Analysis: Chapters T3 & T4

Chapter T3 Technical Provisions

Chapter T3 contains technical provisions for features required to be accessible in Chapter T2.

T302 Conditions for Exceptions

Section T302 sets out four conditions under which exceptions from certain technical provisions are permitted. Each technical provision must be examined individually to determine whether an exception from that provision is permitted. This section does not provide an overall exemption of the entire trail or outdoor element. When an exception is permitted, the proposed guidelines specifically provide an exception to the respective technical provision. This is essential as the outdoor environment is very different than a constructed indoor environment. Factors which influence the ability to provide fully accessible facilities such as soil, surrounding vegetation, hydrology, terrain, and surface characteristics, are fundamental to the outdoor area. Where trails are concerned, the committee recognized that without the opportunity to permit exceptions from the technical provisions, compliance may significantly alter the nature of the outdoor experience.

The conditions in T302 do not obviate or limit in any way the obligation to comply with the technical provisions in Chapter T3 at any point where the conditions do not apply. When the condition for an exception no longer exists, the technical provisions apply. For example, the clear width of a trail tread may be reduced because of a significant natural feature. Once the trail passes this feature, the technical provisions for width shall apply. This approach also applies when designing certain outdoor elements also included in this section. The conditions that permit exception from specific technical provisions are described below.

Condition 1. Compliance Would Cause Substantial Harm to Cultural, Historic, Religious, or Significant Natural Features or Characteristics.

A significant natural feature may include a large rock, outcrop, tree, or a water feature which would block or interfere with trail construction or would be directly or indirectly altered or destroyed by construction of the trail to the extent that the trail could not, at that point, be made accessible. This includes areas protected under Federal or State laws, such as areas with threatened or endangered species or designated wetlands that could be threatened or destroyed by full compliance with the technical provisions. It also includes areas where compliance would directly or indirectly substantially harm natural habitat or vegetation.

Significant cultural features include areas such as archaeological sites, sacred lands, burial grounds and cemeteries, and Indian tribal protected sites. Significant historical features include properties on or eligible for the National Register of Historic Places or other places of recognized historic value. Significant religious features include Indian sacred sites and other properties designated or held sacred by an organized religious belief or church.

Condition 2. Compliance Would Substantially Alter the Nature of the Setting or the Purpose of the Facility, or Portion of the Facility.

This condition includes trails intended to provide a rugged experience such as a cross country training trail with a steep grade or a challenge course with abrupt and severe changes in level. If these types of trails were flattened out or otherwise constructed to comply with the technical provisions for accessible trails, they would not provide the intended and desired level of challenge and difficulty to users. Trails that traverse over boulders and rocky outcrops, are another example. The purpose of such trails is to provide people 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 may also be compromised by actions such as widening a trail through the use of imported surfaces in a remote location or removing ground vegetation in meadows or alpine areas.

Trails and other outdoor elements such as picnic and camping areas are designed to provide a particular opportunity for the user. Throughout the discussions regarding these outdoor elements, many committee members were concerned that complying with the technical provisions could change the nature of some recreation opportunities. Further, compliance could negatively impact the unique characteristics of the natural setting, the reasons why people choose to recreate in the outdoors rather than an indoor environment. People using primitive trails or camping areas, for example, often experience the outdoor environment in a more natural state with limited or no development. Evidence of manufactured building materials or engineered construction techniques in such a setting can change its primitive character, and therefore, the user’s experience. In these settings, people are generally looking for a higher degree of challenge and risk where they can use their outdoors and survival skills. Compliance with the technical provisions, particularly those related to surface and obstacles, could destroy the “natural” or “undeveloped” nature of the setting. This condition addresses these concerns.

Condition 3. Compliance Would Require Construction Methods or Materials That Are Prohibited by Federal, State, or Local Regulations or Statutes.

Federally designated and some State designated Wilderness Areas prohibit use of mechanized equipment, limiting construction methods to hand tools. Imported materials may be prohibited in order to maintain the integrity of the natural ecosystem. Construction methods and materials employed in designated wetlands or coastal areas are also strictly limited. For traditional, historic, or other reasons, many trails are built using only the native soil for surfacing, which may not be firm and stable. Federal statutes such as the Wilderness Act and the Endangered Species Act, and State and local statutes often impose restrictions to protect or address environmental concerns. Many aquatic features are protected under Federal or State laws. Some constructed water crossings, which would be required to provide accessibility, may not be permitted under certain laws or regulations.

“Local regulations and statutes” have been included to address conditions where “conservation easements” or “development rights” programs have prohibited or restricted construction methods and practices. For example, where land is purchased from farms, certain use restrictions may prohibit the importation of surfacing. On the other hand, local regulations or statutes may not be developed or initiated with the sole purpose of prohibiting use by people with disabilities. For example, initiating a new local regulation that arbitrarily restricts trail width to a dimension that would not allow passage of wheelchairs or other mobility devices from accessing a trail, is not permitted under this condition.

Condition 4. Compliance Would Not Be Feasible Due to Terrain or the Prevailing Construction Practices.

Complying with the technical provisions, particularly running slope, in areas of steep terrain may require extensive cuts or fills that would be difficult to construct and maintain, or cause drainage and erosion problems. Also, in order to construct a trail on some steep slopes, a trail may become significantly longer causing a much greater impact on the environment. Certain soils are highly susceptible to erosion. Other soils expand and contract along with water content. If compliance requires techniques that conflict with the natural drainage or existing soil, the trail would be difficult, if not impossible to maintain. This condition may also apply where construction methods for particularly difficult terrain or the presence of an obstacle would require the use of equipment other than that typically used throughout the length of the trail. One example is requiring the use of a bulldozer to remove a rock outcropping when hand tools are commonly used.

Several of these conditions for departures are consistent with other exceptions for trails. For example, it may be impracticable in new construction to follow these provisions where soil and terrain pose obstacles which cannot be remedied. Compliance with the provision for a firm and stable surface might conflict with the prevailing construction practices by requiring the importation of a new surfacing material that would otherwise not have been used. For example, if the prevailing construction practices would not include the importation of a new surface material and the natural surface material could not be made firm and stable, the trail may not be able to comply with that specific provision.

