This section of the toolkit focuses on requirements and good practices for engaging people with disabilities in the public participation activities of a rural transit agency. This section is organized into the following subsections:
Unless stated otherwise, the information in this section is based on U.S. Department of Transportation (U.S. DOT) regulation 49 CFR Part 37 - Transportation Services for Individuals with Disabilities (ADA) and FTA Circular 4710.1, Americans With Disabilities Act (ADA): Guidance.
Transit agencies have public participation requirements (see the Transit Manager's Toolkit Planning and Evaluation section for more information). When conducting public meetings and community outreach, transit agencies need to make sure people with disabilities are able to attend and participate. This includes holding meetings in an accessible facility, providing information in accessible formats, and ensuring accessible two-way communication (see the Rider Information section of this toolkit for additional information on accessible formats and communication methods).
There are specific requirements for transit agencies that provide ADA complementary paratransit service. Agencies that provide complementary paratransit must “create an ongoing mechanism for the participation of individuals with disabilities in the continued development and assessment of services to persons with disabilities” [Section 37.137(c)]. Consultation with people with disabilities is required when planning ADA complementary paratransit services [Section 37.137(b)(2)]. There are also specific requirements for public hearings and notice-and-comment periods if an agency plans to change paratransit reservations systems [Section 37.131(b)(4)] or if it intends to seek a determination of equivalent facilitation to depart from the required accessibility standards for facilities, vehicles, or systems [Section 37.7 and Section 37.9].
Even if a transit agency does not provide ADA complementary paratransit, it is important to engage people with disabilities on an ongoing basis (e.g., through a citizen advisory committee) and especially when planning any changes to policies or services that impact service accessibility for persons with disabilities.
Federal Transit Administration (FTA) has planning requirements associated with its Section 5310 grant program (see the Funding Considerations section of this toolkit) that requires participation by individuals with disabilities. Specifically, projects selected for funding under the Enhanced Mobility for Individuals and Individuals with Disabilities (Section 5310) Program must be included in a locally developed, coordinated public transit-human services transportation plan that was developed and approved through a process that included participation by seniors, individuals with disabilities, representatives of public, private, and nonprofit transportation and human services providers, and other members of the public. The Association for Community Living’s Transit Planning 4 All Toolkit provides case studies and links to numerous resources for including people with disabilities and older adults in the planning process.
There are different ways a transit agency can fulfill the ongoing public participation requirement, including, but not limited to:
- Advisory committees or subcommittees
- Surveys via phone, mail, online, and/or in-person
- Focus groups
- Suggestion forms/boxes
- Complaint analysis - In addition to being a valuable source of feedback, transit agencies are required by 49 CFR Part 27 and Part 37 to have procedures to receive, resolve, keep records of, and report on complaints.
According to Appendix D, Section 37.137, U.S. DOT is most interested in the effectiveness of the public participation effort, and transit agencies are welcome to choose the specific structure used to ensure public participation that best meets this goal..
Establishing an ADA advisory committee or subcommittee is a common way to institutionalize participation and make it permanent. If a transit agency already has an advisory committee or consumer advisory committee, they may want to create a subcommittee to focus specifically on ADA issues.
ADA advisory committees should be comprised of persons with disabilities as well as other stakeholders and representatives in the community. Ideally, the members with disabilities should represent various types of disabilities (such as vision, hearing, mobility, etc.), as well as diversity in terms of age, gender, race, and economic status. It is also important to have riders and non-riders participate, when possible.
Committee members should include representatives from the following stakeholder groups, where appropriate:
- Transit system staff (including volunteers, if used)
- Contract providers (if used)
- Local and regional government officials
- Relevant social service agency staff
- Other agencies and/or organizations involved in transportation-related activities for individuals with disabilities and older adults
Committees should meet regularly and should consider the schedules and needs of the public when setting meeting times. Meetings should be open to the public and it is good practice to post meeting dates, agendas, and minutes online, in addition to distributing them to members. A good practice is to announce meetings far in advance (for example, at least 30 days in advance or longer if required by the transit agency’s local policy for announcing public meetings), potentially establishing a set meeting schedule throughout the year. This will give interested persons time to make plans to attend, and also time to request accessibility accommodations in advance. All meetings must be accessible to persons with disabilities – to be discussed further in the section below.
Here are few examples of ADA advisory committees:
Advisory committees and any other mechanisms for ongoing public participation should be tailored for each transit system and community. Whatever the method, effective public involvement should foster communication and collaboration over the long term to make sure the transit services continue to meet the community’s needs.
For more information about advisory committees and public participation, see Easter Seals Project ACTION's Effective Transportation Advisory Committees guide, the Planning and Evaluation section of the Transit Manager's Toolkit.
All public meetings (e.g., advisory committee meetings, public hearings, and board meetings) must be accessible to individuals with disabilities. Meetings must comply with all applicable ADA accessibility requirements and should also be conducted in such a way that all participants can participate in an equal and meaningful way.
According to Easter Seals Project ACTION’s ADA Essentials for Transit Board Members guide, minimum requirements identified by U.S. DOT include:
- The meeting location must be accessible by public transit, including paratransit.
- Primary entrances and doorways used for the meeting must be accessible, barrier-free, and usable by persons with disabilities, including wheelchair users.
- There should be circulation space for wheelchairs throughout and at the front of the meeting space.
- Microphones should be adjustable to wheelchair height.
- Path of travel signs for an accessible route to the meeting room should be posted.
- Meeting materials should be available in alternative formats prior to the meeting.
- Sign language interpreters should be available if requested.
The above list is based on a checklist in U.S. DOT’s Public Involvement Techniques for Transportation Decisionmaking guide under the Including People Who Are Traditionally Underserved on the Public Involvement Techniques for Transportation Decisionmaking web page.
The South West Transit Association (SWTA) has a helpful Accessible Meetings Guide, which is both comprehensive and concise. It covers all aspects of planning and hosting an accessible meeting or event, including:
- Meeting room set-up
- PowerPoint and other visual presentations
- Incorporating videos, remote speakers, and flip charts/wall boards
- Print and electronic guidelines
Another helpful resource is the Easter Seals Project ACTION’s Including People with Disabilities: Communication & Meeting Etiquette Guide. This brochure provides general communication guidance as well as the following tips for planning accessible meetings:
- When planning events or meetings involving people with disabilities, inquire about their needs.
- The building, parking area, meeting space, restrooms, and water fountains should be accessible.
- If barriers exist, including entrance and doorway barriers, find a way to adapt the space or use another location.
- For meetings, consider whether the path of travel to and from the location, including connections to public transit, is suitable for pedestrians and accessible to pedestrians with disabilities.
- Allow circulation space for wheelchairs, make auditory accommodations and provide meeting materials in alternative formats prior to the meeting.
- Provide a certified sign language interpreter or captioner upon request.
Transit Planning 4 All, an inclusive and coordinated transportation-planning project sponsored by the Administration for Community Living, developed a detailed Tip-Sheet on Planning Friendly Meetings and Going Beyond the ADA to Make a Meeting Place User-Friendly.
Information on communicating and providing materials in accessible formats is covered in the Rider Information section of this toolkit.
Updated June 2, 2020