Providing Public Transportation
Alternatives for the Greater
Phoenix Metro Area

Requesting and Receiving
Reasonable Modifications


The “Reasonable Modifications Policy” sets forth the policy and procedures which Valley Metro will use to receive and act on requests for modifications of transportation policies and procedures (herein referred to as “Reasonable Modifications” or “RM’s”) made by people with disabilities in accordance with the Reasonable Modifications requirements of the Americans with Disabilities Act.

Valley Metro is committed to providing reasonable modification(s) to its fixed-route bus, light rail, and/or ADA paratransit operating policies, practices and/or procedures in order to ensure that its services, programs and facilities are accessible to and usable by individuals with disabilities. 

Reasonable Modification

A reasonable modification (RM) is a change in Valley Metro’s service policies and practices in circumstances where established practices may prevent individuals with disabilities from accessing and participating fully in Valley Metro’s programs, services and facilities. RMs are required when the modification is necessary for a person with a disability to access and/or utilize the program or service, when the modification would not fundamentally alter the character of the program or service, when the modification would not result in the risk of a “direct threat” to other customers, employees or members of the public, and when the requested modification would not pose an undue operational or financial burden to the agency. To assist transit agencies and customers with knowing what constitutes, and what does not constitute a Reasonable Modification, the US Department of Transportation provided guidance in Exhibit E to 49 C.F.R. Part 37. This guidance is available at the following link:

Transportation for Individuals With Disabilities; Reasonable Modification of Policies and Practices

In addition, Valley Metro has created a “Reasonable Modifications FAQs” document to assist you further. It summarizes the federal guidance referenced above and provides concrete examples relevant to the bus, light rail, and paratransit/Dial-a-Ride services available here in the Phoenix area.

Download the Valley Metro Reasonable Modifications FAQs here.(PDF)

Responsible Employee

Valley Metro’s Manager of Accessible Transit Services (ATS Manager) is responsible for implementing this policy and procedures.

Coordination with Participating Communities

This procedure is designed to be used in conjunction with communities that choose to participate in a coordinated, regional approach. Valley Metro will coordinate the receipt, review and documentation of all requests for RM’s. Individuals with disabilities who travel throughout the region will not have to file duplicate requests with each participating community.

The ATS Manager or his/her designee will handle RM requests. Each participating community will designate one person to work with the ATS Manager.

Policy Advertisement

Valley Metro will provide a link to the full text of the RM policy and procedures on its website. The policy includes information about how to make requests for reasonable modifications of its policies. A summary of the Reasonable Modification policy also will be included in the Valley Metro Transit Book as well as in each Dial-a-Ride “Ride Guide.” Participating communities also may provide information about the Reasonable Modification policy in similar ways.

Requesting a Reasonable Modification

Individuals may request RM’s online, by email, in writing or by phone. To facilitate this process, Valley Metro will make this policy and the Reasonable Modifications Request Form available online and in hard copy upon request. Before submitting a request for a Reasonable Modification, read Valley Metro’s Reasonable Modifications FAQs. The FAQs document provides information on what does and what does not constitute a Reasonable Modification.

Valley Metro also will make this policy and the Reasonable Modifications Request Form available in the following alternate formats: large print, braille, audio and electronic (Word or text file formats). This policy and the Reasonable Modifications Request Form also will be available in Spanish.

  • Online: The customer must complete the online request form and attach any supplemental information required by this policy.
  • By Email: The customer must send a completed copy of this form to Valley Metro at .(JavaScript must be enabled to view this email address) along with any supplemental information required by this policy.
  • In Writing: The customer must complete the online request form and attach any supplemental information required by this policy. The completed form and all attachments should be mailed to: Manager of Accessible Transit Services, 4600 E. Washington Street, Phoenix, AZ 85034.
  • By Phone: The customer may request a Reasonable Modification by contacting Valley Metro at (602) 716-2100, Option 1, during standard Valley Metro business hours. Staff will either email, fax or mail this policy and the Reasonable Modifications Request Form to the customer. If needed, staff will complete the online form for the customer based on information provided by the customer.