The term “not feasible” is used in this situation to specify what is “reasonably do-able”. It does not refer to the technical feasibility or possibility of full compliance with the technical provisions. For example, it may be feasible to provide a trail with a 1:20 slope or less up a 1,500 foot tall mountain using heavy construction equipment, but the trail would be at least 5.8 miles long (rather than 2 miles long under a traditional back-country layout), and may cause inappropriate environmental and visual impacts. The intent of this conditional departure is to recognize that the effort and resources required to comply would not be disproportionately high relative to the level of access created. Although technically feasible, the effort and resources required are not “reasonable.”

Trail construction practices vary greatly, from the use of volunteer labor and hand tools, to professional construction with heavy, mechanized equipment. For alterations to an existing trail, the “prevailing construction practices” are defined as the methods typically used for construction or maintenance of the trail. For new trails, it is recognized that the land manager determines the construction practices to be used on each trail. However, the choice of construction practices is primarily determined by the available resources (e.g., machinery, skilled operators, finances) and the environmental conditions (e.g., soil type and depth, vegetation, natural slope). The intent of this condition is to ensure that compliance with the technical provisions does not require the use of construction practices which are above and beyond the skills and resources of the trail building organization. It is not intended to automatically exempt a trail from the technical provisions simply because of a particular construction practice, (e.g., the use of hand tools or to suggest that hand tools should be used to avoid compliance) when more expedient methods and resources are available.

Where specified, the presence of the conditions in T302 may also prevent full compliance with some of the technical provisions for elements in picnic, camping, and beach facilities. While the conditions for departures may be more limited with these outdoor elements, the committee included the option for exceptions based on the conditions in several provisions. In most cases, these are limited to technical provisions for clear floor or ground space, surface slope, and accessible surfacing.

Where designers or operators apply an exception from a specific technical provision because of one or more of the conditions, the other technical provisions should be applied. For example, a significant cultural feature may prohibit a 36 inch trail tread width. However, all other provisions could be met because they would not be affected by the condition.

T303 Trails

T303.2 General Exceptions

The committee realized that there may be situations where the combination of factors and conditions may make it impractical to make the entire portion of the trail accessible according to the technical provisions. Two general exceptions in section T303.2 were developed to address these situations. First, where one or more of the conditions in T302 applies and where one or more of the conditions in this general exception applies, the trail is not required to be accessible after the first point of departure. The segment of the trail between the designated trailhead and the first point of departure is required to be accessible unless the trail segment is 500 feet or less in length. If the trail segment connects to a prominent feature less than 500 feet from the designated trailhead, it is required to be accessible between the trailhead and the prominent feature. The general exceptions are based on these conditions:

  • the combination of running slope and cross slope exceeds 40 percent for over 20 feet; or,
  • a trail obstacle 30 inches or more in height is across the full tread width of the trail; or,
  • the surface is neither firm nor stable for a distance of 45 feet or more; or,
  • a clear trail width is less than 12 inches for a distance of 20 feet or more; or
  • the trail is not required to comply with any of the technical provisions in T303 for more than 15 percent of the length of the trail.

The 15 percent threshold in the last condition is a compromise, negotiated to balance the resources and environmental impact with the practicality of providing meaningful access on trails. The committee recommends that trail designers and managers attempt compliance with all technical provisions throughout the full length of the trail.

Section T303.3 requires the surface of accessible trails to be firm and stable. The “slip resistance” requirement typically required for accessible surfaces was not included because slip resistance cannot be guaranteed in an outdoor environment. Weather conditions (rain, snow, or ice) will affect slip resistance. For example, natural or non-hardened surfaces may not be slip resistant. Slip resistance may also be difficult to control when leafs and other surface debris caused by natural erosion accumulate on the surface.

The means and materials used to establish accessible exterior surfaces are plentiful. Crushed stone, fines, packed soil, and other natural materials can provide a firm and stable surface. Natural materials bonded with synthetic materials can provide the required degree of stability and firmness. An advisory has been added to provide additional information concerning accessible exterior surfaces. An exception is permitted from this provision where one or more of the conditions in T302 exist.

Section T303.4 requires the clear trail tread width to be 36 inches minimum. Exception 1 permits the clear trail tread width to be reduced to 32 inches minimum where one of the conditions in T302 applies. Exception 2 permits departures from T303.4 where a 32 inch minimum width cannot be provided because one of the four conditions in T302 exists.

Section T303.5 requires openings in trail surfaces to be of a size that does not permit the passage of a ½ inch diameter sphere. Elongated openings must be placed so that the long dimension is perpendicular or diagonal to the dominant direction of travel. Exception 1 permits elongated openings to be parallel to the dominant direction of travel where the opening does not permit passage of a ¼ inch diameter sphere. This is necessary to allow trail managers to place boards lengthwise along a boardwalk trail to reduce the environmental impact such as on a wetland area. Exception 2 permits openings that do not permit passage of a ¾ inch diameter sphere where at least one of the conditions in T302 applies. Exception 3 exempts trails from the provisions of T303.5 where openings that do not permit passage of a ¾ inch diameter sphere are not feasible because at least one of the four conditions in T302 apply.

A ¾ inch spacing is permitted through an exception since many trails use wood plank decking or boardwalks to cross wet, sandy, rocky, or environmentally sensitive areas. The planks expand and contract because of weather conditions. The boardwalks may need more than ½ inch spacing between the planks to permit expansion and to allow water to drain.

Section T303.6 requires that any tread obstacles shall not exceed 2 inches maximum in height. Exception 1 permits a 3 inch obstacle where the running and cross slopes are 1:20 or less. Exception 2 permits obstacles greater than 3 inches where at least one of the conditions in T302 applies. The committee recognized that natural features such as rocks, roots, and ruts may require a greater obstacle height than what is permitted in the indoor environment. Some wheelchairs used in an outdoor environment are designed to handle obstacles of these heights. However, trails used by bicyclists or in-line skaters or which serve as alternate transportation routes for sidewalks should be smooth with no abrupt changes in level.

