Attachment_B_ADA_Accessibility-Guide-Book.pdf

Accessibility Guidebook for Outdoor Recreation and Trails

United States Department of Agriculture

Forest Service

Technology & Development Program

2300–Recreation August 2012

1223–2806P–MTDC

In cooperation with

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Fill out the order form and submit it electronically.

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Fax: 814–239–2156

Notice

This publication was produced in cooperation with the U.S. Department of Transportation, Federal Highway Administration’s Recreational Trails Program in the interest of information exchange. The U.S. Government assumes no liability for the use of the information and does not endorse products or manufacturers.

Trademarks or manufacturers’ names and Web sites appear only because they are considered essential to the objective of this publication.

The contents of this publication reflect the views of the authors, who are responsible for the facts and accuracy of the information presented herein. The contents do not necessarily reflect the official policy of the U.S. Department of Transportation. This report does not constitute a standard, specification, or regulation.

Cover photos (counter clockwise, start with the large photo)

• Three generations enjoy a hike on the interpretive trail at Lolo Pass.

• A Forest Service employee points out a good fishing spot that an injured recreationist can reach on crutches.

• The accessible boardwalk makes it possible for these three friends to enjoy the wetlands together.

• Not all disabilities are obvious. This young girl is having fun taking photos at a meadow in the Uncompaghre Wilderness.

• Campgrounds that meet outdoor accessibility requirements, such as the Blackberry Crossing Campground, provide a great place for camping.

Photo credit: Northeast Passage, Durham, NH

Produced by:

USDA Forest Service

Missoula Technology and Development Center

5785 Hwy. 10 West

Missoula, MT 59808–9361

Phone: 406–329–3978

Fax: 406–329–3719

Email: wo_mtdc_pubs@fs.fed.us

The Forest Service, United States Department of Agriculture (USDA), has developed this information for the guidance of its employees, its contractors, and its cooperating Federal and State agencies and is not responsible for the interpretation or use of this information by anyone except its own employees. The use of trade, firm, or corporation names in this document is for the information and convenience of the reader and does not constitute an endorsement by the Department of any product or service to the exclusion of others that may be suitable.

The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of race, color, national origin, age, disability, and where applicable, sex, marital status, familial status, parental status, religion, sexual orientation, genetic information, political beliefs, reprisal, or because all or part of an individual’s income is derived from any public assistance program. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of program information (Braille, large print, audiotape, etc.) should contact USDA’s TARGET Center at (202) 720-2600 (voice and TDD). To file a complaint of discrimination, write USDA, Director, Office of Civil Rights, 1400 Independence Avenue, S.W., Washington, D.C. 20250-9410, or call (800) 795-3272 (voice) or (202) 720-6382 (TDD). USDA is an equal opportunity provider and employer.

Accessibility Guidebook for Outdoor Recreation and Trails

Janet Zeller National Accessibility Program Manager

Ruth Doyle Cibola National Forest Recreation, Engineering, Archaeology, Lands, and Minerals Staff Officer

Kathleen Snodgrass Project Leader

USDA Forest Service Technology and Development Center Missoula, MT

9E92A86 Update to the Accessibility Guidebook

August 2012 ii

Ac kn ow le dg m en ts

The authors would like to express their grateful appre-ciation for the contributions of these individuals and orga-nizations: Forest Service employees Carl R. Bauer, Nancy

Brunswick, Jasmine Budrow, Mark Conn, Donna Graham, Barth Hamberg, Maureen Hanson, Dave Hatch, Kay Hopkins, Alison Koopman, Katrina Kuchenbecker, David Kuykendall, Donna Marks, Ann May, Iran Martinez, Douglas Reeves, Jan

Spencer, Jim Steward, Ron Vance, Mike VanHorn, Brian Wil-liams, James Wyatt, and Lois Ziemann provided photographs or sketches for this version, as well as Mary Watne, MT; Axess

Outdoors, MT, <http://www.axessoutdoors.com>; Jamestown

Advanced Products Corporation, NY, <http://www.jamestown advanced.com>; Northeast Passage, NH, <http://www.nepas sage.org>; Trac About, Inc., KS, <http://www.tracabout.com>;

and Disabled Sports USA, MD, <http://www.dsusa.org>.

The authors thank the Missoula Technology and Devel-opment Center (MTDC) publications and support staff who created an attractive and easy-to-read report: Geraldine Wolf, Sunni Bradshaw, Claudia Ruple, and Amanda Determan. The authors are grateful for the informative illustrations produced by Deb Mucci.

Acknowledgments

During the revision of this document, the authors worked closely with the staff of the U.S. Access Board and would like to thank them for their cooperation. The U.S. Access

Board is an independent Federal agency devoted to accessi-bility for people with disabilities. About 30 employees and a governing board of representatives from Federal Departments and public members appointed by the President have these key responsibilities:

• Developing and maintaining accessibility requirements for the built environment, transit vehicles, telecommu-nications equipment, and electronic and information technology

• Providing technical assistance and training on these guidelines and standards

• Enforcing accessibility standards for federally funded facilities

The authors deeply appreciate the contributions of the following people who provided advice and information for this updated version:

• Christopher Douwes, Federal Highway Administration

• Bill Botten, U.S. Access Board

• Peter Jensen, Peter S. Jensen Associates, LLC

• Jaime Schmidt, Forest Service

Acknowledgments

Contents iii

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Contents

Acknowledgments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii

Introduction

The Outdoors Are for Everyone—Fundamentals of Outdoor Recreation and Trails Accessibility Why Accessibility Is Important What Terminology Should Be Used?

