ADA Toolkit

In 49 CFR Part 37, Section 37.3, a fixed route system is defined as “a system of transporting individuals (other than by aircraft), including the provision of designated public transportation service by public entities and the provision of transportation service by private entities, including, but not limited to, specified public transportation service, on which a vehicle is operated along a prescribed route according to a fixed schedule.” In other words, if a public or private system transports the general public on a regular basis on vehicles that travel a designated route on a fixed schedule, the agency operates fixed route service. 



Importantly, if a private entity is providing transportation services under contract or other arrangement or relationship (including a grant, subgrant, or cooperative agreement) with a public entity, the private entity must abide by the regulations that apply to the public entity as if the public entity were directly operating the service [Section 37.23]. The private entity is regarded as “standing in the shoes” of the public entity. In essence, FTA grantees and subrecipients must comply with the ADA requirements for public entities for the FTA-funded service, as must private contractors operating FTA-funded service. 

For more information, please see the full U.S. DOT, Disability Law Guidance document: Paratransit Requirements for Section 5311-Funded Fixed-Route Service Operated by Private Entities.

Commuter Bus Service

Commuter bus service is a subset of fixed route bus service, and must follow all of the fixed route service requirements, with one exception: Under 49 CFR Section 37.121(c), commuter bus is not subject to the requirements for ADA complementary paratransit service. As defined in Section 37.3, commuter bus service is characterized by service predominantly in one direction during peak periods, limited stops, use of multi-ride tickets, and routes of extended length, usually between the central business district and outlying suburbs. Commuter bus service may also include other service, characterized by a limited route structure, limited stops, and a coordinated relationship to another mode of transportation. As noted in Appendix D to 49 CFR Section 37.3, typical characteristics for commuter bus also include no attempt to comprehensively cover a service area, limited origins and destinations, and limited purposes of travel. These characteristics can be found in some transportation systems other than bus systems oriented toward work trips, such as bus service that is used as a dedicated connector to commuter or intercity rail service.



The stop announcement requirements described under Section 37.167(b) for fixed route systems apply to commuter bus service. See Stop Announcements in the section below.

In some situations, a service referred to by a transit agency as "commuter" does not meet the U.S. DOT definition of commuter service, but would meet the definition of fixed route service, and would thus require ADA complementary paratransit.

General Requirements

Before reviewing the requirements specific to fixed route service, readers should review the ADA requirements that apply to all service types, found in the General Requirements for All Service Types section of this Toolkit.

The following requirements and considerations apply specifically to fixed route bus service. 

On a fixed route, all vehicles must be accessible to and usable by persons with disabilities, including wheelchair users [Subpart D, Sections 37.71, 37.73, and 37.75], and accessibility equipment must be in good working order [Subpart G, Sections 37.161 and 37.163]. Since 1991, Subpart D of 49 CFR Part 37 has required that all non-rail vehicles acquired by public entities for use in fixed route systems be accessible. 

If a transit agency is unable to acquire an accessible used bus after a good faith effort meeting the regulatory requirements found in 49 CFR, Subpart D, Section 37.73(c), or receives an inaccessible bus as a donation with FTA approval [Appendix D to 49 CFR 37.73], an inaccessible used vehicle is permitted to be acquired for fixed route service [Section 37.73]. The requirements for what constitutes good faith efforts are detailed in 49 CFR Section 37.73(c) and Appendix D to 49 CFR 37.73. The regulations require good faith efforts to include at least the following steps: 

1. An initial solicitation for used vehicles specifying that all used vehicles are to be lift-equipped and otherwise accessible to and usable by individuals with disabilities, or, if an initial solicitation is not used, a documented communication so stating;
2. A nationwide search for accessible vehicles, involving specific inquiries to used vehicle dealers and other transit providers; and
3. Advertising in trade publications and contacting trade associations. 

Section 4.2.2 of FTA ADA Circular 4710.1 includes discussion on what would constitute a good faith effort. 

A transit agency may not acquire an inaccessible remanufactured vehicle (or remanufacture an existing vehicle) unless an engineering analysis demonstrates that including the required accessibility features would have a significant adverse effect on the structural integrity of the vehicle [Section 37.75(c)]. 

The accessibility standards for buses and vans, detailed in Subpart B of 49 CFR Part 38, are presented in Section 4.2 of FTA ADA Circular 4710.1 and summarized in the Standards for Vehicles and Facilities section of this Toolkit.

An exception can be made for remanufactured vehicles of historic character under extremely limited circumstances. Vehicles of historic character must be operated solely on a route that is included on the National Register of Historic Places [Section 37.75(d)], in order to be qualified for this exception. Such vehicles are only required to have those modifications to make the vehicle accessible which do not alter the historic character of the vehicle. A transit agency seeking to qualify for this exception should apply in writing to the FTA Administrator. See 49 CFR Section 37.75 and Section 4.2.3 of FTA ADA Circular 4710.1 for details on exemptions for remanufactured vehicles.