Evaluating Requests

Upon receipt of a Request for a Reasonable Modification, Valley Metro staff will evaluate each request as follows:

  • Initial review for completeness: Staff will review the information in the Reasonable Modifications Request Form and all supplemental documentation to ensure that the request is complete. If a request is incomplete, staff will follow up with the customer to advise him/her of the missing information. However, no action will be taken on the request until it is complete.
  • When the request is complete, it will be forwarded to the ATS Manager or his/her designee. The ATS Manager will distribute a copy of the request (along with any and all supporting documentation provided by the requestor) to any transit or paratransit provider which may be called upon to provide the requested modification.
  • When all parties have been provided a copy of the RM request, the ATS Manager will review the request, in consultation with the transit and paratransit providers which may be affected, to determine the best course of action. Within five (5) business days, the ATS Manager (in consultation with all potentially affected service providers) will decide either to:
    • Grant the modification requested by the customer.
    • Deny the modification requested by the customer. If a request is denied, consideration will be given to alternate approaches and/or modifications that will enable the customer to participate in the service(s) and/or benefit from the program(s).
    • Negotiate the request and offer an alternate modification. If a request is negotiated and an alternate modification is proposed, priority will be given to alternate modifications which provide services, programs and activities in the most integrated setting appropriate to the needs of individuals with disabilities.
  • Because transit and paratransit systems across the region have different types of fleets, different operating rules and operate in different areas, it is possible that a requested modification may be feasible for one provider but not for another. When communicating Valley Metro’s final decision regarding each requested modification, the ATS Manager will provide an explanation of any limitations placed on the extent to which a request can be fulfilled.

Factors to Consider in the Evaluation of Requests for Reasonable Modification

The ATS Manager and/or his/her designee will consider the following factors when reviewing and responding to Requests for Reasonable Modifications:

  1. Does the requestor have a disability?: Does the person requesting the modification have a disability? Is the disability “apparent?” (This might include using a mobility device (wheelchair, walker) or using a long white cane or service dog).
    If the noted disability is not apparent, is adequate documentation of disability provided? (This might include a current ADA paratransit eligibility ID number, or some reasonable documentation forwarded by the requestor).
    If the requestor has a disability, proceed. If not, the requested modification will be denied.
  2. Is the requested modification necessary to enable nondiscriminatory use of the service?:  Consider the policy/procedure that the requestor has asked to have modified. Also consider the requestor’s disability and the stated reason for being unable to use the service in a nondiscriminatory manner. Does the current policy/procedure keep the requestor from using the service in a nondiscriminatory way because of the disability? Is the requestor unable to use the service in a nondiscriminatory way because of the current policy/procedure, or is the reasonable modification being requested as a convenience or personal preference?
    If the current policy/procedure does prevent nondiscriminatory use of the service, proceed. If not, the requested modification will be denied.
  3. Would the requested modification fundamentally change the nature of the service, program or activity?:
    If no, proceed. If yes, the modification will be denied.
  4. Would implementation of the requested modification create a situation that would pose a direct threat to the health or safety of others?: If no, proceed. If yes, the exact threat should be documented in writing and the modification should be denied. (Note that possible safety threats to the requestor cannot be used as a reason to deny the requested modification. However, if there are possible safety risks for the requestor, these should be clearly communicated to and acknowledged by the requestor before any modifications are made).
  5. Would implementation of the requested modification create an undue administrative or financial burden?: This could be a burden to Valley Metro, a participating community, or contractors providing the service.
    If no, proceed. If yes, the undue burden should be spelled out in detail, in writing, and the requested modification will be denied.

Examples of Reasonable Modifications

The following list, developed by the USDOT, provides examples of when reasonable modification should generally be made. This list is intended only to provide examples and does not constitute an exhaustive list of the reasonable modifications that Valley Metro may provide, nor does the appearance of any reasonable modification on this list suggest or guarantee that Valley Metro can or will provide the modification in all circumstances.

  • Stopping a fixed-route bus a short distance from the bus stop sign to allow a wheelchair user to avoid an obstacle, such as road construction, to boarding using a lift/ramp (assuming the alternate location does not create an unsafe traffic situation).
  • Permitting passengers to board fixed route or DAR vehicles separate from their mobility device in order to not exceed the weight-bearing load of the lift/ramp (assuming rider can do so safely and the vehicle can bear the combined weight of the passenger and his/her mobility device).
  • Having the vehicle operator wait with a DAR passenger at a transfer location until the connecting vehicle arrives, or providing a direct ride without a transfer, if the passenger cannot be left unattended at a transfer location.
  • At large facilities, such as malls and hospital complexes, DAR passengers who, because of a disability are unable to get to or from designated pickup and drop-off locations, will be dropped off and/or picked up at requested entrances within the facility.
  • For passengers whose disability prevents them from independently using the fare collection systems on fixed-route buses or DAR vehicles, driver will assist with the handling of cash or fare media and with the insertion of cash into the fare box, or with the swiping of a pass or ticket through the fare box. (This does NOT include reaching into passenger backpacks, pockets, etc.)
  • Riders may eat, drink or take medicine on transit vehicles or in transit facilities when doing so is medically necessary for the rider’s safety and is related to a documented disability.