Providing Appropriate Information About Accessibility Legal Requirements Universal Design Program Accessibility Transition Plans Accessibility Evaluation Surveys

Applying Accessibility Guidelines to Your Site The History of Accessibility Guidelines Current Accessibility Guidelines That Apply to the Forest Service What if the Guidelines Appear To Conflict With Each Other?

Railings—Guardrails, Handrails, and Safety Trash Receptacles and Wildlife Handpumps and Water Systems Foot Travel on Trails and Roads With Restrictions

Important Tools for Accessible Recreation Built Environment Image Guide Recreation Opportunity Spectrum and Recreation Site Scale Wilderness Access Decision Tool Appalachian Trail Conservancy’s “Backcountry Sanitation Manual” Appalachian Trail Conservancy’s “Increasing Opportunities for Access on the Appalachian Trail:

A Design Guide” Accessibility Guidebook for Outfitters and Guides Operating on Public Lands Accessibility Guidebook for Ski Areas Operating on Public Lands Cooperative Publications Standard Forest Service National Trail Specifications Trail Construction and Maintenance Notebook Designing Sidewalks and Trails for Access Planning and Designing Outdoor Recreation Facilities for Horses The Facilities Toolbox Natural Resource Manager Recreation and Heritage Resources Integrated Business Systems Deferred Maintenance Construction and Maintenance Practices iv

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Designing Access Into the Outdoor Environment Terminology The Purpose of FSORAG and FSTAG

Applying the Forest Service Outdoor Recreation Accessibility Guidelines Using the Conditions for an Exception in FSORAG

Documenting Exceptions Getting From Here to There—Outdoor Recreation Access Routes

Surfaces for Outdoor Recreation Access Routes Slopes and Resting Intervals for Outdoor Recreation Access Routes Clear Tread Width and Passing Spaces for Outdoor Recreation Access Routes Tread Obstacles on Outdoor Recreation Access Routes Openings in Outdoor Recreation Access Route Surfaces Protruding Objects and Outdoor Recreation Access Routes Gates and Barriers

Providing Comforts and Conveniences—Constructed Features Reach Ranges and Operability Requirements Grab Bars

Recreation Site Layout Vehicle Parking Camping Units Picnic Units Viewing Areas Use of the International Symbol of Accessibility and Other Signs

Constructed Features in Recreation Sites Picnic Tables Fire Rings, Grills, Fireplaces, and Wood Stoves Tent Pads and Tent Platforms Benches Trash, Recycling, and Other Essential Containers Telescopes and Periscopes Utilities at Recreation Sites Water Hydrants Outdoor Rinsing Showers Utility Sinks

Buildings in Recreation Sites Camp Shelters Toilet Buildings and Pit Toilets

Getting to the Water—Beach Access Routes Exceptions to the Guidelines That Apply to Beach Access Routes Notifying the U.S. Access Board About Exemptions Surface and Clear Tread Width on Beach Access Routes Slopes and Resting Intervals for Beach Access Routes v

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Tread Obstacles on Beach Access Routes Openings in Beach Access Routes Protruding Objects on Beach Access Routes Elevated Dune Crossings Gates and Barriers on Beach Access Routes

Applying the Forest Service Trails Accessibility Guidelines Trails Are Not Outdoor Recreation Access Routes Trail Terminology Trail Construction Techniques Conditions for an Exception in FSTAG General Exceptions in FSTAG Short Hikes and Interesting Features Documenting Exceptions and Notifying the U.S. Access Board About Exemptions Technical Requirements for Accessible Hiker/Pedestrian Trails

Surfaces of Trails Clear Tread Width of Trails Trail Slopes Resting Intervals on Trails Passing Spaces on Trails Tread Obstacles on Trails Protruding Objects and Trails Openings in Trail Surfaces Trail Facilities Gates and Barriers on Trails Trailheads Trailhead Signs

Overview of FSTAG Implementation Process Step 1: Determine the Applicability of FSTAG Step 2: Identify the Presence of Limiting Factors Step 3: Apply the Accessibility Provisions Step 4: Calculate Cumulative Deviation Percentage

The FSTAG Implementation Process Flowchart

Resources Acronyms Definitions Links

Appendix: FSTAG Implementation Process Flowchart vi

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Introduction

This publication is an updated version of the original

“Accessibility Guidebook for Outdoor Recreation and Trails” (2006 edition). The original guidebook was released the same day the U.S. Department of Agricul-ture (USDA), Forest Service accessibility guidelines were finalized as the legal standard for the agency. At that time, the Outdoor Developed Areas Accessibility Guidelines

(ODAAG) under the Architectural Barriers Act were still under development by the U.S. Access Board.

Now that ODAAG has been finalized, the 2006 For-est Service Outdoor Recreation Accessibility Guidelines

(FSORAG) and Forest Service Trail Accessibility Guidelines

(FSTAG) have been revised and streamlined, incorporating the applicable sections of ODAAG. FSORAG and FSTAG look much the same as they did before revision and are still individual documents that integrate universal design, as well as agency terminology and processes. These guidelines are legally enforceable on National Forest System lands. While the guidelines are official policy only for the Forest Service, they contain useful concepts to help other agencies and orga-nizations maximize accessibility without changing the setting in outdoor recreation areas and on trails.

