Applying the Forest Service Trails Accessibility Guidelines
The first step in applying the Forest Service Trails Accessibility Guidelines (FSTAG) is to know when and where compliance is required. Section 7.0 "Application" states that FSTAG applies to trails in the National Forest System that meet all three of the following criteria:
- The trail is new or altered.
- The trail has a "Designed Use" of "Hiker/Pedestrian" as defined in the Federal Trail Data Standards.
- The trail connects either directly to a trailhead or to a trail that meets most of the accessibility requirements.
FSTAG doesn't apply to existing trails unless there is a change in the purpose, intent, or function of the trail—an alteration, in other words. It doesn't apply to trails designed for all-terrain vehicle (ATV), equestrian, or any other nonpedestrian use. FSTAG only applies to trails that have been designed for "Hiker/Pedestrian" use in accordance with the Federal Trail Data Standards (FTDS). Information about FTDS is available at http://www.nps.gov/gis/trails/.
FSTAG doesn't prescribe different "levels of accessibility" based on trail class or any other grouping criteria. FSTAG provides guidance for maximizing accessibility, while recognizing and protecting the unique characteristics of the natural setting, level of development, and purpose of each trail.
Cost is not a valid reason for failing to make a trail accessible. (See BUDGET TIP—Extra cost is not an excuse., page 31.) FSTAG won't apply to most portions of existing primitive, long-distance trails. It may, however, apply to new segments that pass through developed areas. FSTAG recognizes, however, that there is no real benefit in making a newly constructed or altered trail in the backcountry accessible if the only way to get to it is by using an existing trail that isn't accessible and probably can't be made accessible.
By applying FSTAG, you will ensure that the full range of trail opportunities continues to be provided. Hiking opportunities to highly developed interpretive trails, popular scenic overlooks, and more remote areas will be options for everyone (figure 119).
An outdoor recreation access route is a continuous, unobstructed path designated for pedestrian use that connects pedestrian elements within a recreation site, such as a picnic area, camping area, or trailhead. In contrast, a trail is defined for purposes of Forest Service Outdoor Recreation Accessibility Guidelines (FSORAG) and FSTAG as a route that is designed, constructed, or designated for recreational pedestrian use or provided as a pedestrian alternative to vehicular routes within a transportation system. A trail is not an outdoor recreation access route and is not subject to the requirements for outdoor recreation access routes found in section 2.0 of FSORAG. This guidebook explains the accessibility requirements for trails designed for hiker and pedestrian use.
Although this guidebook explains requirements in plain language, some phrases and words are important to understanding how FSTAG is applied. The following terminology isn't organized alphabetically; the phrases and words are grouped so that the distinctions between similar terminology are easy to understand.
Federal Trail Data Standards (FTDS) enable national-, regional-, State-, and trail-level managers, and the public, to use mutually understood terminology for recording, retrieving, and applying spatial and tabular information. FTDS make it easier for trail information to be accessed, exchanged, and used by more than one individual, agency, or group. The data standards are available at http://www.nps.gov/gis/trails/Doc2/Federal_Trail_Data_Standards_Final_20111108.pdf.
Designed Use is the "Managed Use" of a trail that requires the most demanding design, construction, and maintenance parameters. In conjunction with the applicable "Trail Class," designed use determines which design parameters will apply to a trail. It is an FTDS term for the intended use that controls the geometric design of a trail and determines the level to which it should be maintained. There is only one "Designed Use" per trail or trail segment. Although the trail may be actively managed for more than one use, the designed use determines the technical specifications for the trail. For example, pack and saddle stock require higher and wider clearances than do hikers, so a trail managed for both foot travel and horse use would have a designed use of "Pack and Saddle" rather than "Hiker/Pedestrian." More information about trail design parameters for the different designed uses is in Forest Service Trail Design Parameters, available at http://www.fs.fed.us/recreation/programs/trail-management/trail-fundamentals/ or available to Forest Service employees at http://fsweb.wo.fs.fed.us/rhwr/ibsc/docs/trails/national_design_parameters_2008-10-16.doc.
Managed Use is an FTDS term for the mode(s) of travel for which a trail is actively managed. Managed Uses are the specific types of trail use that are allowed by management decision or intent on a specific trail or portion of a trail. Each trail or trail segment may have more than one "Managed Use." For example, a trail may be managed for both equestrian and hiker/pedestrian use in the summer and for cross-country skiing in the winter.
