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ADA and Reasonable Modifications

RTS Access Complementary Paratransit

RTS Access provides complementary paratransit service in Monroe County. Complementary paratransit is only available in areas where fixed route service is available in Monroe County. This service is designed to be comparable to fixed route and is specifically intended for people with disabilities who are unable to use fixed route transportation for some or all of their trips. Eligibility certification is required to use the service. Certified customers reserve all their trips in advance and are transported within a service area that mirrors the existing fixed route service area ¾ of a mile around any fixed route.

In order to comply with the ADA, RTS Access complementary service must uphold service criteria that are comparable to the service criteria for fixed route service. The criteria include service area, response time, fares, trip purpose restrictions, hours and days of service, capacity constraints, and additional service. The level of comparability is evaluated in the ADA Paratransit Plan.

The basic operating mode for RTS Access is curb-to-curb. If a customer needs help beyond the curb to reach a destination beyond the curb, the customer can request assistance beyond the curb in advance of or during the ride. RTS Access will refer to the practice of providing assistance beyond the curb as a reasonable modification request.

Reasonable Modifications

In accordance with the ADA, section 504 of the Rehabilitation Act of 1973, and implementing regulations, RTS Access shall make reasonable modifications in its policies, practices, and procedures for Complementary Paratransit service when such accommodations are necessary to avoid discrimination, unless such accommodations would:

  • Fundamentally alter the nature of the service, program or activity; or
  • Result in a significant risk to the health or safety of others (direct threat); or
  • Result in undue financial and administrative burden.

We will deny a requested modification if the person with a disability is able to use the services for their intended purpose without the requested modification. It is not reasonable to request a modification simply to make the service more convenient or to suit individual preferences.  We offer different services. The “reasonableness” of a request will depend on the type of service. If your request is not reasonable based on the type of service, we will try to identify another type of modification that will allow you to use the particular service in a manner that is consistent with the nature of the service and does not cause a direct threat.

The following requests are considered reasonable modifications for complementary paratransit service.

  • Asking for assistance from the curb to the external door of a building or vice-versa
  • Asking for the Bus Operator to open the exterior building door
  • Asking for assistance in order to navigate over snow or ice (except in extreme weather conditions)
  • Requesting that your pickup occurs in a location that is difficult, but not impossible, for the bus to navigate
  • Asking for assistance in order to navigate an incline or around obstacles
  • Agreeing to change a pick up point or drop off point to avoid obstructions, if requested by the customer
  • Requesting a pick-up at a hard to maneuver stop, so long as doing so does not create a direct threat to the Bus Operator and customers
  • Requesting to take medicine, self-administer injections (or do so with the assistance of a PCA), or conduct a finger stick blood glucose test on the vehicle
  • Eating or drinking if necessary to avoid adverse health consequences
  • Boarding the bus separately from a wheelchair where the combined weight exceeds the load of the vehicle lift

These requests are either a fundamental alteration of service or present the risk of a direct threat and will not be considered reasonable under the ADA for trips using complementary paratransit:

  • Requests that would cause the Operator to leave the vehicle unattended for a lengthy period of time or lose the ability to keep the vehicle under visual observation
  • Requests that would expose the vehicle and its occupants to hazards (e.g., running off the road, getting stuck, reversing down a narrow alley
  • Requests for dedicated vehicles or special equipment in vehicles that is not required by ADA
  • Exclusive or reduced capacity transit trips
  • Service outside of service area or operating hours
  • Requests for the Operator to make intermediate stops
  • Request for a specific Operator
  • Door-through-door service (entering the interior of a building)
  • Requests to avoid certain customers
  • Requests to ride for free
  • Requests for the Operator to care for service animals
  • Requests that expose the Operator, customer or other customers to risk
  • Carrying or lifting a customer or providing other personal care services (e.g., request to wait with customer at a destination)

Making a Request

  1. Arrange a reasonable modification in advance when possible by calling 585.426.3520 or when scheduling your ride. (Please note: customers seeking approval to utilize complementary paratransit services may request a reasonable modification as part of the eligibility certification process. A decision will be made as soon as practicable.)
  2. Describe the modification you need and the reason you need it.
  3. Specify the date on which you need the modification and the length of time it is needed.

If you cannot make a request for a modification in advance because you were unaware of a condition or barrier at your destination until arriving, you may make the request at the time of service. Personnel at any subsidiary may consult with management before making a determination to grant or deny the request.

Making a Complaint

If you believe RTS Access has not complied with a reasonable modification request, you may file a complaint. For more information about the process visit