This guidebook was written to help designers and man-agers apply FSORAG and FSTAG to their work and to pro-vide guidance for integrating accessibility into outdoor rec-reation site and trail projects. When recreation professionals understand what is needed, accessibility becomes integrated into the thinking, planning, designing, construction, and maintenance of every project from the beginning. Accessi-bility always is more difficult and costly to implement as an afterthought. Forest Service direction is to integrate accessi-bility from the start of each project.

Continued coordination among Forest Service employ-ees and with partners is essential to successfully implement

FSORAG and FSTAG. The Forest Service is committed to incorporating FSORAG and FSTAG into National Forest

System projects and ensuring inclusive outdoor recreation opportunities.

Introduction

In tr od uc ti on

Introduction

W hy

A cc es si bi lit y Is

Im po rt an t

The Outdoors Are for Everyone— Fundamentals of Outdoor Recreation and Trails Accessibility

It’s all about people having the opportunity to enjoy the out-doors. Public lands offer a wide range of recreation settings and opportunities from highly developed campgrounds to untouched wilderness areas. Visitors may choose both the type of recreation they want to pursue and where to pursue it.

Of course, recreationists must always check to make sure that what they want to do is allowed where they want to recreate.

Why Accessibility Is Important The Forest Service is committed to integrating and maxi-mizing accessibility into the full range of recreation oppor-tunities while protecting natural resources and maintaining the character and experience of the settings so that all people have the opportunity to enjoy the great outdoors. This com-mitment is established in Forest Service policy.

How does accessibility fit into this range of opportuni-ties? We certainly don’t want to pave the wilderness. However, when the decision is made to construct or alter a building, trail, recreation site, or other facility, we must ask, “How can we design, purchase, or build it to ensure all people have an equal opportunity to use this facility?” The key is to ask this question before the facility has been designed and built or purchased.

Then we can provide facilities for use by all people.

For more information on Forest Service recreation opportunities, visit <http://www.fs.fed.us/recreation/>.

How many people benefit from accessible facilities?

At the time of the 2010 census, 54 million people (about 1 in every 5 people in the United States) had a disability that significantly limited one or more major life activities, such as walking, seeing, hearing, breathing, and thinking. Of that number, 7 percent used wheelchairs, and 2.1 percent used crutches, canes, walkers, or other assistive devices. Seventy-five percent have disabilities that are not obvious at first glance. People with disabilities constitute the largest minority in the country.

Additionally, the population of the United States is aging. By the year 2030, more than 80 million people will be 65 or older. As people age, impairments are more likely to hinder activities. If you live long enough, you are likely to join the ranks of people with disabilities.

Recreation Opportunities on National Forests and Grasslands

There are national forest and grasslands in all but six of the States and in Puerto Rico and the Virgin Islands.

• 155 national forests and grasslands

✧ 193 million acres (78.1 million hectares) to enjoy

• 439 congressionally designated wilderness areas

✧ 37.6 million acres (15.2 million hectares) in which to experience solitude and a pristine environment

• 156,000 miles (251,000 kilometers) of trails to hike

• 122 wild and scenic rivers

✧ 4,927 miles (7,929 kilometers) of beautiful water to float or fish

• 19,611 recreation sites and 23,000 recreation buildings

✧ 5,000 campgrounds in which to pitch a tent or set up a trailer or recreational vehicle

• Thousands of miles (or kilometers) of scenic byways to drive

• 172 million visits each year

The Outdoors Are for Everyone— Fundamentals of Outdoor Recreation and Trails Accessibility ha t Te rm in ol og y Sh ou ld

B e

Us ed

If anyone in a group has a disability, accessibility is an issue for the whole group (figure 1.) This influences where the group will go and what they will do together. Ski areas learned many years ago that each skier who has a disability is usually accompanied by three or four additional skiers who don’t have disabilities. They all want to buy lift tickets, rent gear, eat lunch, and ski together. Accessibility is good customer service and good for business.

Just as recreational preferences vary among the general population, people with disabilities enjoy different types of outdoor recreation. We must make sure that facilities allow all visitors to choose their own recreational activities.

Figure 1—Although the Blackberry Crossing Campground in the White Mountain National Forest is not highly developed, it’s a great place for this group of friends to enjoy camping together. Photo credit: Northeast Passage, Durham, NH

What Terminology Should Be Used?

Although people who have disabilities refer to themselves in many different ways and numerous “buzz words” have been used to describe people with disabilities over the years, direc-tion for terminology was provided in the early 1990s. The 1990

Americans with Disabilities Act (ADA) uses the phrase persons with disabilities and the word accessible. When Section 504 of the Rehabilitation Act of 1973 was renewed and amended in

1992, its terminology was corrected to include accessible and persons with disabilities. Federal agency regulations, policies, and documents have used terminology that matches ADA and the Rehabilitation Act since that time.