Constructed Features are commonly found along trails or as part of trails.
- Associated Constructed Feature—A constructed element associated with a trail that provides support for trail users but is not a part of the trail tread. Examples include camp shelters, pit toilets, fire rings, picnic tables, and tent pads. Refer to FSORAG for the technical provisions for associated constructed features.
Trail Constructed Feature—A constructed feature that functions as part of the trail tread. Examples include puncheon, trail bridges, boardwalks, waterbars, and switchbacks. For a listing of trail constructed features, refer to the trail documentation available at http://www.fs.fed.us/recreation/programs/trail-management/index.shtml or available to Forest Service and Bureau of Land Management employees at http://fsweb.wo.fs.fed.us/rhwribsc/tr-cost.shtml.
A trailhead (for purposes of FSORAG and FSTAG) is a site designed and developed by the Forest Service or other Government agency, a trail association, trail maintaining club, trail partner, or other cooperators to provide a staging area for a trail.
For purposes of FSTAG, trailheads are not:
- Junctions between trails where there is no other access
- Intersections where a trail crosses a road or where users have developed an access point, but no improvements are provided by the Forest Service, trail associations, trail maintaining clubs, trail partners, or other cooperators beyond minimal markers or modifications for health and safety
Trail Classes broadly organize trails by desired management characteristics and the level of development. They are based on forest plan direction and represent intended design and management standards. Trail classes take into account user preferences, the setting, protection of sensitive resources, and management activities. Trail classifications range from Trail Class 1 trails that appear little different from animal paths and may disappear intermittently, to Trail Class 5 trails that are usually wide, paved paths associated with highly developed environments. FSTAG does not change Forest Service trail classes. More information about trail classes is available at http://www.fs.fed.us/recreation/programs/trail-management/trail-fundamentals/.
Setting is the word used to describe the nature of the surroundings of a trail. On public lands outside rural and urban settings, the natural surroundings are usually the primary attraction for visitors. Improvements, such as trails, should not adversely affect the setting. For example, the design for a trail crossing a glacial boulder field must protect the geologic features. Accessibility is incorporated to the extent possible without fundamentally altering the natural environment. On the other hand, a trail designed for a wide open, relatively level area should follow the requirements of FSTAG to the highest degree possible.
The following words describe construction and maintenance work:
- Construction is building a new trail or segment of trail where there was no trail before.
- An alteration is work done to change the purpose, intent, or function of the trail.
- Maintenance is the routine or periodic repair of existing trails or trail segments to restore them to the standards or conditions to which they were originally designed and built. Maintenance does not change the original purpose, intent, or function for which the trail was designed. Trail maintenance work isn't covered by the FSTAG. Maintenance includes:
- Removing debris and vegetation, such as fallen trees or broken branches on the trails, clearing the trail of encroaching brush or grasses, and removing rock slides
- Maintaining trail tread, such as filling ruts, reshaping a trail bed, repairing a trail surface or washouts, installing riprap to retain cut and fill slopes, and constructing retaining walls or cribbing to support trail tread
- Performing erosion control and drainage work, such as replacing or installing drainage dips or culverts, and realigning sections of trail to prevent erosion or to avoid boggy areas
- Repairing or replacing deteriorated, damaged, or vandalized trail or trailhead structures or parts of structures, including sections of bridges, boardwalks, information kiosks, fencing, and railings; painting; and removing graffiti
While FSTAG doesn't apply to maintenance, Forest Service policy is to improve accessibility wherever the opportunity arises, including during trail maintenance and repair activities. Every time a trail is maintained, there is an opportunity to improve access.
The word "reconstruction" is not used in Federal accessibility guidelines or FSTAG, even though the term is used frequently by the trails community. For the purposes of FSTAG, actions are categorized as construction, alteration, or maintenance.
What do you call a reroute?
If trail work is grouped into only three categories— construction, alteration, and maintenance—what category do things like rerouting, reconstruction, and extensions of existing trails fall into? The key to answering this question is to concentrate first on the definition of alterations. Does the new work change the purpose, intent, or function of the trail? In other words, will the trail serve a new destination? Will the trail's designed use change from horses to hikers, for example, after you're done? Are you significantly changing the overall trail grade, width, or surface, or adding bridges where the trail used to ford streams or rivers? If the work doesn't fit the definition of alteration, it's either construction (if there was no trail there before) or maintenance.
