Chapter T2: Scoping Requirements

Chapter T2 contains scoping provisions that specify which elements and spaces are required to comply with the technical requirements in Chapters T3 and T4.

T201 Application

This section provides that these guidelines apply to all newly designed and constructed trails, outdoor recreation access routes, beach access routes, and picnic and camping facilities and altered portions of existing trails that connect to an accessible trail or designated trailhead. The requirements apply to both permanent and temporary facilities. It is recognized that compliance with this section will not always result in facilities that will be accessible to all persons with disabilities. These guidelines recognize that often the natural environment will prevent full compliance with certain technical provisions.

T202 Additions and Alterations to Existing Facilities

This section requires that each addition to an existing facility comply with the requirements for new construction.

T202.3 Alterations

This section requires that where existing trails connecting to designated trailheads or accessible trails are altered, they shall comply with the requirements of Chapters T2 and T3. Committee members sought to limit the application of these guidelines where existing trails are not connected to a designated trailhead or an accessible trail. Further discussion is included under T203 Trails. The section also provides that where existing outdoor recreation access routes, beach access routes, and picnic and camping facilities are altered, each altered element or space must comply with the applicable requirements of Chapter T2. Additionally, an alteration is prohibited from decreasing or having the effect of decreasing the level of accessibility below the requirements for new construction or imposing a requirement for accessibility greater than that required for new construction.

Exception 1 addresses the circulation path to an altered element or space. Where the circulation path to the altered element or space is not altered, an outdoor recreation access route is not required.

Exception 2 addresses altered picnic and camping elements. Where picnic or camping elements are altered and the ground surface is not, the ground surface is not required to comply with provisions for clear space, surface slope, and accessible surfaces.

T203 Trails

This section requires that where trails connect to designated trailheads or accessible trails, they shall comply with T303. Where elements or spaces are provided on trails complying with T303, they shall comply with the applicable requirements of Chapter T2.

Committee members were concerned about the application of these proposed accessibility guidelines to new and altered trails connecting to portions of existing trails. They were concerned about the development of newly constructed trails connecting to an existing trail, where it was highly unlikely that the existing portion could ever be made accessible. They were specifically concerned about newly constructed and altered trails in the “middle of nowhere”. To address this concern, section T203 clarifies that the technical provisions apply only to newly designed and constructed trails, and altered portions of an existing trail that connects to an accessible trail or a designated trailhead. Where new trails connect to an existing trail that is not accessible, the technical provisions do not apply. Additionally, the technical provisions do not apply where the new or altered portion is not connected to a designated trailhead.

Section T203 also requires elements provided on trails to comply with the applicable requirements of Chapters T2 and T3. For example, if a bench is provided along a trail complying with T303, the bench must meet the applicable provisions of T313. Where elements are provided along trails, they are not required to be connected by an outdoor recreation access route.

Question 14: Where trails are not accessible, the committee could not agree on whether elements such as benches, picnic tables, or toilet rooms located on a trail should be required to be accessible. For example, an element such as a picnic table may be located on a trail too steep to be accessible. The committee considered how future and existing technology will allow assistive devices to get over more difficult terrain. The committee discussed options to minimize scoping (e.g., one of each element) requirements or limit the requirement to certain elements such as sanitary facilities. Should elements located on inaccessible trails be required to be accessible?

The committee considered many different approaches to developing accessibility guidelines for newly constructed and altered trails. Each approach balanced accessibility with the uniqueness of the outdoor environment. The following are examples of the approaches considered for trails throughout the committee’s deliberations.

Committee members evaluated each approach through extensive discussion and analysis. Within each proposal, the committee weighed the balance between accessibility and the uniqueness of the outdoor environment. Trails are often designed for a certain experience, or for the user or types of use within the setting. Primitive or back country trails for example, are usually found in remote locations or in a natural state with limited development. Throughout the discussions, committee members were concerned that providing access would change the experience or result in a significant environmental impact. Even providing accessible trails in a highly developed setting raised concerns that all trails would begin to look alike. Committee members did not want the proposed guidelines to impede the creativity of planners or designers.

As this discussion evolved, some concerns common to each approach arose regarding the potential impact on the natural environment. The committee attempted to clarify and define these concerns so that all involved could agree. The result is that section T302 defines four conditions where trail construction projects can depart from the technical provisions. This departure is allowed for the duration of the existence of the condition, or unless the condition is such that it makes it impractical to make the remainder of the trail accessible.

