Chapter 3: Trails

 

3.1 Introduction

This chapter discusses the provisions in the accessibility guidelines for outdoor developed areas that apply to the construction and alteration of trails.

3.2 Trail Projects Covered By Guidelines

The trail miles managed by the Federal land management agencies are shown in Table 3.1.[76]

Table 3.1 – Trail Miles Managed by Federal Agencies

Agency

Trail Miles

Department of Agriculture

 

Forest Service

125,000 – 155,000 Total Miles

23,000 – 30,000 Miles Designated Hiker/Pedestrian Use

Department of Interior

 

National Park Service

17,135 Total Miles

8,884 Miles Designated Hiker/Pedestrian Use

Fish and Wildlife Service

Not available

Bureau of Land Management

Not available

Bureau of Reclamation

Not available

Department of Defense

 

Army Corps of Engineers

Not available

The accessibility guidelines for outdoor developed areas cover projects involving the construction of new trails and the alteration of existing trails that are designated for pedestrian use, and that connect to a designated trailhead or an accessible trail.[77] The guidelines distinguish between “maintenance and repair” and an “alteration” with regard to existing trails.[78] Maintenance and repair are work performed to return a trail to the condition or standard to which it was originally designed or built. Examples of maintenance and repair include clearing trails of encroaching brush and grasses; filling ruts; installing drainage structures to prevent erosion of the trail tread; and constructing retaining walls to support the trail tread. An alteration is work performed to change the original purpose, intent, or design of a trail. Examples of an alteration include changing the grade, width, or tread surface of a significant portion of an existing trail. Only projects that involve an alteration of existing trails are covered by the guidelines.

The Federal land management agencies spend a small portion of their capital improvement funds on the construction or alteration of trails covered by the accessibility guidelines for outdoor developed areas. The Forest Service reported in its regulatory assessment for FSORAG and FSTAG that $35 million was spent in FY 2005 to improve 1,378 trail miles in the National Forest System, and estimated that 28 to 30 of these trail miles, or 2 percent of the total, are designated hiker/pedestrian trails and connect to a designated trail head or an accessible trail.[79]

The Access Board requested data from the other Federal land management agencies on trail projects funded in FY 2004 involving the construction or alteration of trails that are designated hiker/pedestrian trails and connect to a designated trail head or an accessible trail. The data provided by the other Federal land management agencies is presented in Table 3.2.[80]

Table 3.2 – FY 2004 Trail Projects Covered by Guidelines

Agency

Number of Projects

Total Project Costs

Department of the Interior

 

 

National Park Service

33

$2.7 million

Fish and Wildlife Service

3

$0.3 million

Bureau of Land Management

1

$25,000

Bureau of Reclamation

3

$1.2 million

Department of Defense

 

 

Army Corps of Engineers

4

$1 million

The Access Board reviewed 26 trail projects for this regulatory assessment involving the construction or alteration of trails covered by the accessibility guidelines for outdoor developed areas, as shown in Table 3.3.[81]

Table 3.3 – Trail Projects Reviewed for Regulatory Assessment

Agency

Trail Projects Reviewed

Total Project Costs

Department of Agriculture

 

 

Forest Service

4

$0.3 million

Department of Interior

 

 

National Park Service

11

$1.7 million

Fish and Wildlife Service

3

$0.3 million

Bureau of Land Management

1

$25,000

Bureau of Reclamation

3

$1.2 million

Department of Defense

 

 

Army Corps of Engineers

4

$1.0 million

Total

26

$4.5 million

3.3 Technical Provisions and Exceptions for Accessible Trails

The accessibility guidelines for outdoor developed areas contain technical provisions for accessible trails. The technical provisions are summarized in Table 3.4. There are specific exceptions to the technical provisions where compliance with a provision would result in any of the following conditions:

  • Cause substantial harm to cultural, historic, religious, or significant natural features or characteristics;
  • Substantially alter the nature of the setting or the purpose of the facility, or portion of the facility;
  • Require construction methods or materials that are prohibited by Federal, state or local law; or
  • Not be feasible due to terrain or prevailing construction practices.

A specific exception to a technical provision does not require compliance with the technical provision only where the condition for the exception exists. For example, where compliance with the technical provision for clear tread width would cause substantial harm to a significant natural feature, the trail would be required to comply with the technical provision for clear thread width before and after the significant natural feature; and the trail would have to comply with all the other technical provisions, unless specific exceptions also apply to the other technical provisions.

Table 3.4 – Technical Provisions for Accessible Trails and Specific Exceptions

Section

Technical Provision

Specific Exception

T303.3

Surface

Trail surface must be firm and stable.

Compliance not required where any condition for exceptions applies.

T303.4

Clear Tread Width

Clear tread width must be 36 inches minimum.

Clear tread width permitted to be reduced to 32 inches minimum where any condition for exceptions applies.

