The remainder of the preamble is from the report of the Regulatory Negotiation Committee.

Alterations and Maintenance

Alterations and maintenance of trails were discussed extensively by the committee. As a result of these discussions, guidance in determining when actions would be considered “maintenance” or an “alteration” was needed. Where actions are considered an alteration, certain technical provisions will apply. There are no obligations to follow any technical provisions where the actions are considered maintenance or repair.

Routine or periodic maintenance or repair of existing trails or trail segments is exempt from scoping and technical provisions for accessible trails. Maintenance and repair is performed to return a trail or trail segment back to the standards or conditions to which it was originally designed and built. In outdoor environments, the ability to maintain a facility is generally more limited, occurring relatively infrequently, except in highly developed areas. This type of work is not an alteration; it does not change the original purpose, intent, or design of the trail. The act of maintenance and repair includes, but is not limited to:

  • removal of debris and vegetation such as downed trees or broken branches in the trailway, clearing a trail of encroaching brush or grasses, and removing rock slides;
  • maintenance of the trail tread such as filling ruts and entrenchments, reshaping trail beds, repairing trail surfaces and washouts; installing rip rap (rock placed to retain cut and fill slopes), and constructing retaining walls or cribbing to support the trail tread;
  • erosion control and drainage, replacing or installing necessary drainage structures such as drainage dips, water bars, or culverts, and realigning sections of trail to deter erosion or avoid boggy or marshy areas; and
  • repair of trail or trailhead structures, including replacing deteriorated, damaged, or vandalized parts of structures such as sections of bridges, boardwalks, information kiosks, fencing, railings, and painting or removing graffiti.

Where practicable and feasible, resource managers are encouraged to maximize the opportunity to improve accessibility on trails through trail maintenance and repair activities. Every time a trail is maintained, the opportunity to improve access is present.

Question 12: The committee recognized that the distinction between alterations and maintenance activities is as critical to picnic areas, campgrounds, and beaches as it is to trails. Although the previous discussion specifically refers to trails, the examples could be extrapolated to include other outdoor elements. How should alteration and maintenance activities be defined for picnic areas, campgrounds, and beaches, including outdoor recreation access and beach access routes?

Question 13: Should there be different construction tolerances for the outdoor environment? For example, should the construction tolerances be greater with respect to trails, picnic areas, camping facilities, and beach access routes than interior accessible routes? If so, how should those tolerances be defined?

Relationship Between Use of All Terrain Vehicles (ATVs) and the Proposed Accessibility Guidelines for Trails

During the committee deliberations, some individuals expressed concern that applying the proposed accessibility guidelines to trails in the “back country” or lesser developed portions of outdoor recreation areas would make it more difficult for public land managing agencies to appropriately manage the use of all terrain vehicles (ATVs) and off highway vehicles (OHVs) in these areas. One concern was that requiring land managing agencies to consider making trails in lesser developed areas accessible according to the proposed guidelines would make it more difficult to control and restrict where these types of devices may be used.

The proposed guidelines for trails address their design, construction, and alteration in the same manner that other accessibility provisions address fixed facilities. They are similarly based on the dimensions and use patterns of those assistive devices commonly referenced throughout the Board’s guidelines. While in the outdoor environment it may be possible to encompass a wider variety of mobility enhancing equipment, the necessity of protecting the environment and maintaining the appropriateness of the setting might exclude certain devices, particularly ATVs or OHVs. That decision is reserved for the administrative agency or owner of the affected property and is beyond the scope of these guidelines.

Trails Used as Transportation Facilities (Shared Use Paths)

Many trails are used as non-motorized transportation facilities. Users may include bicyclists and skaters as well as pedestrians. These accessibility guidelines apply to these trails. However, bicyclists and skaters have design needs which exceed the minimum guidelines for trails. A trail designed only to meet the proposed accessibility guidelines for trails may not be adequate, and possibly hazardous for bicyclists or skaters.

The primary design guide for bicycle and shared use facilities is the “Guide for the Development of Bicycle Facilities” from the American Association of State Highway and Transportation Officials (AASHTO), 1999. The AASHTO Guide defines a “shared use path” as a facility on exclusive right-of-way and minimal cross flow by motor vehicles. Users generally include bicyclists, skaters, and pedestrians. (In areas with heavy snow, shared use paths may be used by cross-country skiers or snowmobilers.) A summary of how the AASHTO Guide relates to the proposed accessibility guidelines for trails is provided. In most cases, the AASHTO Guide requires a greater level of accessibility when designing trails for pedestrians, including bicyclists and skaters.

Shared use paths provide non-motorized transportation connections between neighborhoods and communities. They may be along old railroad corridors or rivers, or pass through parks. Shared use paths are usually separated from adjoining roadways or streets either by distance or a barrier, and are usually distinct from sidewalks. They generally have relatively few driveways or street crossings. A summary of how the AASHTO Guide relates to the proposed accessibility guidelines for trails is included below. Trails designed for recreational use by mountain bicyclists are not expected to meet AASHTO Guidelines.