Responding to Requests for Reasonable Modifications

  • The ATS Manager (in consultation with those providers involved in a requested modification) will have five (5) business days to review and decide on each RM request.
  • The ATS Manager will have an additional (5) business days to provide a final response to the customer

The response will be provided via email if the request was received by email, and by letter (USPS) if the request was made via telephone or letter. Appropriate alternative formats will be used if requested. Acknowledgement of receipt will be requested for all responses.

If a request is denied, or if an alternate modification is proposed, the response will detail the reasons for the denial. Requestors also will be informed of their right to appeal and how to initiate an appeal (see “Appeals”).

Notice of Decision/Outcome: The ATS Manager will send a copy of the response to all participating service providers, to be disseminated as appropriate.

Amendment of Operating Procedure: If a Request for a Reasonable Modification is granted, the appropriate Operations staff will prepare new or amended operating procedure documents and distribute as appropriate. Reasonable modifications generally will be implemented in Operations within seven (7) calendar days, unless the ATS Manager negotiates a longer timeframe with the customer. If a longer timeframe is needed, staff will inform the ATS Manager and indicate a date by which the reasonable modification can be in place.

Records of Requests and Outcomes: The ATS Manager will maintain the following records for a period of not less than five (5) years:

  • Copy of the completed Reasonable Modifications Request Form with all supplemental information
  • Copy of the final decision as communicated to the customer
  • Copy of any appeal with all supplemental information and the final decision of the Appeals Panel
  • Any other pertinent information garnered in connection with the request


If Valley Metro denies the requested Reasonable Modification, or in the event the customer does not agree with the modification offered by Valley Metro, the customer may appeal Valley Metro’s decision.

Requests for appeals must be made either by email .(JavaScript must be enabled to view this email address) or by sending a written request to: Manager of Accessible Transit Services, Valley Metro, 4600 E. Washington St. Ste. 101, Phoenix, AZ 85034.

A request for an appeal must be received no later than sixty (60) days after the date of Valley Metro’s denial or offer of an alternate modification. After sixty days, the customer must initiate a new Request for a Reasonable Modification.

Individuals will be given an opportunity to be heard in person and to bring advocates. If a customer chooses not to appear in person, he or she will be permitted to submit additional documentation.

Appeals will be heard by a Reasonable Modification Appeal Panel consisting of: (1) the ADA or Transportation Coordinator (or that person’s designee) of the customer’s city of residence; 2) a transit or paratransit Operations Manager from one of the agencies who operates service within the customer’s city of residence; and 3) a member appointed by Valley Metro’s Legal Department. None of the members of the Reasonable Modification Appeal Panel will be directly involved in the original decision-making and outcome, or be in a direct line of authority with any of those who made the original determination.

Appeals will be scheduled as soon as is practicable but not more than thirty (30) days after the receipt of a written appeal request. The outcome of the appeal will be made in writing within thirty (30) calendar days of the date the appeal is heard. If an appeal upholds Valley Metro’s original determination(s), the reasoning behind the outcome will be included in the written notification.

In-Service Requests

Individuals are encouraged to request Reasonable Modifications in advance of using the service whenever possible, and if the issue is known in advance. If issues with policies and procedures are encountered while using the service(s), individuals may make a request for a reasonable modification to the appropriate employee on-site (for example, the driver of the fixed route bus or Dial-a-Ride vehicle). The employee on-site will contact and inform dispatch of the request.  Dispatch will provide direction as to whether or not to make the requested modification, and will document the request and any action(s) taken. Individuals are encouraged to make formal request so that appropriate service will be provided thereafter.


Within ninety (90) calendar days of the issuance of this policy and procedures, all transit and paratransit service operations management personnel will be provided with training regarding this policy and procedures.

Appropriate training regarding Reasonable Modification requests made “in-service” (or “on-site) will be developed for all front-line personnel. This training will be incorporated into refresher and new hire training within ninety (90) additional calendar days.