Railbanking: On the Right Track or Time to Throw the Switch

by Casey Semple, Associate Member, University of Cincinnati Law Review Vol. 93

I. Introduction

After decades of neglect, passenger rail in the United States is reentering the national conversation. Most Americans want the federal government to strengthen our national passenger rail network.[1] According to a recent poll completed by the Rail Passengers Association, 78% of respondents to this poll indicated that a strong passenger rail system in the U.S. is “important,” and 66% of respondents indicated that they support adding routes to the passenger rail network.[2] This majority coalition of rail supporters spans across political, gender, and age spectrums as well as urban, suburban, and rural communities.[3] However, the United States Congress has encouraged other modes of transportation at the expense of passenger rail through an assortment of policy choices, including the creation of “railbanking.” [4] This federal law allows for rail corridors no longer used by railroad companies to be preserved so that the lines might be used again in the future.[5] These “banked” lines are often used in “rail-to-trail” projects by converting the corridor from rail lines to biking and walking trails, providing recreational locations, and diversifying transportation in the local community.[6]

While adding value to communities in the interim, these banked rail corridors are rarely converted back to active rails.[7] This article explores the railbanking system that has resulted in many rail corridors being banked but next to no banked lines returning to rail use. Part II explains how railbanking came to be and the legal hurdles an interested party must consider when converting a banked line back into an active rail corridor suited for passenger rail. Part II also surveys the current landscape of railbanking in Ohio and investigates one instance of a railbanked trail being converted back to trail. Part III explores whether railbanking accomplishes the goals for which it was originally created. Finally, Part IV delves into alternative ways to promote passenger rail.

II. Background

Often described as marking the beginning of railroad mania in the United States, the “Laying of the First Stone” of the Baltimore and Ohio Railroad in 1827 was the first rail construction project to be chartered, built, and operated as a common carrier, carrying passengers and goods for those other than the private owner of the railroad.[8] Planning and construction of railroads boomed, rapidly and sometimes haphazardly laying track to meet the demand of the expanding industry.[9] As an economic engine for the U.S., railroads served as a valuable asset throughout their peak in the first two decades of the 20^th century with an impressive 270,000 miles of track crisscrossing the nation.[10] Factors like the Great Depression, the advent of the automobile and airplane, and national projects like President Eisenhower’s Interstate Highway System, all played a role in diverting passengers away from rail.[11] Railroads began viewing passenger rail as a burden and shifted their focus to freight services.[12]

Seeking to maintain the national passenger rail network, Congress passed the Rail Passenger Service Act of 1970, creating the National Passenger Corporation, known as “Amtrak” today.[13] Over the years, however, diminishing budgets to fund Amtrak resulted in diminishing services provided by Amtrak, decreasing the frequency of service and eliminating routes.[14] Rail companies’ declining dedication to passenger rail and Amtrak’s declining services devastated passenger rail’s reliability as a mode of commuting, leading to a feedback loop where even fewer travelers sought out rail, leaving the remaining lines with less business.[15] Major railroad lines became underused or unused, and railroad companies went bankrupt, resulting in rail lines being abandoned at an alarming rate – decreasing by roughly 4,000 to 8,000 miles per year.[16]

Railroad companies were faced with decisions of what to do with their inactive lines. One option was to place the rail line on inactive status, which allows the railroad to stop serving customers.[17] With railroad companies going bankrupt, however, placing the line on inactive status was often not a sufficient option.[18] While railroad companies would no longer be required to service inactive lines, the companies would still be responsible for the property.[19] Another option for the railroad would be to discontinue and sell an inactive rail line through abandonment.[20] Selling through abandonment, however, is disfavored for its own reasons. Unless the right of way of the rail line is purchased in its entirety, the right of way ceases to exist.[21] The phrase “right of way” refers to a right of easement, specifically for passage purposes, such as for a railroad, vehicles, pedestrians, pipelines, aqueducts, etc.,[22] and an easement is a limited nonpossessory property interest that provides the easement holder permission to use another’s land.[23] Therefore, a railroad operating over easements never owned the land over which it operated.[24] Subsequently, because rail line easements are contingent upon continued rail service, portions of the right of way would revert to adjacent property owners after abandonment.[25] These reversions to the original property owners then break up the corridor in a way that makes it nearly impossible to reestablish the corridor’s right of way.[26]