A disability is a medically definable condition that causes a limitation in one or more of a person’s major life activities, such as walking, seeing, hearing, speaking, breath-ing, thinking, and so forth. Person-first terminology is used because the person is more important than his or her disabil-ity. Examples include:

• A person who is blind—not “a blind person”

• A person who uses a wheelchair—not “a wheelchair-bound person” or “a wheelchair person”

A handicap is a barrier or circumstance that makes progress difficult, such as a flight of stairs that may be impassable for a person using a wheelchair or a negative attitude toward a person who has a disability. The word

“handicapped” has negative connotations and has been around for centuries, though it wasn’t used to refer to people with disabilities until the late 1800s. Many people believe

Disability Etiquette

• Use common sense and extend common courtesy to everyone.

• Don’t patronize anyone; treat adults like adults.

• Be patient. Some people need more time to express themselves or move about.

• Relax and be yourself. It’s okay to use common phrases such as “see you later” when talking with a person who is blind or has limited vision.

• Speak directly to the person and maintain eye contact, don’t speak through a companion or interpreter.

• Use person-first terminology. Don’t use words like handicapped, victim, or afflicted to describe a person who has a disability.

• Offer assistance to persons with disabilities, wait for their response, and follow their specific directions.

• Do not pet, feed, or distract service animals without first asking permission. They are working animals, not pets.

The Outdoors Are for Everyone—Fundamentals of Outdoor Recreation and Trails Accessibility

Pr ov id in g Ap pr op ria te

In fo rm at io n

Ab ou t Ac ce ss ib ili ty that “handicapped” was first used in relation to persons with disabilities when Civil War veterans (with injuries that prevented them from working) were begging on the streets with “cap in hand.” Standard references do not support this story. But because the story has become legend and begging for a living is degrading, describing people with disabilities as “handicapped” is offensive to most people with disabilities. The word “handicapped” should be eliminated from vocabulary, publications, and other materials.

Accessible facilities comply with the accessibility guide-lines and standards. A site, facility, or program is either accessible or it is not accessible. For instance, figure 2 illus-trates one type of trail that complies with accessibility guide-lines. The only way to evaluate accessibility is to evaluate the facility’s compliance with the guidelines in effect at the time it was designed, constructed, or altered. There are no shades of accessibility. For instance, a parking space complies with the standards and is accessible, or it doesn’t comply with the standards and is not accessible. The specific technical requirements of the standards for surfacing, slope, and the size of the parking space and walkway connection must be met, regardless of the conditions around the parking space.

Figure 2—Two friends enjoy a trail that complies with the guidelines and allows them to hike through the rain forest.

Other phrases concerning accessibility that are not cor-rect include: partially accessible, accessible with assistance, barrier free, ADA accessible, and handicapped accessible. A facility is either accessible or it is not accessible. If the facil-ity is not accessible, the visitor or employee needs to know which specific areas are not accessible. “Partially accessible” and “accessible with assistance” imply some accessibility problems, but don’t provide enough information to be help-ful. “Barrier free” isn’t legally defined or commonly under-stood. “ADA accessible” confuses laws with accessibility standards. “Handicapped accessible” is a common phrase, but it is offensive to many people with disabilities and should not be used. “Handicapped accessible” is also a contradiction because a handicap is a barrier and accessible means there aren’t any barriers. The best terminology is simply accessible and not accessible.

Providing Appropriate Information About Accessibility

Forest Service policy is to provide nonjudgmental infor-mation about programs and facilities so that visitors may choose the areas, activities, and facilities that best meet their interests and needs. The goal is independence, integration, and dignity for all visitors.

• When composing copy for Web sites, brochures, and other public information sources, consult with forest recreation staff or forest accessibility coordinators to ensure appropriate and accurate information is con-veyed and displayed.

• When describing a specific site or area, use the term accessible only if all facilities, constructed features, and connecting routes are in full compliance with the applicable accessibility guidelines. Accessible refers only to specific facilities, constructed features, or routes that have been constructed or altered in com-pliance with all of the requirements of the applicable accessibility guidelines. Electronic copies of these guidelines are available at <http://www.fs.fed.us/ recreation/programs/accessibility/>.

✧ Don’t use the terms “ADA,” “partially,” “barrier free,” or “handicapped.”

Le ga l R eq ui re m en ts

• Provide specific details about what people can expect to encounter. For instance, include minimum width, maximum slope, and condition of the tread surface

(is it firm and stable?) on information about trails. All information is for all users.

✧ Don’t prejudge or assume what a person can or cannot do by adding comments such as “some people may need assistance,” etc. These notes, even though well intended, are patronizing.

✧ Don’t assign accessibility-related difficulty levels to recreation opportunities, such as camping, boat-ing, fishing, hiking, etc. Individuals will deter-mine which opportunity best meets their interests and abilities after reviewing the specific informa-tion about that opportunity.

• Whenever standard outdoor recreation symbols are used on maps and other information sources, use the color blue to indicate accessible units. For instance, if the tent symbol is used to show the location of camp-grounds on an area map, the tent symbol indicating campgrounds with accessible units should be blue, but the tent symbol for campgrounds without accessible units should be a different color, such as brown. The legend for the map should include the information that blue indicates accessibility.

✧ Don’t use the international symbol of accessibil-ity on information. This symbol only should be used on signs at six legally defined facility loca-tions when they are in full compliance with the applicable accessibility guidelines: toilet, parking space, entrance if not the main entrance, loading zones, areas of refuge in a building, and route of egress out of a building. More information about use of the international symbol of accessibility is available in “Use of the International Symbol of

Accessibility and Other Signs” of this guidebook.

