ACCESSIBILITY FOR ONTARIANS WITH DISABILITIES ACT ALLIANCE UPDATE

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United for a Barrier-Free Ontario

Tell the Ontario Government if You Support the AODA Alliance's and ARCH Disability Law Centre's Brief to the Ontario Government on Reforms to Make Transportation Accessible to People with Disabilities

August 2, 2017

Summary

On July 31, 2017, the AODA Alliance and ARCH Disability Law Centre submitted our finalized joint brief to the Transportation Standards Development committee. In it we offer detailed recommendations on how the Government should strengthen the Transportation Accessibility Standard which the Ontario Government enacted in 2011 under the Accessibility for Ontarians with Disabilities Act. Our finalized brief is available in MS Word format.  

If you have any trouble downloading the brief, you can always email us and ask us to email it to you. Email us at:
aodafeedback@gmail.com

We encourage you to email the Government to express your support for our recommendations, and for the need to substantially strengthen the Transportation Accessibility Standard, in order for transportation in Ontario to become fully accessible to people with disabilities by 2025. Email your message to the Ontario Government at:
AODA.input@ontario.ca

Below we set out the summary of our brief's concerns and recommendations. We also set out a list of the recommendations we made, which are gathered together in Appendix 1 of our brief.

We thank everyone who sent us feedback on our draft brief that we circulated last week for your input. We also thank all of you who have told us over the years about the disability barriers in transportation that you have faced. We drew on all of that feedback when writing our brief and when we finalized it. We did our best to reflect the range of concerns that we have heard about, over and over.

We need your help to get the Transportation Standards Development committee to act on our recommendations. The last Government-appointed Standards Development Committee under the AODA, which reviewed the 2007 Customer Service Accessibility Standard, (the Accessibility Standards Advisory Council) regrettably rejected every recommendation we made. You can help by emailing to voice your support, to: aoda.input@ontario.ca   

All you need to say is something like:

"I support the recommendations for strengthening the Transportation Accessibility Standard submitted by the AODA Alliance and ARCH Disability Law Centre in their July 31, 2017 brief."

Even though the Government's July 31, 2017 deadline for feedback has now passed, your emails to AODA.input@ontario.ca can help us a great deal. Whether you are writing the Government on behalf of an organization or just on your own personal behalf, we welcome your words of support.

MORE DETAILS

Summary of the July 31, 2017 Brief on Disability Barriers in Transportation in Ontario, Submitted to the Ontario Government by the AODA Alliance and ARCH Disability Law Centre

C.        Overview of this Brief

In this brief, we identify deficiencies with the 2011 Transportation Accessibility Standard. We analyze the 2016 Transportation Standards Development Committee's recent draft recommendations, which were posted for public comment on May 19, 2017. Where needed, we offer our recommendations on how they can be strengthened. We then turn to deficiencies with the 2011 Transportation Accessibility Standard which the Transportation Standards Development Committee's recommendations did not address. We there offer recommendations on how to address those deficiencies.

Appendix 1 sets out a list of all the recommendations that this brief includes. In Appendix 2, we describe deficiencies in the 2011 Transportation Accessibility Standard that were directly or indirectly identified in the 2014 final report of the Mayo Moran AODA Independent Review. In Appendix 3, we analyze the contents of the 2015 KPMG report for the Ontario Government on accessibility barriers in transportation in Ontario. In Appendix 4, we provide more detailed recommendations on built environment accessibility requirements for public transit stations and stops that should be included in the Transportation Accessibility Standard.

D.        Deficiencies in the 2011 Transportation Accessibility Standard:  A Broad Look

The first step in an effective review of the 2011 Transportation Accessibility Standard is to identify what that accessibility standard is supposed to achieve. The next step is to assess how well it is doing at achieving that goal. The step after that is to identify how and why it is falling short, if at all. From that can flow recommendations to strengthen the Transportation Accessibility Standard.

The AODA's goal is to ensure that Ontario becomes accessible to people with disabilities by 2025. Therefore, the goal of a Transportation Accessibility Standard must be to ensure that transportation services in Ontario become accessible to people with disabilities no later than 2025.

This goal is critically important. Accessible transportation promotes independence for people with disabilities, and their ability to take part in employment, education, recreation, and social activities, as well as being able to buy goods and get access to services like health care.  Accessible transportation is essential for the inclusion of people with disabilities in our communities and for things people without disabilities daily take for granted.