Faced with the possibility of the painstakingly assembled national rail network being irreparably fragmented by declining railroad companies breaking up their rights of way, Congress amended the National Trails System Act in 1983 to enable the preservation of rail corridors through “railbanking.”[27] When a railroad decides that a segment of its track is no longer needed for active rail service, the railroad can enter a voluntary agreement with a sponsor, either a public or private entity, to bank the railroad corridor so that the otherwise abandoned railroad corridor can be used as a trail until a railroad might need the corridor again for rail service.[28] Sponsors have often been a trail organization or government agency that turns corridor into a trail to be used by the community, and the railbanked lines use the same easements as the once active rail line, thereby preserving the easements for future rail use should a party choose to reactivate the rail functions.[29] This interim trail use of railbanked corridors has preserved thousands of miles of rail corridors that would otherwise have been abandoned or sold in a way that would have resulted in the right of way losing the privileges associated with the easement[30]

A. A Modern Guide on How to Railbank

Nowadays, the Surface Transportation Board (“STB”), among other responsibilities, has broad economic regulatory oversight of railroads including matters related to the construction, acquisition, abandonment of rail lines, railbanking, carrier mergers, and interchanging traffic between carriers and some passenger rail.[31] Therefore, when a modern rail line ceases to be active, a railroad must file with the STB to place the rail line on inactive status, to discontinue service and sell a rail line under abandonment, or to railbank under abandonment.[32]

A railroad must follow a particular process to railbank a section of its rail line. First, ten days before abandonment filing, the railroad must send a notification to the State Service Board, or an equivalent agency.[33] On the day of abandonment, the railroad must file a petition for abandonment exemption, known as a Notice of Exemption with the STB; notice of the abandonment is published in the Federal Register within twenty days of this filing.[34] Thirty days after abandonment filing, which occurs ten days after the notice is published in the Federal Register, an agency or organization interested in trail development may file a request for a Notice of Interim Trail Use (“NITU”) with the STB.[35] This request often includes a statement of willingness to assume financial responsibility, indicating the interested party is capable of assuming financial responsibility should the interested party and the railroad reach a mutual agreement to transfer the rail corridor.[36] This request also often includes a public use condition (“PUC”) preventing the railroad from selling or otherwise disposing of property or structures related to the right of way, such as bridges, tunnels, or culverts, for 180 days from the effective date of abandonment.[37] Because a railroad may not agree to the proposed conditions of the NITU, the PUC may buy the interested party additional time to convince the railroad to negotiate a railbanking.[38] Once the railroad has received the interested party’s notice expressing a desire to negotiate a railbanking, the railroad has ten days to decide whether to participate in a discussion and notify the STB.[39] Within fifty days of the abandonment filing, another railroad can submit an offer of financial assistance (“OFA”) to purchase or subsidize the rail line’s current service.[40] An OFA trumps any railbanking requests.[41]

If the railroad agrees to negotiate, the STB issues a NITU, permitting the railroad to discontinue service, cancel tariffs, and salvage track and materials while railbanking negotiations occur.[42] If an agreement is not reached within this initial one-year period, the parties may request extensions of up to three additional one-year periods.[43] Railbanking with the STB is entirely voluntary, so the STB will not issue railbanking conditions without the consent of the railroad.[44] If the railbanking negotiations were successful, however, the railroad would pass the deed to the interested party like any other land acquisition.[45] When the railroad files a consummation notice with the STB, the rail corridor is officially railbanked.[46] While tracks and ties may be removed, bridges and trestles must remain in place, and no permanent structures may be built on the right of way.[47] A railbanked line is subject to possible future restoration of rail service.[48] The abandoning railroad can apply to the STB to resume rail service on a railbanked corridor which will then vacate the trail use ordinance.[49] The terms and conditions of a transfer back to rail service must be negotiated with the trail manager.[50]

B. Railbanking in Ohio

Of the 8,900 miles of track that existed in Ohio at the peak of rail use in 1910, only 5,188 miles of track remain in Ohio today.[51] The Rails to Trails Conservancy boasts an impressive 1,085 miles of railbanked trails all across Ohio, including 270 miles of Ohio tracks they are considering for potential railbanking-turned-trails projects.[52] One such rail-to-trail conversion occurred when Cincinnati, Ohio’s Wasson railroad corridor was converted to the Wasson Way Trail.[53] The Wasson Way Trail was set to be a bicycle-pedestrian corridor connecting areas between the Uptown neighborhood and Fairfax.[54] The project advertised that it would connect the 83,000 residents along the trail to the second largest employment center in the region, the University of Cincinnati, Xavier University, local high schools, multiple shopping centers, and dozens of shops and restaurants.[55] The project was also marketed to increase mobility, health, and wellness, as well as reduce traffic congestion, accidents, and transportation costs.[56]