As described in the General Requirements for All Service Types section of this Toolkit, transit agencies are required to keep vehicle lifts and ramps and other accessibility equipment in operative condition [Section 37.161(a)]. A recommended practice is for fixed route drivers to cycle the lift or ramp as part of the daily pre-trip inspection.

Other equipment required on fixed route buses, including the wheelchair securement systems, the public address system, and any kneeling feature needed to achieve a compliant ramp slope, also needs to be maintained in operative condition, so that this equipment is readily accessible to and usable by individuals with disabilities [Section 37.161].

Inoperative Lift or Ramp on a Fixed Route Vehicle

In the event a vehicle with an inoperative lift is operating on a fixed route, and the headway to the next accessible vehicle on the route exceeds 30 minutes, the transit agency must promptly (i.e., within 30 minutes) provide alternative transportation to individuals with disabilities who are unable to use the vehicle because its lift does not work [Section 37.163(f)]. If the bus lift is not working, the rider can wait for the next vehicle if its scheduled arrival is 30 minutes or less. The driver must contact the supervisor to arrange for a ride if the headway (wait for the next bus) is longer than 30 minutes. The transportation provider should promptly (i.e., within 30 minutes) send out an accessible vehicle to pick up the rider if the wait for the next bus will be longer than 30 minutes, and if the reason for the bypass is malfunctioning accessibility equipment [Section 37.163(f)].

For ramp-equipped buses, the driver will often be directed to deploy the ramp manually, so alternative transportation may not be needed. For additional discussion and suggested practices, see Section 6.2.1 of FTA ADA Circular 4710.1.

Transit agencies must remove the vehicle with the inoperative lift from service before the beginning of the vehicle’s next day of service and the lift must be repaired before the vehicle returns to service [Section 37.163(d)].

If a spare vehicle is not available to take the place of the vehicle with an inoperative lift, such that putting the latter vehicle into the shop would result in a reduction of service to the public, a transit agency may continue to operate the vehicle with the inoperative lift in service for no more than five days if the transit agency’s service area has a population of 50,000 or less, or three days where the population exceeds 50,000 [Section 37.163(e)].

The sections of this Toolkit on General Requirements for All Service Types and Accommodating Riders Using Mobility Devices discuss requirements for all service types in accommodating riders with disabilities.

As required for all service types, transit personnel are required to make use of accessibility equipment [Section 37.167(e)]. and assist people with disabilities with the use of securement systems, ramps and lifts, even if drivers need to leave their seats [Section 37.165(f)]. If buses are equipped with a “kneeling” feature, which allows the front of the bus to be lowered so that the bottom step is closer to the curb, transit agencies adopt policies that require drivers to use this feature for individuals who may have difficulty stepping on or off the bus due to a disability, as recommended in Section 6.5.1 of FTA ADA Circular 4710.1. Use of the kneeling feature may also be necessary in order to achieve the required ramp slope [per 49 CFR Section 38,23(c)(5)], including in situations when the ramp must be deployed on the street rather than on the sidewalk. Transit providers must permit individuals with disabilities who do not use wheelchairs, including standees, to use a vehicle’s lift or ramp to enter the vehicle [Section 37.165].

Fixed route bus drivers are required to assist people with disabilities with boarding the bus. As stated in 49 CFR, Subpart G, Part 37 Section 37.165(f), “where necessary or upon request, the entity's personnel shall assist individuals with disabilities with the use of securement systems, ramps and lifts. If it is necessary for the personnel to leave their seats to provide this assistance, they shall do so.” 

Transit agencies must ensure that adequate time is provided to allow individuals with disabilities to complete boarding or disembarking from the vehicle [Section 37.167(i)]. A recommended practice when planning fixed route schedules is to build extra time (often referred to as recovery time) into the schedule to accommodate the occasional need for extra boarding time, as well as for other potential delays, such as traffic congestion or inclement weather.

If a system has stops that serve more than one bus line, the transit agency must provide riders with a vision impairment or other disability a means of identifying which bus has arrived. Alternately, riders could be given means to identify themselves as seeking a ride on a particular route at each shared stop [Section 37.167(c)]. External route identification announcements can be automated or spoken by the driver to riders waiting at the stop. The DREDF Topic Guide on Stop Announcements and Route Identification recommends announcing both the bus line and the destination to ensure that the rider can board the correct bus going in the desired direction. TCRP Report 163, Strategy Guide to Enable and Promote the Use of Fixed-Route Transit by People with Disabilities, recommends that a transit agency’s policy “direct drivers always to stop if there are waiting riders, regardless of whether or not they signal for the bus. Vehicle drivers need to come to a complete stop, open the door, and make a route announcement” (page 37). The announcement needs to be audible to waiting riders. External speakers and automated external announcement systems can also be helpful.