Many people with disabilities live at or below the poverty line. Many cannot afford their own car. Many cannot drive due to their disability. Transportation services, whether public or private, are, for all practical purposes, their "car."  

Before the 2011 Transportation Accessibility Standard went into effect, transportation services in Ontario were replete with many disability accessibility barriers. Over a decade ago, the Ontario Human Rights Commission released a comprehensive study of accessibility problems facing persons with disabilities who try to use public transit. It found that Ontario's public transit system is replete with barriers impeding persons with disabilities. It recommended, among other things, that new standards be enacted for transit accessibility. The Ontario Human Rights Commission's Report on Public Transit Accessibility Barriers is available at http://ohrc.on.ca/en/consultation-report-human-rights-and-public-transit-services-ontario 

It is good that the Government decided to create a Transportation Accessibility Standard under the AODA, and enacted one in 2011. However, the 2011 Transportation Accessibility Standard has significant shortcomings. Revisions to that accessibility standard should aim to correct these problems. We summarize these problems as follows:

1. Over six years after the 2011 Transportation Accessibility Standard went into effect, progress towards full accessibility in transportation in Ontario has been far too slow. There are less than 7.5 years to go before 2025. Yet transportation services are still not fully accessible to people with disabilities. In many respects they fall far short.

The 2011 Transportation Accessibility Standard will not ensure that transportation in Ontario becomes fully accessible to people with disabilities by 2025. Even if all transportation organizations fully comply with all of its requirements and time lines, this will not ensure that transportation will become fully accessible by 2025, or ever.

2. The 2011 Transportation Accessibility Standard does not cover all the known recurring disability accessibility barriers in transportation in Ontario.

3. Where the 2011 Transportation Accessibility Standard does address a known accessibility barrier, its requirements are too often too weak or too vague. Its exemptions and exceptions are too broad. This all falls short of meeting the accessibility requirements of the Ontario Human Rights Code, and in the case of public sector public transit providers, the Canadian Charter of Rights and Freedoms.

4. The 2011 Transportation Accessibility Standard takes an erroneous approach to equality and accessibility for people with disabilities, by permitting equivalent services at times, rather than requiring equal services. The Ontario Human Rights Code requires people with disabilities to receive equal services. An approach of unequal access appears to be tolerated if transit providers feel they are providing something they consider equitable access.

5. The time lines for action required under the 2011 Transportation Accessibility Standard are often too long. They permit unjustified delays in providing accessibility in transportation to people with disabilities. This allows transportation providers to create or retain new disability accessibility barriers for too many years.

A further indication that there are significant problems with the 2011 Transportation Accessibility Standard can be gleaned from two major reports, prepared at the request of the Ontario Government:

a) The 2014 final report of the second Independent Review of the AODA, conducted by Mayo Moran. The Government was required to appoint this AODA Independent Review. In Appendix 2 to this brief, we summarize that report's key contents and findings as they relate to the accessibility of transportation in Ontario.

b) The August 2015 report by the KPMG consulting firm, prepared at the request of the Ontario Government, on transportation accessibility barriers. We analyze the key contents and findings in that report in Appendix 3 to this brief.

Our recommendations in this brief build on the key findings and contents in those reports, and on our own analysis and research.
 

E.        Summary of Our Analysis of the Transportation Standards Development Committee's May 19, 2017 Draft Recommendations for Amendments to the 2011 Transportation Accessibility Standard

We commend the Transportation Standards Development Committee for identifying some of the ways that the 2011 Transportation Accessibility Standard needs improvement and for seeking ways to improve it. However, the draft recommendations that the Transportation Standards Development Committee circulated for public feedback on May 19, 2017 are substantially insufficient to remedy the deficiencies in the 2011 Transportation Accessibility Standard. Even if the Ontario Government adopted all the Transportation Standards Development Committee's draft recommendations, this would not ensure that transportation in Ontario would be fully accessible to people with disabilities by 2025, or ever. Indeed, even if the Ontario Government adopted all those draft recommendations, this would not lead to a substantial improvement in the accessibility of transportation services in Ontario. This is because:

1. The Transportation Standards Development Committee's draft recommendations do not identify or address many of the inadequacies in the 2011 Transportation Accessibility Standard. They don't address key problems with transportation services in Ontario or with the 2011 Transportation Accessibility Standard identified in the discussions or findings of the 2014 final report of the Mayo Moran AODA Independent Review or the 2015 KPMG report to the Ontario Government on transportation accessibility barriers.

