Zion National Park Appendix A

Self-evaluation of Policies and Practices and Evaluation for 

Non-discrimination in Park Programs, Services and Activities

September 30, 2016
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Contents

Zion National Park Self-evaluation and Transition Plan........................................................ 4

Self-evaluation of Policies and Practices and Evaluation for Non-discrimination in Park 

Programs, Services and Activities................................................................................. 4

Organization of Policy Requirements, Findings and Recommendations.............................. 4

1. Section 504 Requirements, Findings and Recommendations ..................................... 5

Requirements for NPS programs (43 CFR Part 17, Subpart E):............................................... 5

1.1 §17.501 Purpose. ............................................................................................................ 5

1.2 §17.502 Application. ....................................................................................................... 5

1.3 § 17.510 Self-evaluation ................................................................................................... 5

1.4 § 17.511 Notice................................................................................................................. 6

1.5 § 17.530 General Prohibitions Against Discrimination..................................................... 7

1.6 § 17.540 Employment....................................................................................................... 9

1.7 §17.549 Program Accessibility: Discrimination prohibited........................................... 10

Zion Core Experiences......................................................................................................... 15

Zion National Park Services and Programs.......................................................................... 17

1.8 §17.550 Program Accessibility: Existing Facilities......................................................... 24

Visitor Centers and Museums............................................................................................... 25

Zion Canyon Visitor Center .................................................................................................. 26

Zion Human History Museum.............................................................................................. 31

Nature Center....................................................................................................................... 33

Kolob Canyons Visitor Center .............................................................................................. 35

Campgrounds........................................................................................................................ 39

South Campground .............................................................................................................. 40

Watchman Campground...................................................................................................... 41

Lava Point Campground ...................................................................................................... 45

Picnic Areas.......................................................................................................................... 46

Visitor Center Picnic Area.................................................................................................... 47

Grotto Picnic Area ................................................................................................................ 48

Kolob Canyons Picnic Area .................................................................................................. 50

Nature Center Picnic Area ................................................................................................... 50
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Dining and Lodging................................................................................................................ 52

Zion Lodge ............................................................................................................................ 52

Park Entrances ...................................................................................................................... 59

Entrance Signs....................................................................................................................... 59

Scenic drives and overlooks.................................................................................................. 61

Corral - Horseback Rides....................................................................................................... 63

Trails...................................................................................................................................... 64

ABAAS Excerpts for Trails and Beach Access Requirements ................................................ 66

F247 Trails............................................................................................................................. 66

F248 Beach Access Routes.................................................................................................... 66

1018 Beach Access Routes.................................................................................................... 66

Shuttle stops......................................................................................................................... 68

1.9 §17.550 (d) Transition Plan. .......................................................................................... 74

1.10 §17.551 Program accessibility: New construction and alterations. ........................... 76

1.11 §17.560 Effective Communications. ........................................................................... 77

1.12 §17.570 Compliance procedures. ............................................................................... 77

Requirements for Concessioner and Contracted programs (43 CFR Part 17, Subpart B): ... 78

2. 36 CFR Parts 1 – 7 and the Superintendents Compendium....................................... 79

2.1 36 CFR PART 1 — General Provisions (§§ 1.1 - 1.10) ................................................. 80

2.2 36 CFR PART 2 — Resource Protection, Public Use and Recreation (§§ 2.1 - 2.62) .. 81

2.3 36 CFR PART 3 — Boating and Water Use Activities (§§ 3.1 - 3.19) ......................... 86

2.4 36 CFR PART 4 — Vehicles and Traffic Safety (§§ 4.1 - 4.31).................................... 86

2.5 36 CFR PART 5 — Commercial and Private Operations (§§ 5.1 - 5.14)..................... 87

2.6 36 CFR PART 7 — Special Regulations, Areas of The National Park System (§§ 7.1 -

7.100)89

3. Federal Management Regulation (FMR).................................................................... 90

3.1 Subchapter C—Real Property, Part 102-76—Design and Construction, Subpart C—

Architectural Barriers Act...................................................................................................... 90

3.2 §102-76.70—When are the costs of alterations to provide an accessible path of 

travel to an altered area containing a primary function disproportionate to the costs of the 

overall alterations for facilities subject to the standards in §102-76.65(a)? ....................... 90
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3.3 §102-76.75—What costs are included in the costs of alterations to provide an 

accessible path of travel to an altered area containing a primary function for facilities 

subject to the standards in §102-76.65(a)?.......................................................................... 91

3.4 §102-76.80—What is required if the costs of alterations to provide an accessible 

path of travel to an altered area containing a primary function are disproportionate to the 

costs of the overall alterations for facilities subject to the standards in §102-76.65(a)?.... 92

3.5 §102-76.85—What is a primary function area for purposes of providing an 

accessible route in leased facilities subject to the standards in §102-76.65(a)? ................. 92

3.6 §102-76.90—Who has the authority to waive or modify the standards in §102-

76.65(a)? ............................................................................................................................... 92

4. Directors Order #16A Reasonable Accommodation for Applicants and Employees 

with Disabilities................................................................................................................... 93

4.1 D.O.16A— Training..................................................................................................... 93

4.2 D.O.16A— VII. Specific Duties A. Equal Opportunity Program .................................. 94

4.3 D.O.16A— VII. Specific Duties D. Supervisors............................................................ 94

4.4 D.O.16A— VII. Specific Duties E. Employees.............................................................. 95

4.5 D.O.16A— VII. Specific Duties F. Accessibility Coordinator....................................... 95

4.6 D.O.16A—VIII. Requests for Reasonable Accommodation E. Structural Access ....... 96

5. Directors Order #42 Accessibility for Visitors with Disabilities in National Park Service 

Programs and Services........................................................................................................ 97

5.1 D.O.42—VIII. Roles and Responsibilities - Superintendents...................................... 97

5.2 D.O.42—VIII. Roles and Responsibilities – Accessibility Coordinator........................ 98

6. Other NPS Accessibility Policy and Procedures.......................................................... 98

6.1 Service Animal Policy.................................................................................................. 98

6.2 Service Animal Policy §35.136 Service animals.......................................................... 99

6.3 Audio-Visual Initiative .............................................................................................. 101

6.4 NPS Complaint Process Directive ............................................................................. 101

6.5 Section 508............................................................................................................... 101

6.6 Mobility Device Policy .............................................................................................. 102

6.7 Mobility Device Policy - § 35.137 Mobility devices.................................................. 102

6.8 Emergency operations plan...................................................................................... 104

6.9 Standard Operating Procedures............................................................................... 105
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Zion National Park Self-evaluation and Transition Plan

Appendix A

Self-evaluation of Policies and Practices and Evaluation for Nondiscrimination in Park Programs, Services and Activities

A Self-evaluation is an evaluation of the entities current policies and practices, and the effects 

thereof, and identifies those that do not or may not meet the requirements of Section 504. The 

Self-evaluation identifies modifications of any such policies and practices required; and outlines 

steps the agency needs to take to make the necessary modifications. The Evaluation for Nondiscrimination in Park Programs, Services and Activities is an evaluation of programs provided 

and facilities associated with those programs to determine if the program discriminates against 

persons with a disability to meet the requirements set in Section 504:

17.549 Program accessibility: Discrimination prohibited.

Except as otherwise provided in §17.550, no qualified person with a disability shall, 

because the agency’s facilities are inaccessible to or unusable by persons with disabilities, 

be denied the benefits of, be excluded from participation in, or otherwise be subjected to 

discrimination under any program or activity conducted by the agency.

Organization of Policy Requirements, Findings and Recommendations

The organization of the requirements, findings and recommendations for this Selfevaluation and Evaluation for non-discrimination are listed by location of the policy 

information:

1. Section 504 requirements (43 CFR Part 17)

a. Requirements for NPS programs (43 CFR Part 17, Subpart E)

b. Requirements for Concessioner and Contracted programs (43 CFR Part 17, 

Subpart B)

2. 36 CFR Parts 1 – 7, Superintendents Compendium

3. Federal Management Regulation (FMR), Subpart C—Architectural Barriers Act, §102-

76.70 Disproportionate Cost, and §102-76.80 Setting Priorities for Alterations

4. Directors Order #16A Reasonable Accommodation for Applicants and Employees 

with Disabilities

5. Director's Order #42: Accessibility for Visitors with Disabilities in National Park 

Service Programs and Services
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6. Other NPS Accessibility Policy and Procedures 

1. Section 504 Requirements, Findings and Recommendations

Section 504 of the Rehabilitation Act requirements for the National Park Service are found 

in the Code of Federal Regulations (CFR) in Title 43 Public Lands: Interior, Subtitle A - Office of 

the Secretary of the Interior, Part 17 - Nondiscrimination in Federally Assisted Programs of the 

Department of the Interior. 

43 CFR Part 17, Subpart B - Nondiscrimination on the Basis of Disability (covering entities that 

receive Federal aid i.e. grantees, contractors, concessions, etc.).

43 CFR Part 17, Subpart E - Enforcement of Nondiscrimination on the Basis of Disability in 

Programs or Activities Conducted by the Department of the Interior (covering programs provided 

by government entities).

These regulations require that each park makes the programs, services and activities 

offered in the park (when viewed in their entirety) accessible to visitors and employees with 

disabilities. A Self-evaluation is required to evaluate current policy and practices and identify 

ways to make the programs, services and activities affected by these policies accessible to 

individuals with disabilities.

Requirements for NPS programs (43 CFR Part 17, Subpart E):

1.1 §17.501 Purpose.

The purpose of this part is to effectuate section 119 of the Rehabilitation, Comprehensive 

Services, and Developmental Disabilities Amendments of 1978, which amended section 504 of the 

Rehabilitation Act of 1973 to prohibit discrimination on the basis of disability in programs or 

activities conducted by Executive agencies or the U.S. Postal Service.

1.2 §17.502 Application.

This part applies to all programs and activities conducted and/or administered and/or 

maintained by the agency except for programs or activities conducted outside the United States 

that do not involve persons with disabilities in the United States.

1.3 § 17.510 Self-evaluation

Requirements:

(a) A Self-evaluation is an evaluation of the entities current policies and practices, and the 

effects thereof, and identifies those that do not or may not meet the requirements of Section 504. 

The Self-evaluation identifies modifications of any such policies and practices required; and 

outlines steps the agency needs to take to make the necessary modifications. Self-evaluations 
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need to be conducted with the assistance of interested persons, including persons with disabilities 

or organizations representing persons with disabilities.

(b) The agency shall, for at least three years following completion of the evaluation required 

under paragraph (a) of this section, maintain on file and make available for public inspection—

(1) A list of the interested persons consulted;

(2) A description of areas examined and any problems identified; and

(3) A description of any modifications made.

Findings: 

This document is the Self-evaluation for Zion National Park. It should be filed with other 

park policy documents, the superintendent’s compendium, somewhere it can be reviewed and 

updated.

Recommendations: 

This Self-evaluation (SE) will cover these requirements for the policies and practices 

reviewed. The park should continue to review all policies and practices to assure nondiscrimination.

1.4 § 17.511 Notice.

Requirements:

The agency shall make available to employees, applicants, participants, beneficiaries, and 

other interested persons such information regarding the provisions of this part and its 

applicability to the programs or activities conducted by the agency, and make such information 

available to them in such manner as the agency head finds necessary to apprise such persons of 

the protections against discrimination assured them by section 504 and this regulation.

Although no specific method is required to reach the public, notice should be provided in a 

variety of formats and by using multiple types of media, such as the Park’s website, bulletin 

boards in buildings, print, radio, social media, or television.

Findings: 

ZION’s Discrimination and Harassment policy and procedures are posted in employee areas, 

but not in visitor areas. This policy is not readily available on park websites and it is unknown if 

this statement is available through multiple types of media. 
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Recommendations:

Provide the public notice in a variety of formats and by using multiple types of media such 

as the Park’s website, bulletin boards in buildings, print, radio, social media, or television. It is 

also recommended that the notice be available through an accessibility link on the ZION

homepage. ZION’s policy of non-discrimination on the basis of disability should be readily 

apparent in the normal channels used by visitors, employees and applicants for employment.

The prescriptive regulatory requirement to provide public notice of an entity’s policy of 

nondiscrimination on the basis of disability is intentionally broad in its scope. It does not 

address the use of the internet or websites as use of the internet was not relevant Section 504 

of the Rehabilitation Act was signed. The regulatory expectation is, that whatever media or 

methods are employed, the public statements, announcements, and invitations of a public 

entity will embody the entity’s inclusion of people with disabilities and indicate the means by 

which individuals can request accommodations or other reasonable modifications to policies 

and practices. Regardless of the point of contact, whether virtual, in print, by 

telecommunication, physical access, or any method of broadcast communication, the public 

must have access to an entity’s message of inclusion. A hyperlink to this information on the 

homepage of a website is analogous to a notice posted at the front entrance of a public 

building.

Add non-discrimination policy to park website on the accessibility page and in the park 

brochures and newspapers. Add to bulletin boards in VC 

Notice example for use in the park newspaper, on bulletin boards and on website, etc.:

In accordance with the requirements of Section 504 of the Rehabilitation Act, Zion National 

Park will not discriminate against individuals with disabilities in its services, programs, or 

activities.

1.5 § 17.530 General Prohibitions Against Discrimination 

Requirements: 

§17.530 General prohibitions against discrimination. (a) No qualified person with a disability 

shall, on the basis of disability, be excluded from participation in, be denied the benefits of, or 

otherwise be subjected to discrimination under any program or activity conducted by the agency.

Section 504 prohibits a qualified individual with a disability from being excluded from 

participation in, be denied the benefits of, or otherwise be subjected to discrimination under 

any program or activity conducted by Zion National Park. The park shall administer programs or 

activities in the most integrated setting appropriate to the needs of qualified individuals with a 

disability.
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MTC design and Section 504 specialists prepare a preliminary list of park programs, services, 

and activities provided from park provided documents, park website, concessioner websites, 

and review of documents in the NPS Electronic Technical Information Center (ETIC). 

To prioritize programs found, MTC first identified:

 Park purpose and significance (from the park foundation plan, GMP, park enabling 

legislation, staff interviews, etc.)

 Park fundamental and important resources and values (from the park foundation 

plan, GMP, park enabling legislation, staff interviews, etc.)

 Park interpretive themes (from Park long range interpretive plan, park foundation 

plan, GMP, staff interviews, etc.)

 List of Park programs, activities and services

The purpose of looking at programs provided based on park significance, resources, and 

interpretive themes is to identify the core experiences, key programs, services and activities 

provided. This list is sent to the park for additions and edits. MTC and park staff (park 

management, natural and cultural resource specialists, interpretive and facility management 

division heads) meet on-site to work together to determine programs provided, and prioritize 

these programs based on:

 service need (information, food, lodging, transportation, comfort), 

 core experience programs, 

o Interpretation 

o Recreation

 programs highlighted on the park website or newspaper 

 and key programs common to all parks 

o visiting the superintendent in his/her office, 

o access to the park entrance sign photo-op,

o park maps and wayfinding, 

o Junior Ranger program, 

o Web ranger program

This team then determines if there are duplicated programs that meet all the aspects of the 

program, and determines which of these needs to be accessible.
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Findings:

MTC reviewed programs provided in the park and those highlighted on the park website. 

Many of the programs are not provided in alternative formats or are not physically accessible. 

Recommendations:

These programs and activities are described and evaluated by topic or facility in this SETP.

Physical recommended changes/solutions are included in the Transition Plan Database (TPD).

1.6 § 17.540 Employment 

Requirements:

No qualified individual with a disability may, on the basis of disability, be subjected to 

discrimination in employment under any service program, or activity conducted by the Park. The 

definitions, requirements and procedures of section 501 of the Rehabilitation Act of 1973 (29 

U.S.C. 791), as established by the Equal Employment Opportunity Commission in 29 CFR part 

1613, shall apply to employment in federally conducted programs or activities.

Findings:

The NPS Equal Opportunity/Affirmative Action Policy was evaluated. 

Recommendations:

Provide a clear definition of a “qualified individual with a disability” within the policy

(WASO), park should include detailed essential functions of a position in the written job 

description to not discriminate against an applicant or employee with a disability.

Definition of a qualified individual with a disability (ADA.gov - U.S. Department of Justice

Civil Rights Division):

A qualified individual with a disability is a person who meets legitimate skill, experience, 

education, or other requirements of an employment position that s/he holds or seeks, and who 

can perform the essential functions of the position with or without reasonable accommodation. 

Requiring the ability to perform "essential" functions assures that an individual with a disability 

will not be considered unqualified simply because of inability to perform marginal or incidental job 

functions. If the individual is qualified to perform essential job functions except for limitations 

caused by a disability, the employer must consider whether the individual could perform these 

functions with a reasonable accommodation. If a written job description has been prepared in 

advance of advertising or interviewing applicants for a job, this will be considered as evidence, 

although not conclusive evidence, of the essential functions of the job. 
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1.7 §17.549 Program Accessibility: Discrimination prohibited.

Requirements:

No qualified individual with a disability shall, because the agency's facilities are inaccessible to 

or unusable by individuals with a disability, be denied the benefits of, be excluded from 

participation in, or otherwise be subjected to discrimination under any program or activity 

conducted by the agency.

MTC design and Section 504 specialists prepared a preliminary list of Zion programs, 

services, and activities provided from the parks website, concessioner websites, and review of 

documents in the NPS Electronic Technical Information Center (ETIC).

To prioritize programs found, MTC first identified:

 Park purpose and significance (from the park foundation plan, GMP, park enabling 

legislation, staff interviews, etc.)

 Park fundamental and important resources and values (from the park foundation 

plan, GMP, park enabling legislation, staff interviews, etc.)

 Park interpretive themes (from Park long range interpretive plan, park foundation 

plan, GMP, staff interviews, etc.)

 List of Park programs, activities and services

The purpose of looking at programs provided based on park significance, resources, and 

interpretive themes is to identify the core experiences, key programs, services and activities 

provided. This list is sent to the park for additions and edits. MTC and park staff (park 

management, natural and cultural resource specialists, interpretive and facility management 

division heads) met on-site to work together to determine programs provided, and prioritized 

these programs based on:

 service need (information, food, lodging, transportation, comfort), 

 core experience programs, 

o Interpretation

o Recreation

 programs highlighted on the park website or newspaper

 and key programs common to all parks 

o visiting the superintendent in his/her office, 

o access to the park entrance sign photo-op, 

o park maps and wayfinding, 
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o Junior Ranger program, 

o Web ranger program

This team then determined if there were duplicated programs that met all the aspects of 

the program, and determined which of these needed to be accessible.

Program Background Information:

Park Purpose and Significance Statements (2013 Zion Foundation Plan):

The purpose of Zion National Park is to preserve the dramatic geology including Zion 

Canyon and a labyrinth of deep and brilliantly colored Navajo sandstone canyons formed by 

extraordinary processes of erosion at the margin of the Colorado Plateau; to safeguard the 

park’s wilderness character and its wild and scenic river values; to protect evidence of human 

history; and to provide for scientific research and the enjoyment and enlightenment of the 

public.