Just as external announcements can be used to identify the bus line and destination, it is required that internal announcements (on board the vehicle) be made to inform riders of upcoming stops. These announcements must be made at least at transfer points with other fixed routes, other major intersections and destination points, and intervals along a route sufficient to permit individuals with visual impairments or other disabilities to be oriented to their location. Additionally, any stop requested by an individual with a disability must be announced [Section 37.167(b)]. As recommended in the DREDF Topic Guide on Stop Announcements and Route Identification, announcements should be made in advance of the stop, and they should follow a standard format. For example, as a best practice, the street the bus is traveling on should always be announced before the street it intersects. 

This obligation can be met by requiring bus drivers to announce stops or by using an automated stop announcement system on board the vehicle. If the vehicle is equipped with an on-board public address (P.A.) system, which is required for vehicles over 22 feet in length under 49 CFR Section 38.35, the bus driver should use the P.A. system since the announcements need to be audible to be useful. It is recommended that the disability community and bus drivers be consulted when deciding what stops to announce to ensure the effectiveness of the system. Section 6.6 of FTA ADA Circular 4710.1 provides additional guidance on recommended practices. Section 4.2 of TCRP Report 163, Strategy Guide to Enable and Promote the Use of Fixed-Route Transit by People with Disabilities, provides additional tips for transit agencies on stop announcements.

The stop announcement requirements described under 49 CFR Section 37.167(b) for fixed route systems apply to commuter bus service. By definition in 49 CFR Part 37 Section 37.3, commuter bus service is a fixed route service. Although the ADA Complementary Paratransit requirements for other types of fixed route systems do not apply to commuter bus service [Section 37.121(c)], commuter bus service is not exempt from the stop announcement requirements. These requirements are discussed in Section 6.6 of FTA ADA Circular 4710.1.

Riders who use wheelchairs need access to securement areas on a vehicle in order to ride. Riders with other disabilities may need use of priority seating in order to ride. Under 49 CFR Section 37.167(j), when an individual with a disability enters a vehicle, and because of a disability, the individual needs to sit in a seat or occupy a wheelchair securement location, the transit agency is required to ask other individuals to move in order to allow the individual with a disability to occupy the seat or securement location. Drivers must ask that individuals sitting in the priority seating area relocate if an individual needs to use that priority seating because of a disability. Individuals sitting on a fold-down or other movable seat in a wheelchair securement location, including other individuals with disabilities, must be asked to vacate the securement area if an individual using a wheelchair needs to use the securement area [Section 37.167(j)]. The transit agency has an obligation to ask the person in the priority seat or seating in the securement area to move, but is not required to enforce the request if the other individual(s) refuse. Individuals with “hidden” disabilities may need priority seating. Section 6.3 of FTA ADA Circular 4710.1 provides additional information about this requirement.

In addition to posting the signage required at priority seating and securement locations (summarized in the Vehicle and Facility Accessibility section of this Toolkit), transit agencies can raise awareness of the importance of offering a seat to those who need it as part of any instructions they provide to the general public about how to use the service, and posting additional signage encouraging riders to offer a seat if they are able. Transit agencies may also elect not to install seating in securement areas.

On fixed route bus service, an ADA-related capacity consideration is the number of wheelchair securement positions on the vehicle, and whether or not the transit agency is able to transport all riders who need these positions during peak hours. Under 49 CFR Part 38, buses longer than 22 feet must have at least two securement locations, and smaller vehicles must have at least one (see the Vehicle and Facility Accessibility section of this Toolkit for more information on vehicle requirements). Some transit agencies have found that the demand for fixed route service by riders who use wheelchairs and other mobility devices exceeds the two-wheelchair minimum requirement on fixed route buses, and procure vehicles with more wheelchair securement positions. For example, as described on pages 28-29 of TCRP Report 163, Strategy Guide to Enable and Promote the Use of Fixed-Route Transit by People with Disabilities, Corpus Christi Regional Transportation Authority in Texas procures buses with capacity for three wheelchairs.

Public entities that operate fixed route service are required to provide complementary paratransit service to individuals whose disabilities prevent them from using the fixed route system [Section 37.121]. The exception to this is commuter bus service, which is defined earlier in this section of the Toolkit.

Complementary paratransit service requirements are found in Subpart F of 49 CFR Part 37; additional information can be found in Chapter 8 of FTA ADA Circular 4710.1. This Toolkit includes a section about the ADA Complementary Paratransit requirements.