2. In many cases, the Transportation Standards Development Committee's draft recommendations commendably identify an ongoing problem with the accessibility of transportation services in Ontario. However, the reforms that the Transportation Standards Development committee's draft recommendations propose are still too weak and will not solve the problems identified.

3. In several places, the Transportation Standards Development Committee recommends efforts at better educating people with disabilities, as a solution to accessibility problems they face. Yet the core reason why disability accessibility barriers remain in transportation in Ontario is not because passengers with disabilities are insufficiently educated on what they need to do to obtain accessible transportation services. These accessibility barriers remain because transportation organizations have not acted quickly enough or effectively enough to remove and prevent the accessibility barriers that remain in transportation services.

4. In some places, the Transportation Standards Development Committee's draft recommendations incorrectly propose to shift to others, such as the Ontario Government, responsibilities which properly lie with those who provide transportation services in Ontario.

F.         Summary of Our Recommendations

We urge amendments to the 2011 Transportation Accessibility Standard:

1.  To state that the Transportation Accessibility Standard's purpose is to ensure that transportation services become accessible to people with disabilities by 2025.

2. To require each transit organization to commit to reaching full accessibility by 2025, and to adopt, implement and annually report to the public on a plan to ensure it reaches full accessibility by 2025.

3. To set detailed requirements for the accessibility of the built environment in transit stations and stops, to strengthen accessible signage requirements, to increase transit stations' accessible parking spots, and to ensure that bus drivers enable passengers with disabilities to get on and off a bus  at a bus stop.

4. To improve accessibility requirements for transit vehicles, (e.g. increasing the size and number of mobility devices each can accommodate), and to require retrofit of existing transit vehicles that will remain in service for at least five years.

5. To set stronger requirements to ensure that public transit accessibility equipment is always in good working order.

6. To require transportation organizations to effectively inform people with disabilities about their accessibility services, including, for example, the sizes of mobility devices that their vehicles accommodate.

7. To make it easier for people with disabilities to bring a support person on public transit at no charge, and to prohibit public transit providers from requiring a passenger with a disability to bring a support person with them before allowing them on public transit.

8. To improve pre-boarding and on-board announcements and to require public transit providers to self-audit and publicly report on these.

9. To far more effectively ensure the accessibility of public transit electronic kiosks and fare-payment technology like the Presto Smart Card, and any related apps.

10. To require public transit providers to provide a service to assist passengers with disabilities to navigate transit stations.

11. To strengthen the requirement for public transit providers to hold an annual public forum on accessible transit.

12. To better provide for safety of people with disabilities during emergencies on public transit.

13. To better implement public compliance with priority seating for people with disabilities on public transit vehicles.

14. To require larger transit authorities to make available accessible mobile apps regarding their services.

15. To make it easier to qualify for paratransit services.

16. To require the provision of paratransit same day service, or, if rejected, to substantially narrow any exemptions from this requirement.

17. To require permanent streamlined procedures for getting a paratransit ride across municipal lines.

18. To eliminate the "family of services" retrenchment on paratransit services, that lets a public transit provider force a paratransit passenger to take part of their ride on paratransit and the rest on conventional transit.

19. To ban double-charging people with disabilities when part of a ride is on the conventional service and part of the ride is on a paratransit vehicle.

20. To strengthen requirements to ensure that all taxi services will be fully accessible to people with disabilities by 2025.

21. To set comprehensive accessibility requirements on ridesharing services like Uber.

22. To set substantially stronger guarantees and penalties for violations such as refusals to accommodate service animals.

23. To strengthen requirements for accessible school bussing services for students with disabilities.

We also recommend that the Transportation Standards Development Committee take these steps:

1. Make as the Committee's mission, to ensure that the Transportation Accessibility Standard will make transportation accessible to people with disabilities by 2025.

2. Create opportunities to hear face-to-face from transportation passengers with disabilities e.g. by organizing public forums.

3. Ask the Government to keep its election promise to provide a fulltime staff resource person to disability representatives on each Standards Development Committee.

4. Keep the Government's election promise that Standards Development Committee members will get to separately vote on each of its recommendations, clause-by-clause.

5. Not to recommend the creation of any new barriers to face people with disabilities.

Appendix 1 to the AODA Alliance and ARCH Brief on Barriers in Transportation in Ontario:  List of Recommendations that the AODA Alliance and ARCH Present in this Brief

#1: The Transportation Accessibility Standard should be amended to state that its objective is to ensure that transportation in Ontario becomes accessible to people with disabilities by 2025.