• On newly constructed or altered trails, whether the trail complies with the accessibility guidelines or not, include the following trail information, in addition to other information typically provided for hikers, on trailhead signs:

✧ Destination and length of the trail or trail segment

✧ Surface type

✧ Typical and minimum tread width

✧ Typical and maximum running slope

✧ Typical and maximum cross slope

✧ A statement that the posted information reflects the condition of the trail when it was constructed or assessed, including the date of the construction or assessment

Legal Requirements The Architectural Barriers Act (ABA) became law in

1968. The act <http://www.access-board.gov/the-board/laws

/architectural-barriers-act-aba> mandates that all facilities designed, built, altered, bought, rented, or leased by, for, or on behalf of a Federal agency must be accessible.

In 1973, the Rehabilitation Act became law. Section 504

<http://www.dol.gov/oasam/regs/statutes/sec504.htm> of the act applies to programs and activities that are conducted by

Federal agencies and by entities that receive funding from, or operate under a permit from, Federal agencies. Section 504 requires that these programs and activities provide an equal opportunity for individuals with disabilities to participate in an integrated setting, as independently as possible. The only exception to the requirement is when the program would be fundamentally altered if changes were made solely for the pur-pose of accessibility. An example of a fundamental alteration to a program would be allowing use of a motor vehicle in an area not designated for motorized-vehicle use.

U.S. Department of Agriculture (USDA) implementation guidance for Section 504 is Title 7 of the Code of Federal Regu-lations, Part 15 (7 CFR 15) that was finalized in 1994. Subpart

15e <http://www.access.gpo.gov/nara/cfr/waisidx_03/7cfr15e

_03.html> applies to programs conducted by the Forest Service.

Subpart 15b <http://www.access.gpo.gov/nara/cfr/waisidx_03/7 cfr15b_03.html> applies to programs operating with Federal agency funding, under special use permits, or under other agreements with the agency. If a building or structure must be entered for someone to participate in the activity at the site, the building must be accessible.

Un ive rs al

D es ig n

The Americans with Disabilities Act (ADA) became law in 1990. Except for Title V, Section 508(c), ADA <http:// www.access-board.gov/about/laws/ADA.htm> doesn’t apply to Federal agencies’ facilities and programs. Federal agen-cies were already required to be accessible under ABA and

Section 504 of the Rehabilitation Act before ADA became law. ADA applies to State and local government services, to public accommodations such as motels and hotels, and to organizations that are open to the public. Title V, Section

508(c) of ADA applies to Federal wilderness areas. It reaf-firms the 1964 Wilderness Act and clarifies that agencies aren’t required to change the character of wilderness areas to provide accessibility. Section 508(c) also defines a wheel-chair and states that wheelchairs meeting that definition may be used in Federal wilderness areas.

Universal Design The best way to integrate accessibility is to use the prin-ciples of universal design. Universal design is simply design-ing programs and facilities to be usable by all people, to the greatest extent possible, without separate or segregated access for people with disabilities (figure 3). Using universal design principles is Forest Service policy, as stated in Forest

Service Manual (FSM) 2330.3 These directives are available at <http://www.fs.fed.us/im/directives/>.

Figure 3— Friends enjoy a break during a stroll on a boardwalk through a wetlands area. A trail built on universal design principles makes it possible for a whole group to enjoy the same experience.

Since the early 1990s, the Forest Service has followed the universal design policy that all new and reconstructed facilities, programs, and associated elements are to be acces-sible to the greatest extent possible. This commitment often exceeds the minimum requirements of the Federal accessibil-ity guidelines. The result of universal design is independence, integration, and dignity for everyone.

More information on accessibility guidelines is provided in the next part of this guidebook.

Program Accessibility For the purposes of evaluating accessibility, a “program” is an activity in which people may participate. Basically, the program is the reason a person visits an area and may include opportunities such as:

• Camping in a campground

• Viewing the scenery at an overlook (figure 4)

• Swimming at a beach

• Enjoying solitude in the wilderness

• Gathering information at a visitor center

• Learning about an area on an interpretive trail

The 1994 USDA regulations—7 CFR 15e <http://www

.access.gpo.gov/nara/cfr/waisidx_03/7cfr15e_03.html> and 7

CFR 15b <http://www.access.gpo.gov/nara/cfr/waisidx

_03/7cfr15b_03.html> govern USDA implementation of

Figure 4—Interpretation is for everyone. Signs must be placed so that everyone can see and understand them.

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Section 504 of the Rehabilitation Act. They prescribe the requirements for ensuring access to programs.

If a program is provided inside a building or structure, everyone must be able to enter the facility to participate in the program. All facilities need to be constructed according to the applicable accessibility guidelines. Even historic struc-tures are required to be as accessible as can be accomplished without destroying the historic significance of the structure.

Unfortunately, some historic structures are not yet accessible, and a few cannot be made accessible without destroying their historic integrity. If a facility is not accessible, relocate the pro-gram or provide it in another manner (an alternative program).

Any alternative program must allow everyone to participate together. Separate segregated programs just for people with disabilities aren’t permitted. For example, if an evening pro-gram at a campground previously has been held in an amphi-theater that isn’t accessible, move the program to an accessible location until the amphitheater is accessible.

