DIFFERENCES BETWEEN

the Forest Service Trail Accessibility Guidelines (FSTAG) and

the Access Board’s Proposed Outdoor Developed Areas guidelines based on the 1999 Regulatory Negotiation Committee’s final report.

The Forest Service accessibility guidelines, Forest Service Trail Accessibility Guidelines (FSTAG) and the Forest Service Outdoor Recreation Accessibility Guidelines (FSORAG), are legally mandated for use within the National Forest System. Both guidelines were developed based on the 1999 Regulatory Negotiation Committee final report. The FSTAG and the FSORAG completed the OMB and Federal Register final publication process in May 2006.

The FSTAG addresses pedestrian hiking trails. The FSTAG is a separate document because the Forest Service believes there are many unique and complicated trails issues best addressed in a separate document. The Forest Service Outdoor Recreation Accessibility Guidelines (FSORAG) is a separate document addressing campgrounds, picnic areas and so forth. The FSTAG, the FSORAG and the Forest Service Accessibility Guidebook on Outdoor Recreation and Trails are available at www.fs.fed.us/recreation/programs/accessibility.

On June 20, 2007, the Access Board published in the Federal Register their 1999 Regulatory Negotiation Committee’s Final Report in a Notice of Proposed Rule Making (NPRM) as proposed Architectural Barriers Act Accessibility Guidelines for Outdoor Developed Areas for a 90 day comment period. The proposed guidelines will only be legally required to apply to Federal agencies, under the Architectural Barriers Act, that do not have guidelines of an equal or higher standard. The FSTAG and FSORAG will remain the legal mandate for the National Forest System.

This document was developed in order to assist those commenting in defining the differences between the final FSTAG and the proposed Access Board guidelines. Any questions concerning this summary document should be directed to Janet Zeller, Forest Service National Accessibility Program Manager, at .