#2: The Standards Development Committee should directly consult people with disabilities on the size of mobility devices that public transportation vehicles need to be able to accommodate, and should recommend revisions to the Transportation Accessibility Standard, to ensure that any new vehicles can accommodate those mobility devices.

#3: The Transportation Accessibility Standard should be amended, as further addressed below, to increase the number of mobility devices to be accommodated on public transit vehicles, in order to enable those vehicles to accommodate the largest mobility devices on a trip e.g. when some of the other reserved spots are not needed by other passengers using mobility devices.

#4: The Transportation Accessibility Standard should be amended to provide that any new public transit vehicle should be designed with flexibility to enable it to accommodate future configurations of mobility devices, as the design of those devices evolves.

#5: The Standards Development Committee should withdraw its draft recommendation that shifts responsibility to people with disabilities and to other levels of government, to ensure that people with disabilities do not buy mobility devices that are too big for current public transit vehicles.

#6: The Transportation Accessibility Standard should be amended to require transportation organizations to effectively inform people with disabilities about the sizes of mobility devices that their vehicles can now accommodate.

#7: Transportation organizations should be required to make information available on use of their services for people with disabilities immediately on passage of revisions to the Transportation Accessibility Standard.

Note: See below for related recommendations on providing on-site assistance to people with disabilities in transit stations.

#8: The Standards Development Committee should not recommend the creation of any new barriers to face people with disabilities, such as an obligation to acquire a provincial card to authorize them to be accompanied, at no charge, by a support person on a public transit service.

#9: The Transportation Accessibility Standard should be amended to provide that when people with disabilities are permitted to use a support person on an Ontario transportation organization's services, they should be able to obtain documentation from that transportation organization, confirming that this has been permitted. That documentation should be accepted by any other Ontario transportation organization as authorizing their use of a support person.

#10: The Transportation Accessibility Standard should be amended to:

a) Require a minimum of four spaces for mobility devices on each public transit subway car, bus, streetcar, or other public transit vehicle.

b) Set space requirements for each mobility device that are larger than those to which the current Transportation Accessibility Standard is limited, and that will accommodate the spectrum of mobility devices now on the market or reasonably anticipated.

#11: The Transportation Accessibility Standard should be amended to require public transit providers to provide a service to assist passengers with disabilities to navigate transit stations, on a same-day call-ahead basis.

#12: The Transportation Accessibility Standard and related enforcement regulations should be revised to provide substantially stronger penalties for violations such as refusals to accommodate the use of service animals in transportation services, including stiff penalties for first time violations.

#13: The Transportation Accessibility Standard should be amended, so that a refusal of service to a person with disabilities accompanied by a service animal should be presumed to be a violation absent proof to the contrary.

#14: The Transportation Accessibility Standard should be amended to require transportation organizations to announce to passengers at a transit station, in advance of boarding, about pre-boarding accommodations for passengers with disabilities.

#15: The Transportation Accessibility Standard should be amended to require that all transportation organizations that are obliged to make route stop announcements must:

a) Conduct monthly self-audits of pre-boarding and on route announcements;

b) Make these audits promptly available on the transportation organization's website

and

c) Electronically file these audit reports with the Accessibility Directorate of Ontario on a quarterly basis, which the Accessibility Directorate of Ontario should make available on a publicly-accessible and searchable website.

#16: The Transportation Accessibility Standard should be revised to set comprehensive universal design requirements that exceed the Ontario Building Code, and that meet the Ontario Human Rights Code, for the built environment of transit stations and stops, including for new ones to be constructed, renovated ones, and existing ones that are undergoing no major renovations. These should include, for example, measures set out in Appendix 4.

#17: The Transportation Accessibility Standard should be amended to substitute 100 lux for 20 lux for lighting levels (in all areas it addresses).

#18: The Transportation Accessibility Standard should be amended to require that on signage,

a) Lettering be in sans serif

b) The size of fonts should harmonize with CSA's B65.1 viewing distance chart in clause 4.5.3.3: Viewing distance, 2.5 meters - font size 100 millimeter - example, external route sign viewed from street.

Viewing distance, 2.3 meters - font size 75 millimeters - example, internal line transfer information.

#19: The Transportation Accessibility Standard should be amended to require larger municipal transit authorities to develop, deploy and update fully accessible free mobile apps to enable all users, including all people with disabilities, to know the nearby bus schedule, the location and identity of nearby stops and routes, and to navigate inside transit stations.