The following significance statements have been identified for Zion National Park. (Please 

note that the order of the statements does not reflect the level of significance.)

 Zion is a geologic showcase of brilliantly colored strata highlighted by sheer Navajo 

sandstone cliffs that are among the highest in the world and expose ancient 

remnants of the largest known sand dune system. Geologic processes continue 

today as the free-flowing Virgin River rapidly cuts into the margin of the Colorado 

Plateau, incising a multitude of deep, narrow canyons. An abundance of canyon 

springs, fed by groundwater, create hanging gardens and grottos that support 

endemic varieties of flora and fauna. These exceptional features and processes 

contribute to the outstanding scenery and scientific value of the park.

 Zion National Park’s range of topography and location at the juncture of the 

Colorado Plateau, Mojave Desert, and Great Basin ecoregions have created the 

environment for a wide variety of life forms, including rare and endemic species that 

exist only in this small geographic area. This diversity of life forms provides 

opportunities for valuable scientific research.

 The Zion Wilderness preserves the undeveloped character and natural environment 

of the spectacular network of colorful deep sandstone canyons, high forested 

plateaus, and striking rock towers, as well as opportunities for visitors to experience 

a strong sense of solitude and remoteness from civilization.

 Utah’s first designated wild and scenic rivers flow through the park carving a colorful 

labyrinth of canyons across layers of time. These rivers, fed by natural undiminished 

spring flows from the Navajo sandstone aquifers and sculpted by unimpeded 

torrents of flood waters, have an ecological value that far exceeds their spatial 

extent in the park.
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· In a canyon environment, Zion preserves human history of the Ancestral Puebloan, 

Paiute, pioneers, early 20th century tourism, and NPS development along the Virgin 

River. The remarkable integrity of these resources provides a setting ideal for future 

education and research.

· Zion National Park is a world-renowned destination that offers opportunities for a range 

of recreational and educational experiences including passive activities and high 

adventure excursions. Visitors are able to step inside the scenery and can find 

themselves surrounded by narrow cliff walls in places of extraordinary scale such as the 

Virgin River Narrows. These experiences often create profound emotional and personal 

connections for a diversity of visitors.

Park Fundamental Resources and Values (2013 Zion Foundation Plan):

Fundamental resources and values are those features, systems, processes, experiences, 

stories, scenes, sounds, smells, or other attributes determined to merit primary consideration 

during planning and management processes because they are essential to achieving the 

purpose of the park and maintaining its significance.

 Geologic Showcase. Zion’s spectacular sedimentary layers form the center of the Grand 

Staircase, the great regional sequence of cliffs and slopes linking the ancient rocks of 

Grand Canyon, through the Mesozoic layers of Zion, to the high plateaus of Bryce 

Canyon and Cedar Breaks. Zion contains the finest exposure of Navajo sandstone, in 

places exceeding 2,000 feet in thickness, a remnant of the largest sand dune system 

known to have existed on the planet. In addition to the dramatic high cliffs, the park 

displays a landscape modified by recent volcanism and an exceptionally rapid rate of 

erosion. These natural processes have produced large landslides, inverted valleys, deep 

slot canyons, hanging valleys, and have exposed significant paleontological resources.

 Water Shapes the Landscape. The park’s many free- flowing rivers carry powerful flash 

floods and tremendous sediment loads, which act together as the primary agents of 

erosion. These rivers continue to carve into the edge of the Colorado Plateau, shaping 

Zion’s dramatic scenery. By virtue of rivers cutting through the water-bearing Navajo 

sandstone, numerous canyon springs, fed by groundwater, create hanging gardens and 

seeping alcoves that form moist oases in a desert environment and sustain perennial 

river flows.

 Convergence of Ecoregions. The convergence of the Colorado Plateau, Mojave Desert, 

and Great Basin ecoregions combined with the vertical relief and high concentration of 

canyons has provided a diversity of habitats for the array of life forms found in Zion 

National Park, including rare, endangered, and endemic species.

 Natural Resource Quality and Function. The quality of air, water, vegetation, and 

wildlife resources in Zion National Park are generally preserved, in some cases by 
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allowing natural processes and natural disturbance regimes (such as fires, floods, and 

rockfalls) to exist, thereby promoting an environment predominated by natural 

processes. Wildland fire, in particular, provides the natural disturbance regime that 

maintains many of the park’s ecosystems and is critical to maintaining wilderness 

character and associated natural resource values.

 Wilderness Character. Eighty-four percent of Zion is designated wilderness, managed 

with restraint and humility to protect the natural character of the landscape. The vast 

majority of this wilderness is entirely undeveloped with no trails, campsites, or 

structures. Even in a park with millions of visitors each year one can explore and 

experience the sights and sounds of solitude.

 Wild and Scenic Rivers. Zion’s wild and scenic rivers provide for a wide range of river 

values and are composed of more than 140 miles of free-flowing, largely undeveloped 

water courses that provide habitat for six native fish species. In recent geologic time, the 

rivers have sliced though rock layers’ thousands of feet thick. The carved canyons 

provide habitat for the threatened Mexican spotted owl and cool canyon microclimates 

are home to hanging gardens where the endemic Zion snail resides.

Other Important Resources and Values:

 An Engineered Way of Life. The Zion Lodge / Birch Creek Historic District represents 

early economic development and tourism inside the Grand Circle and Southern 

Utah. Residences and maintenance buildings in the Oak Creek and Pine Creek 

historic districts are intricate pieces of early NPS history representing naturalistic / 

NPS-rustic construction. The Zion-Mt. Carmel Highway and tunnel represent the 

determination, innovation, and engineering feats of the early 20th century. Other 

roads, trails, ditches, bridges, cabins, and remnants of sawmills and homesteads 

showcase early pioneering efforts inside Zion National Park and NPS efforts to 

develop facilities for visitor access and accommodation. Parunuweap Canyon 

contains prehistoric, intact, and valuable cultural resources that provide a valuable 

insight to prehistoric ways of life. Zion preserves and studies these diverse cultures 

and their engineered ways of life in the desert environment.

 The Remnants of Humanity’s Past. The cultural resources in Zion National Park 

encompass a continuum of human experience of both native and nonnative people. 

The nationally significant Parunuweap Canyon Archeological District contains “type” 

sites through which the Virgin Branch of the Anasazi were initially recognized as a 

distinctive regional manifestation of Ancestral Puebloan culture. For contemporary 

people, including American Indians and European American descendants of 

pioneers, many of the park’s cultural sites, objects, landscapes, and natural 
14

resources remain important touchstones that contribute to group identity and 

heritage.

 Opportunities for Connection to the Resources. Zion National Park provides its 

visitors a wide range of high- quality recreational experiences through exceptional 

infrastructure and services, educational opportunities, and resources of high 

integrity. Zion National Park interprets park resource meanings, research, and 

management initiatives to encourage inspiration, learning, and stewardship.

 Preserving and Studying the Natural and Cultural History of Zion. Museum and 

archival collections record Zion’s natural and cultural history. Park collections 

illuminate the stories of American Indians, pioneers, NPS history, and the park’s 

complex natural environment—documenting a long and highly active history of 

scientific study and scholarly research. The collection also demonstrates the ongoing 

importance of continued scientific study to develop and implement best 

management practices.

Interpretive Themes (2013 Zion Foundation Plan):

Interpretive themes are often described as the key stories or concepts that visitors should 

understand after visiting a park—they define the most important ideas or concepts 

communicated to visitors about a park unit. Themes are derived from, and should reflect, park 

purpose, significance, resources, and values. The set of interpretive themes is complete when it 

provides the structure necessary for park staff to develop opportunities for visitors to explore 

and relate to all of the park significances and fundamental resources and values.

 The geologic features of Zion National Park, including the premier exposure of Navajo 

sandstone, the brilliantly colored rock layers, and Zion’s place in the Grand Staircase, are 

both scientifically significant and allow us to immerse ourselves within their immense 

scope of size and time.

 The wild and scenic Virgin River and its tributaries are the lifeblood of Zion National 

Park, continuing to carve with powerful force as they drop uncontrolled through the 

landscape, to reveal Zion’s geologic history, shape majestic canyons, and provide a 

unique watery oasis amidst the arid land.

 Located at the convergence of three ecoregions, Zion National Park contains a richness 

and diversity of flora and fauna that belies the park’s extreme topography and arid 

conditions. 

 The undeveloped vast high plateaus and intimate sandstone canyons of Zion National 

Park and its designated wilderness provide unparalleled opportunities for a limited 

number of visitors to experience solitude, adventure, inspiration, and introspection in a 
15

natural environment, while creating a backdrop for all to appreciate the importance of 

protecting wild places. 

 Zion National Park is the setting for a legacy of generations of people, all of whom lived 

their lives deeply connected to this landscape.

Zion Core Experiences

MTC met with the park management team to review the Park Purpose and Significance 

Statements, Park Fundamental Resources and Values, and Park Interpretive Themes to add new 

values and determine Zion Core Experiences:

Zion Core Experiences

 Understand the geologic features of Zion National Park, including

o premier exposure of Navajo sandstone 

o brilliantly colored rock layers 

o Zion’s place in the Grand Staircase

 Understand how water helped to form Zion National Park, including

o The wild and scenic Virgin River and its tributaries

o continuing to carve with powerful force 

o provide a unique watery oasis amidst the arid land.

 Understand the flora and fauna of Zion National Park

o convergence of three ecoregions

o rich and diverse

o extreme topography and arid conditions

 Understand the importance of wilderness areas in Zion National Park 

o provide unparalleled opportunities for a limited number of visitors to 

experience solitude, adventure, inspiration, and introspection in a natural 

environment

o creating a backdrop for all to appreciate the importance of protecting wild 

places

 Understand that Zion National Park is a wild and dangerous place

o Heavy rainstorms and instant, powerful flash floods

o Dangerous sandstone cliffs

o Dry, arid conditions cause rapid dehydration

o Animals encountered are wild and unpredictable

 Understand the cultural history of Zion National Park

o Native Americans

o Pioneers

o NPS history 

 Zion Lodge / Birch Creek Historic District 

 The Zion-Mt. Carmel Highway and tunnel
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 Zion National Park is a place for recreation

o Camping/Picnicking

o Hiking/Backpacking

o Birding

o Canyoneering/Climbing

o Ranger-led activities

o River trips 

o Photography

o Scenic drives and overlooks

o Bicycling

o Horseback riding
17

Zion National Park Services and Programs

 Visitor Services

o Information

 Website

 Accessibility information

 All accessible programs identified

 Wifi

 Visitor Center

 Information Desk

 Alternative formats

 Knowledgeable staff – knows accessible programs, assistive

devices available and use, can assist visitors with disabilities

 Wayfinding

 Maps

o Accessible facilities and programs identified

 Waysides

 Guest services

o Food

 Red Rock Grill Dining Room at Zion Lodge

 Elevator access

 Castle Dome Cafe at Zion Lodge

 Picnic areas

 Zion VC

 Grotto

 Nature Center

 Lava Point

 Kolob Canyons

o Lodging

 Zion lodge

 Motel rooms

 Cabins

 Suites

 Camping

 Reservation - Watchman

o RV back-in, electric

o RV pull-through, electric

o River view sites, electric

o Tent sites, electric and non-electric

o Group camping

 First come, first served camping - South
18

o RV back-in

o RV pull-through

o River view sites

o Tent sites

o Group camping

 Primitive – Lava Point

 Backcountry – Hop Valley

 Campground host sites – South and Watchman

o Transportation

 Maps and wayfinding

 Park shuttles

 Size and weight limitations on wheelchairs

 Narration script available

 Open air tram

 Private Vehicle

 Accessible drop-offs

 Accessible parking

 Special Permit

o Lodge

o Special needs

o Backcountry access

 Comfort

 Restrooms

o Baby changing stations

o Restroom amenities

 Companion care restrooms

 Other services

o Mail drop at VC and Zion Lodge

o Gift Shops

o Bookstores

o Business Center at the Lodge

 Core Experience - Interpretation

o Geology - Understand the geologic features of Zion National Park; including 

premier exposure of Navajo sandstone, brilliantly colored rock layers, and Zion’s 

place in the Grand Staircase

 Trails

 Nature Center, ZCFI

 Exhibits 

 Waysides

 Films, multi-media, social media, shuttle audio program

 Ranger led Programs, formal, shuttle tour, and drop-ins

 Junior Ranger Program
19

 Website, park brochure, park newspaper

o Water - Understand how water helped to form Zion National Park; including the 

wild and scenic Virgin River and its tributaries, continuing to carve with 

powerful force, and provide a unique watery oasis amidst the arid land.

 Trails

 Nature Center, ZCFI

 Exhibits 

 Waysides

 Films, multi-media, social media, shuttle audio program

 Ranger led Programs, formal, shuttle tour, and drop-ins

 Junior Ranger Program

 Website, park brochure, park newspaper

o Flora and Fauna (F&F) - Understand the flora and fauna of Zion National Park; 

convergence of three ecoregions, rich and diverse, extreme topography and arid 

conditions

 Trails

 Nature Center, ZCFI

 Exhibits

 Waysides

 Films, multi-media, social media, shuttle audio program

 Ranger led Programs, formal, shuttle tour, and drop-ins

 Junior Ranger Program

 Website, park brochure, park newspaper

o Understand that Zion National Park is a wild and dangerous place

 Trail exhibits and waysides

 Website, park brochure, park newspaper

 Ranger led Programs, formal, shuttle tour, and drop-ins

 Nature Center, ZCFI

 Junior Ranger Program

 Films, multi-media, shuttle audio program

o History - Understand the cultural history of Zion National Park, Native 

Americans, Pioneers, and NPS history 

 Zion Lodge / Birch Creek Historic District 

 The Zion-Mt. Carmel Highway and tunnel

 Zion Human History Museum

 Exhibits

 Waysides

 Films, multi-media, social media, shuttle audio program

 Written guide and app

 Ranger led Programs, formal, shuttle tour, and drop-ins

 Junior Ranger Program

 Nature Center

 Website, park brochure, park newspaper
20

o Web Ranger program

o Web education programs

 Core Experience – Recreation

o Camping/Picnicking

o Hiking/Backpacking

o Scenic walks

o Birding

o Canyoneering/Climbing

o Ranger-led activities

o River- water play, water access, Narrows hike

o Photography

o Scenic drives and overlooks

o Bicycling

o Horseback riding

o Shuttle ride

 Key programs common to all parks 

o visiting the superintendent in his/her office 

o access to the park entrance sign photo-op 

o park maps and wayfinding 

o Junior Ranger program 

o Web ranger program

 Special Programs

o Artist in Residence, Grotto

o Zion Canyon Field Institute (ZCFI) programs

Findings: 

 This section is used to define and prioritize the programs, services and activities 

provided at Zion National Park. The Foundation Plan lays out many planning needs

and data collection needs for the park, included in the tables below. Most of these 

plans will impact how visitors with disabilities will experience park resources,

however, the notes column in the table does not address accessibility or nondiscrimination. Only one item in the table includes any accessibility needs: Park 

operations and facilities data needs states: data collection would focus on 

information to enhance visitor safety and accessibility. It is crucial to include an 

accessibility component in these plans to avoid discriminating against visitors and 

employees with disabilities. The plans and data needs highlighted in blue should 

include an accessibility/nondiscrimination component:
21

Planning Needs – Where A Decision-making Process Is Needed 

FRV – fundamental resources and values, OIRV - other important resources and values

Related to an 

FRV or OIRV? 

Planning Need Priority (High, 

Medium, Low) 

Notes 

FRV Visitor use 

management 

plan 

High The plan would address visitor use levels and patterns in key areas 

of the park, including Zion Canyon. It would establish a proactive 

process for managing characteristics of visitor use, the physical and 

social setting, and would establish a variety of strategies and tools 

to sustain desired resources conditions and visitor experiences.

Visitor use characteristics could include the amount, type, timing, 

and distribution of visitor use, and visitor activities and behaviors.

FRV Virgin River 

restoration 

strategy 

High The strategy would address site planning, design, and compliance 

for the removal of levees and other bank stabilizations that impede 

natural river processes along the North Fork Virgin River.

FRV Zion Canyon 

transportation 

plan 

High The plan would address multimodal transportation options and 

consider trail linkages between shuttle stops to improve visitor 

opportunities.

OIRV Cultural resource 

sites 

management 

plan 

High The plan would address the protection and management of select 

cultural sites, including petroglyphs and pictographs.

FRV Commercial 

services plan 

High The plan would help the park determine which commercial services 

are necessary and appropriate in the developed areas of the park 

and how they should be managed.

FRV Comprehensive 

sustainability 

strategy 

High The plan would include a sustainable fuels and fleet operations 

plan and an integrated solid waste management plan.

OIRV Historic 

structures reports 

High The historic structure reports would include inventory of historic 

structures, important character-defining architectural features, use 

history, detailed current condition data, threats, cyclic maintenance 

requirements, and preservation treatments.

FRV South entrance 

reconfiguration 

plan 

High The plan would develop a strategy for reconfiguring the south 

entrance (including campgrounds) to improve vehicle flow and 

wayfinding.

FRV Scientific 

research strategy 

Medium The strategy would identify important scientific research needed to 

better understand and manage the park’s fundamental resources 

and values.

FRV Fire management 

plan update 

Medium The plan would be updated with current information and 

management strategies. This periodic comprehensive review is a 

requirement.

FRV Trail 

management 

plan 

Medium The plan would include a trail inventory, new trail needs and 

locations, maintenance needs, and strategies to accomplish 

maintenance.

OIRV Cultural 

landscape report 

Medium The plan would identify cultural landscapes in the park and how 

they should be protected and managed.

FRV Climate change 

plan

Medium The plan would include climate change scenario planning and an 

adaptation strategy. Cultural and natural resource condition 

assessments and climate change vulnerability assessments would 

be completed as part of the plan.
22

FRV Education plan Medium This plan would identify the messages that park management 

wants to communicate to the on-site and 

who that public is, and determine how bes

audience.

FRV Resource 

stewardship 

strategy

Medium The plan would identify all of the cultural a

the park, would identify current conditions

and would outline management strategies 

V / OIRV Collections 

management 

plan

Medium The plan would address how to protect an

museum collections.

off-site public, identify 

t to inform the target 

nd natural resources in 

, and trends if possible, 

to protect resources.

FR d manage the park’s 

Data Needs – Where Information Is Needed Before Decisions Can Be Made 

Related to an 

FRV or OIRV? 

Data Need Priority (High, 

Medium, Low) 

Notes 

FRV Visitor use data High Visitor use data would provide a better understanding of visitor 

preferences, visitor dispersal in the canyon as linked to shuttle bus 

ridership, and a better understanding of pedestrian use, vehicle use, 

necessary visitor services, and visitor-caused impacts to resources, 

facilities, and the experiential setting. The data would include 

information from the University of Idaho Visitor Services Project.

