered portion is not connected to a designated trailhead.

Does an accessible trail have to be paved?

Paving is not required, as long as the surface is "firm and stable."

What about handrails and other edge protection?

While handrails and edge protection are not required on trails, they may be provided where needed&emdash; for instance, along a steep drop-off. They should also meet appropriate standards.

So what is an accessible trail?

Under the proposed guidelines, an accessible trail would meet these minimum technical provisions:

What if building a trail to an accessible standard just isn't logical, or desirable, or even possible?

While the proposed accessibility guidelines address the special circumstances where designers and operators may not be able to achieve accessibility, they are encouraged to always provide access to the greatest extent possible. Departures from specific accessibility guidelines are permitted for any portion of the trail where compliance would:

1. Cause substantial harm to cultural, historic, religious, or significant natural features or characteristics

2. Substantially alter the nature of the setting or the purpose

3. Require construction methods or materials that are prohibited by Federal, State, or local regulations or statutes

4. Not be feasible due to terrain or the prevailing construction practices

The AASHTO Guide for the Development of Bicycle Facilities is the primary guidebook for facilities built with transportation funds (available for $30 from AASHTO at (800) 231-3475). The final report of the Regulatory Negotiation Committee on Accessibility Guidelines for Outdoor Developed Areas is available at

For detailed information on accessible trails, the proposed ADA guidelines, and how they would apply to specific situations, see the American Trails website: Click on the "Resources & Library" icon, then click on "Accessible Trails."


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