Section T303.7 requires passing space where the clear tread width of the trail is less than 60 inches. Passing space is required at intervals of 1,000 feet maximum. Either a T-shape or a turning circle is permitted. An advisory states that the passing space may be located to one side of the trail. An exception is permitted from this provision where passing space cannot be provided because at least one of the four conditions in T302 exists.

The committee negotiated various intervals for passing space, ranging from 200 feet to no requirement. Those favoring longer intervals or no requirement explained that the outdoor environment often allows users to move off the trail tread without involving trail construction (as opposed to being restricted by walls within a building). There was concern about having an unrealistic construction requirement in a natural setting, and concern that requiring a constructed passing space at more frequent intervals may be unnecessary where few users are on a trail at the same time. An advisory is added recommending that trails expected to have high use and trails with long sections where it is not possible to move off the trailhead (e.g., boardwalks in a wetland) should consider more frequent passing spaces, especially close to the trailhead.

Section T303.8 addresses both the cross slope and the running slope of a trail. This provision was the result of significant compromise among committee members. Exception 1 addresses open drainage structures. For open drainage structures, a running slope of 14 percent is permitted for 5 feet maximum with a cross slope of 1:20 maximum. Cross slope is permitted to be 1:10 at the bottom of the open drain, where the clear tread width is 42 inches minimum. Exception 2 exempts trails from T303.8 where one or more of the conditions of T302 exist.

Section T303.8.1 requires that the maximum cross slope of trail segments not exceed 1:20. Committee members recognized that cross slopes, or the side-to-side slope of a trail, can be difficult to traverse. At the same time, trails need to be designed to provide sufficient drainage to prevent ponding and water damage to the trail. Non-paved surfaces generally require more than a minimum of 1:50 cross slope.

Section T303.8.2 addresses the maximum running slope of trail segments. Section T303.8.2 permits no more than 30 percent of the total trail length to exceed a 1:12 slope. The committee debated various slope ratios for this provision. Committee members advocating steeper slopes were concerned that requiring unrealistic slopes in natural areas could significantly alter the natural terrain. Members advocating less slopes were concerned that steeper slopes would not be accessible, and could be a potential safety hazard.

This section requires that trails comply with one or more of four separate provisions. Designers may choose which provision to apply. Section T303.8.2.1 permits a running slope at 1:20 or less for any distance. Section T303.8.2.2 permits a running slope of 1:12 maximum for 200 feet maximum. Resting intervals must be provided at distances no greater than 200 feet apart. Section T303.8.2.3 permits the running slope to be 1:10 maximum for 30 feet maximum. Resting intervals must be provided at distances no greater than 30 feet apart. Section T303.8.2.4 permits the running slope to be 1:8 maximum for 10 feet maximum. Resting intervals must be provided at distances no greater than 10 feet apart.

Because the terrain in outdoor environments is often steep, the committee realized that applying slope and ramp requirements was not feasible. The proposed running slopes and maximum distances represent a compromise and balances accessibility with the constraints imposed by natural topography.

Question 19: Section T303.8 permits departure from the technical provisions for cross slope with open drainage structures. A cross slope up to 10 percent is permitted at the bottom of the open drain where the clear tread width is 42 inches minimum. Are open drainage structures the only drainage structures where cross slopes up to 10 percent should be permitted? If not, what other areas should be identified?

The committee believed that handrails should not be required on trails, since handrails are impractical in this environment. In addition, steeper grades on trails are usually contiguous with the surrounding terrain rather than elevated above it as with a ramp to a building. Instead, the committee limited the length of steep portions of trail segments and required resting intervals.

Section T303.9 requires resting intervals to be 60 inches in length to accommodate wheelchair users and at least as wide as the widest portion of the trail segment leading to the resting interval. The slope of the resting interval must not exceed 1:20 in any direction. An advisory recommends that the resting interval may be located to one side of the trail to allow other users to pass. An exception exempts trails from this technical provision where one of the conditions in T302 exists.

Section T303.10 does not require edge protection on accessible trails. However, where edge protection is provided, the height must be a minimum of 3 inches. Natural trail surfaces are likely to have variations in the trail surface, and a 2 inch edge protection may not be obvious or detectable in the outdoor environment. In the outdoor environment, many people with limited vision who use canes will search higher than in an indoor environment to distinguish between the edge and variations within the trail.

T304 Outdoor Recreation Access Routes

Section T304.2 requires the surface of an outdoor recreation access route to be firm and stable. This is consistent with the surface provision proposed for trails and other outdoor elements.

Section T304.3 requires the clear tread width of the outdoor recreation access route to be 36 inches minimum. An exception permits the width to be the minimum necessary or 32 inches for a distance of 24 inches where one or more of the conditions in T302 exist.

Section T304.4 addresses openings and does not permit passage of a ½ inch diameter sphere. Elongated openings must be placed so that the long dimension is perpendicular or diagonal to the dominant direction of travel. An exception permits the openings to run parallel so long as the opening does not permit passage of ¼ inch diameter sphere.

Section T304.5 requires that tread obstacles not exceed 1 inch high maximum. An exception permits a 2 inch high obstacle where it is beveled and where at least one of the conditions in T302 applies. Tread obstacles may occur where surface materials changes such as asphalt surfaces leading up to a concrete slab.

Section T304.6 requires passing space where the clear width of the outdoor recreation access route is less than 60 inches. Passing space is required at intervals of 200 feet maximum. Committee members determined that outdoor recreation access routes were more like an indoor accessible route than a trail. The passing space must be either a 60 inch by 60 inch space or an intersection of two walking surfaces which provide a T-shaped space complying with T402.1.2, provided that the arms and stem of the T-shaped space extend at least 48 inches beyond the intersection. An exception permits the passing spaces to be at intervals not to exceed 300 feet. This was added to address settings where it may not be possible to provide passing space within a 200 foot minimum interval, such as environmentally sensitive areas.