When designed and constructed, an accessible trail is a trail that meets the technical provisions included within these proposed guidelines. It is also considered accessible where one of the exceptions within the technical provisions is used to address a specific condition. This is limited to certain exceptions, and does not include those that allow for departure from the entire provision based on the conditions in T302.

T204 Outdoor Recreation Access Route

An outdoor recreation access route is a continuous unobstructed path designated for pedestrian use that connects accessible elements within a picnic area, camping area, or designated trailhead. Outdoor recreation access routes do not include pathways such as sidewalks, pathways in amusement parks, visitor centers, commercial theme parks, or carnivals and between buildings on college campuses already addressed by the Architectural Barriers Act Accessibility Guidelines issued in 2004.

Outdoor recreation access routes are required to connect elements required to be accessible. For example, where a cooking grill and a picnic table are provided in an accessible camp site, the outdoor recreation access route is required to connect these elements. Elements such as benches or picnic tables located along a trail, however, are not required to be connected by an outdoor recreation access route.

At least one outdoor recreation access route must connect accessible elements and spaces within the area. Five exceptions are added to this provision. Elements located on trails are not required to be connected by an outdoor recreation access route. Where multiple picnic tables, fire rings, cooking surfaces or benches are provided, at least 40 percent (of the accessible elements), but not less than two, must be located along an outdoor recreation access route. For example, if ten picnic tables are provided in a picnic area, T206.2.2 requires five tables to be accessible. Of the five tables required to be accessible, 40 percent, or two, would need to be located along an outdoor recreation access route.

In the outdoor recreation environment, the natural terrain often presents a real obstacle. Although this would not affect the accessibility of elements such as picnic tables and fire rings, it could impact getting to them. The committee realized that in many areas, it might not be possible to locate all accessible elements along an outdoor recreation access route. Rather than decreasing the number of accessible elements, the decision was made to reduce the scoping for outdoor recreation access route connections. While some committee members wanted all accessible elements to be located along an outdoor recreation access route, other committee members felt that would be unrealistic in the outdoor environment given constraints of the natural terrain. The committee finally reached consensus on requiring 40 percent of the accessible elements to be located along the outdoor recreation access route.

T205 Beach Access Routes

Section T205.2 addresses the location of beach access routes. Beach access routes shall coincide with or be located in the same area as general circulation paths.

The proposed accessibility guidelines for beaches include two scoping provisions. Section T205.2 addresses new beaches and section T205.3 addresses existing beaches. A “new beach” refers to sites where a beach is created through the importation of sand or other beach surface to create a new beach where none previously existed. The proposed guidelines treat “new beaches” differently from “existing beaches”. A beach access route is required in new construction. The committee agreed that the opportunity to provide access is greater with a newly constructed beach. The committee also considered the option of a scoping requirement based upon the volume of new beach created, but due to the difficulty in measuring a changing volume of sand, did not include that option.

Section T205.2 requires that where a new beach is constructed, a minimum of one beach access route must be provided for every one half mile of linear feet of new beach. The committee considered that one half mile was a reasonable distance between beach access routes on a new beach.

Question 15: Comment is sought on the impact of constructing a beach access route every ½ mile along a new beach. If this distance is not appropriate, other specific distances are requested.

Question 16: The committee outlined several exceptions to the application of the technical provisions for beach access routes in T305. Comment is sought about whether there are any other situations for which site infeasibility would preclude compliance with the technical provisions for a beach access route. If so, are there specific technical provisions (T305) where departures may be necessary due to site constraints?

Section T205.3 addresses beach access routes for an existing beach. Where a pedestrian route is provided from a developed site to the edge of an existing beach surface, a beach access route must be provided. This provision addresses a situation when an entity decides to construct a pedestrian route which is used by everyone to access a beach. In that situation, the action will trigger an obligation to address access for persons with disabilities. The committee did not limit the obligation to only when an entity constructs a path perpendicular to a beach edge because few such paths are developed. The committee also intended to include pedestrian sidewalks or boardwalks along the beach as “pedestrian routes” to the edge of an “existing beach.”

