This section of the toolkit is dedicated to new topics and developments that relate to rural transit accessibility and the Americans with Disabilities Act (ADA) requirements that apply to rural public transit providers. It will be updated as new materials and information are available and when new questions emerge that may need additional explanation. This section is organized into the following subsections:
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 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.
It should be noted that the term “scooter” in the context of shared mobility, microtransit, or shared micromobility generally refers to two-wheeled scooters on which the user stands. This type of device is different from the 3-wheeled (or more) scooter that falls under the U.S. DOT ADA regulation definition of “wheelchair,” on which the user sits. That said, a two-wheeled scooter could be used as a mobility device by some individuals with disabilities.
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 the FTA ADA Circular, and summarized under Equivalent Service Standards in the Demand Response Requirements section of this toolkit. These operating characteristics are:
U.S. DOT has issued guidance specific to using taxis and TNCs to provide part of a transit agency’s services. A “Dear Colleague” letter on shared mobility issued by U.S. DOT on December 5, 2016 affirms that transit agencies that rely on external transportation providers to provide any portion of their demand response services need to ensure that people with disabilities are provided with an equal level of access based on the seven operating characteristics required for demand response systems. FTA has published to its website frequently asked questions on shared mobility guidance and ADA.
Transit agencies may also be asked to accommodate a shared mobility device, such as a two-wheeled scooter or e-scooter, on the vehicle when the device is used by a rider with a disability as a mobility device. Section 2.4.2 of the FTA ADA Circular notes that transit agencies are not required to accommodate devices that are not primarily designed for use by individuals with mobility impairments, including items such as bicycles and skateboards.

Another consideration for shared use equipment like bicycles and scooters is the possibility that the equipment, when not in use, can become a barrier on the sidewalk. This may cause the sidewalk to become temporarily inaccessible to individuals with disabilities and those who use wheelchairs, and potentially block access to bus stops. This may become a factor in determining paratransit eligibility.
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 self-driving vehicle. Connected vehicles and infrastructure use technology to communicate with one another.
As explored in Self-Driving Cars: Mapping Access to a Technology Revolution, a November 2015 report published by the National Council on Disability, automated vehicles hold great promise for people with disabilities, as well as obstacles that people with disabilities face to realizing that promise.
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 developed a working draft checklist for fully accessible autonomous vehicles that addresses the human to machine interface, hardware, and policy and legislation.
The Consortium for Citizens with Disabilities (CCD) issued 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 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 on inclusive design of autonomous vehicles. The summary report on these events provides an overview of accessibility considerations for passengers 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 offer 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.
Coronavirus Disease 2019 (COVID-19) has undoubtably been one of the new developments with the most far-reaching ramifications of our time. The novel respiratory virus has spread rapidly to all areas of the country and the world, and has resulted in shutdowns of businesses, schools, and workplaces where public transportation would normally travel to. At the time of this writing, infection rates have been climbing again as the highly contagious Delta variant has become the predominant strain of the virus. Effective vaccinations are widely available across the U.S.. Other prevention measures include vaccines, wearing masks, frequent hand-washing, cleaning and disinfecting touchable surfaces, ventilation, social distancing with at least 6 feet between individuals, testing symptomatic individuals, and quarantine of infected individuals. For rural transit agencies providing service to riders with disabilities, the pandemic has raised many questions about how to provide U.S. DOT ADA-compliant service while protecting the health and safety of drivers and passengers.
Federal Transit Administration (FTA) has answered many of these questions on their Frequently Asked Questions from FTA Grantees Regarding Coronavirus Disease 2019 (COVID-19) web page. Answers to ADA-related questions posted through July 2021 are summarized here:
At the time of this writing, a Transportation Security Administration (TSA) directive implementing a Centers for Disease Control and Prevention (CDC) federal mask requirement for transit systems requires transit passengers to wear masks on board public transit vehicles and inside transit facilities (through March 18, 2022). However, the requirement to wear a mask does not apply to people with disabilities who cannot wear a mask, or cannot safely wear a mask, because of their disability. The mask requirement also does not apply while communicating with a person who is deaf or hard of hearing or to persons who are unable to remove the mask without assistance.
The publication Wearing of Face Masks While on Conveyances and at Transportation Hubs FAQs on the U.S. DOT website addresses several questions related to the mask requirement and people with disabilities, including:
The Southeast ADA Center and Burton Blatt Institute (BBI) at Syracuse University maintains a technical assistance web page about face mask policies and the ADA which provides examples of people with disabilities who may be unable to wear a face mask. This can include individuals with respiratory disabilities, people with post-traumatic stress disorder (PTSD) and others who may feel afraid when wearing a face mask, people with autism who are sensitive to touch and texture, people with difficulty moving small muscles in the hands, wrists, or fingers, and people who use mouth control devices to operate their assistive equipment.
Note that state governors may enact orders specific to their states. For example, one governor issued an executive order declaring that people and organizations providing services for people with disabilities are exempt from emergency measures impacting movement.
Technical assistance resources are available to transit agencies to help them best serve their riders with disabilities during the COVID-19 pandemic. In 2020, the Community Transportation Association of America (CTAA) published a best practices article on wheelchair securement. They recommend asking passengers to turn their head towards the window as the driver secures their wheelchair, not having conversations during wheelchair securement, a process for sanitizing securement belts, and offering masks to riders. The National Aging and Disability Transportation Center (NADTC) has posted guidance from eight national advocacy agencies representing persons with various types of disabilities on Implementing New COVID-19 Policies for People with Disabilities.
COVID-19 can itself sometimes result in a disability.
Guidance from the U.S. Department of Health and Human Services Office for Civil Rights and U.S. Department of Justice Civil Rights Division explains how the symptoms of long-term COVID-19 (“long COVID”) can be a disability under the ADA and other legislation.
Updated February 16, 2024
" National RTAP offers one-stop shopping for rural and tribal transit technical assistance products and services. Call, email, or chat with us and if we can’t help with your request, we’ll connect you with someone who can! "
" You go above and beyond and I wanted to let you know that I appreciate it so much and always enjoy my time with you. The presentations give me so much to bring back to my agency and my subrecipients. "
" I always used the CASE (Copy And Steal Everything) method to develop training materials until I discovered RTAP. They give it to you for free. Use it! "
" National RTAP provides an essential service to rural and small transit agencies. The products are provided at no cost and help agencies maximize their resources and ensure that their employees are trained in all aspects of passenger service. "
" We were able to deploy online trip planning for Glasgow Transit in less than
90 days using GTFS Builder. Trip planning information displays in a riders'
native language, which supports gencies in travel training and meeting Title VI
mandates. "
" Having a tool like GTFS Builder is really light years ahead of what it used to be at one time in terms of how fast you can put everything together. Our university students really can't imagine transit without it, so I think it's very important for us in terms of attracting that particular demographic. "
" In the past we used proprietary database software that was very challenging, very murky, and hard to update. GTFS Builder is a great opportunity to make this more user-friendly, more readily updatable and it
would enable us to show how to create a GTFS to more of the staff. "
" Collaboration is a buzz word these days in the industry. On behalf of our Tribal segment, I appreciate RTAP for making Tribes a partner in industry opportunities. The organization goes over and beyond reaching partners one would not expect in a busy industry such as public transportation. Thank you for your tireless efforts! "
"We are so very thankful for all your transportation training materials. Your resources are as valuable as gold!"
A program of the Federal Transit Administration administered by the Neponset Valley TMA
National RTAP is committed to making this website accessible to persons with disabilities. If you need assistance accessing any content on our website or need alternative formats for our materials, please contact us at info@nationalrtap.org or 781-404-5020.
by National RTAP |