What definition of 'fixed route systems' does Budget use in relation to its shuttle operations?

According to Budget's 2025 Franchise Disclosure Document, the definition of 'fixed route systems' in relation to shuttle operations stems from an agreement with the Department of Justice. Specifically, Budget, or Avis as referenced in the document, agreed to treat all shuttle systems at its airport facilities as fixed route systems. This definition aligns with section 301(4) of the ADA, 42 U.S.C. § 12181(4), and its implementing regulation, 49 C.F.R. § 37.3. The agreement arose from a Notice Letter where the Department informed Avis that the shuttle system at Detroit Airport was considered a fixed route system. However, Avis does not concede that all such systems are fixed route systems. The Department has not investigated the shuttle systems other than the one at Detroit Airport to determine the type of system being operated at each location.

This agreement mandates that Budget comply with regulations governing the acquisition of shuttle vehicles for fixed route systems. For vehicles purchased or leased after February 16, 1996, with a capacity of over 16 passengers, Budget must ensure they are accessible to individuals with disabilities, including those who use wheelchairs. By December 31, 2000, all shuttle systems at airport facilities operated by Avis as of the agreement's effective date, except for those in Las Vegas and Los Angeles, were required to be in full compliance with regulations for fixed route systems. The Las Vegas and Los Angeles systems, acquired after the investigation began, had until December 31, 2003, to comply.

For a prospective Budget franchisee, this means that if the franchise location includes shuttle services, particularly at airport facilities, they must adhere to the ADA guidelines for fixed route systems. This includes ensuring vehicle accessibility and compliance with specific regulations. Franchisees should be aware of the potential costs associated with maintaining compliance, such as refurbishing or replacing vehicles to meet accessibility standards. Additionally, franchisees should confirm whether their location-specific shuttle system is considered a fixed route or demand-responsive system, as this may affect the specific regulations that apply.