Question 17: The committee considered beach sites where constructed parking spaces or a parking lot is provided adjoining the beach. Should the provision of constructed parking spaces adjoining the beach, trigger a beach access route? If so, should the trigger be based on the number of parking spaces or some other measure?

The committee discussed several options and decided that the obligation to provide a beach access route over the surface of the beach would be triggered when a pedestrian access route to the edge of the beach surface is provided. The committee recognized that this would obligate an entity to extend a path further than they might have originally intended. However, the committee felt strongly that a developed path which ends at the edge of the beach surface would be of little use to a person with a disability who wishes to traverse the beach itself. They also believed that this requirement was reasonable since the provision allows the beach access route to be either temporary or permanent. Designers and operators can decide the type of route appropriate given the different environments. The committee determined that the beach route would be required to the same point appropriate for an ocean, river, lake, or reservoir.

Several exceptions are permitted for routes on existing beaches. Exception 1 permits the use of a “temporary” beach access route where one is required. The committee believed that requiring a permanent structure was far too restrictive from a design or environmental perspective. In particular, constraints of the environment may limit or preclude the construction of permanent structures. Permanent structures may also require additional permits in coastal and shoreline areas. Wave action can also cause significant erosion which can shortly turn a permanent structure into a hazard. Therefore, entities can chose to use a temporary structure for administrative and operational reasons. Vehicular access or access provided by an assistive device would not meet the technical provisions of a beach access route. While these options may enhance access to the beach for persons with disabilities, they are not considered alternatives to providing a beach access route. The committee intended that temporary beach access routes be in place during all hours where the public has access to the beach.

Exception 2 exempts routes created solely for shoreline maintenance from complying with T205. The committee recommended exempting those routes which are strictly established for shoreline maintenance personnel, particularly if accessed by a vehicle.

Exception 3 exempts routes created solely as undeveloped public easements from complying with section T205. The committee recommended an exemption if a “route” is merely an open public easement and right of way, an undeveloped space or opening created between developments where a developer leaves space open under the requirements of State or local laws for shoreline access.

Exception 4 exempts a beach access route from being required where another beach access route exists within one-half mile and is within the beach of the same jurisdiction. The committee recommended that if a beach access route already exists to the beach in close proximity, there should be no requirement to create another beach access route. The committee considered one half mile to be a reasonable distance so long as the existing beach route is served by the same beach. This is similar to the philosophy that all entrances into the same building do not have to be accessible. The one-half mile is also consistent with the requirement for scoping for a second route with construction of a new beach.

Exception 5 distinguishes beach replenishment from alterations. Nourishment is the process of replenishing a beach. While it can occur naturally with the depositing of sand from wave action, it is more commonly accomplished artificially by mechanically depositing sand on the beach. A beach may completely erode before it is artificially nourished, or it may be nourished on a periodic schedule to maintain the desired amount of beach for use or to act as a barrier for adjoining buildings and facilities. Exception 5 permits the process of beach nourishment without triggering the alteration provision. The committee did not believe that such activities should trigger any obligations for a beach access route over the surface of the beach.

Question 18: Comment is sought on whether there is a need to distinguish between certain beach nourishment projects. Should certain beach nourishment activities or projects trigger the requirements of a beach access route? If so, how should these projects be identified or defined?

Exception 6 provides an exception where the pedestrian route which is developed along the edge of an existing beach is elevated higher than 6 inches above the beach surface. This exception is intended to address those situations where a lengthy pedestrian route such as a sidewalk fronts the length of a beach and the route is elevated higher than 6 inches. The committee recognized that those areas would be drop-offs where the creation of a beach access route would require 6 feet of ramp to be constructed to meet the beach surface.

T206 Picnic Tables

Section T206.2.1 requires that where one fixed picnic table is provided in a picnic area, it must be accessible. The table must also be located along an outdoor recreation access route. This provision is included in order to ensure that a picnic area with only one table is accessible to and usable by people with disabilities. If only one table is provided, and it is not accessible, people with disabilities would not have the option of choosing another table. This provision applies only to picnic tables that are “fixed” to the ground, (i.e., permanently attached such as by a chain from the table to a concrete footing below ground).

Section T206.2.2 requires that where two or more picnic tables are provided in a picnic area, at least 50 percent, but no less than two, must be accessible.