When constructing or altering a bus stop (or other transportation facility), a transit agency is required to ensure that the new or altered facility is accessible to people with disabilities [Section 37.41]. U.S. DOT Standards for Transportation Facilities provides specific requirements for bus boarding and alighting areas in Section 810.2. The ADA standards for bus stops and other transportation facilities are also discussed in the Vehicle and Facility Accessibility section of this Toolkit.



Section 2.3.2 of FTA ADA Circular 4710.1 notes that transit agencies are also responsible for clearing obstructions that create accessibility barriers in areas directly controlled by the transit agency’s organization. An example of this is removing snow at bus stops over which the transit agency has direct control. For other bus stops and surrounding sidewalks, FTA encourages coordination with other public entities or private property owners. A resource on this topic is Effective Snow Removal for Pathways and Transit Stops.

Inaccessibility of a bus stop and surrounding pedestrian environment can impact demand for ADA complementary paratransit for a rider who could otherwise use the fixed route service. It is often more cost-effective to make and keep the bus stop and sidewalk accessible than to provide ADA paratransit on an ongoing basis. Improving the accessibility of the built environment also improves mobility for not only riders with disabilities, but also for many other riders, including those who are pushing strollers, pulling wheeled luggage, etc. Additional discussion on and resources for improving bus stop and pedestrian pathway accessibility is found in the Vehicle and Facility Accessibility section of this Toolkit.

Some rural transit systems allow riders to request “flag stops” instead of, or in addition to, fixed stops. An example of a flag stop policy is to allow drivers to have discretion to stop the bus to pick up or drop off riders at any location requested by a rider. In addition to potential safety concerns, rider misunderstandings, and potential inconsistencies from one driver to the next, flag stops can present added challenges to riders with disabilities. Riders with vision impairments may not realize a bus is approaching until it is too late to signal to the driver that they wish to board. Other riders may see an approaching bus, but be unable to signal the driver, because they lack the ability to raise their arms. Flag stops are only recommended in very rural areas as a supplement to fixed stops. Operating on a flag stop basis without also serving fixed stops could result in some riders with some types of disabilities being unable to effectively utilize the service, necessitating ADA complementary paratransit for these riders. Transit agencies that permit flag stops should require drivers to stop for any individual waiting along the side of the road who is using a mobility device, holding a white cane, or accompanied by a service animal. A recommended practice for transit agencies that have no fixed stops is to encourage all riders to telephone the dispatcher in advance to request a pick-up at a specific location along the route, and the dispatcher can then alert the driver of requested pick-ups.

It should be noted that fixed route bus service with flag stops is still fixed route bus service. As discussed in Appendix D to 49 CFR Section 37.3, the need for a rider to interact with the transit system to obtain a ride by flagging down the bus does not make an otherwise fixed route bus service demand responsive.

Appendix E to 49 CFR Part 37 provides a series of examples of reasonable modifications that fixed route riders with disabilities could request. (The requirement to consider reasonable modification requests is summarized in the General Requirements for All Service Types section of this Toolkit.) Two of the examples are related to fixed route bus stops. If snow or icy conditions at a bus stop make it difficult or impossible for a fixed route passenger with a disability to get to a lift, or for the lift to deploy, the driver should move the bus to a cleared area for boarding, if such is available within reasonable proximity to the stop. Likewise, a rider's request for a fixed route bus driver to position the vehicle to avoid obstructions at a designated stop location, such as parked cars, snow banks, and construction, should be granted so long as positioning the vehicle to avoid the obstruction does not pose a direct threat to safety. To be granted, such a request should result in the vehicle stopping in reasonably close proximity to the designated stop location. (However, fixed route providers would not be required to establish flag stop or route deviation policies, as these would be fundamental alterations to a fixed route system rather than reasonable modifications of a system.)

Accessibility of the information provided on how to use the fixed route service can impact a rider’s ability to effectively navigate the system (which in turn impacts ADA complementary paratransit). The Rider Information section of this Toolkit discusses this aspect of transit accessibility. FTA ADA Circular 4710.1 notes that FTA encourages transit agencies to establish travel training programs that promote the use of fixed route services for individuals who have the ability to use the fixed route for a portion of their trips [Section 9.2.2]. (Note, however, travel training cannot be required as part of the paratransit eligibility process; eligibility is determined based on the applicant’s current abilities.)



As explained in National RTAP’s Travel Training Best Practices Spotlight article, travel training can give new riders the skills to read route maps and schedules, locate bus stops, flag down buses, calculate and pay fares, obtain and use transit passes, recognize when the desired stop has been reached, indicate to the bus driver to stop, use mobility devices safely on vehicles, and more. Resources for developing travel training programs include the Association for Travel Instruction, Easterseals Project Action Consulting, and the National Aging and Disability Transportation Center.

Updated February 3, 2025