Section T304.7.1 addresses the cross slope of an outdoor recreation access route and permits a 1:33 maximum cross slope. An exception permits a 1:20 cross slope where necessary to ensure proper drainage. Natural or naturally appearing surfaces often require greater than 1:50 cross slopes to ensure proper drainage. Committee members agreed that water ponding on an outdoor recreation access route may make the route inaccessible; therefore, a greater cross slope is proposed.

Section T304.7.2 addresses running slope. Designers have a choice of applying one or more of the technical provisions in this section. Section T304.7.2.1 permits the running slope to be 1:20 or less for any distance. Section T304.7.2.2 permits the running slope to be 1:12 maximum for 50 feet maximum. Resting intervals must be provided at distances no greater than 50 feet apart. Section T304.7.2.3 permits the running slope to be 1:10 maximum for 30 feet maximum. Resting intervals must be provided at distances no greater than 30 feet apart.

Question 20: The committee was unable to decide whether there should be exceptions from the technical provisions for outdoor recreation access routes based on the conditions in T302. Currently, departures from the technical provisions are permitted for specific elements, (e.g., picnic tables, camp sites) but not for the outdoor recreation access routes that connect those elements. Should exceptions be permitted for specific elements on the outdoor recreation access routes leading to those elements?

Question 21: The committee also discussed potential exceptions from the provisions for slope on an outdoor recreation access route, unrelated to whether the elements themselves complied with the technical provisions. The committee considered two options. One option provided a maximum for the total length of the outdoor recreation access route that could exceed a 1:12 slope. The committee considered that either 10 percent or 15 percent of the total length of the outdoor recreation access route could exceed a 1:12 slope. The second option was to apply the conditions in T302 to the technical provisions for the slope of an outdoor recreation access route. Comment is requested on this issue.

Section T304.8 requires resting intervals to be 60 inches minimum in length and have a width at least as wide as the route connecting it. The slope must not exceed 1:33 in any direction. Where the surface conditions require slopes greater than 1:33 for proper drainage, a 1:20 slope is permitted.

Section T304.9 requires edge protection, where provided, to be 3 inches minimum in height. This is consistent with the proposed provision for trails.

T305 Beach Access Routes

Section T305.2 requires the surface of the required beach access route to be firm and stable. Given the existence of loose material natural to a beach environment such as sand, algae, and barnacles, the committee decided that slip resistance is not an appropriate requirement for a beach access route. This is consistent with the provisions for other outdoor routes. Where a temporary route is provided, it must also be firm and stable.

Section T305.3 requires that a beach access route extend to the high tide level, mean river bed level, or the normal recreation water level. The committee believed that different lines of demarcation would vary depending upon the location of the beach. The committee selected the high tide level for coastal beach, the mean river bed level for river beaches, and the normal recreation water level for lakes and reservoirs. Beach access to the water will vary considerably between geographic locations because the tidal difference between high and low tides varies from place to place. For example, a beach in Alaska may experience tidal differences of tens or even hundreds of feet; beaches in Florida will have much smaller differences between low and high tides. The high tide mark is a reasonable location to terminate permanent structures as built facilities; below this point it is much more likely to wash out. The mean river bed level and the normal recreation water level are comparable for rivers and lakes, respectively.

Question 22: Comment is sought on the appropriateness of these markers and the ability to determine those levels at most beaches.

Question 23: The committee did not require a beach access route to extend beyond the high tide level, mean river bed level, or normal recreation water level. Comment is sought on what technical specifications should be required, if any, if an entity decides to provide the route into the water? Should the technical provisions for sloped entry into pools be applied in these cases?

Section T305.4 requires the clear tread width of the beach access route to be 36 inches minimum. This requirement is consistent with the proposed technical requirement for the clear tread width of trails and outdoor recreation access routes. Unlike other requirements for the clear width of trails and outdoor recreation access routes, no reduction in width is permitted. Since the beach access route will most likely be adjacent to sand, maintaining the 36 inch width is critical to avoid being caught off the path on a nontraversable sandy surface. The need for additional space for passing and resting has been included in other provisions.

Section T305.5 requires openings in the surfaces of the beach access route to be of a size that does not permit passage of a ½ inch diameter sphere. Elongated openings must be placed so that the long dimension is perpendicular or diagonal to the dominant direction of travel. This is consistent with the Architectural Barriers Act Accessibility Guidelines and the proposed technical provisions for outdoor recreation access routes. An exception permits the elongated openings to run parallel to the dominant direction of travel where the opening does not permit passage of a ¼ inch sphere.

Section T305.6 limits the obstacles in the beach access route to be 1 inch high maximum. This departs from the Architectural Barriers Act Accessibility Guidelines but is consistent with the proposed technical requirements for tread obstacles for an outdoor recreation access route and is necessary due to the uniqueness of the outdoor environment.

Section T305.7 requires passing space. Where the clear width of the beach access route is less than 60 inches, passing space must be provided at intervals of 200 feet. Passing space shall be either a 60 inch by 60 inch minimum space or an intersection of two walking surfaces which provides a T-shaped space complying with T402.1.2, provided that the arms and stem of the T-shaped space extend at least 48 inches beyond the intersection. This is consistent with the technical provisions for passing spaces on an outdoor recreation access route.

Section T305.8 requires a turning space or resting space at the end of the beach access route or at the high tide level, mean river bed level, or normal recreation water level. Turning space must not overlap the beach access route and must be either a 60 inch minimum by 60 inch minimum space, or an intersection of two walking surfaces which provide a T-shaped space complying with T402.1.2 provided that the arms and stem of the T-shaped space extend at least 48 inches beyond the intersection.

A resting or turning space allows a person with a disability to be out of the route of travel, to leave their wheelchair while transferring into a beach terrain vehicle, or simply to wait in a place outside the flow of traffic. The location of this resting or turning space should be in an area which is dry. If the route extends further than the minimum distance required, the resting or turning space may be placed at the end of the beach access route, although the location may not always remain dry.