Some committee members initially proposed 100 percent scoping, requiring all tables to be accessible. Other members considered 100 percent too high and more than what is required for the built environment. After much debate, committee members agreed that 50 percent scoping would adequately accommodate the demand for accessible tables. Committee members considered this to be realistic and feasible for most outdoor recreation providers, and would result in a higher number of accessible tables in smaller picnic areas.

The proposed scoping provision addresses picnic tables located in an “area.” An “area” refers to a designated location where picnic related elements are located. For instance, a picnic “area” is a designated location where picnic related elements are located. Areas may be separated and include different settings on the same site. For example, a picnic area located next to a lake in a park is considered a separate picnic area from a pavilion with numerous picnic tables within the same park. Picnic “areas” may also be separated and designated by a name or connected to a separate entrance road.

Section T206.3 requires accessible tables to be dispersed among the various types of picnic settings or opportunities provided. For example, a particular picnic area may offer picnic sites near the lake, in the woods, or in the open sunny portion of the area. This provision requires that the number of accessible tables be distributed throughout the area, so that people with disabilities would have a choice of picnic locations similar to what other visitors to the area have. This section would not increase the total number of accessible tables required in T206.2.

Section T206.4 addresses wheelchair spaces and requires at least one wheelchair space at an accessible picnic table. Where the table top perimeter exceeds 24 linear feet, the number of wheelchair spaces must comply with Table T206.4. More wheelchair spaces would be required where the perimeter of the table top (not including the bench) exceeded 24 linear feet. The location of the wheelchair space(s) would be left to the discretion of the designer, although an advisory note (T306.2) recommends that the wheelchair spaces be dispersed rather than clustered in one location.

Committee members discussed the issue of wheelchair spaces at length, finally basing the number of spaces on an average table dimensioned at ten-feet long by 2 and one half feet wide. Such a table has a perimeter of 25 linear feet and is designed to accommodate up to ten people. The committee decided tables of that size should provide two wheelchair spaces, while smaller tables should only require one space. Tables with a perimeter of 45 to 64 linear feet (i.e., two ten-foot long tables joined together) would require three wheelchair spaces. Tables with 65 to 84 linear feet would require four wheelchair spaces, and so on.

T207 Fire Rings

Section T207.2.1 requires that where only one fire ring is provided in an area, it must be accessible.

Section T207.2.2 requires that where two or more fire rings are provided in an area, at least 50 percent, but not less than 2, must be accessible.

Section T207.3 requires that the accessible fire rings be located throughout an area and be dispersed among the types of fire rings, if different styles or designs are provided. For example, a picnic area may provide fire rings without cooking surfaces (i.e., for camp fires only) and some with cooking surfaces. In addition, the area may offer sites nestled in the trees, some near the water, and others in open meadows. This section would require that accessible fire rings be available in both types and distributed among the different sites, affording people with disabilities the similar choice of fire ring location that is available to other visitors. This provision does not require an increase in the total number of accessible fire rings.

T208 Cooking Surfaces, Grills, and Pedestal Grills

Section T208.2.1 requires that where only one cooking surface, grill, or pedestal grill is provided in an area, it shall comply with section T308. Section T208.2.2 requires that where multiple cooking surfaces, grills, or pedestal grills are provided in an area, 50 percent, but not less than two, shall comply with T308. The rationale for this provision is consistent with picnic tables (T206), fire rings (T207) and other outdoor elements.

Section T208.3 requires accessible cooking surfaces, grills, and pedestal grills to be dispersed throughout the area and among the types provided. For example, if a picnic area offers different types of cooking surfaces, the total number of accessible cooking surfaces is to be distributed among the different types provided. This provision would not increase the number of cooking surfaces, grills, or pedestal grills required to be accessible.

T209 Trash and Recycling Containers

Section 209.1 requires each trash or recycling container to be accessible. The committee considered this to be a health issue making it imperative that each container meet the provisions for accessibility. This requirement is compatible with those for other singly occurring elements in an outdoor setting, as well as providing consistency with the Architectural Barriers Act Accessibility Guidelines. An exemption is provided where the container has one or more compartments. In this case, 50 percent of the compartments must be accessible. The committee determined that this requirement would assure the user of finding at least one accessible compartment in a multi-bin container.