Information that is already available to Forest Service employees is not repeated in this guidebook. The "Trail Construction and Maintenance Notebook" includes practical techniques used to construct and maintain trails. Written for trail crew workers, it is intended to be taken along on work projects. Numerous illustrations help explain the main points. The notebook is at http://www.fhwa.dot.gov/environment/fspubs/07232806/index.htm.
The publication "Wetland Trail Design and Construction" describes materials and techniques used to construct trails in wetlands. Written primarily for workers who are inexperienced in wetland trail construction, it may also be helpful for experienced workers. Techniques suitable for wilderness settings and for more developed settings are included as well as numerous drawings to illustrate important points. The publication is available at http://www.fs.fed.us/eng/pubs/htmlpubs/htm07232804/index.htm or http://www.fhwa.dot.gov/environment/fspubs/07232804/index.htm.
Standard Forest Service trail specifications are available at http://www.fs.fed.us/database/acad/dev/trails/trails.htm.
FSTAG is based on the realities of the outdoor environment and recognizes that complying with accessibility provisions is not always practicable because the natural terrain, existing vegetation, or other constraints impose limitations in some locations. To ensure that the unique characteristics of the outdoor environment and trail recreation opportunities aren't compromised or fundamentally altered, exceptions and deviations from some technical requirements are permitted when certain circumstances, called conditions for an exception, apply.
The following paragraphs explain the four conditions for an exception identified in section 7.1 of the FSTAG. Circumstances under which deviations from the technical requirements are allowed based on the conditions for an exception differ depending on the setting. The four conditions for an exception are the basis for permitting deviations from specific technical requirements when allowed by General Exception 1 or General Exception 2, as explained in "General Exceptions in FSTAG."
Conditions for an exception are not blanket exemptions from all of the technical requirements for an entire trail. If a condition for an exception occurs only on part of the trail or trail component, the technical requirement applies everywhere else. All technical requirements not affected by the condition for an exception also apply. This requirement is explained in "General Exceptions in FSTAG."
The conditions for an exception cover all the important elements of a long-distance trail and the aspects that are considered when locating trail segments, but they shouldn't be used as an excuse or loophole for failing to make trails accessible. Rather, they are to be used when all other design options have been thoroughly explored and a determination has been made that full compliance with the technical requirements would unacceptably alter the nature of the experience the visitor is seeking or unacceptably impact features that are protected by law.
The wording of each exception is brief. General examples for each exception are provided to help explain the intent of the conditions so that designers understand how to apply them according to the site-specific constraints and opportunities of their projects.
Condition for an Exception 1. Where compliance with the technical requirement is not practicable due to terrain (figure 120).
The phrase "is not practicable" in this condition for an exception refers to something that isn't reasonable, rather than to something that is technically impractical. The intent of this condition is that the effort and resources required to comply shouldn't be disproportionately high relative to the level of access established.
Condition for an Exception 2. Where compliance with the technical requirements would fundamentally alter the function or purpose of the facility or the setting.
Public lands provide a wide variety of recreational experiences, from highly developed areas that offer plenty of conveniences and opportunities to relax with family and friends, to wilderness areas that appear unchanged from primeval times and provide opportunities for individuals to experience primitive and challenging conditions. FSTAG recognizes the value of the full range of recreation opportunities by allowing deviations from the technical requirements where compliance would unacceptably change the nature of the recreation opportunities or conflict with the land and the resource management plan for the area.
People using primitive trails, for example, experience the outdoor environment in a nearly natural state, with limited or no development. In these settings, people generally desire challenge and risk so they can use their outdoor skills. Use of manufactured building materials or engineered construction techniques to comply with accessibility provisions could destroy the natural or undeveloped nature of the setting and change the visitor's experience. FSTAG does not require that obstacles be blasted or trails paved to be more accessible if such activity would unacceptably change the character of the setting and the recreation opportunity.
Using heavy construction equipment, it may be possible to provide a trail with a maximum 1:20 (5 percent) grade up a 1,500-foot (460-meter) mountain (figure 121). However, the trail would be about three times as long as under a traditional back-country layout (figure 122). The length of the trail could cause inappropriate environmental and visual impacts and more than triple the amount of ground disturbed. It wouldn't be practicable to construct a trail in compliance with technical accessibility requirements.