Under Section 504 of the Rehabilitation Act and 7 CFR

15, access to programs that don’t depend on constructed facili-ties also are required to provide equal opportunity to all. Peo-ple with disabilities may not be denied the opportunity to par-ticipate in a program if they meet the criteria to participate and their participation doesn’t fundamentally alter the program.

All participants must meet the essential eligibility criteria for the program and abide by any restrictions for that program in that area, including those of the forest land management plan.

While all people are to have an equal opportunity to participate in programs and to strive to gain the same benefits offered by those programs, no guarantee of success is required.

The laws require equal opportunity; they don’t require exceptional opportunity. For example, roads, trails, or other areas on national forests and grasslands that are not desig-nated for motorized vehicle use under a forest travel man-agement plan are closed to all motorized vehicles, including those used by people with disabilities.

Access to programs must be viewed through the lens of the entire program, not through the eyes of an individual.

Access to the program is to be provided so long as doing so doesn’t fundamentally alter the program. That is, providing access doesn’t change the primary functions of the program.

Allowing motor vehicles in a nonmotorized area would be a fundamental alteration of the recreation program for that area.

“Reasonable accommodation” does not apply to access to programs. Reasonable accommodation only applies in employment and involves making the modifications or adjust-ments to a job or the work environment so a specific qualified applicant or employee with a disability can participate in the application process or perform essential job functions. It does not apply to programs under Federal agencies, including rec-reation facilities and trails.

Questions often arise concerning the use of wheelchairs or other mobility devices in areas that restrict or prohibit mechanical devices or motorized vehicle use. As clarified in

Title V, Section 508(c), the legal definition of a wheelchair is:

A device designed solely for use by a mobility-impaired person for locomotion that is suitable for use in an indoor pedestrian area

This is a two-part definition. “Designed solely to be used by a mobility-impaired person for locomotion” means that the wheelchair was originally designed and manufactured solely to be used for mobility by a person with a disability.

The aftermarket retrofit of a motorized unit to make it usable by a person with a disability does not meet this part of the definition. The second part of the definition requires the device to be “suitable for use in an indoor pedestrian area”

(figure 5). This means usable inside a home, courthouse, or other indoor pedestrian area, such as the food court of a mall.

Figure 5—To meet the definition of a wheelchair, a device must be suitable for use in an indoor pedestrian area, such as this food court where two friends take a break from shopping. Like many wheelchairs, the device shown here also is useful for outdoor recreation, as shown in figure 11. Photo credit:

Trac About, Inc., Newton, KS og ra m

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The device must meet both parts of this definition in order for it to qualify as a wheelchair. Figures 6 through 11 show six examples of devices that meet the definition; figures 12 and 13 show two examples that do not.

A person whose disability requires use of a wheelchair or mobility device may use a wheelchair or mobility device

Figure 6

Figure 7—Photo credit: Axess Outdoors, Great Falls, MT

Figure 8

Figure 10

Figure 11—Photo credit: Trac About, Inc., Newton, KS

Figure 12

Figure 13 that meets both parts of the definition in the preceding para-graph anywhere foot travel is permitted in the National Forest

System, in accordance with Title V, Section 508(c) of ADA; 36

CFR 212.1; and FSM 2353.05 and FSM 2320.05. Wheelchairs or mobility devices, including battery-powered wheelchairs that meet both parts of the definition, aren’t categorized as motor vehicles or mechanical devices.

Figure 9

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Terminology Tip Why wheelchairs are not motor vehicles.

In Title 36 of the Code of Federal Regulations, Part 212.1, a motor vehicle is defined as any vehicle that is self-propelled, other than:

• A vehicle that is operated on rails

• Any wheelchair or mobility device, including one that is battery powered, that is designed solely for use by a mobil-ity-impaired person for locomotion, and that is suitable for use in an indoor pedestrian area

Wheelchairs that meet this legal definition may be used anywhere foot travel is allowed within the National Forest

System. Mobility devices that do not meet this definition are considered to be motor vehicles within the National For-est System and may only be used where that class of motor vehicle is allowed.

Terminology Tip

To determine whether a device meets the definition of a wheelchair, evaluate it against the two parts of the definition.

Ask yourself the following questions:

1. Was the device designed solely for mobility by a per-son with a disability?

✧ If “no,” the device doesn’t meet the definition and doesn’t qualify for use as a wheelchair.

✧ If “yes,” ask the second question.

2. Is it suitable for use in an indoor pedestrian area?

Consider whether it could be used in a mall, court-house, or similar area without the security personnel directing the user to leave.

✧ If “no,” the device doesn’t meet the definition and doesn’t qualify for use as a wheelchair.

If the answer to both questions is “yes,” the device meets the definition of a wheelchair or mobility device and may be used wherever foot travel is allowed. Some devices that don’t meet both parts of the definition (see figures 12 and 13) are useful tools for some people with disabilities to move about in the outdoor environment, but they must follow the require-ments for the appropriate class of motor vehicle. A “Motor

Vehicle Use Map” that shows routes (roads and trails) and areas designated as open to motorized travel with allowed uses identified by vehicle class is available at national forest and national grassland offices. These maps also may be available through each forest or grassland’s Web site <http://www.fs.fed

.us/> or through the National Forest Store Web site <http:// www.fs.fed.us/recreation/nationalforeststore/>. Visitors can check the “Motor Vehicle Use Map” to learn where they may use devices that don’t meet the definition.