FSTAG / Proposed Access Board guidelines
Separate document: At the request of trail designers and builders, the 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 FSTAG.
All information related to accessible trails (Scoping, Conditions for Departure, General Exceptions 1 & 2, Definitions, all Technical Provisions for Trail Grade, Cross Slope, Resting Intervals, Surface, Clear Tread Width, Passing Spaces, Tread Obstacles, Protruding Objects, Openings, Edge Protection, and Signs, and FSTAG Implementation Process) is included in one complete document. / Combines trails, outdoor recreation access routes, beach access routes and all other outdoor developed area facilities into one document.
The scoping provisions (how many, where and the conditions for departing from the guidelines) are in a separate section of the document from the technical provisions.
Technical provisions for protruding objects not included with other trail technical provisions. Definitions for trail-specific terms mixed in with all other definitions.
FSTAG / Proposed Access Board guidelines
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 implementation assistive tools
Definitions: The FSTAG defines 32 terms applicable to trails / Definitions: The proposed guidelines
define 7 terms of which 3 apply to trails (trail, trailhead and trail width).
Defines alteration and maintenance per the 1999 Regulatory Negotiation Committee’s draft guidelines and as referenced in the Access Board’s 6/20/2007 NPRM on page 6.
Alteration: A change in the original purpose, intent or design of a trail.
Maintenance: Routine or periodic repair of trails or trail segments to restore them to the standards to which they were originally designed and built. Maintenance does not change the original purpose, intent, or design of a trail. / Defines Alteration (NPRM page 50) as Alteration. “A change to a facility or site that affects or could affect the usability of the facility or site or portion thereof. Normal maintenance and repair, including but not limited to removal of debris and maintenance of a trail head structure are not alterations unless they affect the usability of the facility or site”.
Maintenance is not included in the 7 definitions provided. However it is discussed on pages 6 and 7 of the NPRM where the statement is made that “This type of work is not an alteration; it does not change the original purpose, intent, or design of the trail.”
Protruding Objects: The 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 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 FSTAG permits an exception from the placement of a barrier when such a condition of departure occurs. / Protruding Objects provision in the proposed Access Board guidelines requires the placement of a barrier if there is less than 80” of clear headroom.
No exception is allowed to this requirement for trails regardless of such conditions as narrow pathways through caves, certain type of trees, etc.
FSTAG / Proposed Access Board guidelines
Posting the ISA (wheelchair symbol): The FSTAG specifics the International Symbol of Accessibility (ISA) (the wheelchair symbol) must not be used on trail signs. The ISA is familiar to the public as an indicator of smooth and level surfaces in compliance with the Architectural Barriers Act or Americans with Disabilities Act accessibility guidelines for buildings and other developed recreation areas. Using the ISA, even in combination with another symbol, will create an unreasonable level of expectation of a smooth and level trail resulting in confusion and complaints from trail users with that expectation.
The FSTAG calls for specific trail information to be posted. 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. This universal design approach provides information that useable by all people, allowing the individual to select the trail most appropriate to their abilities without creating false expectations. / Proposes use of the International Symbol of Accessibility (wheelchair symbol) on Trails
Complies with the Federal Interagency Trail Data Standards.
The U.S. Forest Service, National Park Service, Bureau of Land Management and the Fish and Wildlife Service have all accepted and are implementing the Interagency Trail Data Standards (ITDS). The ITDS are also currently being developed as Federal Geographic Data Standards. The ITDS include standardized trail terminology and definitions, and standardized management concepts including Trail Classes, Designed Uses and Managed Uses.
Because the proposed guidelines will apply to these federal agencies, the above-mentioned management concepts and applicable ITDS terminology and definitions must be integrated into the trails related portions of the Access Board’s final Outdoor Developed Areas Accessibility Guidelines.
The ITDS website is http://www.nps.gov/gis/trails / The proposed Access Board guidelines do not comply with the federal agencies Interagency Trail Data Standards (ITDS), although these guidelines are intended for those federal agencies.
FSTAG / Proposed Access Board guidelines
Difference in Terminology: The FSTAG uses and defines the trail related terminology accepted by the trail programs of the federal land management agencies through the ITDS, the Forest Service terminology and terms used in the 1999 final report of the Regulatory Negotiation Committee: Accessible trail, alteration, associated constructed feature, associated constructed feature, trail constructed feature, cross slope, typical cross slope, designed use, general forest area, hiker/pedestrian, maintenance, managed use, ORAR, point of deviation, prominent feature, protruding object, recreation site, scoping requirement, surface, firm, stable, technical provision, trail, trail class, trail grade, trailhead, trail segment, trail terminus, tread width (clear tread width, minimum tread width, minimum trail width), wheelchair. / Does not comply with federal ITDS terminology, although these guidelines are intended for those federal agencies.
Curbs, walls, etc. on tent platforms (where provided): Edge protection is NOT required by the accessibility guidelines, but where provided, is to be at least 3 inches high. 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 provision for tent pads and platforms is addressed in the FSORAG, it has potential significant impact for trails and so tent pads and platforms are also included in the FSTAG appendix. / Curbs, walls, railing or projecting surfaces must be provided on tent platforms.
A minimum of 3 inch high edge protection is required around tent platforms, no exceptions are provided.
Provision for tent pads and platforms is mixed in with all other provisions for outdoor recreation access routes, trails, beach access routes, and related constructed features (e.g. picnic tables, fire rings, etc.)
Condition for Departure 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”. / Condition for Exception 2 states only: “Where compliance would substantially alter the nature of the setting or the purpose of the facility or portion of the facility”.
Does not coordinate with ITDS trail class, designed use or managed use is referenced, although these guidelines are intended for those federal agencies.
FSTAG / Proposed Access Board guidelines
General Exceptions. Two separate general exceptions are included in addition to the Conditions of Departure in order to protect the natural resources and maximize accessibility (principles of both FSTAG and the Access Board guidelines.) / The two general exceptions originally developed by 1999 regulatory Negotiation Committee have been combined into 1 general exception, with a resulting negative impact.
General Exception 1: Covers 4 Limiting Factors beyond which compliance with technical provisions would not be required.
Grade: Limiting Factor 1: Combination of trail grade and cross slope exceeds 20% for over 40 feet.
Width: Limiting Factor 3: The minimum trail width is 18 inches or less for a distance of at least 20 feet. / General Exception covers 5 conditions beyond which compliance with technical provisions would not be required.
Condition 1: Combination of running slope and cross slope exceeds 40 percent for over 20 feet.
Condition 4. The tread width is less than 12 inches wide for a distance of 20 feet or more.
Condition 5. The original 1999 Regulatory Negotiation Committee General Exception 2 has been rewritten and added to General Exception 1. In doing so the original Regulatory Negotiation Committee intent to maximize accessibility, that is stated correctly in the FSTAG, has been changed by the Access Board in this condition.
General Exception 2 , as written by the Regulatory Negotiation Committee addresses trails with numerous environmental barriers that can’t be eliminated, meaning that the trail would have no possibility of meeting the intent or objectives of an accessible hiking opportunity.
Accordingly, the FSTAG states that if conditions of departure exist resulting in deviations from the technical provisions for over 15% of the length of the trail, then the trail provisions do not comply beyond a specified point (see 7.1.2.2 of FSTAG). Specifics are given to ensure accessibility is provided to prominent features within 500 ft. of the trailhead, etc. / The new Access Board General Exception 1: Condition 5 states:
“The trail is not required to comply with any of the technical provisions for more than 15 percent of the length of the trail.” No further specifics are given.
Taken at face value, this condition would imply that only 15% of the trail length ever needs to comply with the technical provisions.
FSTAG / Proposed Access Board guidelines
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, a paragraph or so, is to be written 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 determine its own brief 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 (per the ITDS) 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 content or placement of trail signs.
Constructed features: FSTAG requires that where provided, all new or reconstructed “constructed features” such as pit toilets along trails are to comply with the applicable provisions in the FSTAG, in accordance with the Architectural Barriers Act requirement that facilities constructed by or for a federal agency, on federal land, is to be accessible.
In addition accessible facilities serve all people well. A person has a choice which trail to hike, once on that trail they do not have a choice as to which toilet they can use, so all people should be able to use all facilities.
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. / Not specified
Not addressed

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