ADA Toolkit

The public transportation industry involves a growing array of travel modes and technologies. “Shared mobility,” “microtransit,” and “shared micromobility” are often used to categorize transportation modes which are increasingly part of the landscape of community mobility options. Different organizations offer varying and interrelated definitions of these terms. See the Glossary in this Toolkit for definitions of these terms.

An overarching requirement of U.S. DOT ADA regulations is that “No entity shall discriminate against an individual with a disability in connection with the provision of transportation service” [49 CFR Section 37.5(a)]. In other words, any transportation service must be accessible to and usable by individuals with disabilities. Depending upon the service design, shared-used mobility, microtransit, and shared micromobility modes would be subject to the requirements of either the fixed route or demand responsive categories in 49 CFR Part 37, and vehicles may be subject to 49 CFR Part 38. A transit agency that is considering starting a shared-used mobility, microtransit, and shared micromobility program is advised to consult with the U.S. DOT or FTA to determine how these regulations apply. ADA compliance is required regardless of whether or not federal funding is used for a service or program. However, ADA compliance is also a condition of eligibility for federal funding [49 CFR Part 27]. Further, program access requirements of the U.S. Department of Justice (DOJ) ADA regulations may also apply.

Also, if any of these modes or technologies are used to provide part of a transit agency’s demand responsive system, whether or not federal funding is involved, the transit agency must ensure that the demand responsive system, when viewed in its entirety, provides a level of service to individuals with disabilities equivalent to the level of service it provides to individuals without disabilities. Equivalent service for individuals with disabilities must be provided in the most integrated setting appropriate to the needs of the individual and must be equivalent to the service provided other individuals with respect to seven service operating characteristics which are specified in 49 CFR Section 37.77(c), detailed in Section 7.4 of FTA ADA Circular 4710.1, and summarized under Equivalent Service Standards in the Demand Response Requirements section of this Toolkit. 

These operating characteristics are:

• Response time
• Fares
• Geographic area of service
• Hours and days of service
• Restrictions or priorities based on trip purpose
• Availability of information and reservations capability
• Any constraints on capacity or service availability
  

FTA is exploring the use of automation technologies in transit operations. FTA’s Transit Automation Research web page is based on the Strategic Transit Automation Research (STAR) Plan that outlines FTA’s research agenda on transit bus automation technologies. Autonomous, “self-driving” vehicles, could not only expand transit options in the future, but may also provide individuals with disabilities with expanded personal mobility choices. An autonomous vehicle is a vehicle that is capable of sensing its environment and moving safely with little or no human input. An autonomous vehicle is also referred to as a self-driving vehicle. Connected vehicles and infrastructure use technology to communicate with one another.  Strategic Transit Automation Research Plan 2.0: 2023-2028 (Report 0264) is a successor to the original 2018 STAR Plan published by FTA. It builds upon the work accomplished from the 2018 STAR Plan (referred to now as STAR Plan 1.0) and provides strategic research and demonstration framework for the next five years to advance driving automation systems that meet public transportation needs. Key components of the plan include conducting enabling research on safe and effective transit automation deployments, demonstrating nearly-market-ready prototype technologies in real-world settings, and learning from and sharing knowledge with the transit stakeholder community. 

A June 2018 report from the National Center for Mobility Management (NCMM), Autonomous Vehicles: Considerations for People with Disabilities and Older Adults introduces considerations for physical accessibility and interface (i.e., through an app or a website) accessibility considerations. 

The Disability Rights Education & Defense Fund (DREDF) has published a Letter for the Record, Autonomous Vehicles: Promises and Challenges of Evolving Automotive Technologies (February 2020). The letter, written to the Consumer Protection and Commerce Subcommittee, Committee on Energy and Commerce, U.S. House of Representatives, focuses on the importance of vehicles and the surrounding infrastructure being “fully accessible, i.e., accessible to people with sensory, cognitive, and physical disabilities, including wheelchair users, and people with neurological conditions, including seizure disorders.” The  human to machine interface, hardware, and policy and legislation are also addressed.

In May 2022, the Consortium for Citizens with Disabilities (CCD) updated its CCD Transportation Task Force Autonomous Vehicle Principles. This document lists principles and recommendations adopted by the CCD Transportation Task Force and partner advocacy organizations related to autonomous vehicle accessibility, licensing, insurance, costs, data (including privacy of users and safety data), infrastructure, legislation, research, funding, and service integration.

In April 2019, ITS America published a whitepaper titled Driverless Cars and Accessibility: Designing the Future of Transportation for People with Disabilities. This document outlines the challenges for accessibility in road transportation and unique design considerations for automated vehicles. It discusses accessible human machine interfaces for automated vehicles. The whitepaper also recommends next steps for the industry and the disability community.

Widespread deployment of fully autonomous automobiles may not be as imminent as previously believed, according to news reports such as a July 2019 article in the New York Times. Automated vehicles are also very much an emerging technology in terms of regulation. NCMM's Autonomous Vehicles: Considerations for People with Disabilities and Older Adults notes that, at the time of the report, there was no federal law that specifically governs autonomous vehicles, while many state governments had passed laws that provide for research to be conducted, with some states having passed laws allowing autonomous vehicles to operate on public roads to be tested, or to establish a graduated regulatory system. 

Among the FAQs posted on the FTA website on transit automation is a question on ADA compliance of automated transit vehicles. The response notes that partial automation would still have a driver present (who could provide assistance with securing wheelchairs or helping with other accessibility features). However, for fully automated operations, it is unclear how this assistance could be provided without having an employee in the vehicle. 

In March and April 2021, the U.S. Access Board conducted virtual meetings about autonomous vehicles. The summary report on these events provides an overview of accessibility considerations for riders with mobility disabilities, sensory disabilities, and cognitive disabilities. The report includes a summary of the comments received from the online dialogue. The public forums highlighted a need to establish accessibility standards for autonomous vehicles and ensure that autonomous vehicles are designed for people with all types of disabilities.

This selected list of literature published on autonomous vehicles and considerations related to their use by people with disabilities indicates the complexity of this aspect of autonomous vehicle technology. As the technology (and U.S. DOT regulation) for automated vehicles continues to develop, National RTAP will continue to monitor any ADA-related considerations that may also emerge.

Wheelchair charging stations are an amenity that some transit agencies are beginning to offer at transit stations and even on buses. Municipalities may also offer wheelchair charging stations near transit stations or bus stops. This is a customer amenity-related best practice rather than an ADA compliance concern. Providing riders who use power wheelchairs and other battery-powered mobility devices can help prevent the rider from getting stranded due to an exhausted battery. More information is available in National RTAP’s Best Practices Spotlight Article: Wheelchair Charging at Transit Stations and on the Bus. In addition to the jurisdictions listed in the article, examples of municipalities that offer this amenity include the City of Bellevue, Washington, and Scott County, Iowa. Meridian Township, Michigan is also developing a paved trail and boardwalk that will include a wheelchair charging station.

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