Transition Plans Since the 1968 passage of ABA, facilities designed, built, altered, bought, rented, or leased by, for, or on behalf of a

Federal agency have been required to be accessible. Unfortu-nately, some Federal facilities are not yet accessible.

In the early 1990s, the Forest Service called for all units to complete transition plans identifying the changes needed to make each facility accessible and the timeline for complet-ing those changes. Funding to complete the transition plans was provided to the regions in 1992, 1993, and 1994.

The regulation requiring transition plans for the exist-ing facilities of all USDA agencies is 7 CFR 15e, section

150 “Program Accessibility: Existing Facilities.” It requires a transition plan to be developed and implemented for any facility housing a program that is not accessible. The regula-tion required transition plans to be completed by December

31, 1997. Section 150(d) of 7 CFR <http://www.access.gpo

.gov/nara/cfr/waisidx_03/7cfr15e_03.html> details the spe-cific requirements for transition plans and their contents.

The transition plans covering many Forest Service areas were completed up to 20 years ago. The filed hard copies have been difficult to update and cannot be effectively entered into ce ss ib ili ty

E va lu at io n

Su rv ey s the National Resource Manager database that was later devel-oped. To assure that their transition plans are current, Forest

Service units are now resurveying facilities and recreation sites and recording the results electronically so that the database will contain accurate, current information.

No standardized format was provided in the regulation for the transition plans. Each region and some national forests developed their own transition plan format. Check with your accessibility coordinator or your regional recreation accessibil-ity coordinator <http://www.fs.fed.us/eng/toolbox/acc

/documents/coord.htm#leaders> or <http://fsweb.mtdc.wo.fs

.fed.us/toolbox/acc/documents/coord.htm> (available only to

Forest Service employees) or your region/station facilities pro-gram leader <http://fsweb.wo.fs.fed.us/eng/documents/fac

_leaders.htm> (available only to Forest Service employees) to find out whether your local unit has developed a format. If not, request a sample of the formats used by other units. At a mini-mum, the transition plan must include:

• A list of obstacles to accessing the facility and pro-gram as identified in the accessibility evaluation survey

• A detailed description of the methods that will be used to provide accessibility

• The schedule for implementing the plan, including the actions that will be taken each year if the work takes more than a year

• The signature of the official responsible for imple-mentation of the transition plan

Ensure transition plans are available to the public.

Accessibility Evaluation Surveys During an accessibility evaluation survey, compare each portion of a structure to the accessibility standards, and record compliance and deficiencies. For example, check doorways to see whether they have at least 32 inches (815 millimeters) of clear width (figure 14). This information is important for developing transition plans and for providing useful information about the wide range of Forest Service facilities.

A U.S. Forest Service Accessibility Database has been developed to facilitate the gathering, retention, updating, and use of the survey information. Check with your unit’s acces-sibility coordinator or your regional recreation accessibility coordinator for more information about this database and about opportunities to have the accessibility of the recreation facilities on your unit surveyed. The Youth Conservation

Corps Inclusive Toolbox Project offers one way to have sur-veys conducted and the resulting data entered into the acces-sibility database.

Figure 14—All doorways must have a minimum of 32 inches (815 millimeters) clear width.

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Applying Accessibility Guidelines to Your Site

How did we end up with so many accessibility guide-lines and standards? Which guidelines and stan-dards apply to your site? The following information will demystify accessibility guidelines and standards.

The History of Accessibility Guidelines As explained earlier in this guidebook, accessibility laws have been enacted and updated since 1968. Here is a brief history of the guidelines for buildings, recreation facilities, and trails:

• American National Standards Institute (ANSI)— 1969 to 1980. The first accessibility guidelines used by Federal agencies under the Architectural Barriers

Act (ABA).

• General Services Administration Accessibility Guidelines—1980 to 1984. The General Services

Administration (GSA) developed its own set of guide-lines for all buildings other than those of the U.S.

Department of Housing and Urban Development, the

U.S. Department of Defense, or the U.S. Postal Ser-vice. Those agencies developed their own guidelines.

• Uniform Federal Accessibility Standards (UFAS)— 1984 to 2006. These standards updated and expanded the GSA accessibility guidelines. The standards were adopted under ABA and applied to all federally funded facilities, unless there was a higher standard of accessibility for that type of structure required by other legal standards or guidelines.

• Americans with Disabilities Act Accessibility Guidelines (ADAAG)—1991 to 2010. ADAAG explains how to apply the Americans with Disabilities

Act (ADA) of 1990 in the built environment. These guidelines apply to services provided by State and local governments, and public accommodations, such as motels and hotels.

• Americans with Disabilities Act/Architectural Bar-rier Act Accessibility Guidelines (ADA/ABAAG) of 2004. Issued by the U.S. Access Board, these guidelines were developed as a merger and update of UFAS and

ADAAG requirements. Chapters 1 and 2 contain appli-cation, administration, and scoping requirements. The

100 and 200 series apply only to those entities covered by ADA, (State and local government entities and pri-vate entities open to the public) and are NOT for Fed-eral agency use. The F100 and F200 series apply only to facilities constructed by, for, or on behalf of Federal agencies. Chapters 3 through 10 provide the technical specifications that apply to all entities, unless the State or Federal agency has its own accessibility guidelines that are an equal or higher standard.