 

Compliance not required where 32 inches minimum clear tread width cannot be provided because any condition for exceptions applies.

T303.5

Openings

Openings in trail surfaces must not permit passage of ½ inch diameter sphere.

 

Elongated openings must be perpendicular or diagonal to dominant direction of travel.

Openings that do not permit passage of ¾ inch diameter sphere permitted where any condition for exceptions applies.

 

Compliance not required where openings that do not permit passage of ¾ inch diameter sphere cannot be provided because any condition for exceptions applies.

 

Elongated openings permitted to be parallel to dominant direction of travel if opening does not permit passage of ¼ inch sphere.

T303.6

Tread Obstacles

Tread obstacles must not exceed 2 inches high maximum.

Tread obstacles permitted to be 3 inches high maximum where running and cross slopes are 1:20 or less.

 

Compliance not required where tread obstacles greater than 3 inches high exist because any condition for exceptions applies.

T303.7

Passing Space

Passing spaces must be provided at intervals of 1000 feet maximum where clear tread width is less than 60 inches.

 

Passing spaces must be 60 inches by 60 inches minimum; or a T-shaped space within a 60 inch square minimum with arms and base 36 inches wide minimum that extend 48 inches minimum beyond the intersection.

Compliance not required where any condition for exceptions applies.

T303.8

Slopes

Cross slope must not exceed 1:20.

 

Running slope must not exceed:

1:20 for any distance

1:12 for up to 200 feet

1:10 for up to 30 feet

1:8 for up to 10 feet

 

 

Resting intervals required between each segment where running slope exceeds 1:20

 

No more than 30 percent of total trail length must exceed running slope of 1:12.

For open drainage structures, 1:7 running slope permitted for 5 feet maximum and 1:10 cross slope permitted at bottom of open drain.

 

Compliance not required where any condition for exceptions applies.

 

T303.9

Resting Intervals

Resting intervals must be 60 inches long minimum and at least as wide as the widest portion of the trail leading to the resting interval.

 

Resting interval cross slope must not exceed 1:20 in all directions.

Compliance not required where any condition for exceptions applies.

T303.10

Edge Protection

Where edge protection is provided, it must be 3 inches high minimum.

 

T321.1

Protruding Objects

Protruding objects on trails must comply with technical provisions for protruding objects.

 

Protruding objects on trails must have 80 inches high minimum vertical clearance.

Compliance not required where 80 inches high minimum vertical clearance cannot be provided because any condition for exceptions applies.  Barrier must be provided where vertical clearance is less than 80 inches high.

T322.2

Trail Signs

Signs must be placed at trailhead and designated access points identifying trails complying with technical provisions for accessible trails.

 

Where applying the specific exceptions to the technical provisions would result in any of the following conditions, a general exception exempts the trail from having to comply with any of the provisions beyond the first point where the specific exceptions apply:

  • Combination of running slope and cross slope exceeds 40 percent for over 20 feet;
  • Trail obstacle 30 inches high or more runs across the full tread width;
  • Trail surface is not firm and stable for 45 feet or more;
  • Tread width is less than 12 inches wide for a distance of 20 feet or more; or
  • Trail is not required to comply with any of the technical provisions for more than15 percent of the trail.[82]

3.4 Review of Trail Projects

The 26 trail projects that were reviewed for this regulatory assessment were requested to provide data on the projects using the form in Appendix C. The responses from the projects are summarized in Appendix D. Thirteen (13) projects constructed new trails only; 10 projects altered existing trails only; and 3 projects both constructed new trails and altered existing trails. The projects ranged in size from altering an existing 150 feet trail segment to a prominent feature, to constructing a new 6 mile trail. Approximately half the trails (12 projects) were one-half mile or less. The projects ranged in cost from a low of $12,177 plus volunteer labor to alter 1.3 miles of existing trail and construct 0.7 miles of new trail, to a high of $800,000 to construct a new trailhead and 0.5 miles of new trail. Approximately half the projects (12 projects) cost less than $100,000.

All but one project met all the technical provisions for accessible trails or applied the specific exceptions for certain technical provisions. A Bureau of Reclamation project that involved the construction of 6 miles of new trail did not meet the technical provisions for running slope and resting intervals, and did not indicate whether any conditions existed for applying specific exceptions to the technical provisions. A total of 6 projects applied the specific exceptions to the technical provisions as shown in Table 3.5, and cited one or more of the conditions for the exceptions.[83]

Table 3.5 – Specific Exceptions to Technical Provisions

Technical Provisions

Number of Projects Applying Specific Exceptions to Technical Provisions

T303.8 Running Slope

4

T303.8 Cross Slope

2

T303.9 Resting Intervals

3

T303.6 Tread Obstacles

1

T303.7 Passing Space

1

The most commonly cited condition for the exceptions (5 projects) was that compliance with the technical provision would not be feasible due to terrain or prevailing construction practices. Two projects cited the condition that compliance with the technical provision would cause substantial harm to cultural, historic, religious, or significant natural features or characteristics. One project cited the condition that compliance with the technical provision would substantially alter the nature of the setting or the purpose of the facility, or portion of the facility.