T210 Wood Stoves and Fireplaces

Section T210.1 requires each wood stove and fireplace to be accessible.

T211 Overlooks and Viewing Areas

Section T211.1 requires each viewing area, where provided, on designated overlooks to be accessible.

Overlooks and viewing areas are specifically designed and constructed to provide an unobstructed observation of a vista or to a specific point of interest, such as the view to a mountain range or down into a valley or to a waterfall or geologic formation. As such, they are a destination for the user and should be accessible. An exception permits a minimum of one of each viewing opportunity for distinct points of interest where multiple viewing areas are provided.

T212 Telescopes and Periscopes

Section T212.1 requires that when telescopes or periscopes are provided, 20 percent, but never less than one, telescope or periscope must be accessible. Where only one telescope or periscope is provided, it must be usable from the seated position and also be usable from the standing position. This configuration will provide accessibility and usability.

Viewing areas or overlooks are sometimes equipped with mounted telescopes and less often with periscopes. The purpose of these elements is to provide the visitor with an even closer view of a distinct point of interest (rather than a vista).

Many existing sites only provide scopes usable from a standing position. This does not accommodate the needs of people using wheelchairs, children, or people of shorter stature. The committee made specific mention of children when discussing scopes, based on experiences of having to lift children to use scopes. Lifting may not be possible for people with back difficulty or insufficient strength.

T213 Benches

Section T213.2.1 requires that where only one bench is provided, the bench must be accessible. The committee felt that it was important that where only a single bench is provided, it must be usable by all visitors. This is generally consistent with the Architectural Barriers Act Accessibility Guidelines and with the other elements of this section. The single bench must have at least one armrest to facilitate its use.

The committee recognized that benches, when provided, are key elements in many outdoor settings, such as picnic areas or day use areas. They are used for a variety of purposes, including places of rest or relaxation, meeting spots, and places from which to view events such as sporting activities. Whatever the use, the committee determined that the bench or benches, where provided, should be accessible. However, benches that are part of an assembly area are not addressed and are not required to meet these provisions.

Section T213.2.2 requires that where multiple fixed benches are placed in an area, at least 50 percent must be accessible. This assures the visitor that there will be at least one bench available which is accessible. Further, of the benches that are required to be accessible, 50 percent must provide an armrest. The committee felt that visitors should be provided with a choice of bench configurations that will accommodate different needs. An armrest provides support when occupying the bench and assists in transfer to or from the bench.

Section T213.3 requires dispersal of accessible benches. This provision does not require an increase in the total number of accessible benches. The dispersion of accessible benches throughout an area provides for a variety of settings and is consistent with other provisions in the Architectural Barriers Act Accessibility Guidelines.

T214 Utility Sinks

A utility sink is a sink that has a vertical dimension deeper within the confines of the sink than a standard lavatory basin, and allows the user of a picnic area or campground setting to clean large pots or equipment.

Section T214.1 requires that where utility sinks are provided, at least 5 percent, but not less than one, must be accessible.

T215 Mobility Device Storage Facilities

The committee addressed the need for storage space for mobility devices primarily where an individual using a wheelchair or other mobility device must transfer to another device or vehicle in order to take advantage of the services or programs offered at the outdoor facility. A ski facility where individuals may use an adaptive ski to participate, is an example where this type of element may be provided. The committee believed that where storage facilities are provided to protect from environmental effects or theft or vandalism, at least one storage facility must comply with T315.

T216 Pit Toilets

Pit toilets are very primitive outhouses, and may consist simply of holes dug in the ground covered by a toilet riser. The riser may or may not be surrounded by walls and a roof. Pit toilets are generally located in remote, undeveloped areas, and are provided primarily for resource protection rather than visitor convenience and comfort. Pit toilets may be permanent installations, or may be moved from one location to another as the hole is filled. These provisions apply to fixed pit toilets.

Section T216.1 requires each fixed pit toilet to be accessible, since usually only one pit toilet is provided in an area. This scoping is consistent with what would be required for other individually occurring elements.

T217 Utilities

Section T217.1 requires utilities such as electric, water, sewage, and other similar types of utilities serving accessible elements or spaces to also be accessible.

