Vehicle and Facility Accessibility

This section of the toolkit focuses on the U.S. Department of Transportation (DOT) accessibility standards for transit vehicles and facilities.  It also presents technical assistance information and sample practices.  The information in this section is organized in the following subsections:


The information presented in this section is primarily based on the U.S. Department of Transportation (DOT) regulations:  49 CFR Part 37- Transportation Services for Individuals with Disabilities (ADA) and 49 CFR Part 38- Americans with Disabilities Act (ADA) Accessibility Specifications for Transportation Vehicles, as well as FTA Circular 4710.1, Americans With Disabilities Act (ADA): Guidance and the U.S. Access Board ADA Standards for Transportation Facilities.


U.S. Access Board

The U.S. Access Board is a federal agency statutorily required to develop and issue standards for accessibility under the ADA and the Architectural Barriers Act of 1968. The Access Board is structured to function as a coordinating body among federal agencies and to directly represent the public, particularly people with disabilities. Twelve of its members are representatives from most of the federal departments. Thirteen others are members of the public appointed by the President, a majority of whom must have a disability. By statute, the standards issued by the Access Board become the basis for regulatory requirements issued by enforcement agencies including U.S. Department of Justice (DOJ) and the U.S. DOT.

Additional information about the Access Board can be found on their website.  Information about the Access Board’s guidelines for transportation vehicles and facilities can be found here.


U.S. Department of Transportation

The U.S. DOT-adopted standards for vehicles and facilities are found in the following regulations:


Transportation Vehicles

The requirement for public entities to acquire accessible vehicles is found in 49 CFR Part 37, Subpart D.  Generally speaking, all vehicles must be accessible to and usable by persons with disabilities, including wheelchair users. Demand responsive vehicles must also be accessible, unless an equivalent level of service is provided to all riders, including those who use mobility devices, according to specific regulatory critiera.  For more information on determining equivalent service, see the Demand Response Requirements section of this toolkit.

Summary of the Accessibility Specifications for Buses and Vans

The vehicle accessibility standards are found in 49 CFR Part 38.  Subpart B addresses buses and vans, except over-the-road buses, which are found in Subpart G.  Section 4.2.5 of the FTA ADA Circular provides guidance on accessibility features of buses and vans.  For those vehicles that are required to have accessible features, each feature must be fully operational any time the vehicle is in use.  This following is a summary of key features specified in Subpart B of Part 38.

