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ADA Frequently Asked Questions

Reasonable Modification/Accommodation
Frequently Asked Questions

The Federal Department of Transportation (DOT) has revised the rules under the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act of 1973. The revised rules provide for public transit organizations to make reasonable modifications and accommodations to policies, practices, and procedures to avoid discrimination, and to ensure accessibility to individuals with disabilities.

A reasonable modification/accommodation will enable a person with a disability to fully use transit services.

The rule is effective July 13, 2015.

Reasonable modification/accommodation applies to OCTA bus services.

Individuals with disabilities may request a reasonable modification of OCTA policies, practices, and procedures in order to accommodate a disability. OCTA asks that a written request be made in advance using the Reasonable Modification Request form.

There are several ways to obtain a Reasonable Modification request form:

  • Fill out an online form at
  • Send an email to
  • Send a request to: Federal Compliance Officer, P.O. Box 14184, Orange, CA 92863
  • Call the Federal Compliance Officer at (800) 636-RIDE (7433).

A written reply will be sent as soon as reasonably possible. The written response will communicate the decision regarding the requested reasonable modification/ accommodation, and the reason(s) for the decision.

Requests are reviewed to determine if the reasonable modification/accommodation provides use or access to OCTA’s transit services that the requestor otherwise would not have. OCTA’s focus is on accessibility, as distinct from convenience.

The DOT has prescribed four types of requests for modification/accommodation.

Requests may be declined if:

  1. It fundamentally alters the nature of the service, program or activity
  2. It creates a direct threat to the health or safety of others
  3. It results in undue financial and administrative burden
  4. The requestor would still be able to fully use the service provided by OCTA without the modification.

Here are some examples of accommodations that can be made for customers with disabilities:

  • Customer request for partial wheelchair securement
  • Customer request to use lap and shoulder belt without wheelchair securement
  • Customers requiring self-medication while in transit or at an event; this includes administering insulin or conducting a finger stick blood test
  • Customers requiring food related to medical conditions, such as a person with diabetes needing a high-sugar snack or covered drink to control low blood sugar
  • Customer request to stop ahead of or behind a bus stop due to an obstruction (such as a parked car) or construction, when it is safe to do so, for either boarding or exiting a bus
  • Customer request for a convenience stop due to lack of curb cuts or accessible path of travel

Here are some examples of accommodations that will be denied:

  • Customer flagging a bus to pick up in-between bus stops
  • Customer request for bus operator to perform personal care attendant functions
  • Boarding a customer whose service animal is not under control
  • Boarding a customer whose wheelchair is being used to transport only possessions

Requests can be made to Bus Operators if you are unable to make requests in advance. Service may be delayed as your request is considered. Please indicate if you have already made a written request. The OCTA representative may need to contact a supervisor or Central Communications regarding your request.

All complaints should be directed to OCTA’s Federal Compliance Officer. Complaints can be filed online at, via email to or by phone to (800) 636-RIDE (1433). Written letters should be directed to Federal Compliance Officer, P.O. Box 14184, Orange, CA 92863. You will receive an acknowledgment of receipt of your complaint and a tracking number for reference. Complaints are resolved within ninety (90) days and you will receive a letter advising of the complaint resolution. For complaints involving reasonable modification/ accommodation, you will be informed about the decision and the reasons for the decision.

To obtain more information about OCTA’s policies for reasonable modification/accommodation, including potential accommodations or declined requests, please visit The Department of Transportation (DOT) rule revision can be viewed at

Additional Contact Information:

Federal Transit Administration (FTA) – (202) 366-4043
Monday through Friday, 8:30 AM and 5:00 PM EDT, excluding Federal Holidays.

Department of Transportation (DOT) General Information – (855) 368-4200
Main Switchboard is available Monday through Friday (excluding Federal Holidays)
8:00 AM to 5:30 PM EDT (5:00 AM to 2:30 PM PDT)

U.S. Department of Transportation
Federal Transit Administration, East Building
1200 New Jersey Ave., SE, Washington, DC 20590
TTY: 1 (800) 877-8339
Voice: 1 (866) 377-8642
VCO: 1 (877) 877-6280

To contact OCTA about reasonable modification/ accommodation, please email the Federal Compliance Officer at or call (800) 636-ride (7433).