FRV Visitor impacts 

on park 

resources 

High The effort would include gathering resource data from popular 

visitor locations, analyzing the data to determine the condition and 

trends, then identifying management strategies to improve 

conditions if needed.

FRV Water quality High The data would include the continued collection of water quality 

parameters at existing monitoring sites and additional monitoring at 

new sites where there are threatened waters or where basic 

information is lacking.

FRV Park operations 

and facilities 

High Data collection would focus on information to enhance visitor safety 

and accessibility.

FRV Night skies High Updated data would include Zion-specific night sky data, trends, and 

management strategies to improve viewing of night skies.

FRV Visual resource 

assessment 

High In order to protect and enhance wild and scenic values, complete a 

visual resource assessment for river segments with outstandingly 

remarkable scenic values.

FRV Paleontology High The data would include inventory, monitoring, and management 

strategies to protect these resources.

A key component in communicating the interpretive core experiences to all visitors, 

including those with disabilities are the Interpretive ranger programs observed throughout the 

park at formal programs, shuttle tours, and the informal tactile, interactive, drop-in programs 

at many locations in the park. These programs are very effective in communicating the 

important stories of this park.
23

Recommendations:

The park planning needs identified in the Foundation Plan should include an accessibility 

component to avoid discriminating against visitors and employees with disabilities. 

Recommendations include:

 Include sustainable, accessible river access (as required in ABAAS under beach 

access routes) for visitors and campers in the Virgin River restoration strategy

 Transportation Plan should include accessible options as well

 Commercial services plan needs to include accessible programs

 Historic structures reports need to include accessibility treatments in the treatment 

section – these plans are prepared by experts that can provide sensitive, integrated 

solutions that maintain character defining features while providing access.

 South Entrance plan needs to address access to the entrance sign photo-op, 

accessible campground, wayfinding to accessible programs, etc.

 The Education Plan should include strategies for providing programs to people that 

are blind or have low vision, are deaf or hard of hearing, those with mobility 

impairments, and those with cognitive disabilities.

 Etc.

These are just starting points when beginning these plans. Recommend having plans 

reviewed by accessibility specialists to avoid discrimination and future program access issues.

Interpretive programs – the ranger led programs are the main way that the key interpretive 

stories of Zion National Park are provided. Recommended ways to improve access to these

programs:

 Yearly accessibility training for all interpretive staff

o Disability awareness

o Spontaneous audio description

o Assistive devices

o Methods for communication

 Providing assistive listening devices for large groups (easily available to rangers, 

training in operation)

 Provide meaningful tactile elements for the ranger drop-in locations

 Provide scheduled sign language programs for ongoing large group programs
24

 Provide alternative formats for the main publications; large print, audio guide, 

braille, tactile maps (such as bubble print or swell form paper), etc.

 Identify accessible programs and media on website and in newspaper

Non-discrimination in program access recommendations are included in the facility 

recommendations in Section 1.8 where the programs take place, in the policy 

recommendations in Sections 2 through 6 of this document, In the website evaluation and in 

the Transition Plan Database for each facility.

1.8 §17.550 Program Accessibility: Existing Facilities

Requirements:

(a) General. The agency shall operate each program or activity so that the program or 

activity, when viewed in its entirety, is readily accessible to and usable by persons with a 

disability.

This may require modification of policies and procedures to eliminate inadvertent 

discrimination and/or removal of architectural barriers to provide program access. With respect 

to the viewed in their entirety language of the regulation, identification of program, services, or 

activities that are unique to a specific building will be critical to determining compliance with 

program access requirements. In the event that a program, service, or activity is available only 

by being present in a specific facility, that facility must be accessible to and usable by qualified 

individuals with disabilities. 

(d) Transition plan. In the event that structural changes to facilities are necessary to achieve 

program accessibility, the agency shall develop, within six months of the effective date of this 

part, a transition plan setting forth the steps necessary to complete such changes. The plan shall 

be developed with the assistance of interested persons, including persons with disabilities or 

organizations representing persons with a disability. A copy of the transition plan shall be made 

available for public inspection. The plan shall, at a minimum—

(1) Identify physical obstacles in the agency's facilities that limit the accessibility of its programs 

or activities to persons with a disability;

(2) Describe in detail the methods that will be used to make the facilities accessible;

(3) Specify the schedule for taking the steps necessary to achieve compliance with this section 

and, if the time period of the transition plan is longer than one year, identify steps that will be 

taken during each year of the transition period;

(4) Indicate the official responsible for implementation of the plan; and

(5) Identify the persons or groups with whose assistance the plan was prepared.
25

(See Appendix B for full text.)

Program access, when programs, services, and activities are provided in more than one 

location, can be achieved in light of the viewed in its entirety provision. All aspects of program 

access, such as policies and procedures considering other power-driven mobility devices, 

effective communication, reasonable modification, and service animals, must be considered 

when assessing physical barriers in the facilities of a federal entity. Adoption and 

implementation of such policies is critical to providing program access. 

MTC design and Section 504 specialists prepared a preliminary list of Zion facilities and the 

programs, services, and activities provided at these facilities from a review of documents in the 

NPS Electronic Technical Information Center (ETIC), park documents and Asset Priority Index 

(API). The purpose of this list is to identify the types of facilities provided, and determine all 

facilities of each type in the park and determine distinct park areas for area SETP’s. This list is 

sent to the park for additions and edits. MTC and park staff (park management, natural and 

cultural resource specialists, interpretive and facility management division heads) met on-site 

to work together to determine park areas with facilities provided, and the services and 

programs included at each facility, and prioritize these areas, facilities and programs based on 

 service need (information, food, lodging, transportation, comfort), 

 core experience programs, 

o Interpretation 

o Recreation

 programs highlighted on the park website or newspaper 

 and key programs common to all parks 

This team (park and MTC) then determined if there were duplicated programs that met all 

the aspects of the program, and determined which of these needed to be accessible.

Findings: 

Self-evaluation of Programs at Zion Facilities by Facility Type

Visitor Centers and Museums

There are four visitor centers or museums at Zion National Park: Visitor Zion Canyon Visitor 

Center, Nature Center, Human History Museum and the Kolob Canyons Visitor Center. Each 

facility provides unique interpretive themes and all are important in communicating the 

fundamental resources and values of the park. The programs provided at each facility are not 

duplicated at a different facility; all programs provided at each facility need to be accessible to 

visitors with disabilities to meet the “when viewed in their entirety” requirement of Section 

504. 
26

Zion Canyon Visitor Center

From park website: Zion Canyon Visitor Center - The starting point for any visit to Zion Canyon.

Outdoor exhibits, information desk, wilderness permits, bookstore, restrooms, picnic area, and 

water bottle filling station. Ranger-led programs. Access to the Pa’rus Trail and Watchman 

Trail.

Requirements:

Programs, services and activities provided at the Visitor Center need to be accessible to people 

(visitors and employees) with disabilities.

Findings:

 Interpretive Programs: the rangers at the information desk and wilderness desk provide 

information about the park, things to do, places to go, etc. Alternative format media 

was not readily available, only a braille brochure is obtainable. The drop-in ranger 

programs provide a lot of the information about the key interpretive stories identified in 

the Foundation Plan. These are provided in the plaza and in the VC. Information about 

these programs is provide in the newspaper for time and location.

 Parking: Car and RV – There are several different types of parking spaces provided 

including standard car spaces, 10-minute parking spaces, parking for the integrated 

picnic sites, RV parking, and electric charging station parking. There is an adequate 

number of accessible spaces in total, need to assure there is one van space for every six 

accessible spaces provided: F208.2.4 Van Parking Spaces. For every six or fraction of six 

parking spaces required by F208.2 to comply with 502, at least one shall be a van 

parking space complying with 502. Key issues found:

o The oversized parking area does not include an accessible space.

o The electric vehicle charging station has two accessible parking spaces with no 

access aisle. This is the only charging station and most visitors would need to 

park illegally to charge their vehicle. 

o No signage provided for the accessible parking adjacent to the visitor center

 Pedestrian routes

o The distance from the 

accessible parking to the 

shuttle stop is excessive 

– 700’ from the closest 

space, the NPS 

recommended maximum 

is 200’
27

 Plaza – trip planning kiosks

o Few visitors were observed using these kiosks – most visitors were walking to 

the restroom and shuttle stop. There are a few built-in tactile exhibits provided 

including animal sculptures and a large Zion valley model (too large to touch 

middle of the valley).

 Restrooms

o The existing restrooms do not meet ABAAS requirements, see TPD for 

deficiencies found

 Information desk

o Accessible counters are provided and useable (clear of clutter)

o Only a braille brochure provided for alternative formats – difficult to retrieve 

from the info desk

 Gift shop

o There are several checkout stations, all accessible counters are too short to meet 

ABAAS requirements

 Exhibits, films, etc. 

o Minimal exhibits provided in the VC, most are exterior.

o Monitor with film playing provides open captioning.

 Picnic Area throughout VC parking – There are 16 picnic units in this parking areas, most 

are single tables, three are double tables. There is one accessible single table unit 

adjacent to the accessible parking. ABAAS requires three accessible units, with one 

being a double table unit: 

F245.2.2 Picnic Facilities with More Than Two Picnic Units. Where picnic facilities 

contain more than two picnic units, at least 20 percent, but not less than two, of the 

picnic units shall provide mobility features complying with F245.2.

Recommendations:

Interpretive Programs –

 Provide yearly accessibility training for all interpretive staff

o Disability awareness

o Spontaneous audio description

o Assistive devices

o Methods for communication

 Providing assistive listening devices for large groups (easily available to rangers, 

training in operation)
28

 Provide additional wayfinding information for the ranger drop-in programs (topics, 

general locations and times) to help visitors with disabilities find these programs in 

newspaper, temporary signage, etc.

 Provide meaningful tactile elements for the ranger drop-in locations

 Provide scheduled sign language programs for ongoing large group programs; such 

as once a week during the summer, with program information included in the

newspaper.

 Provide alternative formats for the main publications; large print, audio guide, 

braille, tactile maps, etc.

 Identify accessible programs and media on website and in newspaper

 Information Desk – Have large print versions of standard information provided by 

rangers readily available at each station. Provide designed note paper and pen set 

permanently on the counter at each station to make communicating with visitors 

who are deaf or are hard of hearing more intuitive. 

 New exhibits were being installed during final information gathering site visit in 

August 2016. Recommend including the accessible version – the Access Guide with 

this exhibit or identify where to pick it up. This might be a good guide to provide at 

the accessible queue for the shuttles, may have fewer walk away with visitors that 

won’t use them. 
29

Parking - The 10-minute parking spaces do not include an accessible space, but the existing 

accessible spaces are just as close to the VC and easier to find; recommend keeping all of the 

accessible spaces and amenities together to keep circulating through this parking lot looking for 

an accessible space elsewhere to a minimum. Add an accessible RV space in the oversized 

parking lot with same length as other spaces and width of space and access aisle the same as 

required for van accessible spaces. Specific recommendations for the Visitor Center area 

parking are included in the TPD.

Electric Charging Station - Provide a compliant parking space and access aisle (van accessible) at 

the electric charging station. Sign accessible space and add a second space signed for vehicle 

charging use only – no accessible parking sign or pavement markings.

Pedestrian Routes – The distance from the accessible parking to the shuttle stop is excessive. 

Recommend regrading an accessible route from the accessible parking to the shuttle stop and 

visitor center – see picnic area recommendation for one option to make the accessible route 

shorter.

Plaza – Very few visitors were observed using the kiosks during the two data gathering trips 

(end of June and mid-August). Recommendations for making these areas more usable:

 Provide additional shade. The existing spacing of the shade slats is too far apart to 

provide shade, making these areas too hot to spend time in.

 These function as the interpretive exhibits for the VC, should include some type of 

outdoor cooling system (high pressure misting, ceiling fans), interactive exhibits, and 

ranger drop-in stations.

 Provide context for tactile exhibits, the bronze animals by themselves are sculpture, 

included in the flora and fauna exhibit area, they are interpretive.

 The 3d map of the valley is too large to be used by the blind. Consider making crosssections at named locations in the valley so that you can feel the narrowing of the 

canyon. 

 Provide a small tactile model of the valley - 2 by 3’ that a person can feel both ends and 

understand the narrowing of the canyon and steep side walls.

 Picnic Area throughout VC parking – See Picnic Areas for recommendations. 
30

 Consider providing timed 

tickets for the shuttle so that 

visitors don’t have to stand in 

line for more than 10 – 15 

minutes, they can learn about 

the park instead. Allow 

wheelchair, walker and cane 

users to go to a shaded no-wait

lane beside the general queue 

to board as soon as possible 

(one wheelchair per shuttle). 

 Does not appear there is 

adequate clear floor space to 

place a compliant queue line 

between the existing benches 

and the base of the stone 

columns. The queues need to 

be a minimum of 36” clear 

between the narrowest points 

along the queue (rock bases at 

end and middle of benches, 

base of columns, base of chain stanchions), need 5’ clear at ends of lines to make the 

180 degree turn.

 Specific structural recommendations for the Visitor Center area are included in the TPD.
31

Zion Human History Museum

Zion Human History Museum

From park website: Explore the human 

history of Zion Canyon Indoor exhibits, 

orientation film, rotating art exhibit, 

restrooms, bookstore, and water bottle filling 

station. Ranger-led programs. Views of the 

Towers of the Virgin and Bridge Mountain. 

Access to the Pa’rus Trail.

Requirements:

Programs, services and activities provided at 

the Human History Museum need to be 

accessible to people (visitors and employees) 

with disabilities.

Findings:

Interpretive programs and Exhibit room–

The Human History Museum is where many 

of the park fundamental resources and values

are interpreted for visitors. The exhibits are 

not accessible to visitors that are blind or have 

low vision, no alternative formats were 

observed. Several locations have narrow 

openings that wheelchair users cannot 

negotiate. The large topographic model in the 

center of the exhibit room has sign to not 

touch and is too large to function as a tactile 

exhibit. The film shown in the auditorium is 

open captioned.

Ranger talk gathering space–

The outdoor seating area where ranger led 

programs are provided does not provide 

integrated wheelchair seating and visitors with 

mobility impairments will have a difficult 

time getting near the speaker.

Parking–

There is an adequate number of accessible 

spaces provided. The accessible parking 
32

spaces and access aisles exceed the maximum 

slopes allowed by ABAAS (3.5 - 4.4%). A 

van accessible space, access aisle and sign are 

not provided.

Restrooms – The restrooms have many 

accessibility issues. These are documented 

with data and photographs in the TPD.

Information desk/Gift shop - The gift shop 

area is tight and does not provide adequate 

maneuvering space throughout. 

Pedestrian Routes - The concrete walks and 

terrace use wide wood joints. The wood is 

deteriorating and sinking causing tripping 

hazards and gaps that do not meet ABAAS 

requirements. The concrete is spalling in 

several locations causing similar problems as 

well.

Recommendations:

Interpretive Programs –

Provide yearly accessibility training for all interpretive staff

o Disability awareness

o Spontaneous audio description

o Assistive devices

o Methods for communication

 Providing assistive listening devices for large groups (easily available to rangers, 

training in operation)

 Provide meaningful tactile elements integrated throughout the exhibits

 Provide scheduled sign language programs for ongoing large group programs

 Provide alternative formats for the main publications; large print, audio guide, 

braille, tactile maps, etc.

 Develop an audio tour of the exhibits

 Identify accessible programs and media on website and in newspaper

Pedestrian Routes – Replace wood joints in the concrete walks with a material that can be 

more easily maintained.
33

Restrooms – Restrooms will require a major remodel to meet ABAAS requirements.

Specific recommendations for the Human History Museum area are provided in the TPD.

Nature Center

From park website: The Zion Nature 

Center, located north of South Campground 

has a variety of exhibits, activities, books, 

and games for children and families to 

explore.

Nature Center Youth Programs - These 

programs are offered daily from Memorial 

Day Weekend through Labor Day. The Zion 

Nature Center is located next to the South 

Campground. The shuttle does not stop here, 

but it can be accessed from the Pa'rus Trail. 

Limited Parking is available. Programs are 

designed specifically for children and 

families, and are 30-45 minutes long.

Findings:

The Nature Center is the key facility for the Junior Ranger Program, children and family 

education, and family oriented ranger programs. The Junior Ranger program is difficult for 

children that are blind or have low vision to complete, the carved badge is beautifully crafted 

and tactile for all that earn it.

There are many interactive exhibits, several are out of reach range requirements. There are no 

alternative formats available for the exhibits. 
34

Recommendations:

Recommend developing an alternative format for the Junior Ranger program booklet and 

requirements for the badge. Develop interpretive ranger training for providing inclusive 

programs and SOP’s for assistive devices, qualified ASL interpreter, etc. Specific structural 

recommendations for the Nature Center area are included in the TPD.

Alternative 1 accessible route location

There are two parking areas for 

the nature center, one for visitors 

and one for employees. ABAAS 

requires accessible parking for 

each area. Two ways to provide 

this program are diagrammed 

below:

Alternative 1 places a van 

accessible parking space and 

access aisle in the employee lot 

with an accessible route to the 

visitor ramp at the front of the 

building.
35

Alternative 2 places both 

accessible parking spaces in the 

visitor lot per ABAAS F208.3.1 

EXCEPTION 2. Parking spaces shall 

be permitted to be located in 

different parking facilities if 

substantially equivalent or greater 

accessibility is provided in terms of 

distance from an accessible

entrance or entrances, parking fee, 

and user convenience.

Recommend using a flush curb and landing at walk adjacent to access aisle and ramp the walks 

up from there, rather than a standard curb ramp that requires a landing at the top of the curb 

ramp for new construction that requires a minimum 9’ wide walk (for a 6” curb) at this location:

Figure 406.4 Landings at the Top of Curb Ramps

EXCEPTION: In alterations, where there is no landing at the top of curb ramps, curb ramp flares shall 

be provided and shall not be steeper than 1:12.

Kolob Canyons Visitor Center

From park website: Kolob Canyons Visitor Center - All guests are required to stop at the Kolob 

Canyons Visitor Center to show an Interagency Park Pass or pay the Zion National Park entrance 

fee. Wilderness Permits can be obtained here for backpacking campsites and canyoneering 

routes in the park. There is also a bookstore operated by the Zion Natural History Association.
36

Requirements:

Programs, services and activities provided at the Visitor Center need to be accessible to people 

(visitors and employees) with disabilities.

Findings:

Parking: There are 38 car parking spaces 

with two designated accessible at the 

visitor center (two required by ABAAS); 

neither space meets ABAAS 

requirements; excessive slope, access 

aisles are not provided and curb ramp is 

not compliant. Buses and large vehicles 

park in the center of the parking area, no 

designated accessible RV/bus spaces 

provided.

There is a staff parking space and 

accessible electric charging station 

parking adjacent to the VC. 