One project applied the general exception exempting a trail from all the technical provisions because the specific exceptions to the technical provisions would result in more than 15 percent of the trail not complying with any of the technical provisions.
A variety of materials were used to provide firm and stable trail surfaces. Thirteen (13) projects constructed or replaced wooden boardwalks or bridges over wet or muddy land for all or part of the trails. The other trail surface materials included native soils, crushed and compacted stone, asphalt, and concrete. Eighty-five (85) percent of the projects (22 projects) responded that, if accessibility were not required, the trails would still have been constructed with firm and stable surfaces. Fifty-four (54) percent of the projects (14 projects) responded that, if accessibility were not required, the trails would still have been constructed with 3 feet minimum clear tread width. The Federal land management agencies reported that trails that connect to a designated trailhead generally receive heavier use and are constructed with firm and stable surfaces, wider tread widths, and gentler slopes for resource protection and sustainability.

3.5 Costs

Trail design and construction costs are very site specific. The costs will vary depending on the length of the trail; the terrain or landform the trail will be traversing (e.g., elevation changes, water seeps or springs, rock croppings, protected areas); the type and number of structures needed to sustain the trail (e.g., retaining walls, bridges, drain lenses, puncheons); the tools and equipment used (e.g., hand tools, power tools, mechanized equipment); materials (e.g., native materials, imported materials); and labor resources. An accessible trail generally will cost more than a non-accessible trail. The features that will generally add costs to an accessible trail include tread width; slopes, especially if it results in lengthening the trail; and firm and stable surfaces. However, some trails are designed and constructed with wider tread ways, gentler slopes, and firm and stable surfaces for sustainability and other reasons not associated with accessibility, especially trails that connect to designated trail heads and are visited more frequently by the public. The project reviews showed that 54 percent of the trails would have been constructed with 3 feet minimum clear tread width if accessibility were not required, and that 85 percent of the trails would have been constructed with firm and stable surfaces if accessibility were not required. Thus, it is not possible to estimate specific additional costs associated with accessibility for all trail projects.

For this regulatory assessment, the Access Board used a model that assumes the number of projects funded annually by Federal land management agencies for the construction and alteration of trails that are designated for pedestrian use and that connect to a designated trailhead or another accessible trail is the same as in FY 2004. The model further assumes that the trails are one-half mile or less; that the projects cost less than $100,000; and that the additional costs associated with accessibility are approximately 20 percent or $20,000. The first two assumptions are based on the majority of projects reviewed in FY 2004, and may not be true for all future years. The last assumption is a reasonable estimate based on the fact that some projects will be constructed with wider tread ways, gentler slopes, or firm and stable surfaces for reasons not associated with accessibility, and that the conditions for applying specific exceptions to the technical provisions will not result in disproportionately higher costs.

As discussed in Chapter 1, the Access Board used two baselines for this regulatory assessment. The first baseline assesses the costs associated with the accessibility guidelines for outdoor developed areas compared to the Federal land management agencies current accessibility policies and practices. The second baseline assesses the costs associated with the guidelines if accessibility were not required by the Access Board or otherwise.

Based on the model, the additional annual costs for trail projects associated with the accessibility guidelines for outdoor developed areas compared to the Federal land management agencies current accessibility policies and practices are shown in Table 3.6 and range from $0.2 million to $0.5 million.

Table 3.6 – Additional Annual Costs for Projects Associated with Baseline 1: Guidelines Compared to Agencies' Current Accessibility Policies and Practices

Agency

Trails

Department of Agriculture

 

Forest Service

$0

Department of the Interior

 

National Park Service

$180,000  to  $340,000

Fish and Wildlife Service

$20,000 to $40,000

Bureau of Land Management

$20,000

Bureau of Reclamation

$20,000 to $40,000

Department of Defense

 

Army Corps of Engineers

$20,000 to $40,000

Total

$260,000 to $480,000

The additional annual costs for trail projects associated with the accessibility guidelines for outdoor developed areas if accessibility were not required by the Access Board or otherwise are shown in Table 2.23 and range from $0.9 million to $1.2 million.

Table 3.6 – Additional Annual Costs for Projects Associated with Baseline 2: Accessibility Not Required by Access Board or Otherwise

Agency

Camping & Picnic Areas

Department of Agriculture

 

Forest Service[84]

$157,000 to $166,000

Department of the Interior

 

National Park Service

$660,000

Fish and Wildlife Service

$60,000

Bureau of Land Management

$20,000

Bureau of Reclamation

$60,000

Department of Defense

 

Army Corps of Engineers

$80,000

Total

$1,037,000 to $1,046,000