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Transit provider responses

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Over the fall and winter of 2007-2008, the Commission communicated with 41 transit providers. Of these, 40 provided the requested information.[7] On the whole, most of the organizations expressed broad commitment to accessibility within the transit sector.[8] This commitment was further demonstrated by the willingness of many transit providers to develop or speed up stop announcement plans in response to the Commission’s inquiry.

The Commission is encouraged by the overall movement toward implementing stop announcements. However, there is significant variation among transit providers in terms of the methods, processes and timelines they have put forward. While many have responded by taking concrete steps to improve the breadth and timeliness of accessibility through stop announcements, some have limited or delayed their commitments, and some have not indicated any clear commitment to address the specific issues raised in this inquiry.

At the outset of the inquiry, only the TTC was announcing all transit stops, in accordance with HRTO decisions. As of the end of March 2008, of the 38 provincially regulated transit providers: [9]

  • 254 committed to begin announcing all stops by June 30, 2008
  • 2 more appeared likely to do so.

Of the remaining 11 provincially regulated organizations:

  • 4 indicated that they would begin announcing all stops announcements in the fall of 2008
  • 2 described plans for longer term compliance over the next 2-4 years
  • 2 made no commitments to our inquiry, referring instead to commitments to meet any future AODA standard
  • 3 did not provide sufficient information about their intentions or timelines for implementation.

Two of the three federally regulated agencies contacted indicated plans for partial or long-term compliance; the other did not reply.

The Commission is very pleased that a number of organizations took immediate and positive steps in response to its request, and that they committed to fully implement universal stop announcement plans within short time frames. In particular, in addition to the TTC, four transit providers – Brampton, Durham, Owen Sound, and Sault St. Marie – indicated that they would announce all stops before or by the end of the first quarter of 2008.

In all, more than two-thirds of provincially regulated transit operators committed to announce all stops by the end of the second quarter of 2008. These transit providers span the province, and range in size from small to very large systems: their efforts represent a considerable advancement in transit accessibility. The result is that over a relatively short period of time, persons with visual impairments and other transit riders will enjoy a significant improvement in services that are so essential to their daily lives.

The means by which organizations choose to announce stops has been the subject of some discussion over the course of this inquiry. Broadly speaking, there are two ways to deliver stop announcements:

Manual stop announcement:

A simple verbal call-out is made by the driver or vehicle operator, often with amplification using a PA system, to ensure greater audibility. Transit provider responses showed that plans for putting these systems into place may include steps such as: policy development; developing and implementing training for drivers on accessibility principles, policies and announcement procedures; naming mid-block or rural stops; providing cards or other tools listing the stops; and in some cases, acquiring and installing public address systems.

Of the many organizations that committed to announce all stops by June 30, 2008, all but one indicate that they will do so, at least initially, through manual call-out.[10] Overall, manual call-out offers a fairly quick and inexpensive solution, and has been the means by which many organizations, of a range of sizes, have been able to begin stop announcements within short time frames.

Automated systems:

These systems vary in complexity and cost. Because they can include both audio and visual announcement, they can provide broader accessibility than manual call-out, in that they benefit persons with either hearing or vision impairments, as well as other transit riders. A number of transit providers cited broader accessibility, convenience for the drivers, or alleged safety concerns (addressed and found not to have amounted to undue hardship in Lepofsky) as their rationale for pursuing this option. However, transit providers also indicated that these systems are expensive, and due to cost, availability and complexity, may require several months to several years to acquire, develop and install.

A number of organizations chose to focus solely on implementing electronic systems in the long term, or simply restated their commitment to meet any transit standard eventually finalized under the AODA, without addressing the immediate need for an interim solution. These responses do not sufficiently address the specific barriers and remedy described in the Lepofsky decision, relating to persons with visual impairment.

It should be noted that the Commission position, as set out in its Policy and Guidelines on Disability and the Duty to Accommodate (the “Policy”), is that organizations should actively identify and remove barriers to inclusion. Furthermore, the Policy states that service providers have a duty to:

  • provide timely solutions to accommodation requests
  • provide interim solutions where a broader or more appropriate accommodation may take some time to implement
  • provide accommodation to the point of undue hardship. This excludes business inconvenience, employee morale and third-party preference, and involves a detailed analysis of any alleged cost or health and safety concerns.[11]

A few transit providers felt that their current accommodation practices for persons with visual impairment, such as access to separate specialized transit systems, or stop call-out on request, were sufficient. The Lepofsky decision has already established that “on request” call-out is unreliable and insufficient. These responses also fail to take into account the human rights principles of integration, inclusive design and the dignity of the person. [12]

The question of dignity arises where persons with visual disabilities have to request and depend upon assistance from others every time they use transit, as a condition of gaining access, when other people do not have to do so. There is also a practical impact based in regular human error, in that, where call-out is not routine, drivers sometimes forget to call out the requested stop. These issues can all be addressed through inclusive design, that is, through consistently and audibly announcing all stops.

Several transit providers indicated that, while working toward long-term implementation of automated audio-visual announcement systems, or completing a phase-in of such systems, they will implement manual call-out systems. The Commission is pleased that these organizations are incorporating the concept of interim accommodation in their planning.

As several transit providers have noted, some steps taken toward manual call-out, such as the naming of stops, will facilitate eventual transition to automated systems. Others have pointed out that manual call-out remains an important back-up for automated systems. Organizations that have provided drivers with tools and training for manual call-out will be able to ensure seamless delivery of stop announcements, even if there are delays in implementing automated systems, or when there are system failures or malfunctions.

[7] Coach Canada, which is federally regulated, did not respond to the Commission’s inquiry. Two other federally regulated transit providers, Windsor and Ottawa (OC Transpo), did respond. See appendices for details.
[8] Many transit services provided detailed information about their programs and plans to improve access for transit users with disabilities, such as staff training , fare-free use of public transit for persons with visual impairment, accessibility improvements to bus stops and fleet vehicles, among others.
[9] See Appendix A for a summary breakdown of responses, and Appendix B for details of responses, arranged alphabetically by municipality or organization.
[10] Guelph indicated that it will have an automated system in place in Spring 2008. See appendices for more detailed information.
[11] See section 4 of the Policy.
[12] See section 3.1 of the Policy.

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