Existing employee parking space and electric vehicle charging station

Restrooms: The existing restrooms do not comply with ABAAS and will require significant 

alterations that will reduce the number of stalls in each restroom. See the TPD for issues found.

Plaza: Much of the plaza is too steep to meet ABAAS requirements (4 to 7%) – ABAAS requires 

2.08% max in all directions for plazas. 
37

Entrance: The entrance doors to the VC are heavy to open, greatly exceed the 5lbs. allowed for 

interior doors (exterior doors are not required to meet the 5 lbs. opening force, however, 

Section 504 requires access into the 

building.

Information desk and Association 

counter: 

Neither counter provides an 

accessible counter height for 

wheelchair users. There were no 

alternative formats available at the 

counter except for a braille brochure.

Exhibits:

This space is very tight to provide 

information desk, exhibits and gift 

shop functions. The exhibits are not 

accessible to visitors that are blind or 

have low vision. The passport 

stamping station is located on the 

window sill that does not meet 

ABAAS requirements for approach or 

height. 

The gift shop counter and front of 

counter are filled with product, 

making the transaction counter 

inaccessible.

Employee space: 

The offices are located on two levels, 

the VC level and the basement. The 

breakroom is located in the 

basement and is not accessible to 

employees that use wheelchairs or 

other mobility devices.
38

Recommendations:

Parking: Recommend making 

two accessible car spaces with a 

compliant access aisle and 

accessible route to VC. Add an 

accessible RV/bus space at the 

current staff parking space 

(move employee space to 

central island parking). Provide a 

compliant parking space and 

access aisle (van accessible) at 

the electric charging space, but 

do not put the ASI on the 

pavement or sign this space –

This is the only charging station 

and needs to be useable by all visitors and signing would make it illegal for most visitors to use.

Restrooms: Recommend adding compliant accessible stalls to the men’s and women’s 

restrooms as an addition to this building or adding unisex toilets as a separate building adjacent 

to the VC. There is not adequate space in the existing restrooms to make them compliant 

without losing one stall in each restroom. See the TPD for specific issues with these restrooms.

Plaza: Provide a compliant accessible route from the accessible parking spaces to waysides, 

restrooms and building entrance.

Entrance: Recommend adding power assist door openers on these doors to allow useable 

access into building.

Information and gift store counters: Provide accessible counter height for parallel or 

perpendicular approach to each counter, include an accessible employee workspace behind 

each counter.

Exhibits: Provide accessible exhibits (interior and exterior) that are accessible, include 

alternative formats and tactile elements to interpret the key stories told here.

Employee Space: Offices are located on both floors; the basement does not need to be made 

accessible as long as an equivalent breakroom space with refrigerator and microwave is 

provided on the main level. 

Specific structural recommendations for the Kolob Canyon Visitor Center area are included in 

the TPD.
39

Campgrounds

Requirements:

ABAAS Scoping requirements for Campgrounds:

F244.2 Camping Units with Mobility Features. Camping facilities shall provide camping units with 

mobility features complying with F244.2 in accordance with Table F244.2. Where a camping 

facility provides different types of camping units, Table F244.2 shall apply to each type of camping 

unit provided.

Table F244.2 Camping Units with Mobility Features

Total Number of Camping Units 

Provided in Camping Facility

Minimum Number of Camping Units with 

Mobility Features Required

1 1

2 to 25 2

26 to 50 3

51 to 75 4

76 to 100 5

101 to 150 7

151 to 200 8

201 and over 8, plus 2 percent of the number over 200

Advisory F244.2 Camping Units with Mobility Features. Camping units for recreational vehicles only, 

camping units for tent camping only, and camping units with camp shelters are different types of 

camping units.

Camping units with mobility features are not required to be identified by signs. Entities should provide 

information on the location of camping units with mobility features on websites, in brochures, and at 

bulletin boards or information kiosks at the camping facility. Where entities operate reservation 

systems for camping units or assign camping units upon arrival, entities should establish policies to 

ensure that camping units with mobility features are available for individuals with disabilities until all 

the camping units are occupied.

F244.2.1 Alterations and Additions. Where camping units are altered or added, the requirements of 

F244.2 shall apply only to the camping units that are altered or added until the number of camping 

units with mobility features complies with the minimum number required in Table F244.2. F244.2.2 

Dispersion. Camping units required to provide mobility features complying with F244.2 shall provide 

choices of camping units comparable to, and integrated with, those available to others.
40

South Campground

Findings: 

From park website: South Campground is located 1⁄2 mile from the South Entrance. There are 

117 campsites (including three 

wheelchair accessible) available firstcome, first-served. For the 2016 

season, 4 group sites were added that 

accommodate 7-15 people, available 

first-come, first-served.

The accessible sites do not meet ABAAS 

scoping or technical requirements and 

are not readily usable by people with 

mobility disabilities. The group sites, 

walk-in sites and campground host 

sites are not accessible.

The South Campground Amphitheater 

is not accessible for wheelchair users, 

there is no route to the stage or compliant integrated seating. Availability of assistive listening 

devices was not observed.
41

Recommendations:

South Campground has many of the same types of facilities as Watchman Campground – the 

main program provided here, not available at Watchman Campground, is that South 

Campground is a non-reservation campground. Zion should conduct a Transition Plan of South 

Campground and Amphitheater to have MTC provide recommendations and physical solutions 

to make these programs accessible. 

To meet ABAAS requirements, South 

Campground needs a minimum of 7 

accessible campsites distributed among 

the types of sites available: back-in and 

pull-through tent/RV; walk-in tent; 

river view sites; campground host site; 

and group site. Accessible sites need to 

be dispersed throughout the 

campground, the three accessible sites 

currently provided need to be 

redistributed throughout the 

campground.

Accessible sites need to have outdoor recreation access routes connecting to campground 

amenities including restrooms, water stations and trash collection. There is only one accessible 

unisex restroom, may need to add additional to meet ABAAS dispersion requirements.

Watchman Campground

Findings: 

From park website: Watchman Campground is located 1⁄4 mile from the South Entrance. Tent

and electric campsites are available year-round and group campsites are available by 

reservation from March through October. There are 176 regular sites, 2 wheelchair accessible 

sites and 7 group sites.

There are currently 2 accessible back-in RV sites (A 16HC, A 19HC) for the 182 site Watchman 

Campground per the Recreation.gov reservation site, both sites are in a loop to be closed in 

October 2016 for construction work (asphalt overlay). 

ABAAS requires a minimum of 8 dispersed accessible sites total for alterations to a 182 site 

campground, however, for new construction, this campground would need 14 accessible sites 

dispersed among the different types of sites provided:

1. 85 tent only sites ($20/nt.) – requires 5 accessible spaces per ABAAS for new 
42

construction

2. 84 back-in RV sites (12 with river view) ($30/nt.) – Requires 5 accessible sites for 

new construction

3. 6 pull through RV sites (4 with river view) ($30/nt.) – requires 2 accessible sites for 

new construction

4. 7 Group sites) ($50 /nt.) – requires 2 accessible sites for new construction

5. 2 Campground host sites – Section 504 program access requires 1 host site to be 

accessible, all host sites need to be accessible to visitors (campers)

Accessible sites need to have outdoor recreation access routes connecting to campground 

amenities including restrooms, water stations, gray water disposal drain, trash and recycling, 

and amphitheater. There are several signed river access trails in the campground, none meet 

the requirements for a beach access route. Beach and river access is required per ABAAS.

The amphitheater does not have usable accessible wheelchair seating areas (steep slopes and 

inadequate clear space) or access to the stage.

Recommendations:

Program access - Section 504 of the Rehabilitation Act requires that all programs are accessible 

when viewed in their entirety. Each of these different types of campsite is a program. These 

sites need to be dispersed among all of the loops.

Accessible campsites - The team met on-site with the park landscape architect and determined 

which of the existing sites met these requirements and required the lowest initial cost to 

implement. Data was collected for these sites and is included in the TPD. To provide an 

equivalent camping experience, MTC recommends making the following sites ABAAS compliant: 

Sites recommended to be made accessible:

 A 8, back-in RV site

 A 16, back-in RV site

 B 44, pull-through RV site

 B 54, pull-through RV site

 B 57, back-in RV site

 C 14, tent only site

 C 16, tent only site

 D 11, tent only site

 D 16, tent only site

 D 22, tent only site

 E 3, group tent only site

 E 6, group tent only site

 F 7, walk-in tent site
43

 F 12, walk-in tent site

 Camp Host Site, back-in RV site

Existing designated accessible site - A 19HC, would require site clearing, grading and pavement 

work to meet ABAAS requirements. Recommend removing sign and designation on websites 

and using other campsites identified to be made accessible. Recommended sites to be made 

accessible are shaded in the plan and detailed in the TPD. The alterations to the loop being 

closed this fall should include the alterations included in the TPD for this loop.

Amphitheater - The amphitheater will require removing the bottom and top row of benches, 

paved surface and pedestrian routes to these areas; and regrading to get these rows level for 

dispersed accessible seating with companion seating allowing users to sit shoulder to shoulder 

(an additional 12” behind these benches is 

needed to meet this requirement). In addition, 

the outdoor access routes to the amphitheater 

seating and stage will need to be regraded to 

meet ABAAS requirements. 

River Access - Add a compliant beach access 

route, recommended access point across from 

site B57 is included in the TPD.
44
45

Lava Point Campground

From park website: This campground is 

typically open June through October, as 

weather allows. There are 6 primitive 

campsites available first-come, first-served, pit 

toilets, and trash cans, but no water. Vehicles 

longer than 19 feet are not permitted on the 

road to the campground. There is no charge 

for camping.

Findings: 

The 6 primitive campsites are not accessible 

for people with mobility impairments, there is 

no compliant outdoor recreation access route

(ORAR) to the vault toilets, the parking at the 

comfort station does not meet ABAAS 

requirements, the toilet rooms will require 

minimal alterations to meet ABAAS. There is a 

trail to an overlook that begins in this 

campground that should be made accessible. 

This campground will require two accessible 

sites to meet ABAAS requirements:

Table F244.2 Camping Units with Mobility Features

Total Number of Camping Units 

Provided in Camping Facility

Minimum Number of Camping Units with 

Mobility Features Required

1 1

2 to 25 2

26 to 50 3

51 to 75 4

76 to 100 5

101 to 150 7

151 to 200 8

201 and over 8, plus 2 percent of the number over 200

Recommendations:

Lava Point Campground is the only primitive campground in the park, very different from the 

camping experiences available at South or Watchman Campgrounds. Zion should conduct an 
46

existing facility evaluation and Transition Plan for Lava Point Campground to make programs 

provided there accessible. The Lava Point campground programs identified during the site visit 

in August 2016 include: 6 back-in RV/tent sites with picnic table, fire ring and tent pad; vault 

toilet with parking, trash and recycling; registration and regulation/notice board; and trail to 

overlook. While reviewing the campground, two sites appeared to be easily altered to meet 

accessibility standards with campground road as ORAR to comfort station. Trail begins at one of 

these sites:

Picnic Areas

Requirements:

ABAAS Scoping requirements for Picnic Areas:

F245 Picnic Facilities

F245.1 General. Picnic facilities, other than picnic facilities on trails, shall comply with F245.

Advisory F245.1 General. Picnic facilities on trails are addressed in F247.4.2.
47

F245.2 Picnic Units with Mobility Features. Picnic facilities shall provide picnic units with mobility 

features in accordance with F245.2.

Advisory F245.2 Picnic Units with Mobility Features. Picnic units with mobility 

features are not required to be identified by signs. Entities should provide 

information on the location of picnic units with mobility features on websites, in 

brochures, and at bulletin boards or information kiosks at the picnic facility.

F245.2.1 Picnic Facilities with Two or Fewer Picnic Units. Where picnic facilities contain two or fewer 

picnic units, each picnic unit shall provide mobility features complying with F245.2.

F245.2.2 Picnic Facilities with More Than Two Picnic Units. Where picnic facilities contain more than 

two picnic units, at least 20 percent, but not less than two, of the picnic units shall provide mobility 

features complying with F245.2.

F245.2.3 Alterations and Additions. Where picnic units are altered or added, the requirements of 

F245.2 shall apply only to the picnic units that are altered or added until the number of picnic units 

with mobility features complies with the minimum number required in F245.2.1 or F245.2.2.

EXCEPTION: Where an entity is implementing a transition plan for program accessibility developed 

pursuant to regulations issued under section 504 of the Rehabilitation Act that designates specific 

picnic units to provide mobility features complying with F245.2, the entity shall not be required to 

comply with F245.2 when altering individual elements within picnic units that are not designated to 

provide mobility features complying with F245.2.

Advisory F245.2.3 Alterations and Additions Exception. When all the elements 

within a picnic unit are altered, the altered picnic unit is required to comply with 

F245.2 unless the minimum number of picnic units with mobility features required 

in F245.2.1 or F245.2.2 is provided.

F245.2.4 Dispersion. Picnic units required to provide mobility features complying with F245.2 shall 

provide choices of picnic units comparable to, and integrated with, those available to others.

Program Requirement Findings: 

The picnic areas in Zion are spread out throughout the park and are associated with adjacent 

programs and facilities. Providing picnicking at only a few of these areas would not meet the 

equivalent experience requirement in Section 504. All picnic areas in the park need to meet the 

scoping and technical requirements of ABAAS. Findings:

Visitor Center Picnic Area

From park website: Located .3 miles from the South Entrance on the outer edge of the visitor 

center parking lot. Picnic sites are level but unpaved. Most tables are extended. Accessible 

unisex restroom is available near the visitor center.

Findings: 

Picnic tables are dispersed around the Visitor Center parking area. There is one accessible table 

adjacent to the accessible parking. There are individual picnic units and double picnic units 

provided around the parking area.
48

Recommendations:

This is an extremely busy parking area and the picnic tables are located in the parking islands 

throughout. Recommend keeping the accessible picnic tables adjacent to the accessible parking 

spaces rather than dispersing the picnic table throughout the parking area. It would be very 

difficult to provide directions to an accessible parking space and picnic table in another location 

of the parking area, when wayfinding to the VC, shuttles, restrooms, etc. is complicated 

already. There are 16 picnic units provided, with one accessible. Need to provide a minimum of 

3 accessible picnic units (two single table and one double table unit) to meet ABAAS 

requirements. Other specific recommendations for this area are included in the TPD. One 

solution to provide these units:

Grotto Picnic Area

From park website: Shaded picnic area among cottonwood trees Restrooms, picnic area, and 

water. Views of the Virgin River and Angels Landing. Access to The Grotto Trail, Kayenta Trail, 

and West Rim Trail. Located 3.5 miles up the Zion Canyon Scenic Drive and accessible only by 

shuttle bus from April through October. Reserved parking spaces in the off months. Picnic 

grounds are level but unpaved. Accessible, unisex bathroom.
49

Findings: 

Picnic Units - There are two types of picnic units here: 

single table, and group site with 2 or more tables. The 

picnic table posts are embedded which causes table 

height and knee clearance to vary between the tables. 

Need to assure 27” clear knee space and maximum 

table height of 34”. Maintaining these table 

requirements and firm, stable ground surface of 

pedestrian routes will require weekly, scheduled 

maintenance.

Restrooms – The accessible unisex restroom does not meet ABAAS requirements. The

deficiencies and recommendations are documented with data and photographs in the TPD.

Recommendations:

Recommend replacing crusher fines surface material with concrete to assure accessible tables 

remain accessible to wheelchair users. Move the (non-compliant) accessible parking space to be 

adjacent to picnic area. The concrete walk at the curb ramp has a very steep cross slope, 

recommend replacing ramp and concrete walk to the new accessible space with a compliant 

walk. The existing unisex accessible restroom does not comply with ABAAS requirements. See

specific recommendations for this area in the TPD.
50

Kolob Canyons Picnic Area

From park website: Located at the end of the 5-mile scenic drive. Restrooms accessible. Tables 

located up steep, unpaved path.

Findings: This picnic area is not accessible to people with mobility impairments. The route to 

the picnic area exceeds slopes for outdoor recreation routes or trails. There is a picnic table in 

the center of the parking area island, the table is not accessible and there is a full height curb 

surrounding the island with no curb cut.

Recommendations: Recommend making the picnic table in the island of the parking area 

accessible; add a curb ramp, ORAR from accessible parking space (van accessible) and access 

aisle to picnic table, and adequate clear space around compliant table. If natural shade does not 

cover this table, recommend adding a shade structure to be equivalent to the natural shade 

provided at the picnic area on the hillside. See the TPD for additional recommendations.

Nature Center Picnic Area

Findings: This picnic area is stretched out in two islands adjacent to the Nature Center. There is 

no designated accessible parking or ORAR for the picnic facility on the south island. The full 

height curb is not accessible to people with mobility impairments. 

Recommendations:

Recommend adding an accessible van parking space, access aisle, curb ramp and ORAR to two 

picnic units (a single table and a double table) in the area circled on the plan. Provide an ORAR 

to the lawn area and accessible tables on the level areas of the lawn adjacent to the nature 

center – these are movable tables; need to provide an SOP for placement of tables by 

maintenance crew to assure accessibility is maintained following mowing operations and 

movement by visitors. The accessible parking space for the nature center will provide compliant 
51

parking for this picnic facility. (see parking under the Nature Center review in this document for 

alterations required)

Other recommendations for this area are included in the TPD.

Lava Point Picnic Area and Overlook
52

Requirements:

Findings: The Lava Point Picnic Area provides five picnic sites. Two are required to be 

accessible per ABAAS. The picnic area includes a vault toilet and overlook parking and trail to 

overlook, and trail from the Lava Point Campground. The overlook needs to meet ABAAS 

requirements for viewing areas. This picnic area is not accessible to people with mobility 

impairments. The ground surface material is not firm and stable; picnic tables and sites are not 

accessible. This picnic area is not included in the park newspaper or on the website. 

Recommendations: Recommend making two picnic sites accessible, accessible parking at 

comfort station or overlook, with accessible pedestrian routes connecting trail from 

campground, picnic sites, vault toilet and overlook. Include information in newspaper and on 

park website with other picnic areas. Recommend completing SETP for this area. 

Dining and Lodging

Zion Lodge

From the park website: Three miles north on the Zion Canyon Scenic Drive. Open year-round. 

Motel rooms, cabins, and suites available. 
53

Requirements: All programs provided at the lodge (visitor, NPS and concession employees) are

required to be accessible per Section 504 of the Rehabilitation Act 

Findings: The lodge provides many varied programs. Findings are listed by program:

 Lodging

o Motel rooms – All accessible motel rooms are located on the first floor, adjacent 

to each other in one of the two motel buildings. ABAAS requires that lodging 

units be dispersed

o Motel suites. – All suites are located on an inaccessible floor, accessible suite is 

not provided, ABAAS requires all room types to be accessible.

o Cabins- One cabin is accessible, ABAAS requires a minimum of two accessible 

cabins.