  • Mobility aid accessibility – Vehicles must have a lift or ramp to allow individuals with a disability, including individuals who use wheelchairs, to safely board, and there must be sufficient clearances to permit a user of a wheelchair or other mobility aid to reach a securement location.  Vehicles in excess of 22 feet must have at least two securement locations, and smaller vehicles must have at least one.  Securement systems must be either forward-facing, or rear-facing with a padded barrier (with a least one forward-facing position on vehicles longer than 22 feet).  The securement area(s) must be located as near to the accessible entrance as practicable, and provide a clear floor area of at least 30 inches by 48 inches. The vehicle lift or ramp design load must be at least 600 pounds. Lifts must permit both inboard and outboard facing of wheelchair and mobility aid users, and must be equipped with handrails to support standees. Ramps must have the least slope practicable and must not exceed 1:4 when deployed to ground level.  The maximum allowable slope to a 6-inch curb varies with the height of the vehicle floor.  On a vehicle with a floor height that is 3 to 6 inches above a 6-inch curb, a maximum ramp slope of 1:6 is permitted.  A vehicle floor height that is 6 to 9 inches above a 6 inch curb can have a slope no greater than 1:8, while a vehicle floor height that is greater than 9 inches above a 6 inch curb requires a slope no greater than 1:12 [Section 38.23].  Additional mobility device accessibility considerations are discussed following the rest of this list of requirements under Part 38.
  • Doors, steps, and thresholds - must be slip resistant, and all steps, edges, thresholds, and the boarding edge of the ramp must have a band of contrasting color running the full length of the step or edge.   Door height must be a minimum of 68 inches for vehicles in excess of 22 feet and a minimum of 56 inches for smaller vehicles [Section 38.25]. Vehicle step heights are not specified in the U.S. DOT ADA regulations. Considerations for vehicle step heights are discussed later on this page of the toolkit, following Additional Mobility Device Accessibility Considerations. 
  • Priority seating signs - must be placed at the front of the bus, including at least one set of forward-facing seats. Signs are also required at securement locations [Section 38.27].  (As discussed in the Accommodating Riders with Disabilities section of the toolkit, bus drivers must ask other passengers to make securement locations and priority seats available to individuals with disabilities when necessary [Section 37.167(j)]).
  • Interior handrails - The placement of interior handrails and stanchions must permit sufficient turning and maneuvering space for wheelchairs and other mobility aids to reach a securement location from the lift or ramp.  Handrails or stanchions must also be located at the entrance to the vehicle [Section 38.29].  A stanchion is an upright bar, post, or frame forming a support or barrier.  On a transit vehicle, stanchions are commonly positioned along the aisle.  They provide standing passengers with something to hold to maintain their balance. 
  • Lighting - is required at any stepwell or doorway [Section 38.31].
  • Fare Boxes - If your vehicles have fare boxes, they must be located as far forward as practicable so as not to obstruct traffic in the vestibule [Section 38.33].
  • Public address systems - must be installed in any vehicle in excess of 22 feet that is used in multiple-stop, fixed route service [Section 38.35].
  • Stop request controls - must be located adjacent to the securement location in vehicles in excess of 22 feet that make multiple stops.  These controls must be located between 15 inches to 48 inches off the ground, and must be operable with one hand and must not require tight grasping, pinching, or twisting of the wrist. [Section 38.37].
  • Signage - For destination or route information displayed on the exterior of the vehicle, each vehicle must have illuminated signs on the front and boarding side of the vehicle [Section 38.39]. 

Additional Mobility Device Accessibility Considerations

  • While the weight load and dimension requirements listed above are the current minimum requirements, transit agencies that acquire vehicles that can accommodate larger dimensions and heavier weight loads will be able to accommodate more individuals and their larger mobility devices.  For example, a transit agency could procure securement areas that are 31 by 52 inches, instead of the minimum dimensions of 30 by 48 inches required in 49 CFR Part 38.  While Part 38 requires a lift to accommodate 600 pounds, a transit agency could procure lifts that accommodate 800 or more.  TCRP Report 171: Use of Mobility Devices on Paratransit Vehicles and Buses recommends accommodating a minimum of 30 by 54 inches and 800 pounds.  Transit agencies should check with their State DOT about any state requirements to accommodate larger dimensions and heavier weight loads.
  • Some transit agencies acquire buses or vans with the accessible entrance located at the rear of the vehicle or at the side behind the rear axle, with controls that the driver operates while standing outside the vehicle.  For many smaller vehicles operated in demand responsive service, this may be the most practical approach to meeting the accessibility standards. However, it can provide a less comfortable ride for those riding in securement positions that are behind the rear axle.  Lifts on buses operated in fixed route service are commonly installed on the side near the front of the vehicle, with controls that the driver can operate while seated.  This approach provides a more integrated setting for boarding and disembarking of all passengers.
  • Side-facing securement areas are not allowed on buses and vans under the U.S. DOT regulations; securement areas must be forward-facing, or rear-facing with a padded barrier [49 CFR Section 38.23(d)(4)].
  • Although it is not specifically required, a “kneeling” feature on the bus allows the bus to lower at the front door and reduce the vertical distance between vehicle floor height and the ground.  This makes it easier for other ambulatory riders to enter and exit the bus (see discussion below under Vehicle Step Height Considerations). In some situations, such as when deploying a ramp on the street or to a low curb, the use of the kneeling system may be necessary to achieve a compliant ramp slope.
  • Information on transit industry approaches to vehicle configuration to accommodate individuals using a wide range of mobility devices can be found in TCRP Report 171: Use of Mobility Devices on Paratransit Vehicles and Buses, Chapter 6, and TCRP Report 163, Strategy Guide to Enable and Promote the Use of Fixed-Route Transit by People with Disabilities, Chapter 4.  Note that these research and technical assistance documents were published by the Transportation Research Board (TRB) and have not been endorsed or approved by FTA or U.S. DOT.
  • Operational requirements for lifts, ramps, and securement systems are discussed in the Accommodating Riders Using Mobility Devices section of this toolkit.