Additionally, on the Ohio railbanking agenda, is an Indiana & Ohio Railway corridor in eastern Cincinnati.[57] Great Parks of Hamilton County, a political subdivision of Ohio that manages parks and nature preserves in the Cincinnati area, announced an agreement with governmental and railroad parties that could result in them acquiring the corridor and building the Oasis Trail.[58] Set to begin construction in 2027, the project would bridge downtown trails to the regional and state trail network, connecting citizens of Cincinnati, Columbus, and Cleveland, Ohio with over 300 miles of trail.[59] Some advocates highlight that the new trail would make biking more practicable for everyday transportation, make biking safer, and encourage economic development in the nearby region.[60] Although the rail-to-trail conversion projects are abundant in Ohio and beyond,[61] it is unclear how successful these conversions, that preserve property rights, are at preserving for future rail use.

C. A Rare Trail to Rail

While rare, it is not altogether unprecedented for a railbanked trail to be converted back to rail. Ten miles of track abandoned by Conrail in 1990 had been railbanked into the Snow Shoe Rails to Trails, and nearly thirty years later, the R.J. Corman Railroad Company moved to reclaim and reactivate this railbanked section of right of way for rail use.[62] The “trail to rail” conversion would connect a proposed landfill in northern Centre County, Pennsylvania, with its track in Clearfield County, Pennsylvania.[63] Some community members were frustrated with the conversion, including the Centre County Commissioner at the time who voiced that the trails had a “lot of people [work] very hard to put it in,” that the popular trails were “used extensively,” and that the decision would be met with “public consternation.”[64] Snow Shoe Rails to Trail treasurer at the time also condemned the decision, explaining that the “organization had put countless hours into repairing and maintaining the multi-use trail” which had “become a favorite amongst local[s].”[65] The SBT received hundreds of comments regarding the issue, although the nature of the comments was not disclosed.[66] Indeed, those on the opposite side in favor of the trail to rail conversion, like one of Rush Township’s supervisors, lauded the decision to bring rail and, therefore, “jobs back to the area.”[67]

Ultimately, in 2012, the SBT issued a decision approving a railroad company’s ability to reclaim the rail, citing the company’s right to reclaim previously abandoned rail lines.[68] The SBT also factored in that the railroad’s service to planned and existing industrial development in the area[69] and that the rail would remove up to 1,164 trucks from local roads per day.[70] While not impossible, it is ultimately quite rare for these railbanked trails to be converted back to any rail despite the ever-present promise that railbanking could allow the rail to return one day.

III. Discussion

Railbanking has resulted in thousands of miles of rail lines being converted into more than 100 multi-use trails, and advocacy groups like the Rail to Trails Conservancy laud railbanking as a practice, stating that they are “building a nation connected by trails” and that they “reimagine public spaces to create safe ways for everyone to walk, bike and be active outdoors.”[71] While some organizations like the Rail to Trails Conservancy measure the success of the railbanking amendment of the National Trails System Act (“NTSA”) by how much rail is saved and the windfall benefits of such rail-to-trail conversions,[72] there are other organizations whose missions more closely align with that of the stated purpose of the NTSA railbanking amendment and should consider different means of measuring the success of the NTSA amendment. The purpose of the NTSA amendment was not to build trails, but instead to preserve abandoned railroad corridors for future rail use.[73] Therefore, organizations like All Aboard Ohio (“AAO”), a group dedicated to promoting improved public transportation and passenger rail service throughout the state of Ohio, might consider halting their indiscriminate praise of railbanking as a practice. Instead, passenger rail advocacy groups like AAO should measure the success of the NTSA railbanking amendment by how many preserved corridors that are reactivated and should promote that railbanking be used discriminatorily and only when the situation calls for it.