 Dining

o Red Rock Grill Dining Room and outdoor deck dining at Zion Lodge – an elevator 

is provided to access the dining room. The elevator is difficult to find, no signage 

to direct visitors.

o Castle Dome Cafe at Zion Lodge

 Seating Areas

o Interior – the seating 

areas in the lobby are 

tight conversation 

groups with movable 

rugs in the center. 

Accessible wheelchair 

space out of circulation

routes is not provided.

o Exterior – The fixed 

benches around the 

lawn in front of the 

lodge do not provide 

wheelchair seating 

space beside benches.

 Services

o Front Desk – the front desk has an accessible counter on the side of the space, 

not visible from front of counter. Alternative format lodging/dining information 

is not provided.

o Concierge – there is no accessible counter at this location

o Restrooms – Restrooms in the lobby do not have an ABAAS compliant stall 

(inadequate clear space adjacent to toilet for side transfer).
54

o Business Center – the 

business center is a 

standing counter with 

computer and printer 

in the cabinet below in 

a narrow alcove in the 

lobby with ATM 

opposite at the other 

end of alcove. There is 

no accessible counter, 

computer, printer, or 

ATM available.

o After hours’ door bell –

Lobby doors are locked at night and doorbell button is located behind chairs and 

above reach range for wheelchair users.

 Gift Shop – there is no accessible counter in the gift shop

 Auditorium – the door is not accessible, no signage for assistive listening devices, 

movable furnishings rely on each setup to meet requirements, no standard setup 

floorplans were observed.

 Parking and pedestrian routes

o Lodge Registration and Cafe parking area – This parking area adjacent to the 

shuttle stop provides two programs; signed 20-minute registration parking on 

one side of island and unsigned, longer term parking on the other side. Both 

accessible parking spaces are on the 20- minute parking side and do not provide 

the shortest accessible route to the Cafe/Lodge.

o Guest lodging parking – Inadequate number of accessible parking spaces.

o Curb ramps – All curb ramps in this area do not comply with ABAAS 

requirements.

 Employee spaces and programs – Employee spaces were not included in this SETP unless 

they are part of visitor programs as well; these are covered under the visitor programs.

Recommendations:

See the Transition Plan Database for deficiencies and recommendations to make the programs 

provided in this area accessible to visitors with disabilities. Recommend having all renovation 

plans reviewed by an accessibility specialist to assure changes meet requirements for facilities 

on federal properties (ABAAS, not ADA requirements) Highlighted program recommendations:
55

Lodging – Recommend providing additional 

information about the accessible rooms 

available and services provided, website 

states there are “Physically disabled services 

– hearing impaired services” - not sure what 

this means. Restrooms in the lodging rooms 

do not meet minimum requirements for 

ABAAS and tight clearances will make them 

difficult to use by wheelchair users. 

Recommend including a site plan and

floorplans on the reservation website to 

provide adequate information to determine if 

room will function for the visitor (include now 

and after renovating to meet ABAAS). Provide 

specific services that are provided.

Recommend conducting an SETP of the 

concession website and reservation system, 

and training for the reservation system 

employees in providing services to people 

with disabilities.

o Motels – All of the rooms in the two motel buildings provide similar views and 

other amenities. Providing the required number of accessible units on an 

accessible floor of one of these units should be considered equivalent access to 

this program. Two different types of units are provided:

 Motel rooms – Recommend dispersing the motel rooms throughout the 

first floor of the accessible motel building including the types of rooms 

available to other guests.

 Motel suites – Recommend making an accessible suite on the first floor of 

the accessible motel building (requires eliminating a storage room on this 

floor).

o Cabins – Provide two accessible cabins on accessible routes to provide the 

scoping required by ABAAS.

o Other deficiencies and recommendations in the TPD.

 Dining – Provide yearly employee training in serving people with disabilities.

 Seating Areas

o Interior- recommend providing staff training and an SOP for placement of the 

moveable furniture to assure an accessible space is available out of pedestrian 

routes. If lighting is available for other seats, provide a wheelchair space with 

lighting as well.
56

o Exterior – pave a level landing (that 

extends one foot beyond bench – to 

allow wheelchair user to sit shoulder to 

shoulder with companion on bench) 

adjacent to several of the fixed benches 

around the lawn area. Provide training 

and SOP for placement of rocking chairs 

on porch to integrate wheelchair 

seating and clear maneuvering space.

 

Typical additional pavement to add at existing 

benches:

 
57

 Services

o Front Desk – Provide accessibility training for staff to direct visitors to accessible 

counter and general yearly training on serving people with disabilities. Provide

alternative format lodging information (tactile map of lodging area) to aid 

wayfinding.

o Concierge – provide an accessible counter at this location

o Restrooms – Recommend 

removing sink and mirror to 

provide required clear space next 

to toilet in the accessible stalls in 

lobby restrooms. See TPD for 

additional deficiencies in restrooms 

that need to be addressed.

o Business Center – the alcove is too 

tight to include these programs, 

recommend modifying space, 

removing wing walls and making an accessible business center in this space. 

o After hours’ door bell – move to an accessible location and sign.

 Gift Shop – provide accessible counters in the gift shop

 Auditorium – provide assistive listening devices and sign their availability. Provide staff 

training and SOP for setting up room to be accessible for any program, banquet, or 

meeting taking place here.

Recommended locations for wheelchair spaces (good for strollers as well):
58

 Parking and pedestrian routes

o There are many issues with the parking areas in the Lodge area, see the TPD for 

specific deficiencies and recommendations.

o Lodge Registration and Cafe parking area – Recommend placing a van accessible 

parking space on each side of the island with striped access route to compliant 

curb ramp at cafe:

 Open Air Tram

Findings: The tram is accessible, was not in good working order when evaluated. There is no 

walker/wheelchair storage near the loading area.

Recommendations: Recommend providing yearly training for staff in ramp use and providing 

services to visitors with disabilities. Provide seating and wheelchair storage at the 

loading/unloading area. Provide accessibility information on website and in park newspaper.

Employee spaces and programs – Recommend conducting an SETP for concessions.
59

Park Entrances

Requirements: The entrance stations need to be accessible for visitors and employees with 

disabilities per Section 504 and ABAAS.

Findings: The stations are not accessible for employees.

Recommendations: The transition plan for the East Entrance station with deficiencies and 

recommendations are included in the TPD. Recommend completing the SETP for the South 

entrance station.

Entrance Signs

One of the key experiences in national parks is the photo-op at the iconic entrance signs. This 

experience needs to be accessible to all visitors. Each sign is unique; visitors may only go past 

one sign; all need to be accessible to meet this program.

Findings: The pedestrian entrance sign provides access to this program; all road-side signs are 

inaccessible. Issues: no compliant van accessible parking space, access aisle or accessible route 

to signs.

Recommendations: Provide accessible parking and an accessible route to the sign with clear 

space at sign for maneuvering.

South Entrance sign and parking South Pedestrian Entrance Sign
60

East Entrance Sign and parking Kolob Canyons Entrance Sign and parking

Shuttle Vehicles and Facilities

Shuttle Vehicles: 

Findings and Recommendations:

o The front car of the two-car shuttles is accessible with ramps at the driver’s door,

making this system functional for most visitors with mobility impairments.

o The audio interpretive program provided on the shuttles is not provided in alternative 

formats; recommend providing a written transcript provided on the shuttles, could also 

be a downloadable app that functions without cell phone service or Wifi.

o There is a weight restriction for wheelchairs; these visitors can receive a pass to drive 

their own vehicle into the canyon. Provide information on the website accessibility page 

about shuttle restrictions for wheelchair users. 

o The shuttle ventilation system functions well in most seats, recommend adding a note 

to website information about the shuttles that there is no air conditioning and that 

seats in the middle to rear of the bus are cooler from the windows and roof ventilation 

system for visitors with temperature sensitivities

o The shuttle windows do not open wider than 6” making it difficult for visitors to see and

photograph the canyon. Visitors need to purchase tickets for the open-air tram to have 

clear views. Recommend when shuttles are replaced to provide windows with clear 

views to make this program accessible; the shuttle is the only way some visitors with 

disabilities will see the canyon.

o Staff training in accommodations for visitors with disabilities

o SOP’s
61

The shuttle facilities were not reviewed in this project. Recommend conducting an SETP of the 

entire transportation system. Include:

 Maps and Information

 Shuttle storage/maintenance bldg.

 Staff training

 SOP’s

Park Operations and Headquarters Bldgs.

Park operations and facilities were not reviewed in this project. Recommend conducting an 

SETP of NPS employee facilities, policies, and practices. Include:

 Park Housing

 Administration Building

 Maintenance buildings

 Ranger stations

 Parking

 Programs for staff

 Staff training

 SOP’s

Scenic drives and overlooks 

Requirements:

ABAAS Scoping requirements for Viewing Areas:

F246 Viewing Areas

F246.1 General. Viewing areas, other than viewing areas on trails, shall comply with F246.1.

Advisory F246.1 General. Viewing areas on trails are addressed in F247.4.3.

F246.2 Distinct Viewing Locations. Each distinct viewing location within a viewing area shall comply 

with 1015.

Advisory F246.2 Distinct Viewing Locations. Viewing areas can provide more than 

one distinct viewing location. For example, a viewing area can provide a distinct 

viewing location for observing a mountain range, and another distinct viewing 

location for observing a river. Distinct viewing locations within a viewing area can 

be designated by signs or other markers.

F246.3 Outdoor Constructed Features. Where provided within viewing areas, at least 20 percent, but 

not less than one, of each type of outdoor constructed feature shall comply with 1011.

F246.4 Outdoor Recreation Access Routes. At least one outdoor recreation access route complying 

with 1016 shall connect accessible parking spaces or other arrival points serving the viewing area with 

accessible elements, spaces, and facilities provided within the viewing area.
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Advisory F246.4. Outdoor Recreation Access Routes. There are exceptions in 

1016.1 that can be used where conditions specified in 1019 apply.

Recommendations: There are many overlooks throughout the park, many are without 

sidewalks or other amenities, meant to be viewed from inside the vehicle – these pulloff/overlook areas are used the same way by all visitors and do not discriminate; accessible 

parking, signs, accessible slopes are not required at this type of overlook.

 Scenic drive overlooks – There are several overlooks with the same views along the east 

entrance road, Section 504 program requirements “when viewed in their entirety” 

would apply to these pull-offs with equivalent programs. Recommend altering all pulloffs that can be made accessible with minimal alterations when alterations are made to 

these pull-offs. (minimal in this context is if the alteration does not cost more than 20%

of the overall alteration to make the facility accessible)

 Waysides – Waysides need to be accessible to visitors with disabilities. This requires:

o an accessible van parking space, access aisle, and an accessible route to wayside

with turning space and clear floor space at wayside.

o wayside should be placed for a forward approach, on a firm and stable surface 

with height from the ground surface to exhibit frames at exactly 27” to meet 

protruding object and clear knee space ABAAS requirements. 

o information provided on the wayside needs to be in an accessible font and

provide an alternative format for the blind.

 Restrooms – Restrooms provided at pull-offs need to be accessible, all are at different 

locations along the scenic drives and do not meet the requirements of “viewed in their 

entirety”.

 Parking at the east tunnel portal – recommend moving the accessible space to the level 

side of the parking lot and provide accessible route to restroom and ranger station:
63

Corral - Horseback Rides

Requirements: This program is required to be accessible per Section 504 of the Rehabilitation 

Act. 

Findings: Canyon Trail Rides operates this program in the park. In interviewing the staff, 

several issues were identified: 

o they have many people with mobility impairments that go on the rides; users have a 

difficult time making their ride time due to shuttle wait time and distance from lodge 

shuttle stop to corral, (the scheduled rides cannot wait for latecomers);

o there is no accessible parking for the corral and no accessible route from the parking 

area to the check-in building; 

o there are no accessible amenities provided: covered porch is not accessible; no 

wheelchair storage; no horse mounting ramp provided, riders cannot transfer to 

horseback from a ramped platform, they must be lifted by staff

o website does not provide information on accessibility
64

Recommendations: Recommend providing a van accessible parking space, and accessible 

routes to all visitor use areas; provide access to the covered porch and an accessible seating 

space and horse mounting ramp. Provide training for staff on providing services for people 

with disabilities. Recommend providing an SOP to allow people with disabilities with 

reservations for a trail ride to obtain a pass to drive their own vehicle to this location.
65

Suggested Portable Ramp solution (provide a mounting block as well for helpers to use):

The Handi-Ramp Portable Horse Mounting Ramp:

 Portability – Our aluminum mounting ramp can be stored in pieces and transported in the 

back of a pickup truck. It can be assembled wherever it is needed in 3 minutes by 2 people 

without any tools or special skills.

 Walking surface – Made from our 360° Non-Slip aluminum walking surface, the same 

surface used in our wheelchair ramp systems for homes and businesses. The surface 

requires no special treatment or maintenance and can be cleaned completely with a 

garden hose.

Horse Mounting Ramp

800-876-RAMP (7267)

Trails

Zion Canyon has many trails to hike, almost all of them start on the flat valley floor then quickly 

begin to climb the steep, vertical walls of the canyon. Trails in the park (from park website):

 Pa’rus Trail - accessible

 Archeology Trail

 Lower Emerald Pool Trail

 The Grotto Trail

 Weeping Rock Trail

 Riverside Walk - accessible

 Watchman Trail

 Sand Bench Trail

 Upper Emerald Pool Trail

 Kayenta Trail

 Canyon Overlook Trail

 Taylor Creek Trail
66

 Timber Creek Overlook Trail

 Angels Landing via West Rim Trail

 Hidden Canyon Trail

 Observation Point via East Rim Trail

 The Narrows via Riverside Walk

 Kolob Arch via La Verkin Creek Trail

Requirements: 

ABAAS Excerpts for Trails and Beach Access Requirements

F247 Trails

F247.1 General. Where a trail is designed for use by hikers or pedestrians and directly connects to a 

trailhead or another trail that substantially meets the requirements in 1017, the trail shall comply with 

1017.

Advisory F247.1 General. The Federal Trail Data Standards classify trails by their 

designed use and managed use. A trail has only one designed use that determines the 

design, construction, and maintenance parameters for the trail. A trail can have more 

than one managed use based on a management decision to allow other uses on the 

trail. Trails that have a designed use for hikers or pedestrians are required to comply 

with 1017. Trails that have a designed use for other than hikers or pedestrians are 

not required to comply with 1017.

A trail system may include a series of connecting trails. Only trails that directly connect to a trailhead 

or another trail that substantially meets the requirements in 1017 are required to comply with 1017.

F247.2 Existing Trails. Where the original design, function, or purpose of an existing trail is changed 

and the altered portion of the trail directly connects to a trailhead or another trail that substantially 

meets the requirements in 1017, the altered portion of the trail shall comply with 1017.

Advisory F247.2 Existing Trails. Routine or periodic maintenance activities that are 

performed to return an existing trail to the condition to which the trail was originally 

designed are not required to comply with 1017.

F247.3 Trailheads. Trailheads shall comply with F247.3.

Advisory F247.3 Trailheads. Trailhead information signs are addressed in F216.13.

F248 Beach Access Routes

F248.1 General. Beach access routes complying with 1018 shall be provided in accordance with 

F248.1. Beach access routes shall be permanent or removable.

EXCEPTION: Beach access routes shall not be required where pedestrian access to the beach is not 

permitted.

Advisory F248.1 General. There are exceptions in 1018.1 that can be used where 

conditions specified in 1019 apply. Removable beach access routes can be moved to a 

protected storage area during storms and other periods when the routes are subject to 

damage or loss.

1018 Beach Access Routes

1018.1 General. Beach access routes shall comply with 1018.
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EXCEPTIONS: 1. When an entity determines that a condition in 1019 does not permit full compliance 

with a specific provision in 1018 on a portion of a beach access route, the portion of the beach access 

route shall comply with the provision to the extent practicable.

1018.2 Connections. Beach access routes shall connect an entry point to the beach to the:

1. High tide level at tidal beaches;

2. Mean high water level at river beaches; or

3. Normal recreation water level at lake, pond, and reservoir beaches.

1018.3 Surface. The surface of beach access routes and resting intervals shall be firm and stable.

1018.4 Clear Width. The clear width of beach access routes shall be 60 inches (1525 mm) minimum.

Findings: None of the trails is the park meet the requirements in ABAAS for accessible trails. 

Trailheads do not meet requirements for an accessible van parking space with access aisle. 

Almost all trails, within 100 yards from the trailhead, become too steep to make accessible 

without extreme cuts and fills that will negatively impact the natural resources in the valley. 

The Riverside Walk ends with steps down to the river, there is no accessible route (ABAAS 

beach access route) to the river edge in the park; river play is a key activity during the summer 

months.

There are no accessible backcountry trail experiences in Zion National Park, although not 

required by the wilderness act or ABAAS, experiencing the backcountry wilderness is a core 

value and key experience in the park.
68

Recommendations:

Recommend focusing on providing accessible trail experiences in Zion N.P. on the Pa’rus Trail, 

Riverwalk Trail including access to the river, and backcountry trail to campsite (by horseback) at 

Hop Valley. Recommend completing a transition plan for these three trails. Identify key 

inaccessible trail experiences to 

provide in alternative format 

including the Court of the 

Patriarchs at waysides at the 

shuttle stop, a wayside and 

tactile model of Angels Landing 

chain climbing trail section 

(location? – lodge?), Great 

White Throne tactile model at 

the overlook, etc. 

Provide accessible parking, 

route to restroom and a horse 

transfer station at the Hop 

Valley trailhead and a freestanding transfer station 

at the backcountry campsite in the valley to make 

this an accessible experience. When completed, 

provide information on the website and let disability 

organizations know about it.

Study potential of providing accessible trails at the 

top of the canyon on the east side of park to 

provide accessible views into the canyon.

Shuttle stops 

There are nine shuttle stops in the main canyon:

1. Zion Visitor Center – see evaluation under Zion Visitor Center in this document

2. Human History Museum - see evaluation under Human History Museum in this 

document

3. Canyon Junction

4. Court of Patriarchs

5. Zion Lodge – see evaluation under the Lodge in this document

6. The Grotto – see evaluation under The Grotto Picnic Area in this document

7. Weeping Rock
69

8. Big Bend

9. Temple of Sinawava

Requirements:

Programs, services and activities provided at the shuttle stops need to be accessible to people 

(visitors and employees) with disabilities.

Canyon Junction

From park website: The junction of the Zion-Mt. Carmel Highway and the Zion Canyon Scenic 

Drive Views of the Virgin River and Zion Canyon. Access to the Pa’rus Trail.

Findings: The Pa’rus trail connects this shuttle stop with the visitor center. The trail drops 

steeply to go under the bridge of the main canyon road; this section far exceeds maximum 

slopes allowed by ABAAS. The shelters do not provide integrated accessible seating.

Recommendations: Recommend regrading this area to make the starting section of the 

Pa’rus trail accessible – it is one of the opportunities to provide an accessible trail in Zion 

National Park.

