National Council on Public History

I work trails for the National Park Service, many of the projects I work on have entailed repairing, rebuilding or constructing trails within the park unit I work for. Following the adoption of the ABA standards addressing accessibility in outdoor recreation areas in November of 2013 I was given training and the task of addressing accessibility at the Flagstaff Area National Monuments, the park units I was working at the time. Walnut Canyon, Wupatki and Sunset Crater Volcano National Monuments are managed collectively as the Flagstaff Area National Monuments. The Monuments preserve and interpret ancestral pueblo dwellings, Ponderosa Pine and Painted Desert ecosystems and the newest cinder cone in the San Francisco Volcanic Field.

There are four general exemptions written into the ABA laws regarding entire trail exemption. Compliance isn’t practicable due to terrain, cannot be accomplished with prevailing construction practices, would fundamentally alter the function or purpose of the facility or setting and is precluded by another law. (Endangered Species Act, National Environmental Policy Act, National Historic Preservation Act, Wilderness Act, etc.) This can be a challenge in Parks in the Western States, many of the parks are located in steep terrain, in designated Wilderness or the park preserve significant archeological sites. This was the case at the Flagstaff Area National Monuments, two of the monuments preserved cultural sites and the third protected a volcanic cinder cone that produced significant lava flows as well as dunes of cinders.

Trails have a unique place in National Parks, they protect resources by isolating visitor impact to a designated location but are also the arteries into the most significant and beautiful areas in the United States. Trails really reflect how we want people to utilize the parks but also acknowledge how people will utilize the parks. If a spot is worth seeing and an established trail isn’t provided guest will make their own.  In fact, many of the oldest trails are simply improved social paths beat down by visitors following the areas exploitation or even possibly improvements on thousand year old routes used by Native Americans when the parks were their homes.

My education in ABA laws came from a week long class hosted by the National Center for Accessibility (NCA) in March of 2014. During the class we were shown numerous examples of the right and wrong way to apply ABA laws as well as a few examples of the right way but in the wrong place. Parks were actually spending money to construct short accessible trails that looped around a picnic area or paralleled a road just to be in compliance with the law. It was obvious to me that, a) no one used the trails, b) the trails didn’t provide the experience the park was established for, and c) the trails cost a lot of money to build and maintain.

I was fortunate on my return to Flagstaff that we had an accessible trail already planned and funded for the following summer, it was an improvement to an area that guest were already exploring, an overlook of the Bonito Lava Flow at Sunset Crater Volcano. The route was fairly level aside from a climb out of the parking lot and it needed a 30 foot bridge over a void in the lava flow. The trail construction was fairly basic, but with standards codified in federal law that I hadn’t been subject to before. The best resource I had in the construction was the information I received at the training hosted by the NCA and the support of my supervisors and the leadership team at the park.

During and following the completion of the trail at Sunset Crater Volcano we planned accessibility into all of our trail plans and accessed the trails we already had for improvements we could make to bring them into compliance with the law. We found that three of the four trails at Wupatki National Monument could be re-aligned or a surface could be installed to bring them into compliance and most of the major work was already done for us. Plans turned into action in the summer of 2015 when we completed resurfacing and realigning some barriers at the Citadel Pueblo and made accessible a pueblo sight for the first time at Wupatki National Monument. Two other program areas are scheduled to be brought into compliance in the coming years.

In my trade, to make an area accessible is to bring the site into compliance with the Architectural Barriers Act, (ABA), of 1968. ABA was expanded to include outdoor recreation areas in November of 2013, those standards include trails, campgrounds, picnic areas, beach access and other outdoor recreation facilities. The information I received from the NCA course is the best tool I have, other than that, the tools are basic construction tools. The best resources I have had available are Ray Bloomer from the National Center for Accessibility and Bill Botten from the Access Board. They have always taken the time to answer whatever question I may have had.

With any federal government project, public scoping and input is sought before construction begins. Quite often the local communities, affiliated tribal groups and environmental organizations are the only groups that comment on the project. If the project is a new trail that crosses a riparian area that is home to an endangered species, organizations want to see that proper mitigation is done in order for the project to be in compliance with the Endangered Species act. Compliance with ABA laws have the same weight as any other law and I have rarely seen comments addressing accessibility. Many times accessibility is already addressed in the plans or at least the designer believes they have addressed accessibility but planning and doing are two separate entities to a project. Accessibility needs to be addressed the same as all other laws.

As far as training, the trainings I have been to are usually attended by supervisor level employees of various agencies. I believe the best way to train employees is to train the employees that are doing the work and not the employees supervising the crew that is doing the work. Knowledge is lost when it is relayed and the classes I have been to do a great job of showing examples while going over the different aspects of the code. The classes also cover more than the texts of the law, they teach evaluating program areas for accessibility, give examples of products that are available and what to look for in products and also teach the spirit of the law and why we do what we do.

~ Jim Huck, National Park Service

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