First, in examining the benefits of railbanking, the most obvious way in which passenger rail advocates are drawn to railbanking is the preservation of rail corridors. Railbanking preserves the easement property interests, thereby preserving the right of way for reactivation.[74] Keeping these corridors intact prevents them from being sold off or developed which would complicate future rail reactivation. Additionally, because railbanking is often used for rail-to-trail projects, there are other windfall benefits as well. These trails allow for increased recreational outdoor activities like hiking and biking and are added to local and regional trail networks. In turn, these trails attract tourism as well as residents who bring their money with them, leading to a boost in the local economy and an increase in property values near the trail. Finally, the trails also promote alternative modes of transportation that are environmentally friendly, enhancing and protecting the local ecosystem.

While, theoretically, railbanked lines could be placed back into rail service, doing so can be a challenge once a recreational trail has been established on a railroad right of way or once noncompatible land uses have developed adjacent to the railbanked corridor. Similar to the Pennsylvania trail to rail conversion, there are likely to be constituents that seek to preserve the trail, especially a trail that becomes popular among locals and brings in tourism.[75] As an unused rail corridor, the area might at worst be an eyesore or full of dangerous, degrading infrastructure and at best be something to which no one pays any mind. By building a trail over the unused rail corridor, however, the rail advocates may believe they are preserving the corridor for future use but could in fact be digging their own graves by creating a constituency for the trail.

When the corridor is occupied by unused railroad tracks, many in the community are not interested in doing anything with the property. However, as soon as a rail-to-trail conversion occurs, these previously unassociated members of the community are brought together by the trail itself. There must be a sponsor willing to maintain the property, often groups or organizations of people, and these groups now share trail in common this trail project.[76] There are also those in the community who utilize the trail, whether for recreational purposes like running, off-road vehicles, or horse-riding or commuting by foot or bicycle. Additionally, the surrounding community benefits from the trail, whether it is businesses increasing their customer base or homes with increased property values. These groups now share a common bond of maintaining, utilizing, and enjoying the use of such a trail and now serve as constituency groups that can activate to protect and enhance the trail.

Therefore, when a group is interested in reactivating a corridor for passenger rail use, there now exist constituency groups that will fight against the rail reactivation. Faced with the possibility that the trail they maintain, use, or benefit from may disappear so that the corridor can once again be used for passenger rail purposes, these constituency groups often stand in opposition to the rail reactivation. These groups that stand in opposition to rail reactivation are created by the very act that is meant to allow for rail reactivation. If the corridors were never used for recreational trails to preserve corridors’ right of way, the groups that stand in opposition to rail reactivation would not exist.

It is possible in some instances to reactivate railbanked rail corridors while keeping recreational trails on the right of way. This coexistence, referred to as “rail with trail,” is often seen as creating a safer, integrated multimodal transportation network, connecting rail users to the trail network and vice versa.[77] A rail with trail, however, cannot be implemented everywhere.[78] A rail with trail project must take into consideration the security of the rail corridor from trespassers, the safety of nearby trail users, and the space required to ensure these needs are met.[79] A potential rail with trail project should also take into consideration environmental concerns, space for future track expansions, and more.[80] Therefore, a rail with trail conversion often requires a larger right of way,[81] and this larger right of way may be larger than is available from a railbanked line to accomplish all the goals kept in mind.

While railbanking is often advertised as preserving the property interests of underused or unused rail for future use, railbanking can organize a constituency activated against converting railbanked trails back to rail. Unused rail tracks that could not serve as passenger rail in strategic corridors can still be railbanked, with the property interests preserved for when it may be useful and used for recreational trails in the meantime, but those rail lines ripe for passenger rail should avoid railbanking. Passenger rail groups with more discriminatory approaches to railbanking could have saved the Cincinnati, Ohio Wasson Way that was ripe for passenger rail from becoming a trail. Therefore, when railbanking groups like the Rail to Trails Conservancy propose railbanking Ohio rail corridors, passenger rail advocacy groups like AAO should consider the difference in missions between their organizations and remember that some of these groups, like the Rails to Trails Conservancy, focus first on creating recreational trails and preserving rail second. Before more Ohio rail corridors are railbanked and converted into recreational trails, passenger rail advocacy groups like AAO should consider the corridor’s potential for passenger rail before advocating for it being railbanked. Because public opinion of passenger rail in the United States is so high at the moment, passenger rail advocates like those at AAO should capitalize on such an opportunity by steering clear of railbanking vital corridors and instead push for these vital unused corridors to be revitalized and serve the surrounding communities. Railbanking has seen many deposits; it’s time to see some withdrawals.