Comparison of American Association of State Highway and Transportation Officials (AASHTO) Guidelines for Bicycle Facilities and the Proposed Guidelines for Trails

Outdoor Developed Areas Accessibility Guidelines

AASHTO Guide for the Development of Bicycle Facilities

T303.3 Surface:
Firm and stable

Bicycles need the same firmness and stability as wheelchairs; skaters usually require a smooth, paved surface. Most shared use paths are paved, although crushed aggregate surfaces are used on some paths.

T303.4 Clear Tread Width:
36 inches (3 feet; 915 mm); exception for 32 inches (815 mm)

Shared use paths usually require a minimum 3 meter (10 foot) width, plus a 0.6 meter (2 foot) safety buffer on both sides. A 2.4 m (8 foot) width may be allowed in low use facilities. Posts or bollards installed to restrict motor vehicle traffic should be spaced 1.5 m (5 feet) apart. Posts or bollards should be brightly painted and reflectorized for visibility. When more than one post is used, use an odd number, with one on the centerline to help direct opposing traffic.

T303.5 Openings (Gaps):
To prevent wheelchair wheels and cane tips from being caught in surface openings or gaps, openings in trail surfaces shall be of a size which does not permit passage of a ½ inch (13 mm) diameter sphere; elongated openings must be perpendicular or diagonal to the direction of travel; exception to permit parallel direction elongated openings if openings do not permit passage of a ¼ inch (6 mm) sphere; second exception to permit openings which do not permit passage of a ¾ inch (19 mm) sphere.

The AASHTO Guide does not specify a maximum dimension for a surface opening, but openings should be minimized. Openings should not permit a bicycle wheel to enter. Grates should be flush with the surface, and elongated openings should be perpendicular to the direction of travel (diagonal openings are more difficult for bicyclists to negotiate). Where openings are unavoidable, they should be clearly marked.

T322.1 Protruding Objects:
T405 provide a warning if vertical clearance is less than 80 inches (2030 mm)

Protruding objects should not exist within the clear tread width of a shared use path. Vertical clearance on shared use paths should be a minimum of 3 m (10 feet) or the full clear width including safety buffers. Where vertical barriers and obstructions, such as abutments, piers, and other features are unavoidable, they should be clearly marked.

T303.6 Tread Obstacles (Changes in level, roots, rocks, ruts): Up to 2 inches (50 mm); exception up to 3 inches (75 mm)

Tread obstacles are hazardous to bicyclists and skaters. The surface of a shared use path should be smooth and should not have tread obstacles.

T303.7 Passing Space:
At least 60 inches (1525 mm) width within 1,000 foot (300 m) intervals. Advisory recommends more frequent intervals for some trail segments

Shared use paths should have a minimum clear width of 3 m (10 feet); exception for 2.4 m (8 feet).

T303.8.1 Cross Slope:
1:20 (5%) maximum; exceptions for open drains up to 1:10 (10%)

For drainage, shared use paths should have a minimum 2 percent (1:50) cross slope on a paved surface. On unpaved shared use paths, particular attention should be paid to drainage to avoid erosion. Curves on shared use paths may require super elevation beyond 2% (1:50) for safety reasons. The Guide suggests limited cross slope for accessibility reasons.

T303.8.2 Running Slope:

1:20 (5%) any length
1:12 (8.33%) for up to 200 feet
1:10 (10%) for up to 30 feet
1:8 (12.5%) for up to 10 feet

No more than 30% of the total trail length shall exceed 1:12

Running slopes on shared use paths should be kept to a minimum; grades greater than 5 percent are undesirable. Grades steeper than 3 percent may not be practical for shared use paths with crushed stone or other unpaved surfaces. Where terrain dictates, grade lengths are recommended as follows:

< 5% (< 1:20) any length
5-6% (1:20-16.7) for up to 240 m (800 feet)
7% (1:14.3) for up to 120 m (400 feet)
8% (1:12.5) for up to 90 m (300 feet)
9% (1:11.1) for up to 60 m (200 feet)
10% (1:10) for up to 30 m (100 feet)
11+% (1:9.1) for up to 15 m (50 feet)

T303.9 Resting Intervals:
Size: 60 inch (1525 mm) length, at least as wide as the widest trail segment adjacent to the rest area. Less than 1:20 (5%) slope in all directions. Resting areas are required where trail running slopes exceed 1:20 (5%), at intervals no greater than the lengths permitted under running slope (see T302.6.2 above).

The Guide does not address resting intervals.

T303.10 Edge Protection:
Where provided, 3 inch (75 mm) minimum height. Handrails are not required.

The Guide does not address edge protection. Some kinds of edge protection may be hazardous to bicyclists and skaters. The Guide has minimum railing height recommendations when needed for safety reasons.

T222 Trail Signs:
Accessible trails require designation with a symbol of accessibility, and information on total length of the accessible segment.

No traffic control sign information.

Guidance on signing and marking is provided in the Manual on Uniform Traffic Control Devices (MUTCD), incorporated by reference as a Federal regulation (23 CFR 655.601). A proposed amendment for Part 9 (Traffic Controls for Bicycle Facilities) was published in the Federal Register on June 24, 1999 (64 FR 33802).

The “Guide for the Development of Bicycle Facilities” is available through the American Association of State Highway and Transportation Officials (AASHTO), 444 North Capitol Street, NW, Suite 249, Washington, DC 20001, (202) 624-5800, fax (202) 624-5806,