Section T305.9 addresses the cross slope and running slope of beach access routes. Section T305.9.1 requires the maximum cross slope of a beach access route to not exceed 1:33. An exception permits cross slopes of 1:20 maximum for drainage. This is consistent with the proposed technical requirements for cross slope of an outdoor recreation access route and is necessary for drainage in the outdoor environment.

Section T305.9.2 addresses running slope. Designers have a choice of applying one or more of the technical provisions in this section. Section T305.9.2.1 permits running slope to be 1:20 or less for any distance. Section T305.9.2.2 permits the running slope to be 1:12 maximum for 50 feet maximum. Resting intervals must be provided at distances no greater than 50 feet apart. Section T305.9.2.3 permits the running slope to be 1:10 maximum for 30 feet maximum. Resting intervals must be provided at distances no greater than 30 feet apart. The rationale for requiring a resting interval is the same as for trails or outdoor recreation access routes. The running slope provisions are the same as those for an outdoor recreation access route.

Section T305.10 requires edge protection where drop-offs from the beach access route to the beach are 6 inches or higher. The edge protection includes curbs, walls, or projecting surfaces that prevent people from falling off the route. Edge protection must be a minimum of 2 inches high. If the drop-off is greater than 1 inch, but less than 6 inches, then the edge must be beveled. While a raised edge may be considered a tripping hazard in some instances, the committee recognized that in some locations, an elevated route such as that created by a boardwalk might necessitate a raised edge for safety. Where these locations occur, the elevation of the route is already an impediment to the perpendicular traffic and the addition of edge protection would not create any more of a tripping hazard than that already created by the elevated route itself. Therefore, the committee recommended that those elevated routes, defined as 6 inches or more above the beach surface, have a requirement for edge protection equivalent to the edge protection requirement in the Architectural Barriers Act Accessibility Guidelines for ramps. If the height of the route is greater than 1 inch but less than 6 inches, the committee felt that edge protection was not required, although the edge should be beveled. If the height of the route is 1 inch or less, then there is no requirement for beveling, as an inch or less elevation is virtually a flat route and is a reasonable to expect in a beach environment given the shifting of sand.

T306 Picnic Tables

Section T306.2 addresses the technical provisions for wheelchair spaces. Each wheelchair space must provide knee space of at least 30 inches wide, 19 inches deep, and 27 inches from the ground or floor to the bottom of the table top. This provision is different from the Architectural Barriers Act Accessibility Guidelines in that it also requires a toe clearance of 9 inches above the ground or floor extending for a total depth of 24 inches. This is an additional 5 inches minimum beyond the 19-inch knee space depth. This ensures that adequate toe clearance is provided at tables that have a solid leg at each end (rather than an A-shape frame or individual legs). A 19-inch deep space at the end of a solid leg table would not allow a person using a wheelchair to be sufficiently close to the table.

Section T306.3 addresses table clearance. This provision requires a 36-inch wide minimum clear floor or ground space surrounding the usable portions of a table, measured from the back edge of the seat, or the back edge of the table if no seat is provided.

Tables placed in buildings are generally expected to have ample space for moving around. This is not always the case where picnic tables are located in an outdoor environment. For that reason, the committee recommended a minimum clear floor or ground space that would provide maneuvering room beyond the accessible seating space to all usable portions of a table to allow for movement around the table.

Section T306.4 addresses clear spaces. Section T306.4.1 requires the surface of the clear floor or ground space and the wheelchair space to be firm and stable. Slip resistance is not required because of the tree leaves and needles, duff (partly decayed organic material on the forest floor), mud, snow, and ice that often cover outdoor areas. Exception 1 permits an exception from this requirement where at least one of the conditions of T302 applies.

Section T306.4.2 requires slopes of the required clear floor or ground spaces not to exceed 1:50 in any direction. Exceptions are provided to address the unique aspects of the outdoor environment. Natural and natural-appearing surfaces are often used in picnic areas. A 1:50 slope on these surfaces may not be adequate to ensure proper drainage. In these cases, exception 1 allows the slope in any direction to be 1:33 maximum. Exception 2 states that this provision does not have to be met where at least one of the conditions in section T302 applies.

T307 Fire Rings

Section T307.2 requires that a clear floor or ground space extending a minimum of 48 inches deep by 48 inches wide be provided at all usable portions of a fire ring. This clear floor or ground space exceeds what is generally required in the Architectural Barriers Act Accessibility Guidelines to allow both a forward and parallel approach and to provide more space to move away from the heat. Exception 1 permits the clear floor or ground space to be reduced to no less than 36 inches deep by 36 inches wide when one of the conditions in T302 exists. A clear floor or ground space of less than 36 inches by 36 inches at accessible fire rings could pose a safety hazard to users. As a result, no exception is provided to further reduce the clear floor or ground space to less than 36 inches by 36 inches.

The surface and slope requirements of the clear spaces required by T307.2 must comply with T306.4. Many of the elements included in this rule share the same requirements for the surface and slope of clear spaces. A discussion regarding this requirement is included in the preamble discussion for T306.4.

Section T307.3 requires the fire surface height to be 9 inches minimum above the ground or floor and is inconsistent with the Architectural Barriers Act Accessibility Guidelines specifications for a low side reach which is 15 inches.

Section T307.4 addresses raised edges around fire rings. Where a raised edge or curb is provided around a fire ring, this provision would require that the combined reach over the edge or curb and down to the fire building surface must be 24 inches maximum.

T308 Cooking Surfaces, Grills, and Pedestal Grills

The surface and slope requirements of the clear spaces required by T308.2 must comply with T306.4. Many of the elements included in this rule share the same requirements for the surface and slope of clear spaces. A discussion regarding this requirement is included in the preamble discussion for T306.4.

Section T308.3 requires accessible cooking surfaces to be installed between 15 inches and 34 inches above the ground or floor. This provides a comfortable reach range for cooking.