IV. Conclusion

Passenger rail advocates must put a finger to the wind and recognize the current climate surrounding passenger rail. While railbanking may be a tool that can provide returns down the line, railbanking without analyzing a corridor’s potential is unwise considering the popular public opinion regarding expanding passenger rail. Restoring rail service for a corridor that has been railbanked may be easier than restoring rail service for a corridor that has been abandoned, but the tendency for railbanking to create a constituency that will stand against rail restoration should give rail advocates pause to consider if creating this constituency is worth railbanking the corridor for use down the line. A passenger rail advocate’s knee-jerk reaction to railbank a rail corridor very may well derail momentum for expanding passenger rail. Therefore, passenger rail advocacy groups like AAO must consider whether a rail corridor runs through areas with potential transit ridership to prevent the trainwreck of railbanking corridors ripe for passenger rail. A more discerning passenger rail advocate who recognizes when railbanking is useful and when it will derail efforts down the line will play a stronger role in building a robust passenger rail system in the United States.

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[1] Madison Butler, Majority of Americans Want More Investments in Passenger Rail, Rail Passengers Ass’n (Mar. 21, 2022), railpassengers.org/happening-now/news/releases/new-poll-78-of-americans-want-increased-investments-in-passenger-rail-in-the-u.s/.

[2] Id.

[3] Id.

[4] 16 U.S.C. § 1247.

[5] Id.

[6] Railbanking: Trail-Building Toolbox, Rails to Trails Conservancy (Nov. 12, 2024), http://www.railstotrails.org/trail-building-toolbox/railbanking/#:~:text=In%201983%2C%20Congress%20amended%20Section,converting%20them%20to%20interim%20trails.

[7] Id. The Rails-to-Trails Conservancy’s Review of Railbanking from 2011 is the last time a reputable source published statistics regarding corridors that had been preserve as trails being restored to rail service, and this Review states that nine railbanked corridors have had rail service restored out of the 301 corridors that had been railbanked at that time.

[8] Ed Parkison, National Historic Mechanical Engineering Landmark: Baltimore and Ohio Railroad “Old Main Line”, Dedication Ceremony Baltimore & Ohio Railroad (Apr. 27, 1978), http://www.asme.org/wwwasmeorg/media/ResourceFiles/AboutASME/History/landmarks/32-Balt-Ohio_Railraod.pdf.

[9] The Beginnings of American Railroads and Mapping, The Library of Cong., https://www.loc.gov/collections/railroad-maps-1828-to-1900/articles-and-essays/history-of-railroads-and-maps/the-beginnings-of-american-railroads-and-mapping/ (last visited Feb. 27 2025).

[10] What Happened to U.S. Passenger Rail?, Transp. For Am. (May 22, 2024), t4america.org/2024/05/22/what-happened-to-u-s-passenger-rail/; Rails to Trails Conversions, Mctlaw (Mar. 7, 2024), http://www.mctlaw.com/federal-takings/rails-to-trails-conversions/.

[11] Id.

[12] Id.

[13] P.L. No. 91-518; 84 Stat. 1327.

[14] The Beginnings of American Railroads and Mapping, supra note 9.

[15] Id.

[16] Reed v. Meserve, 487 F.2d 646, 649 (1st Cir. 1973).

[17] Railbanking: Trail-Building Toolbox, supra note 6.

[18] Id.

[19] Id.

[20] State of Ohio Rail Plan, Ohio Rail Dev. Comm’n (Jan. 2019), dam.assets.ohio.gov/image/upload/rail.ohio.gov/Documents/State%20of%20Ohio%20Rail%20Plan%20Final.pdf.

[21]“Right of way” has been accorded two meanings in railroad parlance—the strip of land upon which the tract is laid— and the legal right to use such strip. Schuermann Enterprises, Inc. v. St. Louis Cnty., 436 SW 2d 666 (Mo. Sup. Ct. 1st Div. 1969).

[22] Since then, the term has come to have another meaning which is the land burdened by the easement even if the land has been dedicated in fee. Gary R. Kent, Railroads and Rights of Way, Missouri Soc’y of Pro. Surveyors (Oct. 22, 2020), http://www.missourisurveyor.org/images/1185/document/railroadsmobw20201022_545.pdf.