#20: We endorse the Transportation Standards Development committee's draft recommendation that the Transportation Accessibility Standard should be amended to ensure that grab bars, handholds, handrails and stanchions in public transit vehicles have no protruding ends.

#21: The Transportation Accessibility Standard should be amended to include comprehensive, detailed technical accessibility requirements for persons with vision loss in transit stations, vehicles and stops, including, as examples:

a) Tactile walking surface indicators should be located at all unprotected drop-off edges on transit platforms and ferry docks.

b) Tactile walking surface indicators should be installed on the full width of the drop-off.

c) The base surface should be level with or not more than three millimeters above the surrounding surface.

d) The depth of the tactile walking surface indicators should be 610 mm to 650 mm.

e) Tactile walking surface indicators should have the following specifications:

            (i) The height of the flat-topped domes should be 5mm +/- 1mm.
            (ii) The diameter of the top of the flat-topped domes should be between 12 mm and 20 mm.
            (iii) The diameter of the lower base of the flat-topped domes should be 10 mm +/- 1 mm more than the diameter of the top.
            (iv) The distance between the bases of adjacent domes should be a minimum of 15 mm.
            (v) The spacing between adjacent flat-topped domes should be adjusted depending on the size of the domes, as shown in the table below. The larger the individual domes, the farther the space between them:
            Top diameter of flat-topped domes (mm): 12, 15, 18, 20     
Spacing between the centres of adjacent domes (mm): 55 to 61, 57 to 63, 60 to 61, 63 to 68

f) Stairs on ferries and in transit stations should have a detectable warning surface located at the top of all stairs. The texture of the detectable warning should:

i) be 70% colour contrasted from the surrounding surface and run the full width of the stairs;
            ii) Have a depth of 920 mm;
            iii) Commence one tread depth from the edge of the stair.
            iv) Be the same texture and dome dimension as the tactile walking surface             indicator used on ferry docks.

g) Transit stations and stops should have directional way-finding including tactile walking surface indicators.

h) Detailed lighting and colour contrast requirements should be specified and should be sufficient to accommodate the needs of people with low vision.

#22: Section 63 of the Transportation Accessibility Standard should be amended to delete the category of "conditional eligibility" for paratransit services.

#23: Section 64(6) of the Transportation Accessibility Standard should be amended to require an appeal decision regarding eligibility for paratransit services, to be rendered within 14 calendar days of the appeal being filed.

#24: Section 64(8) (for Ontario residents) and 67(4) (for visitors) of the Transportation Accessibility Standard should be amended to set strict minimum privacy requirements for any para-transit service's policy on collection and disclosure of private passenger information.

#25: The Transportation Accessibility Standard should be amended to repeal any reference to and to eliminate any authorization of the "family of services" retrenchment on paratransit services, that lets a public transit provider force a paratransit passenger to take part of their ride on paratransit and the rest on conventional transit.

#26: The Transportation Accessibility Standard should be amended to ban any transit organization from double-charging people with disabilities when part of a ride is on the conventional service and part of the ride is on a paratransit vehicle, with stiff penalties imposed on both the transit organization and the individual who tries to impose a double charge, including for a first violation.

#27: The Transportation Accessibility Standard should be amended to require public transit providers to regularly announce on their public address systems that no passenger with a disability should ever be charged a double fare, and providing a hotline number and email to report any such violations.

#28:

a) Section 71 of the Transportation Accessibility Standard should be amended to require the provision of same day service on paratransit, with 2 hours advance notice.

b) If Recommendation (a) above is not accepted, then as a less acceptable alternative, section 71(1)(b) of the Transportation Accessibility Standard should be amended to provide:
           
"71. (1) Every specialized transportation service provider shall, where the specialized transportation services require reservations, provide same day service, either via vehicles operated by that service or by accessible taxis or accessible ridesharing services, for which that specialized transportation service contracts, when booked at least five hours in advance, and provide assured service if booked the day prior, except where it is demonstrably impossible to provide the same-day service due to unexpected harsh inclement weather.

#29: Section 71(2) of the Transportation Accessibility Standard should be amended to provide:

"(2) A specialized transportation service provider to whom subsection (1)applies shall provide accessible means to accept reservations, and shall ensure that phone calls to book the service during regular operating hours will be answered by an individual operator within 5 minutes."

#30: The Transportation Accessibility Standard should be amended to require transportation organizations, who require medical documentation to qualify for paratransit, to cover the cost of that medical documentation, in order to remove this transportation barrier, particularly for people with disabilities who have limited financial means.