Section T308.4 requires operating controls and mechanisms to comply with T407.

T309 Fixed Trash and Recycling Containers

The surface and slope requirements of the clear spaces required by T309.2 must comply with T306.4. Many of the elements included in this rule share the same requirements for the surface and slope of clear spaces. A discussion regarding this requirement is included in the preamble discussion for T306.4. Section T309.3 requires operating controls for the containers to comply with T407.2 and T407.3. However, an exemption from this requirement is provided where the container has a hinged, sliding, or other cover and is situated where it is subject to large animal intrusion, thus dictating animal-resistant controls. Current designs for controls and operating mechanisms preclude providing secure storage of trash or recycled material from large animals, and still meet the reach and operating force requirements of T407.3.

T310 Wood Stoves and Fireplaces

The surface and slope requirements of the clear spaces required by T310.2 must comply with T306.4. Many of the elements included in this rule share the same requirements for the surface and slope of clear spaces. A discussion regarding this requirement is included in the preamble discussion for T306.4.

Section T310.2 requires that a clear floor or ground space 48 inches deep minimum and 48 inches wide minimum be provided from all usable portions of the wood stove or fireplace. This is consistent with space requirements for other elements in outdoor developed facilities, such as fire rings and grills. The 48 inch requirement allows for a front and side approach. The committee agreed that the extra space required beyond 30 inches by 48 inches is warranted in this case where safety is paramount. An exception is provided to reduce this requirement to 36 inches minimum depth where one or more of the conditions in section T302 exist.

Section T310.3 requires the controls for operation of wood stoves and fireplaces to comply with T407.

Question 24: Are there controls and operating mechanisms available for fireplaces that will meet the requirements of T407? If not, what modifications will allow for most operating mechanisms of woodstoves and fireplaces to meet this provision?

T311 Overlooks and Viewing Areas

Section T311.2 requires at least one turning space with a circular or T-shaped space complying T402. The surface and slope requirements of the turning spaces required by T311.2 must comply with T306.4. Many of the elements included in this rule share the same requirements for the surface and slope of clear spaces. A discussion regarding this requirement is included in the preamble discussion for T306.4.

Section T311.3 requires that each location providing a viewing opportunity to one or more distinct points of interest must have at least one unrestricted viewing area for each viewing opportunity. The committee felt that the attraction of a viewing area is to bring persons to a place where they can enjoy all the aspects of the site and persons with disabilities should have the opportunity to experience the attraction. The committee determined that an arc extending from 32 inches minimum above the level surface of the viewing area to 51 inches maximum above the surface would be sufficient to allow an unobstructed view. Often the overlook or the viewing area has an adjacent drop-off that would present a hazard to the user of the area. Safety barriers are often installed (such as a guardrail, railing, or wall) to protect the visitor from the edge and may block the view. This provision requires an unobstructed view to the distinct point of interest. There must be a means by which a field of view in the described arc is obtained. Various designs or recommendations to manage this are provided in the advisory, and include see-through panels in walls or elevated platforms away from the guarded edge. A periscope complying with T212.1 is also an option for a view over a barrier. This provision does not apply where one of the conditions in T302 exists.

T312 Telescopes and Periscopes

Section T312.2 requires the surface conditions of the clear floor or ground space adjacent to the telescope or periscope to be firm and stable, and comply with the clear space requirement of T403. In the interest of safety and the ability to use the elements in an unchanging and balanced condition, a dependable surface condition is a necessity.

Section T312.2 also requires the slope of the required clear floor or ground space to not exceed 1:50 in any direction, unless the surface condition is such that drainage is a problem. Where drainage is of concern, a 1:33 maximum slope is permitted. Drainage from the area adjacent to the elements is essential to preserve the integrity of the surface condition and to provide a comfortable location to use the elements.

Section T312.3 requires the controls and operating mechanisms of telescopes and periscopes to comply with T407.

Section T312.4 requires the eye piece to be usable from a seated position so that each distinct point of interest is viewable. This will provide the widest range of viewing opportunities, not only for seated individuals but also for children. An advisory provides suggestions on how to accomplish this. Options include an adjustable scope mount, a swivel seat or installing an element that would allow for a high/low option similar to what is offered for water fountains. The requirement for use from the seated position is necessary for people using wheelchairs and other mobility devices. The committee recognized that this may also benefit children or individuals of short stature.

T313 Fixed Benches

Section T313.2 requires the surface and slope requirements of the clear spaces to comply with T306.4. Many of the elements included in this rule share the same requirements for the surface and slope of clear spaces. A discussion regarding this requirement is included in the preamble discussion for T306.4.

Section T313.2 also requires that clear spaces be located at one end of the accessible bench, and not overlap other clear floor or ground space requirements. The committee debated the location of the clear floor or ground space, recognizing that many different configurations could exist. The requirement of a clear floor or ground space at one end without intruding into other clear floor or ground spaces provides users with the same perspective as the occupant of the bench, no matter which direction the bench is facing and avoids obstructing the outdoor recreation access route. Shoulder-to-shoulder alignment of the clear floor or ground space enhances the opportunity for and ease of interaction or conversation with someone seated on the bench.

Section T313.3 requires that the top of the seat surface be between 17 inches and 19 inches above the ground or floor space to facilitate transfer. This provision is consistent with the Architectural Barriers Act Accessibility Guidelines.

Section T313.4 addresses back support. Back support is required on accessible benches and must extend the full length of the bench.

Section T313.5 addresses armrests. Where required by T213.2, at least one armrest is required on a single bench. Section T213.2.2 requires armrests where multiple benches are provided. All armrests must comply with T411.8. This will facilitate transfer to the bench and provide support to maneuver to or from the bench seat.

T314 Utility Sinks

Section T314.2 requires a clear floor or ground space complying with T403.1 to be provided at the sink for adequate reach and turning space. Section T314.2 requires that the clear floor or ground space not have a slope greater than 1:50. An exception permits the slope of the clear floor or ground space to be 1:33 maximum to provide proper drainage. Section T314.2 also requires that the surface of the clear floor space be firm and stable.