Vehicle Step Height Considerations

  • As noted earlier, vehicle step heights are not specified in the U.S. DOT ADA regulations.  The vehicle floor height is a factor in achieving a compliant ramp slope, and floor height affects step height.  Low floor vehicles, which can minimize the vertical gap between the curb and the vehicle floor, are an option to consider.  Transit agencies need to consider curb heights in the communities they serve when determining the appropriate vehicle clearance and bottom stop height on their vehicles.
  • The 2013 APTA Bus Procurement Guidelines recommend that the step height at transit bus doorways not exceed 16.5 inches without “kneeling” (lowering to the ground) [Section TS 6.4].  These APTA Guidelines do not specify whether the 16.5 inches are measured from the street or curb. (The optional kneeling feature on buses is discussed above under Additional Mobility Device Accessibility Considerations.)
  • An example of step heights and depths specified in an ADA paratransit vehicle procurement document is found on the California Association for Coordinated Transportation (CALACT) website, from the Morongo Basin Transit Authority (MBTA), which serves as the lead agency for the CALACT Vehicle Purchasing Cooperative California Association for Coordinated Transportation.
  • The November 2009 CALACT Specifications indicate a maximum step height of 9.5 inches with a minimum tread depth of 9.5 inches. The bottom step height is to be a maximum of 12 inches from the ground when the vehicle is unloaded, with a minimum tread depth of 9 inches. 
  • The 2010 Michigan Department of Transportation Small Bus Specifications similarly call for a maximum step height of 9.5 inches (except 12 inches from the ground for the bottom step) with a minimum tread depth of 9 inches.  Many State DOTs procure vehicles on behalf of their subrecipients, and transit agencies should check ask their State DOT about recommended vehicle specifications.


Transportation Facilities

The U.S. DOT requirement to make transportation facilities accessible is found in Subpart C of Part 37.  If a public entity constructs new facilities to be used for providing designated public transportation services, they must be readily accessible to and usable by individuals with disabilities, including individuals who use wheelchairs [Section 37.41].  If a public entity alters an existing facility or part of an existing facility used for providing designated public transportation services, and that alteration affects or could affect the usability of the facility, the agency must make the alterations in a way that is readily accessible to and usable by individuals with disabilities [Section 37.43].  Private entities that “stand in the shoes of” (or act on behalf of, due to a grant or contract or other arrangement or relationship) public entities (including Section 5311 grantees) are also subject to the applicable U.S. DOT requirements for public entities. [Section 37.23(a)]   Section 504 of the Rehabilitation Act of 1973 requires that recipients of U.S. DOT funding comply with the same transportation facilities standards as public entities [49 CFR Part 27, Section 27.3]. The Transportation Facilities Standards themselves were developed by the Access Board and adopted by U.S. DOT with some modifications.

U.S. DOT ADA regulations define a facility as all or any portion of buildings, structures, sites, complexes, equipment, roads, walks, passageways, parking lots, or other real or personal property, including the site where the building, property, structure, or equipment is located [Section 37.3].

Alteration means a change to an existing facility, including, but not limited to: remodeling, renovation, rehabilitation, reconstruction, historic restoration, changes or rearrangement in structural parts or elements, and changes or rearrangement in the plan configuration of walls and full-height partitions [Section 37.3].