#31: The Transportation Accessibility Standard should be amended to specify that all taxis in each municipality must be accessible by 2025, and that each municipality must take all required steps, to be included in their accessibility plans, to ensure that this goal is reached. This should include, among other things, requiring each municipality to:

a) give a priority or preference, when issuing permits for new taxicabs, to applicants who undertake that the new taxicab will be accessible, on the understanding that they are permitted to carry any passenger, whether or not he or she has a disability, and

b) In consultation with any special transportation services provider in the community, consider using accessible taxi services as an option for providing specialized transportation services under this Act.

(c) Annually identify progress made toward meeting the need for accessible taxicabs in its status report required under the AODA.

(d) Where the Accessibility Advisory Committee of a municipality is of the opinion that sufficient progress towards fully accessible taxicabs in the community has not been made, it may ask the council of the municipality to develop additional strategies to promote a sufficient increase in the number of accessible taxicabs in the community, and the council of the municipality shall review the sufficiency of the strategies, and report on the result of this review to its accessibility advisory committee, and to the public, including  via a posting on its website.

#32: Section 80(2) of the Transportation Accessibility Standard should be amended to provide:

"(2) Any municipality that licences taxicabs shall ensure that owners and operators of taxicabs shall place vehicle registration and identification information on

(a) The rear bumper and adjacent to both rear entrance doors of the taxicab, and

(b) In Braille and large type on the back of the front passenger seat of the taxicab, in plain view and reach of a person sitting in the back seat thereof."

#33: The Transportation Accessibility Standard should be amended to require accessibility training for taxi drivers, and for those who drive for ride-sharing services like Uber, at the time of obtaining or renewing a license, with this requirement to go into effect immediately upon enactment of revisions to this accessibility standard.

#34: The Transportation Accessibility Standard should be amended to increase the percentages of accessible parking spots for parking facilities associated with transit stations, setting specific ratios.

#35: The Transportation Accessibility Standard should be amended to require permanent streamlined cross-jurisdictional paratransit services along the lines of those temporarily provided in the Greater Toronto Area during the Toronto 2015 Pan/ParaPan American Games.

#36. Efforts on ensuring transportation accessibility should focus on substantially strengthening the Transportation Accessibility Standard's detailed barrier-removal and prevention requirements, and on substantially strengthened enforcement, rather than focusing efforts on raising awareness, particularly among public transit providers which are public sector governmental organizations.

#37: The Transportation Standards Development Committee should hold a series of public forums on accessible transportation, to enable people with disabilities to share their experiences face-to-face, and to describe the transportation accessibility barriers they experience.

#38: The Transportation Standards Development Committee should attend the forthcoming TTC 2017 Public Forum on Accessible Transit, likely in the 2017 fall.

#39: If the Government has not already done so, it should immediately provide the disability sector representatives on the current Transportation Standards Development Committee with a full time staff support person, in accordance with its September 14, 2007 election promise, to assist them in ensuring that the needs of people with disabilities are effectively represented and presented there.

#40: The Transportation Standards Development Committee should make public whether its members were afforded the option of voting, clause-by-clause, on its draft recommendations. If so, a record of the votes should be made public. If not, the public should be told why this promise was not kept.

#41: The Transportation Standards Development committee should ensure that when its members' give their final vote on its recommendations to be presented to the Government, members are allowed to vote clause by clause on any recommendations that are brought forward for a vote, with a record made public on that voting. 

#42: The Transportation Accessibility Standard should be amended to require each public transit provider to now make public a commitment to achieve accessible public transit as soon as possible, and in any event, no later than 2025.

#43: The Transportation Accessibility Standard should be amended to require each transportation organization to:

a) create a 7.5 multi-year plan, listing all the steps needed to ensure its transportation services become accessible to passengers with disabilities by 2025, and its plans to take all these steps in time to reach that goal;

b) Implement that plan;

c) Post this multi-year plan on its website, make it available to the public in an accessible format on request, and submit it electronically to the Accessibility Directorate of Ontario for posting online on a searchable data base;

d) Annually report on its progress in fulfilling that plans' requirements, and indicating whether it is on schedule for reaching the goal of accessible transportation services by 2025, and

e) Post these annual reports on its website, and in an electronic filing with the Accessibility Directorate of Ontario, which will post them online in a searchable data base.

#44: The Transportation Standards Development Committee should survey Ontario's public transit providers to find out how many of them have held the required annual public accessible transit meetings each year since 2013, as the Transportation Accessibility Standard requires.

