37.77  Purchase or lease of new non-rail vehicles by public entities operating a demand responsive system for the general public.


(a) Except as provided in this section, a public entity operating a demand responsive system for the general public making a solicitation after August 25, 1990, to purchase or lease a new bus or other new vehicle for use on the system, shall ensure that the vehicle is readily accessible to and usable by individuals with disabilities, including individuals who use wheelchairs.

(b) If the system, when viewed in its entirety, provides a level of service to individuals with disabilities, including individuals who use wheelchairs, equivalent to the level of service it provides to individuals without disabilities, it may purchase new vehicles that are not readily accessible to and usable by individuals with disabilities.
Section 224 of the ADA requires that a public entity operating a demand responsive system purchase or lease accessible new vehicles, for which a solicitation is made after August 25, 1990, unless the system, when viewed in its entirety, provides a level of service to individuals with disabilities, including individuals who use wheelchairs, equivalent to the level of service provided to individuals without disabilities.  This section is the same as the October 4, 2020 final rule which promulgated the immediately effective acquisition requirements of the ADA.

(c) For purposes of this section, a demand responsive system, when viewed in its entirety, shall be deemed to provide equivalent service if the service available to individuals with disabilities, including individuals who use wheelchairs, is provided in the most integrated setting appropriate to the needs of the individual and is equivalent to the service provided other individuals with respect to the following service characteristics:
  1. Response time;
  2. Fares;
  3. Geographic area of service;
  4. Hours and days of service;
  5. Restrictions or priorities based on trip purpose;
  6. Availability of information and reservationscapability; and
  7. Any constraints on capacity or service availability.
The Department has been asked to clarify what "accessible when viewed in its entirety" means in the context of a demand responsive system being allowed to purchase an inaccessible vehicle.  First, it is important to note that this exception applies only to demand responsive systems (and not fixed route systems).  The term "equivalent service" was discussed during the passage of the ADA.  Material from the legislative history indicates that "when viewed in its entirety/equivalent service" means that "when all aspects of a transportation system are analyzed, equal opportunities for each individual with a disability to use the transportation system must exist. (H. Rept. 101-184, Pt.2, at 95; S. Rept. 101-116 at 54).  For example, both reports said that "the time delay between a phone call to access the demand responsive system and pick up the individual is not greater because the individual needs a lift or ramp or other accommodation to access the vehicle." (Id.)

Consistent with this, the Department has specified certain service criteria that are to be used when determining if the service is equivalent.  As in previous rulemakings on this provision, the standards (which include service area, response time, fares, hours and days of service, trip purpose restrictions, information and reservations capability, and other capacity constraints) are not absolute standards.  They do not say, for example, that a person with a disability must be picked up in a specified number of hours.  The requirement is that there must be equivalent service for all passengers, whether or not they have a disability.  If the system provides service to persons without disabilities within four hours of a call for service, then passengers with disabilities must be afforded the same service.
(d) A public entity receiving UMTA funds under section 18 or a public entity in a small urbanized area which receives UMTA funds under Section 9 from a state administering agency rather than directly from UMTA, which determines that its service to individuals with disabilities is equivalent to that provided other persons shall, before any procurement of an inaccessible vehicle, file with the appropriate state program office a certificate that it provides equivalent service meeting the standards of paragraph (c) of this section.  Public entities operating demand responsive service receiving funds under any other section of the UMT Act shall file the certificate with the appropriate UMTA regional office. A public entity which does not receive UMTA funds shall make such a certificate and retain it in its files, subject to inspection on request of UMTA.  All certificates under this paragraph may be made and filed in connection with a particular procurement or in advance of a procurement; however, no certificate shall be valid for more than one year.  A copy of the required certificate is found in  Appendix C to this Part.
The Department has been asked specifically where an entity should send its "equivalent level of service" certifications.  We provide the following: Equivalent level of service certifications should be submitted to the state program office if you are a public entity receiving UMTA funds through the state  All other entities should submit their equivalent level of service certifications to the UMTA regional office (listed in Appendix B to this part).  Certifications must be submitted before the acquisition of the vehicles.
(e) The waiver mechanism set forth in 37.71(b)-(g) (unavailability of lifts) of this Subpart shall also be available to public entities operating a demand responsive system for the general public.
Paragraph (e) of this section authorizes a waiver for the unavailability of lifts.  Since demand responsive systems need not purchase accessible vehicles if they can certify equivalent service, the Department has been asked what this provision is doing in this section.

Paragraph (e) applies in the case in which an entity operates a demand responsive system, which is not equivalent, and the entity cannot find accessible vehicles to acquire.  In this case, the waiver provisions applicable to a fixed route entity purchasing or leasing inaccessible new vehicles applies to the demand responsive operator as well.