T218 Camping

Section T218.2 requires camping spaces (e.g., recreational camping vehicle or trailer spaces, tent camping spaces, camping shelters, or tent pads and tent platforms), where provided, to be accessible in accordance with Table T218.2. Table T218.2 provides the number of accessible camping spaces and is based on the total number of spaces provided.

Modifications were made to the existing transient lodging scoping in the Architectural Barriers Act Accessibility Guidelines to create higher numbers of accessible camping spaces in the low range and more accessible campsites in each of the three basic camping styles. Each camping style category must achieve the proper scoping independently of the others.

The proposed scoping provisions require higher accessibility where lower numbers of features are provided. This was extensively debated among committee members and is intended to address the higher probability of utilization where low numbers of elements are provided. As an example, the chance of two picnic tables being occupied at the same time and place is much higher than five picnic tables being occupied at the same time, even though the demand may increase proportionately to the number of tables offered.

This section divides campsites into three categories: Recreational Camping Vehicle or Trailer Spaces, Tent Spaces, and Camping Shelters and Additional Campground Spaces. Campsite use requires specific equipment and a specially designed area may not be suitable for every use. For example, if someone comes prepared to use a tent, they may not be able to use a paved recreational camping vehicle site.

Section T218.2 also addresses other camping elements provided in accessible camping spaces. To ensure usability, all elements that are provided as a part of an accessible campsite must meet the applicable provisions of Chapters T2 and T3. All elements provided in accessible campsites must be accessible.

Section T218.2.1 requires recreational vehicle spaces or trailer spaces to comply with Table T218.2. An exception is included where camping spaces are designed for both tent camping and recreational camping vehicle or camping trailer use. In this case, at least 50 percent of the accessible multi-use spaces must be 20 feet wide minimum and the remainder are permitted to be reduced to 16 feet wide minimum.

Section T218.2.2 requires that where camping spaces are designed for use for tent camping and camping shelters, accessible tent and camping shelter spaces shall comply with T318.2.2, T318.2.4, and T318.3.

Section T218.3 addresses general use parking areas. Where recreational camping vehicle spaces or trailer spaces are provided, at least one must comply with T318.2.3 and T318.2.4. Accessible recreational camping vehicle spaces or trailer spaces in general parking areas are necessary to accommodate short-term parking needs. The exception separates campsite parking from general parking. This requirement provides a special recreational camping vehicle parking space in addition to the current Architectural Barriers Act Accessibility Guideline scoping for parking areas.

T219 Warming Huts

Section T219.1 requires each warming hut to have a turning space that complies with T402. Where doors are provided, they must comply with T408.

T220 Outdoor Rinsing Showers

Section T220 addresses outdoor rinsing showers. The committee recognized that provisions for shower stalls already existed. However, the provisions are clearly intended for indoor facilities. Some provisions (grab bars and a seat) may not be applicable for an outdoor shower stall or rinsing shower typically found at a beach or at camping facilities. Outdoor rinsing showers are not typically designed with walls like other showers in the built environment. Therefore, the committee recommended that specifications for an outdoor shower be developed. In order to distinguish this type of shower from those already addressed, the committee used the term “outdoor rinsing shower”. An advisory note has been added to further identify what is considered a rinsing shower.

Section T220.2 addresses the minimum number of accessible outdoor rinsing showers. The committee examined several ways to scope showers, considering a percentage formula, a chart similar to parking or telephones, and a minimum number. Because the committee ultimately recommended two types of outdoor rinsing showers, a low and high version, the committee recommended that a minimum number, one of each type, be accessible where rinsing showers are provided. If only one is provided, it must be a dual shower.

T221 Signs

Section T221.1 requires signs on accessible trails and trail segments to be designated with a symbol at the trail head or designated access points.

Section T221.2 requires signs on accessible campsites by using the International Symbol of Accessibility (ISA). Identification of accessible campsites by the ISA was determined to be necessary where campsite occupancy and site selection is made by users and is based on a first come, first served basis. To accommodate campground operations that assign sites either through a reservation service or upon arrival, the ISA is not required and an exception is provided to accommodate this distinction. It was determined that site assignment would create better utilization of accessible sites than the use of ISA signage. Signage is also not required where all sites are accessible.

T222 Protruding Objects

Section T222.1 requires protruding objects on trails, outdoor recreation access routes, and beach access routes to comply with T405 and to have 80 inches minimum clear head room.