Court of the Patriarchs

From park website: Short and steep trail to viewpoint Views of Abraham, Isaac, and Jacob 

Peaks, Mount Moroni, and The Sentinel.

Findings: The trail to the overlook does not meet ABAAS accessibility standards. The 

interpretive waysides for this geological feature are located at the inaccessible overlook.
70

Recommendations: Recommend providing the waysides at the overlook in an accessible 

location at one of the shuttle stops as well. Conduct an evaluation of the trail to the 

overlook and measure site amenities and complete a transition plan for this area.

Weeping Rock

From park website: Dripping springs create hanging gardens Restrooms. Ranger-led programs. 

Views of Angels Landing and Big Bend. Access to the Weeping Rock Trail, East Rim Trail, Hidden 

Canyon Trail, and Observation Point Trail.

Findings: There is no compliant accessible route from the shuttle stop to the trailhead. The 

seating/gathering space does not provide a level space for wheelchair seating and all seating is 

in the busy path of travel to the trail (important to provide a shaded waiting space as the trail is 

not accessible).
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Recommendations: Provide a compliant accessible route from shuttle drop-off to trailhead 

and restrooms. The trail should be made accessible to the point the grades exceed those 

allowed by ABAAS, and provide a covered seating area (numbered spaces below are 

suggested locations) with interpretation about the resource, and tactile model.

Big Bend

From park website: Sweeping bend in the Virgin River with towering cliffs above Ranger-led 

programs. Views of the Virgin River, Angels Landing, and The Great White Throne.

Findings: There is no accessible parking space with access aisle provided in this parking area. 

One van accessible parking space is required. Appears there is inadequate clear floor space 

under shelter for wheelchair.
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Recommendations:

Add a van accessible parking space and access 

route to site amenities. Provide wheelchair 

space under shelter – there is adequate clear 

space at the center bench, recommend 

removing bench section in center to provide 

wheelchair space (red outlined rectangle on 

sketch. ABAAS requirement for seating areas 

for four or more people is for an integrated 

wheelchair seating space (ability to sit shoulder 

to shoulder with companion). Appears a 

wheelchair will fit under the shelter roof, but is 

not equivalent to the fixed benches provided 

for getting away from rain, snow, etc. 

Recommend completing the SETP for this park 

area including all measurements to determine 

most cost-effective way to provide access.
73

Temple of Sinawava

From park website: The gateway to The Narrows Restrooms and water bottle filling station. 

Ranger-led programs. Access to the Riverside Walk, Virgin River, and The Narrows.

Findings: The shuttles load and unload in the travel lane for the parking area – visitors 

enter and exit buses on the pavement of the off-season parking instead of onto the sidewalk 

(curb height) as in all other stops. The wheelchair lift does reach the pavement level, but 

visitors in the rear shuttle have to step down a very high, unexpected step. The two buses 

are unloading and loading at the same time, similar to operations at the visitor center. The 

curb length and turning radii do not allow two shuttles at the curb at the same time. Other 

findings:

 The accessible route to the restrooms is only by the outermost paths on each end of the 

parking area

 Restrooms appear to have same issues as those measured for the transition plans 

included in the scope of this project.

Recommendations: Recommend adding handrails on ramp section from shelter to 

restroom, extending the curb length at the loading/unloading zone with compliant curb 

ramp for accessible parking with adequate curb radius to allow shuttles to smoothly drive 

through drop-off:
74

Recommend completing the SETP for this park area including accessible trails and river access.

1.9 §17.550 (d) Transition Plan.

Requirements:

If structural changes to facilities are necessary to achieve program accessibility, the park is 

required to develop a transition plan identifying the steps necessary to complete such changes. 

The plan needs to be developed with the assistance of interested persons, including individuals 

with disabilities or organizations representing individuals with disabilities. A copy of the 

transition plan needs to be made available for public inspection. The plan includes, at a 

minimum—

(1) Identify physical obstacles in the agency's facilities that limit the accessibility of its 

programs or activities to individuals with disabilities;

(2) Describe in detail the methods that will be used to make the facilities accessible;

(3) Specify the schedule for taking the steps necessary to achieve compliance with this 

section and, if the time period of the transition plan is longer than one year, identify steps that 

will be taken during each year of the transition period;

(4) Indicate the official responsible for implementation of the plan; and

(5) Identify the persons or groups with whose assistance the plan was prepared.

Findings: 

Zion National Park does not have a Transition Plan on file.

The park and MTC determined the following park areas for Zion National Park. The highlighted 

areas were determined to be the highest priorities for making the park more accessible to 

visitors with disabilities and are included in this Self-evaluation and Transition Plan for High 

Priority Areas:

Zion Park Areas and Facilities Provided

Highlighted Areas Are Included in this Self-evaluation and Transition Plan Database (TPD)

 South Entrance Area

o Zion Canyon Visitor Center

 Shuttle stop

 Plaza, restrooms, gift shop, 

exhibits, films, etc. 

(includes all programs 

 South Entrance Area

o South Entrance Station

o South Campground

 Transportation System

o Shuttle stops

o Amenities at shuttle stops –
75

taking place here).

 Picnic area

o Zion Human History Museum

o Pedestrian Entrance Station

o Watchman Campground

o Nature Center

o Ranger led Programs

o Junior Ranger Program

 Zion Lodge Area

o Lodging

o Dining

o Grotto Picnic Area

o Parking and pedestrian routes

o Shuttle Stop

o Open Air Tram Loading Area

o Horseback rides

 East Entrance Area

o Entrance sign and parking

o Entrance station

o Restroom

o Overlooks/pull-outs

 Kolob Canyons Area

o Visitor Center

o Parking and pedestrian routes

o Scenic drive overlooks

o Scenic drive restroom

restrooms, seating areas, 

trailheads, etc.

o Vehicles

o Maps and Information

o Shuttle storage/maintenance bldg.

o Open Air Tram

 Trails and Wilderness Use

o Trails

o River access, river play

o Wilderness programs and policies

o Identify key inaccessible trail 

experiences to provide in 

alternative format

 Lava Point Campground

o Campsites

o Comfort Station

o Amenities

o Trail, and Outdoor Access Routes

 Park Administration 

o Maintenance and Headquarters 

Bldgs./Areas

o Special use Buildings

o Housing areas

 Concession Administration

o Maintenance and Headquarters 

Areas

o Employee areas, parking, rec.

o Housing

o Employment policies

Recommendations:

This Self-evaluation of policies and practices and evaluation of non-discrimination in park 

programs (SE) identifies park programs and experiences and prioritizes park areas and physical 

assets to be assessed in park area Transition Plans. The park should continue to review all 

programs and facilities to assure non-discrimination: The Zion SETP is not up to date until all 

park areas and programs are evaluated.

MTC utilizes a Transition Plan Database (TPD) to identify physical barriers found; recommend 

methods to remove these barriers; and provide a customizable schedule for barrier removal. 

The TPD is converted to an Excel spreadsheet for the park, known as the TPD. The TPD is 

sortable by asset, API, level of difficulty, type of work etc. 
76

Example Transition Plan Database:

1.10 §17.551 Program accessibility: New construction and alterations.

Requirements:

Each building or part of a building that is constructed or altered by, on behalf of, or for the use 

of the agency shall be designed, constructed, or altered so as to be readily accessible to and 

usable by people with disabilities. 

Findings: 

Zion National Park has applicable construction planned at this time.

Recommendations:

All new construction or covered alterations should meet the requirements of Section 504, 

the Architectural Barriers Act Accessibility Standards (ABAAS) and other applicable codes, laws 

and regulations.
77

1.11 §17.560 Effective Communications.

Requirements:

The park is required to take appropriate steps to ensure effective communication with 

applicants, participants, personnel of other Federal entities, and members of the public.

(1) The park needs to furnish appropriate auxiliary aids where necessary to afford individuals 

with disabilities an equal opportunity to participate in, and enjoy the benefits of, a program or 

activity conducted by the agency.

Findings: 

Zion offers auxiliary aids for the shuttle rides, film in Museum of Human History. Additional 

findings are included under specific topics.

Recommendations:

Provide assistive listening devices for all amphitheaters, auditoriums and for large ranger 

talks.

1.12 §17.570 Compliance procedures.

Requirements:

The park is required to adopt and publish grievance procedures providing prompt and 

equitable resolution of complaints alleging discrimination on the basis of disability in programs 

or activities conducted by the park.

Findings: 

ZION does not have grievance procedures published on website and in park newspaper.

Additional findings are included under specific topics.

Recommendations:

Provide and publish grievance procedures for providing resolution of complaints.

From NPS.gov Accessibility website:

Filing a Complaint

If an individual with a disability or his or her representative believes that the NPS has not complied with 

any of the above-named accessibility laws, he or she can file a disability rights complaint as explained on 

this website. Complaints may be filed by sending a letter to the National Park Service Equal Opportunity 

Program Office. 

Filing A Disability or Accessibility Complaint with the NPS:
78

An individual may file a disability rights complaint with us regarding any aspect of the National Park 

Service’s operations.

In filing a complaint with us, the complaint must be in writing, signed and dated, and filed no later than 

180 days from the date of the alleged discrimination. The complaint should include your name, address, 

zip code, and telephone number; the name and address of the alleged discriminatory official(s) and/or 

public entity; the nature of the complaint and the date the alleged discrimination occurred. The 

complaint may be filed directly with the EEO Program Manager, National Park Service, 1849 C. Street 

NW, (0008), Washington, D.C. 20240.

Technical guidance for filing a complaint is available in a variety of formats: (this document is included in 

Appendix B, under title - NPS Section 504 Complaint Process Directive)

Requirements for Concessioner and Contracted programs (43 CFR Part 17, Subpart B):

Concessions

This section applies to programs provided by concessions and contractors (non-federal 

employees). Programs that take place in one of the facilities covered by transition plans 

included in this document are included in those sections. Employee programs and facilities 

were not reviewed in this project. Recommend requiring concessioners to conduct a Selfevaluation and Transition Plan of employee programs, employment practices and facilities. Key 

topics included in Section 504 to cover:

§17.201 Application.

§17.203 Discrimination prohibited.

§17.205 Remedial action, voluntary action, and self-evaluation.

§17.206 Designation of responsible employee and adoption of grievance procedures.

§17.207 Notification.

§17.210 Employment practices.

§17.211 Reasonable accommodation.

§17.212 Employment criteria.

§17.217 Existing facilities.

§17.218 New construction.

§17.260 Historic Preservation Programs.

§17.270 Recreation.

Programs to evaluate include:
79

 Employee Living areas

o housing

 Dorms

 Apartments

 House

o Recreation (interior/exterior)

o Dining

o Laundry

o Restrooms and showers

o Parking

o Other amenities

 Concession operations

o Maintenance facilities

o Vehicles

o Service areas

o Housekeeping

o Kitchen and bar areas

2. 36 CFR Parts 1 – 7 and the Superintendents Compendium

The Superintendent’s Compendium is the summary of park specific rules implemented 

under 36 Code of Federal Regulations (36 CFR). It serves as public notice, identifies areas closed 

for public use, provides a list of activities requiring either a special use permit or reservation, 

and elaborates on public use and resource protection regulations pertaining specifically to the 

administration of the park. The Superintendent’s Compendium does not repeat regulations 

found in 36 CFR and other United States Code and CFR Titles, which are enforced without 

further elaboration at the park level. 

The regulations contained in 36 CFR, Parts 1-7, are the basic mechanism used by the 

National Park Service (NPS) to preserve and protect the natural and cultural resources of the 

park and to protect visitors and property within the park. Parts 1 through 6 are general 

regulations applicable to all areas of the National Park system, and Part 7 contains special 

regulations specific to individual parks. Each of these Parts has many sections and subsections 

articulating specific provisions. Within some of these Part 1-7 sections and subsections, the 

Superintendent is granted discretionary authority to develop local rules to be responsive to the 

needs of a specific park resource or activity, park plan, program, and/or special needs of the 

general public.
80

2.1 36 CFR PART 1 — General Provisions (§§ 1.1 - 1.10)

§ 1.5 Closures and public use limits. 

(a) Consistent with applicable legislation and Federal administrative policies, and based 

upon a determination that such action is necessary for the maintenance of public health and 

safety, protection of environmental or scenic values, protection of natural or cultural resources, 

aid to scientific research, implementation of management responsibilities, equitable allocation 

and use of facilities, or the avoidance of conflict among visitor use activities, the superintendent 

may: 

(1) Establish, for all or a portion of a park area, a reasonable schedule of visiting hours, 

impose public use limits, or close all or a portion of a park area to all public use or to a 

specific use or activity. 

(2) Designate areas for a specific use or activity, or impose conditions or restrictions on a 

use or activity. 

§ 1.6 Permits. 

(a) When authorized by regulations set forth in this chapter, the superintendent may issue a 

permit to authorize an otherwise prohibited or restricted activity or impose a public use limit. 

§ 1.7 Public notice.

Requirements:

The Superintendent’s Compendium public use limits and area designations should not 

discriminate against individuals with disabilities, unless use restrictions are required to prevent 

resource damage greater than standard use allowed. Provide Section 504 compliant use limits, 

permit process, and accessible public notices.

Findings: 

ZION restricts the use of mobility devices in wilderness areas to non-motorized wheelchairs 

only. Research Natural Areas (RNAs) are closed to all recreational use. Excerpt from ZION 2015

Compendium:

(a)(1)(xi) The Zion wilderness (including the area of the park within Kane County which has 

been recommended to congress for wilderness designation), is closed to the possession or use 

of any mechanical equipment for moving people or material in or over land, water, snow or air. 

This includes, but is not limited to, non-motorized wheeled vehicles, conveyances and 

devices, such as bicycles, SegwaysTM and other Electric Personal Assistance Mobility Devices 

(EPAMD), carts, game carriers, canoe dollies, wheelbarrows, wagons, ski kites, hang gliders and 
81

paragliders. Wheelchairs as defined in Title V Section 507(c) of the Americans with Disabilities 

Act (ADA) may be used by persons with disabilities. 

Justification: The Wilderness Act of 1964 prohibits certain uses in areas included within the 

national wilderness preservation system including any form of mechanical transport.

Recommendations:

These restrictions meet ABAAS, Wilderness Act and NPS policy. Recommend including policy 

on accessibility page of park website.

2.2 36 CFR PART 2 — Resource Protection, Public Use and Recreation (§§ 2.1 - 2.62)

36 CFR Part 2 provides regulations for protecting park natural and cultural resources and 

regulations for public use and recreation. Key sections to verify Section 504 compliance in the 

Superintendent’s Compendium:

§ 2.1(a)(5) Walking on, climbing, entering, ascending, descending, or traversing an 

archeological or cultural resource, monument, or statue, except in designated areas and under 

conditions established by the superintendent.

§ 2.10 Camping - designated sites, areas, conditions and permits 

§ 2.11 Picnicking - designated areas 

§ 2.15 Pets. 

(a) The following are prohibited: 

(1) Possessing a pet in a public building, public transportation vehicle, or location 

designated as a swimming beach, or any structure or area closed to the possession of pets by 

the superintendent. This subparagraph shall not apply to guide dogs accompanying visually 

impaired persons or hearing ear dogs accompanying hearing-impaired persons.

Requirements:

The Superintendent’s Compendium resource protection, public use and recreation use 

limits and designations should not discriminate against individuals with disabilities, unless use 

restrictions are required to prevent resource damage greater than standard use allowed. 

Provide Section 504 compliant use limits, permit process, and designations.

Findings: 

ZION has use limits identified for the preservation of natural and cultural resources. Part 

2.15 Pets restricts pets except service dogs. Part 2.16 identifies horse use limits and designated 

parking; there is no designated accessible parking or horse mounting ramp provided for Hop 

Valley backcountry horse trail and campsite. Excerpts from ZION 2015 Compendium:

§2.10 Camping and Food Storage
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Requirements:

The Superintendent’s Compendium camping and food storage limits should not 

discriminate against individuals with disabilities, unless use restrictions are required to prevent 

resource damage greater than standard use allowed. Provide Section 504 compliant use limits.

Findings: 

ZION camping and food storage use limits are the same for all users and do not 

discriminate.

Recommendations:

Although the use limits are the same, there are uses not available to people with 

disabilities: there are no accessible backcountry campsites, walk-in tent or group campsites 

identified. Food is required to be stored in bear-proof boxes, these are not accessible. 

Recommend making these programs accessible to people with mobility impairments.

§2.15 Pets 

(a)(1)(i) Pets are prohibited on all trails (with the exception of the Pa’rus trail) and in the 

wilderness. This prohibition does not include service animals. 

No pets, other than service animals, are allowed on the park transportation shuttle buses. 

Pet excrement must be picked up from all areas within Zion National Park. 

Park employees residing in the park may keep pets in accordance with Zion National Park 

Housing Plan. 

Properly restrained pets are allowed along public roads and parking areas (generally within 100 

feet of the road surface), in the developed campgrounds and picnic areas, and on the grounds 

of the Zion Lodge. 

Justification: Consistent with public health and safety, protection of natural resources and 

avoidance of conflict among visitor use activities, pets must be restricted. The burden is placed 

on pet owners to assure their pets do not destroy park values for others in those areas where 

they are allowed. Pet disposal stations are provided along the Pa’rus Trail for this purpose.

§2.16 Horses and Pack Animals 

(a) “Saddle stock” is defined, for purposes of the Zion National Park General Management Plan, 

as stock carrying either riders or equipment/supplies and is limited to horses, mules, and 

burros. 
83

“Pack animals,” for purposes of 36 CFR 2.16(a) are defined as mules and burros. Llamas, goats, 

dogs, and all other animals are specifically excluded for use as pack animals within Zion 

National Park. 

(b) The use of saddle stock or pack animals is prohibited, except in the following areas: 

The following trails are open to horse or pack animal use: 

- LaVerkin Creek Trail west of Beartrap Canyon 

- Hop Valley Trail 

- Connector Trail 

- Northgate Peaks Trail 

- Wildcat Canyon Trail 

- West Rim Trail north of Cabin Spring 

- Sawmill Spring Trail 

- Telephone Canyon Trail 

- East Mesa Trail east of the Observation Point Trail junction 

- East Rim Trail south of Stave Spring 

- Deer Trap Mountain Trail 

- Cable Mountain Trail 

- Chinle Trail 

- Sandbench Trail (open to public use from November 1 to March 1 only) 

Off-trail use of horses or pack animals is permitted only in: 

- Lower Coalpits Wash from the trailhead to the junction with Scoggins Wash 

- Scoggins Wash 

- Huber Wash 

Horse or pack animal use on wilderness trails is prohibited during spring thaws, during 

unusually wet periods, and at other times when, at the Superintendent’s discretion, use would 

cause undue trail damage. 

NPS administrative uses are exempt in these areas for the purpose of resource/visitor 

protection and the utilization of minimum tool for trail maintenance. 
84

(g)(1) Grazing of horses or pack animals within park boundaries is prohibited. 