• Architectural Barriers Act Accessibility Standards (ABAAS) of 2006. The GSA, standard-setting agency for Forest Service facilities, adopted the ABA por-tion of ADA/ABAAG as the standard for all agen-cies under its standard-setting jurisdiction. The new

ABAAS replaced UFAS.

• ADA Standards for Accessible Design (ADASAD) of 2010. The U.S. Department of Justice adopted the

ADA portion of ADA/ABAAG for use by State and local government entities and private entities open to the public. ADASAD is effective as of March 15, 2012.

• Outdoor Developed Areas Accessibility Guidelines (ODAAG) of 2012. The U.S. Access Board developed

ODAAG as a component of ADA/ABAAG. It contains accessibility guidelines for outdoor developed recre-ation areas and trails that are federally funded. Federal agencies may develop and use their own guidelines only if they are an equal or higher standard.

• Forest Service Outdoor Recreation Accessibility Guidelines (FSORAG) and Forest Service Trail Accessibility Guidelines (FSTAG), 2012 Updates.

These guidelines are an equal or higher standard than

ODAAG for outdoor recreation facilities and trails on the National Forest System. These guidelines must be used for the design, construction, alteration, purchase, or replacement of recreation sites, facilities, constructed features, and trails that meet FSTAG criteria on the

National Forest System (FSM 2330 and FSM 2350).

Applying Accessibility Guidelines to Your Site

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Current Accessibility Guidelines That Apply to the Forest Service

The Forest Service and those working with or for the

Forest Service on National Forest System land must comply with the following enforceable guidelines and standards when designing, constructing, or altering any facility or component addressed by those standards on National Forest System land.

Architectural Barriers Act Accessibility Standards

(ABAAS). Forest Service drinking fountains, toilet facilities, parking lots and spaces, cabins, and administrative buildings are among the components covered by ABAAS. The com-plete ABAAS is available at <http://www.access-board.gov

/guidelines-and-standards/buildings-and-sites/about-the-aba

-standards/aba-standards>.

Forest Service Outdoor Recreation Accessibility Guidelines

(FSORAG) and Forest Service Trail Accessibility Guidelines

(FSTAG). These guidelines must be used for the design, con-struction, alteration, purchase, or replacement of recreation sites, facilities, constructed features, and trails on the National Forest

System. The complete FSORAG and FSTAG are available at

<http://www.fs.fed.us/recreation/programs/accessibility/>.

Table 1 shows examples of different facilities that are covered by ABAAS, FSORAG, and FSTAG.

Table 1—Accessibility guidelines quick guide (which accessibility guidelines apply where).

ABAAS FSORAG

(Apply only within National Forest

System boundaries)

FSTAG

(Apply only within National Forest

System boundaries)

Buildings, Boating, and Fishing Recreation Site Features Hiker and Pedestrian Trails All buildings, including:

• Administrative offices

• Residences

• Crew quarters

• Visitor centers

• Entrance stations

• Parking lots

Building components such as:

• Restrooms with and without water

• Work stations

• Doors

• Operating controls (door handles, faucet controls, thermostats, etc.)

• Drinking fountains

Boating and fishing facilities, including:

• Boating facilities

• Docks

• Fishing piers and platforms

New or reconstructed:

• Picnic areas

• Fire rings

• Picnic tables

• Grills

• Woodstoves

• Benches

• Cooking surfaces

• Pedestal grills

• Fireplaces

• Beach access

• Outdoor recreation access routes

• Camping units (eating and cooking areas, parking spurs, tent pads)

• Campground utility connections

• Water hydrants

• Outdoor rinsing showers

• Pit toilets in remote areas

• Trash and recycling containers

• Viewing areas and overlooks

• Telescopes and periscopes

Trails that are new or altered and

• Have a Federal Trail Data Standard

(FTDS) Designed Use of Hiker/Pedestrian and

• Connect either directly to a trailhead or

• Connect directly to a trail that sub-stantially complies with FSTAG

What if the Guidelines Appear To Conflict With Each Other?

It may appear that some accessibility guidelines conflict with other guidelines or codes, or with the realities of the out-door environment. Railings must be high enough to protect visitors from a drop off, but railings that high might limit the viewing opportunity for a person using a wheelchair. Which requirement takes priority? Trash receptacles are supposed to be accessible so that everyone can use them, but then how do we keep bears out? Handpumps are vital to drawing water in campgrounds where the water system isn’t pressurized, but operating the long handle of the traditional pump requires more force and a longer reach than allowed by accessibil-ity provisions. Roads that have restrictions or closures to use by motorized vehicles may be open to foot travel, so how can a road be gated or bermed to keep out vehicles but still allow access by a person using a wheelchair? When you are faced with these types of situations, stop and think carefully about the issues. The solution always comes back to ensuring safety, abiding by the regulations, and doing so in a manner that includes the needs of all people.

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Railings—Guardrails, Handrails, and Safety Accessibility never supersedes the requirements for safety. This issue most commonly arises at overlook areas, on viewing structures, and in similar locations. For safety, the

International Building Code (IBC), <http://www.iccsafe

.org>, section 1003.2.12 contains requirements for guardrail height and the spacing of rails where there is a drop off of 30 inches or more.