Section T314.3 requires the height of the counter or rim to be 34 inches maximum above the floor or ground surface.

Section T314.4 requires the depth of the bowl to be 15 inches minimum above the floor or ground surface. The committee recognized that there may be some difficulty in providing a deep enough sink to accomplish the purposes of cleaning larger pots or pans given current reach range requirements. However, the committee believed that adhering to the established reach ranges was important.

Section T314.5 requires operable parts of the sink to comply with T407.

T315 Mobility Device Storage Facilities

Section T315.2 requires the surface and slope requirements of the clear spaces to comply with T306.4. Many of the elements included in this rule share the same requirements for the surface and slope of clear spaces. A discussion regarding this requirement is included in the preamble discussion for T306.4.

Section T315.3 requires that the size of the storage space be 38 inches minimum in height, 28 inches minimum in width and 40 inches minimum in length. These dimensions are based on the space needed for a collapsed standard adult wheelchair. The committee agreed that a wheelchair would be the most commonly occurring device which would require storage and based the requirements accordingly.

Section T315.4 requires controls and operating mechanisms for accessible mobility storage facilities to comply with T407.

T316 Pit Toilets

Section T316.2 requires the surface and slope requirements of the clear spaces to comply with T306.4. Many of the elements included in this rule share the same requirements for the surface and slope of clear spaces. A discussion regarding this requirement is included in the preamble discussion for T306.4.

Section T316.2 also requires compliance T409. Where one of the conditions in T302 applies, exception 1 permits the size of the clear floor or ground space to be reduced to 48 inches by 48 inches. Where a 48 inch by 48 inch clear floor or ground space cannot be provided because at least one of the conditions of T302 applies, exception 2 does not require compliance with T316.2.

Section T316.3 requires the height of the pit toilet seat to comply with T409.4. No exceptions for the outdoor environment were necessary.

Section T316.4 requires grab bars complying with T411 only where the pit toilets are provided with walls. Since many pit toilets consist of a riser placed on the ground, the committee agreed that the requirement for grab bars should only be triggered if a structure surrounds the riser.

T317 Utilities

Section T317.2 requires the slopes of clear floor or ground spaces at utilities to have a 1:50 maximum slope in any direction. Where surface conditions require a slope greater than 1:50 for proper drainage, an exception permits a 1:33 maximum slope. Section T317.2 also requires the surface of the clear floor or ground space to be firm and stable.

Section T317.3 requires fixed water spouts to be located 28 inches minimum to 36 inches maximum above the ground or floor surface and to be centered at the edge of a 60 inch minimum by 60 inch minimum clear floor or ground space.

Section 317.4 requires controls and operating mechanisms associated with utilities to comply with T407. Exception 1 does not apply T407 to sewage hookups. Exception 2 exempts hand pumps from T407.3. The rationale for not requiring sewer hookups to meet height and reach range provisions is based on their ground level location necessary for gravity drainage. Most are foot drains or have a small handle at the ground level to open the connection to the system.

T318 Camping Facilities

Section T318.2 addresses accessible camping space parking. Section T318.2.1 requires accessible recreational camping vehicle or trailer camping spaces to be 20 feet minimum in width. This was determined to be necessary to accommodate existing equipment manufactured by the recreational camping vehicle industry and lifts required to gain access out of and into this equipment. The extra width associated with this parking space is necessary to provide 3 feet of space on the driver’s side for access to utilities. The parking space is 9 feet to allow for vehicle width and an 8 foot space on the passenger side for deployment of a lift with room to exit conveniently. An exception permits one space to be 16 feet minimum in width, where only two accessible parking spaces are required. The exception allows a smaller parking pad (van size) for the second accessible campsite. This deviation will limit the impact on the environment and the user’s experience.

Section T318.2.2 addresses tent camping spaces and camp shelter spaces. Where parking is provided, a tent camping and camp shelter parking space 16 feet wide is required and follows the Architectural Barriers Act Accessibility Guidelines for van accessible parking spaces which would accommodate the maximum size vehicle used for this type of campsite. A “camp shelter” also includes cabin accommodations.

Section T318.2.3 requires recreation camping vehicle and trailer parking spaces located in general use parking areas to be 12 feet minimum wide and to have an adjacent access aisle of 8 feet extending the full length of the parking space. The surface of the parking space and access aisle must be firm and stable.

Section T318.2.4 requires that the slope of an accessible parking space not exceed 1:50 in any direction. Where surface conditions require a greater slope for proper drainage, an exception permits a 1:33 maximum slope.

Section T318.3 addresses tent pads and tent platforms. Section T318.3.1 addresses clear space. A 48 inch clear space around the tent pad is required to allow both side and front approach access to assembling equipment. An exception allows the clear space to be reduced to 36 inches where at least one of the conditions in T302 applies.

Section T318.3.2 requires the tent pad surface to be firm and stable, consistent with other provisions in Chapters T2 and T3. An exception is permitted where at least one of the four conditions specified in T302 exist.

Section T318.3.3 requires that the slope of the tent pad or platform not exceed 1:50 in any direction. An exception permits a 1:33 maximum slope where necessary for proper drainage.

Section T318.3.4 requires edge protection to be 3 inches minimum where a raised tent platform is provided. The 3 inch minimum is necessary to ensure visibility and to prevent wheelchairs and other mobility devices from rolling off the raised platform.

Section T318.3.5 addresses the connection where a tent platform is raised above grade to provide a level surface to pitch a tent. Access is provided in a similar fashion to playground equipment by a transfer system including a platform and transfer steps. The need for mobility equipment on the platform surface was not deemed to be necessary for use, as the surface area is the same size as the tent.

T319 Warming Huts

Section T319.1 requires warming huts to provide a turning space that complies with T402 and if a door is provided that it comply with T408.