Stock must be fed only certified weed-free feed 24 hours prior to entering the wilderness. Stock 

users are required to pack feed such as grain or pellets that are certified as weed-free. This feed 

must be protected from animal depredation and any unused feed must be packed out. A feed 

bag must also be used in the wilderness. Stock manure must be collected upon unloading and 

loading from trailers with the manure removed from the park to reduce the potential for exotic 

plant introduction. 

(g)(2) Overnight camping with horses or pack animals is limited to Hop Valley Site A, and is 

permitted for one night only. 

(g)(3) Horses or pack animals will be hobbled or tethered on a high line (6-7 feet) between 

trees, or otherwise restrained in a manner preventing damage to trees. Animals will not be 

picketed or tied to a single tree. 

(g)(4) Horses or pack animals will be kept more than 200 feet from any spring, stream, or other 

water source unless in the act of watering, riding or leading the animal near or across the water 

as a necessary function of wilderness travel. 

(g)(5) A maximum of 6 horses or pack animals are allowed in any single party traveling in Zion 

National Park. These groups may not be split up as referenced in section 1.5 (a)(2)(xiii). 

The contracted concessionaire is excluded from this restriction while traveling along the 

Sandbench Trail for commercial horse trail rides. 

Justification: Stock and pack animals are defined as horses, mules, and burros for the purpose 

of this regulation. Stock use within the park is historically documented and their continued 

presence is conditionally permitted. Consistent with public health, protection of environmental 

values and natural resources, and avoidance of conflict among visitor use activities, the 

Superintendent has determined that restriction of horse and saddle stock is necessary. 

The LaVerkin Creek drainage is not suitable for overnight-pack stock use due to designated 

campsites that are heavily used and not adequate for stock tethering, picketing, or high-lining. 

Tying of animals is necessary to minimize resource damage, pollution of water sources and 

destruction of vegetation. 

The Kolob Arch trail is not appropriate for saddle stock as it involves scrambling over large 

boulders, steep slickrock, and stream bottom areas. 

Beartrap Canyon and Willis Creek are narrow canyons characterized by no maintained trail, a 

number of steep banks, slopes, and stream bottom areas, which make the route unsuitable for 

stock use. 
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The East Mesa Trail below its junction with the Observation Point Trail and Zion Canyon trails 

from the rim to the canyon floor are heavily traveled by hikers, and the trails are often steep 

and narrow. 

Restricting the presence of animals in developed areas is necessary to maintain a non-offensive 

and sanitary condition in these areas of intensive use. 

For the safety of riders, the Sandbench Trail is closed to non-concessionaire use during the 

operation of the concessionaire-contracted trail rides. 

The Taylor Creek Trail, a front country route, is characterized by numerous steep creek banks, 

steep slopes, and numerous short stream crossings. Large groups of stock with riders create 

unacceptable resource impacts while standing/stopping in fragile riparian and canyon areas. 

Due to problems with the spread of noxious/exotic weeds, all stock using Zion National Park 

must be fed only certified weed-free hay and feed 24 hours prior to entering the park and using 

park trails.

Recommendations:

Part 2.16 Horses and pack animals identifies camping at Hop Valley Site A campsite –

provide accessible amenities and horse transfer system to make this program accessible. Add to 

accessibility, things to do and stock use pages on the park website.

Park website horse use information:

Zion National Park Service

U.S. Department of the 

Interior

Hop Valley Trail

Campsite A and view from the site 
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Campsite A (#1) Horse Camp

This is a designated stock camp or suitable for large groups. The main trail crosses Hop Creek 

at this point to begin the ascent through the forest towards the La Verkin Creek Junction. 

There is great shade provided by the ponderosa trees around the site. This site has a maximum 

group size of 12 and is available for walk-up permit only.

Stock Use

Trails

Check the Wilderness Map to find out what trails open to stock use. Where trails are present, 

stock animals must remain on trails. Free trailing or loose herding is not allowed. Maintain a 

slow walk when passing hikers. When standing, stock must be kept at least 100 feet from 

drainages. Off-trail use is permitted only in Lower Coalpits Wash from the trailhead to the 

junction with Scoggins Wash, in Scoggins Wash, and in Huber Wash.

Overnight Trips

The only overnight stock camp is Hop Valley Site A and your stay is limited to one night. A 

permit is required. Stock must be hobbled or tethered to reduce damage to vegetation. To 

reduce the spread of noxious and exotic weeds, stock must be fed certified weed-free hay two 

days prior to the trip.

2.3 36 CFR PART 3 — Boating and Water Use Activities (§§ 3.1 - 3.19)

Requirements:

The Superintendent’s Compendium boating and water use limits and designations should 

not discriminate against individuals with disabilities, unless use restrictions are required to 

prevent resource damage greater than standard use allowed. Provide Section 504 compliant 

use limits, permit process, and designations including designated launching areas.

Findings: 

ZION has no boating uses. 

Recommendations:

N/A

2.4 36 CFR PART 4 — Vehicles and Traffic Safety (§§ 4.1 - 4.31) 

Requirements:

The Superintendent’s Compendium vehicle use limits should not discriminate against 

individuals with disabilities, unless use restrictions are required to prevent resource damage 

greater than standard use allowed. Provide Section 504 compliant use limits.
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Findings: 

ZION has no additional vehicle use limits in the Compendium.

Recommendations:

N/A

2.5 36 CFR PART 5 — Commercial and Private Operations (§§ 5.1 - 5.14) 

§ 5.8 Discrimination in employment practices. 

(a) The proprietor, owner, or operator of any hotel, inn, lodge or other facility or 

accommodation offered to or enjoyed by the general public within any park area is prohibited 

from discriminating against any employee or maintaining any employment practice which 

discriminates because of race, creed, color, ancestry, sex, age, disabling condition, or national 

origin in connection with any activity provided for or permitted by contract with or permit from 

the Government or by derivative subcontract or sublease. As used in this section, the term 

“employment” includes, but is not limited to, employment, upgrading, demotion, or transfer; 

recruitment, or recruitment advertising; layoffs or termination; rates of pay or other forms of 

compensation; and selection for training including apprenticeship. 

(b) Each such proprietor, owner or operator shall post either the following notice: 

Notice

This is a facility operated in an area under the jurisdiction of the United States Department 

of the Interior. No discrimination in employment practices on the basis of race, creed, color, 

ancestry, sex, age, disabling condition, or national origin is permitted in this facility. Violations 

of this prohibition are punishable by fine, imprisonment, or both.

Complaints or violations of this prohibition should be addressed to the Director, National 

Park Service, P.O. Box 37127, Washington, D.C. 20013-7127.

or notices supplied in accordance with Executive Order 11246 at such locations as will 

ensure that the notice and its contents will be conspicuous to any person seeking employment.

§ 5.9 Discrimination in furnishing public accommodations and transportation services. 

(a) The proprietor, owner or operator and the employees of any hotel, inn, lodge, or other 

facility or accommodation offered to or enjoyed by the general public within a park area and, 

while using such a park area, any commercial passenger-carrying motor vehicle service and its 

employees, are prohibited from: (1) Publicizing the facilities, accommodations or any activity 

conducted therein in any manner that would directly or inferentially reflect upon or question 

the acceptability of any person or persons because of race, creed, color, ancestry, sex, age, 
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disabling condition, or national origin; or (2) discriminating by segregation or otherwise against 

any person or persons because of race, creed, color, ancestry, sex, age, disabling condition, or 

national origin in furnishing or refusing to furnish such person or persons any accommodation, 

facility, service, or privilege offered to or enjoyed by the general public. 

(b) Each such proprietor, owner, or operator shall post the following notice at such 

locations as will insure that the notice and its contents will be conspicuous to any person 

seeking accommodations, facilities, services, or privileges: 

Notice

This is a facility operated in an area under the jurisdiction of the U.S. Department of the 

Interior.

No discrimination by segregation or other means in the furnishing of accommodations, 

facilities, services, or privileges on the basis of race, creed, color, ancestry, sex, age, disabling 

condition or national origin is permitted in the use of this facility. Violations of this prohibition 

are punishable by fine, imprisonment, or both.

Complaints of violations of this prohibition should be addressed to the Director, National 

Park Service, P.O. Box 37127, Washington, D.C. 20013-7127.

Requirements:

Employment practices: public accommodations and services are required to post notices of 

non-discrimination in public and employee spaces at such locations as will ensure that the 

notice and its contents will be conspicuous to any person seeking employment.

Public accommodations and transportation services are required to provide notice at such 

locations as will insure that the notice and its contents will be conspicuous to any person 

seeking accommodations, facilities, services, or privileges: 

Findings: 

MTC did not verify required notices posted at ZION.

Recommendations:

Provide (verify) notices of non-discrimination are posted in public, concession and 

employee (NPS and concession) spaces.
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2.6 36 CFR PART 7 — Special Regulations, Areas of The National Park System (§§ 7.1 -

7.100)

Requirements:

The Superintendent’s Compendium special regulations should not discriminate against 

individuals with disabilities, unless use restrictions are required to prevent resource damage 

greater than standard use allowed. Provide Section 504 compliant special regulations.

Findings: 

§7.10 Zion National Park.

(a) Vehicle convoy requirements. (1) An operator of a vehicle that exceeds load or size 

limitations established by the superintendent for the use of park roads may not operate such 

vehicle on a park road without a convoy service provided at the direction of the 

superintendent.

(2) A single trip convoy fee of $15 is charged by the superintendent for each vehicle or 

combination of vehicles convoyed over a park road. Payment of a convoy fee by an operator of 

a vehicle owned by the Federal, State or county government and used on official business is not 

required. Failure to pay a required convoy fee is prohibited.

(b) Snowmobiles. After consideration of snow and weather conditions, the superintendent may 

permit the use of snowmobiles on designated routes within the park. Snowmobile use is 

restricted to the established roadway. All off-road use is prohibited. The designated routes are 

defined as follows: 

(1) All of the paved portion of the Kolob Terrace Road from the park boundary in the west onehalf of Sec. 33, T. 40 S., R. 11 W., Salt Lake Base and Meridian, north to where this road leaves 

the park in the northwest corner of Sec. 16, T. 40 S., R. 11 W., SLBM. This paved portion of the 

Kolob Terrace Road is approximately three and one-half miles in length. 

(2) All of the unplowed, paved portions of the Kolob Terrace Road from the park boundary, 

north of Spendlove Knoll, in Sec. 5, T. 40 S., R. 11 W., SLBM, north to where this road leaves the 

park in the southwest corner of Sec. 23, T. 39 S., R. 11 W., SLBM, a distance of approximately 

five miles. 

(3) The unplowed, graded dirt road from the park boundary in the southeast corner of Sec. 13, 

T. 39 S., R. 11 W., SLBM, south to Lava Point Fire Lookout in the northwest quarter of Sec. 31, T. 

39 S., R. 10 W., SLBM, a distance of approximately one mile. 

(4) The unplowed, graded dirt road from the Lava Point Ranger Station, southeast to the West 

Rim Trailhead and then to a point where this road divides and leaves the park, in the southeast 
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corner of Sec. 30, and the northeast corner of Sec. 31, T. 39 S., R. 10 W., SLBM, a distance of 

approximately two miles. 

(5) The unplowed, graded dirt road from the Lava Point Ranger Station, north to the park 

boundary where this road leaves the park, all in the southeast corner of Sec. 13, T. 39 S., R. 11 

W., SLBM, a distance of approximately one-fourth mile.

Recommendations:

2.7 36 CFR PART 71—Recreation Fees

Requirements:

The Superintendent’s Compendium recreation fee regulations should not discriminate against 

individuals with disabilities. Provide Section 504 compliant recreation fee regulations.

Findings: 

This regulation does not include the access pass for visitors with disabilities

Recommendations: 

Clearly state in park regulations and on the website how to obtain access pass.

3. Federal Management Regulation (FMR)

3.1 Subchapter C—Real Property, Part 102-76—Design and Construction, Subpart C—

Architectural Barriers Act

GSA is the standard setting agency for the National Park Service. GSA sets regulations 

requiring ABAAS as the standard for NPS to follow. In these sections, GSA sets requirements for 

accessible alterations and priority order for providing access. These sections also define a 

primary function area, and describe the waiver and modification process for the NPS and other 

agencies under GSA’s authority.

3.2 §102-76.70—When are the costs of alterations to provide an accessible path of travel to 

an altered area containing a primary function disproportionate to the costs of the overall 

alterations for facilities subject to the standards in §102-76.65(a)? 

Requirements: 

For facilities subject to the standards in §102-76.65(a), the costs of alterations to provide an 

accessible path of travel to an altered area containing a primary function are disproportionate 

to the costs of the overall alterations when they exceed 20 percent of the costs of the 

alterations to the primary function area. If a series of small alterations are made to areas 

containing a primary function and the costs of any of the alterations considered individually 

would not result in providing an accessible path of travel to the altered areas, the total costs of 
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the alterations made within the three year period after the initial alteration must be considered 

when determining whether the costs of alterations to provide an accessible path of travel to 

the altered areas are disproportionate. Facilities for which new leases are entered into must 

comply with F202.6 of the Architectural Barriers Act Accessibility Standard without regard to 

whether the costs of alterations to comply with F202.6 are disproportionate to the costs of the 

overall alterations. 

Recommendations:

Future alterations should strive to be made fully accessible, if costs are disproportionate, 

comply with these regulations.

3.3 §102-76.75—What costs are included in the costs of alterations to provide an accessible 

path of travel to an altered area containing a primary function for facilities subject to the 

standards in §102-76.65(a)? 

Requirements: 

For facilities subject to the standards in §102-76.65(a), the costs of alterations to provide an 

accessible path of travel to an altered area containing a primary function include the costs 

associated with—

(a) Providing an accessible route to connect the altered area and site arrival points, 

including but not limited to interior and exterior ramps, elevators and lifts, and curb ramps;

(b) Making entrances serving the altered area accessible, including but not limited to 

widening doorways and installing accessible hardware;

(c) Making restrooms serving the altered area accessible, including, but not limited to, 

enlarging toilet stalls, installing grab bars and accessible faucet controls, and insulating pipes 

under lavatories;

(d) Making public telephones serving the altered area accessible, including, but not limited 

to, placing telephones at an accessible height, and installing amplification devices and TTYs;

(e) Making drinking fountains serving the altered area accessible; and

(f) Making parking spaces serving the altered area accessible.

Recommendations:

Future alterations should strive to be made fully accessible, if costs are disproportionate, 

comply with these regulations.
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3.4 §102-76.80—What is required if the costs of alterations to provide an accessible path of 

travel to an altered area containing a primary function are disproportionate to the costs 

of the overall alterations for facilities subject to the standards in §102-76.65(a)? 

Requirements: 

For facilities subject to the standards in §102-76.65(a), if the costs of alterations to provide 

an accessible path of travel to an altered area containing a primary function are 

disproportionate to the costs of the overall alterations, the path of travel must be made 

accessible to the extent possible without exceeding 20 percent of the costs of the alterations to 

the primary function area. Priority should be given to those elements that will provide the 

greatest access in the following order: 

(a) An accessible route and an accessible entrance;

(b) At least one accessible restroom for each sex or a single unisex restroom;

(c) Accessible telephones;

(d) Accessible drinking fountains; and

(e) Accessible parking spaces.

Recommendations:

In determining priority for accessibility alterations, utilize this priority order along with 

priorities set to make Zion core experiences accessible.

3.5 §102-76.85—What is a primary function area for purposes of providing an accessible 

route in leased facilities subject to the standards in §102-76.65(a)? 

Requirements: 

For purposes of providing an accessible route in leased facilities subject to the standards in 

§102-76.65(a), a primary function area is an area that contains a major activity for which the 

leased facility is intended. Primary function areas include areas where services are provided to 

customers or the public, and offices and other work areas in which the activities of the Federal 

agency using the leased facility are carried out. 

3.6 §102-76.90—Who has the authority to waive or modify the standards in §102-76.65(a)? 

Requirements: 

The Administrator of General Services has the authority to waive or modify the standards in 

§102-76.65(a) on a case-by-case basis if the agency head or GSA department head submits a 
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request for waiver or modification and the Administrator determines that the waiver or 

modification is clearly necessary. 

4. Directors Order #16A Reasonable Accommodation for Applicants and 

Employees with Disabilities

This Director’s Order establishes the framework for meeting reasonable accommodation 

requirements in all areas of employment, including: application, hiring, retention, promotion, 

recognition, and Special Hiring Authority. Within this framework, NPS Human Resources and 

Equal Opportunity Program officials will take the lead in providing specific guidance and 

services to applicants, employees, and supervisors and other managers with respect to the 

provision of reasonable accommodation. 

This Director’s Order is a key ingredient of NPS goals to achieve diversity within the 

organization and provide equal employment opportunities. Supervisors will be accountable for 

ensuring diversity through reasonable accommodation in all areas of employee selection and 

development. Supervisors are encouraged to become knowledgeable of the many resources 

available and to make a complete evaluation of the essential functions of the position as 

related to the disability before determining a reasonable accommodation. Although the 

procedures in this Director’s Order give detailed guidance, managers are encouraged to meet 

or exceed the requirements for reasonable accommodation and general access through 

innovative techniques.

4.1 D.O.16A— Training

Requirements:

In order to provide information to all employees concerning accessibility and reasonable 

accommodation, brief annual training sessions are required by this Director’s Order at each 

Park/Office. These sessions may include identification of basic access requirements, a review of 

this Director’s Order, or any other access information. These sessions may be accomplished by 

a variety of methods including technology-enhanced learning. 

Findings: 

The Zion Park Group Accessibility Coordinator provides accessibility training at the annual 

employee Life Fair. 

Recommendations: 

Continue to provide yearly training, include seasonal staff.
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4.2 D.O.16A— VII. Specific Duties A. Equal Opportunity Program

Requirements:

EO staff at all levels are required to have expertise in the civil rights requirements related to 

reasonable accommodation, counseling, Alternative Dispute Resolution (ADR), complaint 

processing/ enforcement, and direct access to the highest administrative levels. They also 

required to have knowledge and access to technical resources within and outside of the NPS 

and the Department.

Findings: 

Not verified. This program is included in the SETP for Park Administration and Concession 

Administration

Recommendations: 

Provide training for EO staff.

4.3 D.O.16A— VII. Specific Duties D. Supervisors

Requirements:

Supervisors must:

 Become knowledgeable of the reasonable accommodation guidance in order to 

comply with the necessary requirements. This includes general knowledge of the 

various types of disabilities, related terminology, and characteristics.

 Allow input by the applicant or employee in determinations related to reasonable 

accommodation.

 Avail themselves of the assistance provided by the HR, EO, and Accessibility 

Coordinators, at all levels, and attend the annual access training.

 Report, through the immediate HR office, all accommodation requests and final 

resolutions to the appropriate regional HR office verbally or in writing, indicating the 

type of disability, the reasonable accommodation, and date. The qualified individual 

will not be named. All such information must be delivered and maintained in the 

most confidential manner. 