Fixed bus stops (i.e., stops with a designated location) are considered transit facilities.  The simple placement of a sign on a pole in the ground is not considered construction. However, if a concrete pad is poured or a passenger shelter is installed at the stop, this is considered construction or alteration, and the bus stop must meet minimum accessibility standards summarized below.  As a best practice, transit agencies should endeavor to only establish bus stops at locations where riders who use mobility devices would be able to board using the lift or ramp, to the extent feasible given existing sidewalk conditions.   

Chapter 8 of the FTA ADA Circular provides additional guidance and discussion on the U.S. DOT ADA requirements for transportation facilities of FTA grantees.

As a reminder, accessibility features of vehicles and facilities must be maintained in operative condition.  When an accessibility feature is out of order, the transit agency must take reasonable steps to accommodate individuals with disabilities who would otherwise use the feature [Section 37.161].

Making public transportation accessible for individuals with disabilities and maintaining accessibility of bus stops includes snow removal at bus stops.  According to Section 2.3.2 in the FTA ADA Circular, transit agencies that have direct control over the area have an obligation to remove snow, as well as bicycles and illegally parked vehicles that obstruct accessible routes. An example of direct control is a transit agency that is part of a city government with bus stops on city-owned public right-of-way.  Where a transit agency does not have direct control over the areas with accessibility features, FTA encourages coordination with other public entities or private property owners.

Easter Seals Project ACTION’s Effective Snow Removal for Pathways and Transit Stops provides information on innovative practices and partnership to ensure snow removal.

Summary of the Accessibility Specifications for Transportation Facilities

The accessible transportation facilities standards are found within Appendix A to 49 CFR Part 37, ADA Standards for Transportation Facilities. The following is a brief summary of the requirements for bus stops, bus shelters, and bus stop signs, which can be found within Chapter 8, Section 810 of these standards.

Newly constructed or altered bus boarding and alighting areas (Section 810.2) must:

  • Have a firm, stable surface.
  • Provide a clear length of 96 inches (8 feet) minimum, measured perpendicular to the curb or vehicle roadway edge, and a clear width of 60 inches (5 feet) minimum, measured parallel to the vehicle roadway.
  • Be connected to streets, sidewalks, or pedestrian paths by an accessible route complying with Section 402 of the ADA Standards for Transportation Facilities
  • Have a slope the same as the roadway, to the maximum extent practicable.  Perpendicular to the roadway, the slope of the bus stop boarding and alighting area must be no steeper than 1:48.

New or altered bus shelters (Section 810.3) must:

Bus route identification signs must comply with Section 703.5.1 through 703.5.4 (finish and contrast, case, style, and character proportions), and 703.5.7 and 703.5.8 (stroke thickness and character spacing) of the ADA Standards for Transportation Facilities. In addition, to the maximum extent practicable, bus route identification signs must comply with 703.5.5 (character height).  Bus schedules, timetables and maps that are posted at the bus stop are exempted from this requirement, but a recommended practice is to prominently display the transit agency’s phone number on all bus stop signs, as close as possible to meeting the requirements of 703.5, to help riders with carrying mobile phones who can then call for information.  Transit agencies can use interior panels of shelters to post larger-format schedule information.  Transit agencies with real-time bus arrival technology can post schedule information on real time information display boards at stops with electrical infrastructure.

Bus Stop Inventory and Improvement Planning

Transit agencies that operate fixed route transit can maximize the user-friendliness of the system and reduce the potential demand for complementary paratransit by ensuring that as many of the bus stops as possible meet accessibility standards. Bus stops must also be connected to sidewalks to be considered accessible.  Sidewalks ideally are also fully accessible.  A good practice is to develop and to build and maintain an inventory of all fixed stops, with information about accessibility characteristics and other key features.  The information in the inventory can be used to provide customer information, determine complementary paratransit trip eligibility, and plan for improvements in a systematic fashion.  Bus stops should be assessed based on locally-developed bus stop standards that incorporate not only ADA requirements but also locally-determined standards, such as spacing along the route and amenities to be installed.