T320 Outdoor Rinsing Showers

Section T320.2 addresses the requirement for clear space. A clear space which would permit a front or parallel approach is necessary in order to make the shower usable. For most elements, such as a telephone or drinking fountain, a 30 inch by 48 inch clear floor space would suffice. Committee members agreed that only providing a front approach without a 5 foot turnaround space would not allow someone in a wheelchair to turn 360 degrees to rinse off under all angles of the water. For ease and convenience of use for people using wheelchairs, the full turnaround space must be provided.

Section T320.2 also addresses the requirement for slope. The committee recommended that the slope of the clear space not exceed 1:33 in all directions. This is consistent with recommendations by the committee for other outdoor elements where drainage is a concern. Many park maintenance managers indicated that a 1:20 slope is required for the floors of outdoor showers to ensure proper drainage. The committee believed that the increase to 1:33 would suffice and allow for a reasonable tolerance.

Section T320.3 addresses the requirements for grab bars. Grab bars are typically not found in outdoor showers, primarily because the majority of the showers are free-standing poles and there is no place to mount a grab bar which conforms to the Architectural Barriers Act Accessibility Guidelines. Nonetheless, the committee believed that a grab bar was essential for stability in a wet environment, but not for transfer. The committee also recommended providing three options for the grab bar: vertical, circular (if the shower is on a pole), and horizontal, (if the shower is on a wall). If a vertical grab bar is chosen it would be permitted only on a post. The committee recommended that it be provided 33 inches above the floor, the lowest height currently for a grab bar, and extend the length of the pole within 3 inches below the shower head. If a circular grab bar is chosen it would also be permitted only on a post. This type of grab bar would resemble a spoked wheel mounted perpendicular to the post. The committee recommended that the grab bar be provided 33 to 36 inches above the floor, consistent with a horizontal grab bar in an indoor shower. If a horizontal grab bar is chosen, the committee recommended a 33 to 36 inch mounting height, consistent with the mounting height for horizontal grab bars in indoor showers.

Section T320.4 addresses the requirements for controls. In order for controls to be usable, they must be within reach ranges and be operable. The committee recommended that controls comply with T407. Many outdoor showers have a twist-type knob because those controls are less subject to vandalism. Although vandalism is a legitimate concern in outdoor settings, the committee agreed that accessible controls could be vandal-proofed, particularly if push controls are used. Therefore, the committee recommended that controls and operating mechanism comply with T407. If self-closing controls are used, the controls shall remain open for at least 10 seconds, the minimum time needed for rinsing.

Section T320.5 addresses the requirements for a low outdoor rinsing shower spray head. The appropriate height for a low rinsing shower is taken from the current requirements for indoor showers. In order to provide flexibility, rather than an absolute mounting height, the committee recommended a range of 48 to 54 inches. A hand-held shower spray unit is permitted, although the committee realized that this would be an infrequent choice in an outdoor environment due to vandalism concerns.

Section T320.6 addresses the requirement for the height of a high outdoor rinsing shower spray head. The height of the shower head must be a minimum of 72 inches above the floor or ground. A hand-held shower spray is permitted.

The committee also discussed shower seats. Indoor showers which are designated as accessible require a seat. This requirement may not be reasonable for all outdoor showers. An adjacent bench might be conveniently located for the placement of items, but not in conjunction with showering itself. With an outdoor pole shower, there is no adjacent wall on which to mount a fold-down seat. In an outdoor shower mounted to a wall, a fold-down bench would likely be vandalized. Therefore, the committee recommended that there be no requirement for a shower seat in an outdoor rinsing shower.

T321 Signs

Section T321.2 requires trails or trail segments that comply with T303 to provide a sign at the trail head and all designated access points. The sign must display a symbol designating that the trail or trail segment is accessible and shall include the total distance of the accessible trail or segment and the location of the first point where exceptions from the technical provision in T303 apply.

An example of a sign to be used at accessible trails is included in an advisory note. Signs identifying accessible trail segments must include the total distance of the accessible segment and the location of the first point of departure from the technical provisions.

Signs for trails were extensively debated by the committee. While certain trail information is critical for users, there was concern about requiring too many signs with too much information. There were also concerns that the requirement may be too onerous in terms of providing detailed information about trail characteristics. As a compromise, the committee agreed to include a requirement for a symbol to identify those trails that are accessible. Additionally, where the symbol is used to identify accessible trail segments, the total distance of the accessible trail segment to the location of the first point of departure from the technical provision must be provided.

An extensive advisory note has been provided on the issue of trail information. The advisory note includes recommendations for the types of information which should be provided and examples of different formats for providing the information. Where trails are provided and conditions have required departure from some of the technical provisions, it is recommended that more detailed signs be provided to help users make informed decisions about trail use.

Question 25: Some examples of proposed signs designating accessible trails are included in an advisory note. The committee did not reach a consensus on a particular sign. Comment is sought on these signs and other options. The proposed guidelines for trails require a sign on trails that meet the provisions and exceptions of T303.

Section T321.3 requires camping spaces that comply with T318 to be identified by the International Symbol of Accessibility complying with T412.2.

T322 Protruding Objects

Section T322.1 requires protruding objects on trails, outdoor recreation access routes, and beach access routes to comply with T405. Protruding objects on trails must have 80 inches of vertical clearance. An exception permits a reduction in the 80 inch vertical clearance provided that a barrier is provided to warn persons with visual impairments. This allows a trail to pass through narrow, winding corridors, under ledges or through caves. This provision represents a compromise reached by committee members. Some committee members saw the need for a departure from the minimum 80 inches overhead clearance, while others felt that permitting this could present barriers to people with visual impairments.

Question 26: The committee could not reach consensus on allowing a complete departure from this provision if the minimum overhead clearance could not be provided along a trail. After some debate, the committee agreed to propose the technical requirements for headroom clearance. Providing such a warning along a trail in the outdoor environment may have the effect of creating a barrier for all trail users. What other options are available on trails, specifically where there is a lack of sufficient space to move around an obstruction without significantly impacting the natural environment or setting?

Chapter T4

Chapter T4 provides supplementary technical provisions that apply where required by Chapter T3 or where referenced by a requirement in this document.