Consider a trail intended to provide a rugged experience, such as a cross-country training trail with a steep grade or a fitness challenge course with abrupt and severe changes in elevation. If these trails were flattened out or otherwise constructed to comply with the technical accessibility requirements, they wouldn't provide the desired challenge for users. Trails that traverse boulders and rock outcroppings are another example. The purpose of these trails is to provide users with the opportunity to climb the rocks. To remove the obstacles along the way or reroute the trail around the rocks would destroy the purpose of the trail. The nature of the setting also may be compromised by actions such as widening a trail for an imported surface or removing vegetation from fragile or erosive soils.
Condition for an Exception 3. Where compliance with the technical requirements cannot be accomplished with the prevailing construction practices.
This condition for an exception may apply when the construction methods needed to comply with a technical requirement would require the use of equipment or methods other than those typically used in that setting. For instance, in an area where small equipment is normally used to minimize impact on a sensitive adjacent stream, blasting might be necessary for rock removal to meet the technical width requirement for a trail. Because blasting typically would not be used in this situation, this condition for an exception would apply. If the work could be done using small equipment, this condition for an exception wouldn't apply.
This condition for an exception is not intended to exempt the trail from the technical requirements of FSTAG simply because a trail builder's favorite construction practice (such as the use of a large mechanical roller rather than a smaller vibrating plate or "whacker" type compactor) is inappropriate or impractical. A contractor's or designer's preference for different equipment is not a prevailing construction practices issue. A deviation from a specific technical requirement only can be allowed if the equipment is essential to complete the construction in that location.
Condition for an Exception 4. Where compliance is precluded because the cultural, historic, or significant natural features are protected or are eligible for protection under Federal, State, or local law by:
- Endangered Species Act (16 U.S.C. 1531 et seq.)
- National Environmental Policy Act (42 U.S.C. 4321 et seq.)
- National Historic Preservation Act (16 U.S.C. 470 et seq.)
- Wilderness Act (16 U.S.C. 1131 et seq.)
- Other Federal, State, or local law (the purpose of which is to preserve threatened or endangered species; the environment; or archaeological, cultural, historical, or other significant natural features)
Cultural features include archeological sites, burial grounds and cemeteries, traditional cultural properties, tribal protected sites, and other properties considered sacred by an organized religion. Historical features are properties listed or eligible for listing on the National Register of Historic Places or other places of recognized historic value. Significant natural features are objects that are regarded as distinctive or important locally, regionally, or nationally and, therefore, have been placed under legal protection, such as a large boulder or rocky outcrop, body of water, or unique tree or vegetation such as a giant sequoia grove (figure 123). Areas that are legally protected include wilderness areas designated by Congress and areas protected under Federal or State laws, such as habitat for threatened or endangered species or designated wetlands.
Situations when this condition for an exception may apply include these examples:
- Where use of mechanized equipment is prohibited by
law, such as in wilderness areas designated by Congress,
and work necessary to comply with a technical
accessibility provision can't be accomplished using
- Where imported materials, such as soil stabilizers, are
prohibited to maintain the integrity of a natural ecosystem
or historic resources
- Where construction methods and materials are
strictly limited to protect designated wetlands or
- Where the physically undisturbed condition of the
land is an important part of a sacred observance, such
as at tribal sacred sites
- Where water crossings are restricted to safeguard aquatic features or species protected under Federal or State laws
The Federal laws specified in Condition 4 prescribe certain activities or require certain analyses or procedures to be followed when planning projects that may impact features protected under those laws. This condition for an exception applies when it is determined that the actions, required analyses, or other impacts necessary to meet the technical requirements would directly or indirectly substantially harm the protected feature.
Determine the extent of impact.
Only consider the additional impact of increasing the width, reducing the trail grade or cross slope, or other change required for accessibility. For example, consider a trail project that crosses a hill where a population of wildflowers of an uncommon species is growing. The surrounding river drainage and a nearby town are named for the plants. The trail construction will destroy most of the flowers, as well as the seep-dampened hanging meadow that provides their habitat. Condition 4 wouldn't apply if 323 square feet (30 square meters) would be disturbed to construct a trail that is not accessible and only an additional 75 square feet (7 square meters) would be disturbed to construct a trail that meets the technical accessibility requirements. The majority of the proposed damage to the wildflowers is not attributable to compliance with accessibility requirements. In this case, an alternate location should be selected for the trail.