Chapter 5 of TCRP Report 163, Strategy Guide to Enable and Promote the Use of Fixed-Route Transit by People with Disabilities provides additional information and examples of transit agency efforts to improve bus stop and pedestrian pathway accessibility. A rural example on installing low-cost bust stop pads (passenger boarding areas in Wenatchee, Washington) can be found on pages 48-49 of TCRP Report 163.

An example of a rural bus stop inventory and planning study is the Northwest Pennsylvania Regional Planning and Development Commission (Northwest Commission) Bus Stop Inventory, Assessment, and Recommendations.  This study was conducted for Crawford Area Transportation Authority, Venango County Transit, and Transit Authority of Warren County, referencing the Northwest Commission’s Bus Stop Guidelines: Design and Amenity Standards.

Resources for developing bus stop standards and assessing bus stop accessibility include Easter Seals Project ACTION’s Toolkit for the Assessment of Bus Stop Accessibility and Safety and TCRP Report 19: Guidelines for the Location and Design of Bus Stops.

Easter Seals Project ACTION (ESPA) and National Aging and Disabilities Transportation Center (NADTC) have also developed several resources on accessible pedestrian pathways which can be accessed through the NADTC website.  These resources include Accessible Pathways to Bus Stops & Transit Facilities Findings in BriefAccessible Pathways & Livable Communities Pocket Guide, and course materials from a 2019 Accessible Pedestrian Pathways mini-course.

Transit agencies can work with the jurisdictions they serve to incorporate bus stop improvements as part of roadway and sidewalk improvements, and with adjacent property owners/developers as part of land use improvements. 

Bus stop and associated sidewalk improvements should also be addressed in each jurisdiction’s transition plan that is required by the U.S. Department of Justice (DOJ).  Under the ADA and Section 504, as established in 28 CFR Part 35 - Nondiscrimination on the Basis of Disability in State and Local Government Services, Section 35.150(d), State and local governments with 50 or more employees are required to perform an ADA self-evaluation and develop a transition plan to address ADA compliance deficiencies (including inaccessible sidewalks).  This plan provides a schedule for needed pedestrian accessibility upgrades and must be updated periodically.  The Federal Highway Administration (FHWA) is the oversight agency for ADA compliance with regards to sidewalks, and the U.S. DOJ has enforcement responsibility.   

Signage and Wayfinding for People with Vision and Hearing Disabilities

When designing and improving transportation facilities, including facilities with multiple bus stops such as transfer centers, transit agencies should consider the need for people with visual and hearing disabilities to safely navigate to and through the facility. Wayfinding assistance can include providing tactile (touchable) indication of pathways and bus boarding areas as well as higher tech approaches such as audible information (that can be heard).  Audible information, such as announcements over the public address system, also need to be provided in a visual format so that people with hearing disabilities have access to the same information.  Easter Seals Project ACTION’s Improving Transit Facility Accessibility by Employing Wayfinding Technology Information Brief provides more information on this topic.  TCRP-sponsored research on Tactile Wayfinding in Transportation Settings for Travelers Who Are Blind or Visually Impaired is currently under way, with a guidebook to be developed.


Equivalent Facilitation

Equivalent facilitation is the process for requesting permission to depart from the technical standards in the DOT ADA regulations and to use alternative designs or technologies that provide equal or greater accessibility. Requests for determinations of equivalent facilitation are made to, and determinations are made by, the Administrator of the concerned U.S. DOT operating administration, in this case FTA, with concurrence from the Office of the Secretary of Transportation. Transit agencies can request permission from FTA to depart from the standards for transportation vehicles and facilities.  The ability to make requests for determinations of equivalent facilitation is found in Section 37.7(b) for vehicles and Section 37.9(d) for facilities.  For transit agencies pursuing equivalent facilitation, significant public participation is required, including consultation with individuals with disabilities and groups representing them in the community, at all stages of the development of the request for equivalent facilitation. For more information, see Chapter 5 of the FTA ADA Circular.


Section Sources

Updated June 2, 2020