#45: The Transportation Accessibility Standard should be amended to:

a) Require the members of the governing board and senior management team of each public transit provider to attend the annual accessible transit public forum required under s. 41 of the Transportation Accessibility Standard.

b) Require each transportation organization to ensure that these public forums are fully accessible for all people with disabilities.

c) Require each public transit authority to post on its website an advertisement or announcement of its forthcoming annual accessible public transit public forum, and to post a report after the fact summarizing the contents of that meeting, including which members of its governing board and senior management team did or did not attend, and

d) Require each public transit authority to electronically file the report referred to in (b) with the Accessibility Directorate of Ontario, which shall post these online on an accessible and searchable data base.

#46: The Transportation Accessibility Standard should be amended to require public transit providers to take and document proactive steps, to be specified in the standard, to ensure the maintenance of equipment and facilities, as well as all vehicles, needed to ensure accessible transit, such as escalators and elevators. This should include a requirement to regularly post online and file with the Accessibility Directorate of Ontario reports on rates of their break-down and time taken to repair them. The Accessibility Directorate of Ontario should post these reports on a public, online, searchable data base.

#47: The Transportation Accessibility Standard should be amended to require that:

a) Audible public announcements in transit stations must be provided in both audio and visual formats, in all passenger and staff areas. This includes such things as audible announcements of information concerning departure delays; gate assignments; and schedule or connection changes. Announcements should be of good quality, in plain language, with clear enunciation and spoken slowly with repetition. 

b) In transit stations, at transit stops or on transit vehicles, where information is provided to passengers and the public via screens or electronic kiosks, the same information should be made available in an accessible format at the same time, and with equal ease of access, such as via audible announcements.

c) Where monitors displaying transit information for passengers are placed above eye level, the size of text to distance viewing should be specified. The monitor's location should ensure a seated person using a bench or mobility aid will be able to read them easily. The information displayed on the monitors should use plain language. Where electronic signage is within touching range, the monitor should include an intercom link with a help button and braille so that a user who cannot read the signage or understand what they are seeing can push the help button and speak to a staff person to be told the information being displayed.

d) All electronic signage should be at appropriate heights, to be specified in the Transportation Accessibility Standard, using fonts, colour contrast and letter sizes to be specified in the standard, and using plain, clear language.

#48: The Transportation Accessibility Standard should be amended to require that:

a) Electronic kiosks or other fare-paying technology used by any public transit provider should be required to allow a person with a disability to independently use the kiosk or technology.

b) Where an electronic kiosk or other fare-payment technology meets the requirements of this amendment, the kiosk should be marked with the international symbol of access.

c) Braille and large print should be placed on the machines, and should include a sequence of activities in a list with a tactile line leading from each item to the location of the activity.

d) An audio jack should be made available and be the first item on the list of sequence activities for those with both hearing and vision loss, to provide full audio interactive guidance on the kiosk's use.

e) Approach to the kiosk shall allow for front access with an assistive device such as a wheelchair, using the knee and toe clearances.

f) Surfaces on the kiosk should be non-glare, matte finishes.

g) The kiosk should include an intercom link with a help button and braille so that a user who cannot read the signage or understand what they are seeing can push the help button and speak to a staff member.

h) The kiosk should be designed to enable effective use with a mobile app that is accessible.

i) A mobile app for paying fares, or related to the electronic fare-payment technology, should be provided which are fully accessible.

#49: The Transportation Accessibility Standard should be amended to require that

a) A public transit provider should include in any emergency procedures, a plan of measures to ensure that emergency announcements (such as fire alarms) are available in an accessible means (e.g. flashing lights for the benefit of persons with hearing loss).

b) A public transit provider should provide specific disability-related emergency training for transit staff, including the designation of on-duty officials in each station and on each transit route, who has lead responsibility in an emergency for disability-related emergency procedures.

c) Public transit stations should be reviewed to ensure that there are safe accessible ways to exit in an emergency, and safe refuges for passengers with disabilities who must await help to leave the building or facility.

#50. The Transportation Accessibility Standard should be amended to require specified measures to ensure the accessibility of bus stops, beyond those addressing the design of the bus stop itself, such as:

a) Setting requirements that prevent any significant increase in the distance between bus stops.

b) Requiring that where a bus stop must temporarily be relocated specified measures are taken to ensure that the temporary bus stop location is accessible.

c) Banning any street furniture, garbage cans, garbage bags or other objects being left in the area of a bus stop, with strict penalties (such as confiscation of a bicycle.)

d) Requiring bus drivers to park alongside the curb when pulling into a stop, with strict penalties for violations.

e) Requiring bus drivers, when deploying a bus's ramp, to lower it entirely to the ground, with strict penalties for violations.

