1. Federal Transit Administration, Office of Civil Rights
Six Things Every Transit Board Member Should Know about ADA Compliance: ACCESS!
Aida Douglas
Federal Transit Administration, Office of Civil Rights
Washington, D.C.

2. • Trend: Uber/Lyft/Bridj partnerships
Agenda
• ADA Resources
• What is “ACCESS”?
• Trend: Uber/Lyft/Bridj partnerships

3. Resources Are Available
You are not alone!
FTA’s ADA Circular provides one-stop shopping
Covers 49 CFR 27, 37, 38, 39, and Facility Standards
Contains no new requirements
Helps avoid oversight findings

4. Resources cont. Check out our ADA webpage at:
Circular link can be found at:

5. What is ACCESS? A C C E S S is your responsibility!
A—acquire accessible vehicles
C—construct accessibility
C—communicate with disability community
E—equivalent facilitation
S— sustain your accessible features
S—sensible changes to policies when needed
A C C E S S is your responsibility!

6. A—Acquire Accessible Vehicles
Vehicle purchases:
--Your transit agency must acquire accessible vehicles
If you receive a proposal that departs from a standard bus or rail car purchase, please ask:
“Will the delivered product be accessible to people who use wheelchairs?”

7. C—Construct Accessibility
All new construction must be accessible
Any alterations to any existing facility must be accessible
When presented with a plan to construct a new facility or alter an existing one, please ask:
“Have you conducted an analysis to determine the accessibility features for this facility?”

8. C—Communicate with the Disability Community
Communicate, communicate, communicate!
Transit agencies should have a list of independent living centers or similar organizations
When proposed changes in service or facilities will impact people with disabilities, please ask:
“What was your outreach to disabled?”

9. E—Equivalent Facilitation
Concept allows for innovation in accessible design.
Innovations must provide “equal or greater accessibility”
When presented with proposal that differs in design from Part 38 requirements, please ask:
“May I see the FTA letter approving this new design?”

10. S—Sustain Accessible Features
A transit agency must maintain accessibility features in facilities and on vehicles
When accessibility features are damaged or out of order, the agency must repair them promptly.
When presented with a proposal that would delay repairs to an accessible feature, please ask:
“What does this delay do to system-wide accessibility?”

11. S—Sensible Changes to Policies When Needed
Transit agencies must make “reasonable modifications” to their policies, when needed.
Reasonable—fair and sensible; not extreme or excessive; possessing sound judgment
Modification-the act or process of changing parts of something
When presented with a new policy, please ask:
“How has the agency communicated to the public it will modify this policy, if needed?”

12. Trend
Uber/Lyft/Bridj partnerships

13. The Issues
Transportation Network Companies (TNCs) seeking to partner with transit
Transit agencies seeking to partner with TNCs
Disability community concerns:
TNCs lack accessible vehicles
Segregated service
Second-class paratransit service for wheelchair users

14. Basic Principles ADA applies regardless of Federal funding
DOT ADA regulations apply to public and private entities
Service must be provided in the most integrated setting

15. Partnership Examples Feeder Service (“First mile/last mile”)
Uses TNCs to connect transit systems with underserved areas
Ridesharing
TNCs integrated with existing carpool programs
Guaranteed Ride Home
TNCs integrated with existing program

16. Questions? www.transit.dot.gov Civil Right Training Page
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