[23] Easement, Legal Info. Inst., http://www.law.cornell.edu/wex/easement (last visited Feb. 27, 2025) .

[24] State of Ohio Rail Plan, supra note 20.

[25] Id.

[26] Id.

[27] Railbanking: Trail-Building Toolbox, supra note 6.

[28] Id.

[29] Id.

[30] Id.

[31] 16 U.S.C. § 1247. See also About STB, Surface Transp. Bd. (May 16, 2023) , http://www.stb.gov/about-stb/.

[32] Railbanking: Trail-Building Toolbox, supra note 6.

[33] Id.

[34] Id.

[35] Id.

[36] Id.

[37] Id.

[38] Id.

[39] Id.

[40] Id.

[41] Id.; If no NITU, PUC, or OFA has been filed within 50 days of the abandonment filling, and the railroad has “addressed all environmental, historic-preservation or other conditions imposed by the STB, then the railroad may consummate abandonment of the line.” Consummation occurs when the railroad files a notice of consummation with the STB; following consummation, the STB loses jurisdiction over the corridor and railbanking is not possible. Id.

[42] Id.

[43] Id.

[44] Id.

[45] Id.

[46] Id.; If the negotiations were unsuccessful, the railroad must file a consummation notice with the STB within one year of abandonment authorization or within 60 days after the removal of any legal barriers to consummation. Id.

[47] Id.

[48] Id.

[49] Id.

[50] Id.

[51] State of Ohio Rail Plan, supra note 20.

[52] Ohio, Rails to Trails Conservancy (Mar. 14, 2024) , http://www.railstotrails.org/state/ohio/.

[53] Phases – Wasson Way, Wasson Way (Dec. 18, 2023), wassonway.org/map-and-timeline/.

[54] Id.

[55] Id.

[56] Id.

[57] Casey Weldon, ‘Transformative’ Trail to Link Downtown to Lunken Airport, Beyond, Movers & Makers (May 15, 2024), moversmakers.org/2024/05/14/transformative-trail-to-link-downtown-to-lunken-airport-beyond/.

[58] Id.

[59] Id.

[60] Id.

[61] For example, consider the rail-to-trail conversions of Katy Trail in Missouri or the Great Allegheny Passage in Pennsylvania and Maryland. Jennifer.sieg. Katy Trail State Park, Mo. State Parks, mostateparks.com/park/katy-trail-state-park (last visited Apr. 7, 2025); Great Allegheny Passage, Great Allegheny Passage, gaptrail.org/ (last visited Apr. 7, 2025).

[62] Steelriver Infrastructure Partners Lp, Steelriver Infrastructure Assocs. LLC, Steelriver Infrastructure Fund N. Am. Lp, & Patriot Funding LLC – Control Exception – Patriot Rail Corp., No. FD 35622, 2012 WL 2194139, (June 15, 2012) [hereinafter Steelriver].

[63] Id.

[64] Cliff White, Railroad Company Gets OK to Reclaim Tracks; Decision Will Eliminate Half of Rails to Trails, Centre Daily (May 22, 2012), web.archive.org/web/20130228143729/https://www.centredaily.com/2012/05/22/3203995/railroad-company-gets-ok-to-reclaim.html.

[65] Id.

[66] Id.

[67] Id.

[68] Steelriver.

[69] This development included fracking water treatment plants, surface deep mining on area coal reserves, highway improvement projects and the quarry.

[70] Id.

[71] Railbanking and Railtrails: A Legacy for the Future, Rails to Trail Conservancy (July 2006), http://www.railstotrails.org/wp-content/uploads/2024/02/Railbanking-and-Rail-Trails-A-Legacy-for-the-Future-.pdf.

[72] Id.

[73] 16 U.S.C. § 1247.

[74] 16 U.S.C. § 1247; See also Railbanking: Trail-Building Toolbox, supra note 6.

[75] White, supra note 64.

[76] Railbanking: Trail-Building Toolbox,  supra note 6.

[77] Rails with Trails: Best Practices and Lessons Learned, U.S. Dep’t of Transp. Federal R.R. Admin. (May 2021) , railroads.dot.gov/elibrary/rails-trails-best-practices-and-lessons-learned-0.

[78] Id.

[79] Id.

[80] Id.

[81] Id.

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Cover Photo by Sascha Pfyl on Unsplash.