Findings: 

Accessibility training is provided at the yearly Life Fair; specific supervisory training is not 

currently provided.
95

Recommendations: 

Provide reasonable accommodation training for supervisors. Recommend utilizing 

askjan.org the Job Accommodation Network that specializes in this topic and provides free 

assistance in determining accommodations to provide:

4.4 D.O.16A— VII. Specific Duties E. Employees

Requirements:

All employees should be provided an opportunity to become familiar with the reasonable 

accommodation process and the basic access requirements. All employees have a responsibility 

to use proper terminology and etiquette when relating to employees, applicants, and visitors to 

create a hospitable work environment.

Findings: 

Accessibility training is provided at the yearly Life Fair; specific training for all employees on 

reasonable accommodation is not provided.

Recommendations: 

Continue yearly Life Fair training and provide yearly on-line training from askjan.org for all 

employees on reasonable accommodation.

4.5 D.O.16A— VII. Specific Duties F. Accessibility Coordinator

Requirements:

Accessibility Coordinators, who service one or more Park/Office, will provide specific 

guidance for structural and non-structural accessibility to applicants and employees. 

Accessibility Coordinators will also provide a brief annual update of selected parts of the "504 
96

Self-Evaluation" and "Transition Plan" in order to establish work and budget priorities. The 504 

Self-evaluation update includes structural and non-structural items, which need improvement. 

The Transition Plan update uses the structural aspects of the 504 Self-evaluation and assigns 

timetables, financial, and other resources for renovation of existing facilities. Both are crucial 

for responding to accommodation requests and achieving NPS Diversity and GPRA goals. 

Coordination with Department, contractors, and other Service offices for funding and other 

resources is essential.

Accessibility Coordinators must become knowledgeable about 504/ADA requirements for 

provision of reasonable accommodation and access design standards in order to provide 

guidance to supervisors and facility managers. Accessibility Coordinators must be able to 

provide basic formal and informal training for employees and management.

Findings: 

The Zion Park Group Accessibility Coordinator is knowledgeable in Section 504 and 

ADA/ABA requirements, and regularly develops projects to increase access for visitors with 

disabilities.

Recommendations: 

Provide an annual update of selected parts of this Self-Evaluation in order to establish work 

and budget priorities for structural and non-structural items, which need improvement. 

Continue to provide training and management support for the park Accessibility Coordinator.

4.6 D.O.16A—VIII. Requests for Reasonable Accommodation E. Structural Access 

Requirements:

Structural access to NPS facilities affects both visitors and employees with disabilities. 

Structural access should generally be in place before the need arises. It is timely and much less 

expensive to provide structural access during initial or subsequent construction. For existing 

facilities, 504 regulations require a site evaluation and a Transition Plan in order to provide 

structural access before the need arises.

Immediate office and site Accessibility Coordinators (park coordinator) should accomplish a 

site evaluation at least once per year in order to update their respective site Transition Plans. A 

Transition Plan describes the structural modifications that are required for the removal of 

barriers for access. A transition plan should contain at least the following elements:

 A list of the physical barriers in the site’s facilities that limit accessibility to its programs, 

activities, or services to individuals with disabilities;

 An outline of the methods to be utilized to remove these barriers;

 The time schedule for achieving compliance; and
97

 The name of the official responsible for the Plan’s implementation.

In addition, Accessibility Coordinators should be involved in the review and oversight of 

facility construction and or alterations to assist with compliance design issues.

Findings: 

The park is meeting the requirements for a Self-evaluation and Transition Plan (SETP) for 

the major visitor use areas in the park with this document; the transportation system, park 

administration/employee areas, and concession administration are not included in this SETP.

Recommendations: 

This SETP should be reviewed yearly and updated, and the park should complete the SETP’s 

for the areas not covered in this document.

5. Directors Order #42 Accessibility for Visitors with Disabilities in 

National Park Service Programs and Services

Directors Order #42 is out of date (sunset date 2004) and is currently being updated. This 

Order provides the best available information on roles and responsibilities for making the parks 

accessible (this section needs to be updated when new version is published)

5.1 D.O.42—VIII. Roles and Responsibilities - Superintendents

Requirements:

Each superintendent will be responsible for appointing a site accessibility coordinator and 

for providing the support and direction needed to develop and implement a park or site 

strategy to accomplish Service-wide goals and objectives regarding accessibility. A site 

accessibility coordinator may service more than one park or unit. The coordinator may be the 

same accessibility coordinator as appointed in Director's Order #16A: Reasonable 

Accommodation for Employees. Personnel issues may require that an individual from the 

Human Resources program be appointed to assist in the implementation of reasonable 

accommodation, in addition to the site access coordinator. 

Findings: 

The park has a designated accessibility coordinator

Recommendations: 

Continue to provide training and management support for the Zion Park Group Accessibility 

Coordinator.
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5.2 D.O.42—VIII. Roles and Responsibilities – Accessibility Coordinator

Requirements:

The park or site accessibility coordinator will be responsible for the coordination, planning, 

and monitoring of park-wide activities concerned with architectural and programmatic 

accessibility for people with disabilities, including technical assistance and training. Programs 

and activities should be closely coordinated with the regional accessibility coordinator to 

ensure actions taken conform to applicable laws, regulations, standards and policies. These 

programs and activities should also be closely coordinated with the Chiefs of Maintenance, 

Interpretation, Concessions Management and other program heads to ensure appropriate 

implementation. It is the responsibility of the park or site accessibility coordinator to advise 

park staff, with the approval of their supervisor and the superintendent, on actions necessary 

to achieve the goal of providing the highest level of accessibility that is reasonable within the 

park. 

It is the responsibility of the park or site coordinator to work with their supervisor and the 

superintendent, in determining how best to achieve these duties for the benefit of the entire 

park.

Findings: 

The park has a designated accessibility coordinator

Recommendations: 

Continue to provide training and management support for the Zion Park Group Accessibility 

Coordinator.

6. Other NPS Accessibility Policy and Procedures 

6.1 Service Animal Policy

Requirements:

On September 5, 2002, the NPS Director issued a memorandum updating policies and 

procedures for service animals in the National Parks.1 This memorandum indicates that the 

National Park Service should follow the same guidelines and procedures for service animals as 

laid out in the Americans with Disabilities Act §35.136 Service animals. It provides specific 

 

1 Memorandum, Use of Service Animals by Persons with Disabilities in the National Park System, Fran P. Mainella, 

Director, September 5, 2002.
99

guidance on allowable questions that may be asked to verify that an animal is a service animal. 

The memorandum also indicates that it is the responsibility of each park superintendent to 

identify any areas closed to service animals and provide a justification for such closure such as 

“allowance of any domesticated animal would pose a direct threat to the health and safety of 

people or wildlife.”

Findings:

The park website requires visitors with service animals to check in at the VC before going on the 

trails. Typical visitors are allowed to go directly to trails from their vehicles. 

Recommendations:

The park management team with natural and cultural resource specialists should determine 

if this requirement is necessary. Update compendium and website to use language from 

§35.136 Service animals.

6.2 Service Animal Policy §35.136 Service animals

(a) General. Generally, a public entity shall modify its policies, practices, or procedures to 

permit the use of a service animal by an individual with a disability.

(b) Exceptions. A public entity may ask an individual with a disability to remove a service 

animal from the premises if—

(1) The animal is out of control and the animal's handler does not take effective action to 

control it; or

(2) The animal is not housebroken.

(c) If an animal is properly excluded. If a public entity properly excludes a service animal 

under § 35.136(b), it shall give the individual with a disability the opportunity to participate in 

the service, program, or activity without having the service animal on the premises.

(d) Animal under handler's control. A service animal shall be under the control of its 

handler. A service animal shall have a harness, leash, or other tether, unless either the handler 

is unable because of a disability to use a harness, leash, or other tether, or the use of a harness, 

leash, or other tether would interfere with the service animal's safe, effective performance of 

work or tasks, in which case the service animal must be otherwise under the handler's control 

(e.g., voice control, signals, or other effective means).

(e) Care or supervision. A public entity is not responsible for the care or supervision of a 

service animal.

(f) Inquiries. A public entity shall not ask about the nature or extent of a person's disability, 

but may make two inquiries to determine whether an animal qualifies as a service animal. A 

public entity may ask if the animal is required because of a disability and what work or task the 
100

animal has been trained to perform. A public entity shall not require documentation, such as 

proof that the animal has been certified, trained, or licensed as a service animal. Generally, a 

public entity may not make these inquiries about a service animal when it is readily apparent 

that an animal is trained to do work or perform tasks for an individual with a disability (e.g., the 

dog is observed guiding an individual who is blind or has low vision, pulling a person's 

wheelchair, or providing assistance with stability or balance to an individual with an observable 

mobility disability).

(g) Access to areas of a public entity. Individuals with disabilities shall be permitted to be 

accompanied by their service animals in all areas of a public entity's facilities where members of 

the public, participants in services, programs or activities, or invitees, as relevant, are allowed 

to go.

(h) Surcharges. A public entity shall not ask or require an individual with a disability to pay a 

surcharge, even if people accompanied by pets are required to pay fees, or to comply with 

other requirements generally not applicable to people without pets. If a public entity normally 

charges individuals for the damage they cause, an individual with a disability may be charged 

for damage caused by his or her service animal.

(i) Miniature horses.

(1) Reasonable modifications. A public entity shall make reasonable modifications in 

policies, practices, or procedures to permit the use of a miniature horse by an individual with a 

disability if the miniature horse has been individually trained to do work or perform tasks for 

the benefit of the individual with a disability.

(2) Assessment factors. In determining whether reasonable modifications in policies, 

practices, or procedures can be made to allow a miniature horse into a specific facility, a public 

entity shall consider—

(i) The type, size, and weight of the miniature horse and whether the facility can 

accommodate these features;

(ii) Whether the handler has sufficient control of the miniature horse;

(iii) Whether the miniature horse is housebroken; and

(iv) Whether the miniature horse's presence in a specific facility compromises legitimate 

safety requirements that are necessary for safe operation.

(3) Other requirements. Paragraphs 35.136 (c) through (h) of this section, which apply to 

service animals, shall also apply to miniature horses.
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6.3 Audio-Visual Initiative

Requirements:

On October 20, 2006, the NPS Director issued a memorandum requiring that all of the films 

and audio-visual programs presented in our parks provide three basic services: 

 open captions, 

 audio-description, and 

 assistive listening devices available for those with hearing loss. 

Findings:

The parks films are open-captioned and audio described. Assistive listening systems are 

available for the film. The exhibit area has an audio described version available.

Recommendations:

Provide signage at the information desk and at theater spaces on assistive technology 

available.

6.4 NPS Complaint Process Directive

Requirements:

On September 5, 2008, the Equal Employment Opportunity Program Manager issued a 

directive to communicate the Section 504 requirements and process for complaints of 

discrimination filed by visitors to our sites. Park management and EO office should be 

knowledgeable on this process.

Findings:

All parks are required to follow this directive, should be reviewed by park staff yearly.

Recommendations:

Provide information on complaint process with annual EO training for staff.

6.5 Section 508

Section 508 standards apply to electronic and information technology procured by the 

federal government, including computer hardware and software, websites, phone systems, and 

copiers. They were issued under section 508 of the Rehabilitation Act, which requires access for 

both members of the public and federal employees to such technologies when developed, 

procured, maintained, or used by federal agencies.
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Findings:

Electronic and information technology is a specialized requirement that WASO is developing 

standards for parks to use.

Recommendations:

Follow WASO and regional office guidance.

6.6 Mobility Device Policy

Requirements:

This requirement is defined explicitly in the ADA amendments act regulations promulgated 

by the U.S. Department of Justice. While these regulations do not apply to Federal entities, NPS 

has been advised by their legal counsel that Congress has stated that their intent is that the 

coverage of the ADA and Section 504 should be essentially the same. Thus, the national 

requirement relative to powered mobility should be based on §35.137 Mobility Devices of the 

title II ADA regulations and §36.311 Mobility Devices of the title III ADA regulations.

These regulations and guidance documents issued with the regulations make it clear that 

Segway-type devices, golf carts, scooters and other such devices must be allowed anywhere the 

public is allowed to go unless the organization can identify specific reasons for limiting one or 

more of these types of mobility devices in specific areas.

Currently, the NPS has not fully embraced the ADA language. Rather they have asked each 

park superintendent to “to review this issue by January 19, 2007, for their individual park and 

make a decision on whether they can accommodate the use of this device. If the decision is 

made that you can accommodate it, you must do so. If you determined that they will not be 

allowed, you must state in writing the reasons for that determination.” 

Findings:

The Superintendents Compendium has use limits on where Segways can be used. These limits 

adhere to DOJ, Wilderness and NPS guidance.

Recommendations:

Edit Compendium to identify the accepted forms of identification for mobility devices. 

Recommend using language in § 35.137 to identify any restrictions. Provide staff training on 

mobility devices.

6.7 Mobility Device Policy - § 35.137 Mobility devices.

(a) Use of wheelchairs and manually-powered mobility aids. A public entity shall permit 

individuals with mobility disabilities to use wheelchairs and manually-powered mobility aids, 
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such as walkers, crutches, canes, braces, or other similar devices designed for use by individuals 

with mobility disabilities in any areas open to pedestrian use.

(b) (1) Use of other power-driven mobility devices. A public entity shall make reasonable 

modifications in its policies, practices, or procedures to permit the use of other power-driven 

mobility devices by individuals with mobility disabilities, unless the public entity can 

demonstrate that the class of other power-driven mobility devices cannot be operated in 

accordance with legitimate safety requirements that the public entity has adopted pursuant to 

§ 35.130(h).

(2) Assessment factors. In determining whether a particular other power-driven mobility 

device can be allowed in a specific facility as a reasonable modification under paragraph (b)(1) 

of this section, a public entity shall consider—

o (i) The type, size, weight, dimensions, and speed of the device;

o (ii) The facility's volume of pedestrian traffic (which may vary at different times 

of the day, week, month, or year);

o (iii) The facility's design and operational characteristics (e.g., whether its service, 

program, or activity is conducted indoors, its square footage, the density and 

placement of stationary devices, and the availability of storage for the device, if 

requested by the user);

o (iv) Whether legitimate safety requirements can be established to permit the 

safe operation of the other power-driven mobility device in the specific facility; 

and

o (v) Whether the use of the other power-driven mobility device creates a 

substantial risk of serious harm to the immediate environment or natural or 

cultural resources, or poses a conflict with Federal land management laws and 

regulations.

(c)(1) Inquiry about disability. A public entity shall not ask an individual using a wheelchair 

or other power-driven mobility device questions about the nature and extent of the individual's 

disability.

(2) Inquiry into use of other power-driven mobility device. A public entity may ask a person 

using an other power-driven mobility device to provide a credible assurance that the mobility 

device is required because of the person's disability. A public entity that permits the use of an 

other power-driven mobility device by an individual with a mobility disability shall accept the 

presentation of a valid, State-issued, disability parking placard or card, or other State-issued 

proof of disability as a credible assurance that the use of the other power-driven mobility 

device is for the individual's mobility disability. In lieu of a valid, State-issued disability parking 

placard or card, or State-issued proof of disability, a public entity shall accept as a credible 
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assurance a verbal representation, not contradicted by observable fact, that the other powerdriven mobility device is being used for a mobility disability. A “valid” disability placard or card 

is one that is presented by the individual to whom it was issued and is otherwise in compliance 

with the State of issuance’s requirements for disability placards or cards.

6.8 Emergency operations plan

The NPS Resource Management Reference Manual #77 Planning section, there is specific 

guidance on Emergency Management. Under roles and responsibilities, this guidance indicates 

that, “The superintendent is responsible for the preparation, approval, and implementation of 

the emergency operations plan and necessary action plans.”2

A comprehensive emergency operations plan should describe how and by whom decisions 

are to be made in order to maintain control over the incident. The plan presents a step-by-step 

process for dealing with emergencies. Adequate manpower and equipment should be 

identified. The emergency operations plan should outline responsibilities and contain a list of 

non-NPS resources.

Additional guidance on emergency management procedures is provided in DO/RM 50C, 

Visitor Safety; DO/RM 18, Wildland Fire Management; DO/RM 9, Law Enforcement Program; 

DO/RM 28, Cultural Resource Management; and DO/RM 51, Emergency Medical Services. See 

also in this Reference Manual, Hazardous Waste Management.

Findings: 

MTC did not receive the emergency operations plan and necessary action plans from the 

park law enforcement or park management. 

Recommendations:

ZION should develop an SOP for emergency operations. Survey staff. Sample questions: 

 I know how to assist in a fire emergency at the park.

 We have accessible shelters for guests with disabilities in case of weather emergencies.

 In an emergency situation, such as a fire in the Park, what procedures are in place for 

notification, evacuation assistance, and transportation for people with disabilities?

 What type of emergency warning system does the Park utilize for providing prompt 

notification of emergencies to people with disabilities?

 

2 NPS Resource Management Reference Manual #77, Emergency Management Roles and Responsibilities, 

http://www.nature.nps.gov/Rm77/emergency.cfm.
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6.9 Standard Operating Procedures.

Utilize standard operating procedures (SOP’s) for maintenance operations, staff training, 

interpretive and recreational programming that affect access to these programs, services and 

activities. 

Findings: 

The park has many SOP’s for visitor center and visitor contact operations. 

Recommendations:

The NPS should add accessibility accommodation best practices to existing SOP’s and 

develop SOP’s that cover accessibility topics. Preliminary outline of topics to cover:

NPS Accessibility Standard Operating Procedures

Maintenance SOP’s

Facility

1. Doors

2. Elevators and Lifts

3. Restrooms

4. Seating Areas

5. Group Gathering Areas 

6. Theater

7. Information Desk

Hotels

1. Accessible guest rooms

2. Front Desk

Exhibits

1. Mechanical Components

2. Alternative Formats

3. Maneuvering Space

4. Lighting

Site 

1. Snow Removal

2. Signs and Pavement Markings

Training SOP’s

1. Interpretive Staff

2. Maintenance Staff

3. Accessibility Coordinator

4. Law Enforcement

5. Ranger led programs

6. Concession Staff

7. Other

Interpretive Program SOP’s

1. Ranger led programs

2. Concession led programs

3. Junior Ranger programs

4. Self-Guided programs

Recreational Program SOP’s 

1. Camping

2. Backcountry Camping

3. Picnicking

4. Hiking

5. River access (beach access routes)

6. Horseback Riding
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3. Accessible Routes

4. Trails

5. Outdoor Access Routes (Picnic 

Areas and Campgrounds)

6. Service Animals

7. Pet Relief Area

Transportation

1. Shuttles

2. Shuttle Stops

3. Lifts

4. Signs and Pavement Markings

5. Accessible Routes

6. Bus Loading/Unloading Areas

7. Service Animals

8. Pet Relief Areas

7. Biking

8. Snowmobiles 

9. Nature Walks

10. Overlooks

Emergency management Plan

Other