#51: The Transportation Accessibility Standard should be amended to require public transit providers to provide in transit stations, raised line, tactile maps with accessible text and braille, near the main entrance at every station. These should also be available on request to be given out, as individual station maps, as well as booklets of all the system's transit stations. These maps should identify the main entrance, provide a tactile path from the main entrance to the ticket purchase area then to the transit connection points. They should identify the location of all emergency exit stairs, elevators, washrooms and transit connection points. Where posted in the transit station, this should match the dimensions for access, space and reach of the automated information kiosks.

#52:   The Transportation Accessibility Standard should be amended to require every municipality, rural or urban, to have accessible vehicles for persons with disabilities, which are available for public transit regardless of the passenger's purpose for their trip.

#53: The Transportation Accessibility Standard should be amended to prohibit public transit providers from requiring that a conventional transit passenger or paratransit passenger be accompanied by a support person. The public transit provider should instead have in place an effective means to receive and convey to its paratransit driver, pre-issued instructions on a passenger's destination, in the case of a passenger who cannot themselves communicate their destination.

#54: The Transportation Accessibility Standard should be amended to require public transit providers to implement readily achievable measures to enable passengers with disabilities who use service animals to be able to meet the animal's need to relieve itself, whether by providing nearby relief areas within a transit station, or by providing a fee waiver if the passenger must leave the station for the animal to relieve itself.

#55: The Transportation Accessibility Standard should be amended to:

a) Set strong requirements for the accessibility of subway, train and LRT, cars, including a requirement that they properly line up with a subway platform. This should apply to both new and existing vehicles.

b) Require that before new public transit vehicles are purchased, the chief executive officer and the chair of the public transit provider should be required to sign that they have personally verified the accessibility of the vehicle for people with disabilities.

c) Require that any contract to procure such public transit vehicles require the vender to remediate any accessibility problems that arise on or after their delivery.

d) Require that within a public transit provider, there is clear and public accountability for the officials who make decisions regarding the accessibility or lack of accessibility in the procurement of public transit vehicles.

#56: The Transportation Accessibility Standard should be amended to set accessibility requirements for public transit platforms. These should ban the use of the center platform design for a public transit station, unless a safe solid shoreline is provided for persons with vision loss, at a designated distance away from the platform's edge.

#57: The Transportation Accessibility Standard should be amended to require readily-achievable accessibility retrofits of public transit vehicles unless they are slated to be removed from service in the next five years.

#58:

a) The Transportation Standards Development Committee should secure input from the Special Education Advisory Committee of each publicly-funded school board on issues arising in connection with the school bussing services for students with disabilities.

b) The Transportation Accessibility Standard should be amended to strengthen the school bussing requirements, in accordance with feedback the Transportation Standards Development Committee will obtain from the Special Education Advisory Committees around Ontario, to, for example:

            i) Require school boards to provide timely information students with disabilities and their families about the requirements of the Transportation Accessibility Standard as it relates to school transportation;

             ii) Require school boards to carefully monitor and oversee the provision of safe, accessible transportation for students with disabilities;

             iii) Designate public accountability for school board officials for approving the accessibility measures in school bussing for students with disabilities, which should be made public on the school board's website and filed with the Accessibility Directorate of Ontario for online posting in a searchable data base.

#59:  The Transportation Accessibility Standard should be amended to impose comprehensive accessibility requirements on ridesharing services operating anywhere in Ontario, that at least include and build upon those enacted in Toronto and in some U.S. cities.

Helpful Background Resources

To learn more about the AODA Alliance's campaign for accessible transportation in Ontario.

You can always send your feedback to us on any AODA and accessibility issue at aodafeedback@gmail.com

Have you taken part in our "Picture Our Barriers campaign? If not, please join in! You can get all the information you need about our "Picture Our Barriers" campaign by visiting www.aodaalliance.org/2016

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We encourage you to use the Government's toll-free number for reporting AODA violations. We fought long and hard to get the Government to promise this, and later to deliver on that promise. If you encounter any accessibility problems at any large retail establishments, it will be especially important to report them to the Government via that toll-free number. Call 1-866-515-2025.

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Learn all about our campaign for a fully accessible Ontario by visiting http://www.aodaalliance.org