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Jaye Robinson
Chair
TTC Board of Directors
Toronto Transit Commission
1900 Yonge Street
Toronto, ON M4S 1Z2
Donald Wright
Chair
Metrolinx Board of Directors97 Front Street West
Toronto, ON M5J 1E6
Dear Councillor Robinson and Chair Wright:
Re: Human Rights Code barriers linked to PRESTO on the TTC
The Ontario Human Rights Commission (OHRC) is concerned that the use of the PRESTO electronic fare payment system may present barriers to accessing Toronto’s public transit for some Human Rights Code-protected groups. The OHRC calls on the Toronto Transit Commission (TTC) and Metrolinx, as the owner and operator of PRESTO, to make sure that they adopt a human rights-centred approach to their fare system planning and implementation.
The OHRC is aware that the TTC and Metrolinx are engaged in ongoing negotiations and work on TTC fare systems and PRESTO implementation. Under the Code, the TTC and Metrolinx are both required to provide equitable access to transit services, and human rights obligations must play a central role in these discussions and work.
The OHRC’s key concerns relate to barriers PRESTO may present for people who have low incomes or are experiencing poverty. Code-protected groups disproportionately experience poverty, and persons most at risk include people with disabilities, racialized and Indigenous peoples, women (especially single mothers and older women), and recent immigrants or newcomers. The OHRC has been engaging with individuals and organizations working to promote equitable transit, and issues with TTC fares and PRESTO that have come to our attention and may pose barriers for Code-protected groups include:
- Reducing physical locations where TTC fares can be purchased: We are aware that Metrolinx is responsible for providing a network for PRESTO sales throughout Toronto, and has tried to achieve this through PRESTO sales at about 136 Shoppers Drug Mart locations and PRESTO fare machines in select community centres. We are concerned that this will not provide sufficient access to physical locations for purchasing PRESTO fares, with the most significant gaps occurring in areas where more residents are racialized or experience poverty, such as North-west Toronto and Scarborough. Physical fare sale locations are also particularly important for people who do not have access to credit cards or the internet and need to buy fares with cash. As well, needing to travel further distances to buy fares may present challenges for people with disabilities.
- Up-front costs of PRESTO cards, minimum balance loading requirements, and access to discounted fares: The up-front costs of buying a PRESTO card ($6) and the minimum balance load requirements (as high as $10 online) may make it harder for people with low incomes or experiencing poverty to buy fares. Further, we understand that people who qualify for discounted TTC fare rates – such as youth, seniors and individuals using the City of Toronto’s Fair Pass Program – can only access these reduced fares with a PRESTO card, meaning that they must bear these up-front costs to even access discounted rates in the first place. While we appreciate the efforts to distribute complimentary PRESTO cards (for example, through select Toronto Public Library locations), you may need to implement a more systematic and comprehensive approach to removing these up-front financial barriers.
- Issues with the bulk sales and expiry of PRESTO tickets: Switching from tokens to PRESTO tickets creates challenges for community organizations that purchase TTC fares in bulk to subsidize transit costs for people using their services. One issue is that PRESTO tickets are not yet available for bulk discount purchases in the same way as tokens. Another issue is that unlike tokens, PRESTO tickets expire, meaning that these organizations may struggle to manage their ticket inventory or could risk losing money by purchasing PRESTO tickets that expire before they can be used.
- PRESTO issues with the City of Toronto’s Fair Pass Program: PRESTO also appears to create barriers for people using the City of Toronto’s Fair Pass Program. The program aims to make transit more affordable for people living in poverty, and currently provides TTC fare discounts for people receiving social assistance or childcare subsidies. The program operates by applying a discount on PRESTO cards. One challenge presented by the PRESTO system is that it requires applicants to navigate multiple steps to obtain, load and validate a PRESTO card, and imposes technical limits on the ability of City staff to help with this process. In addition, there have been reports that eligible participants – particularly Indigenous persons – may be discouraged from using the program because of potential stigma, embarrassment, and concerns about interactions with fare inspectors due to the distinct light and sound emitted when they use a PRESTO card with a Fair Pass discount. Efforts to remove this distinct light and sound should be made as soon as possible.
The significance of these barriers is heightened by the reality that people who have low incomes or live in poverty are especially reliant on public transit systems. For many, the ability to do things like work, receive health care and attend school hinges on their ability to access public transit. This increased reliance continues to play out during the COVID-19 pandemic. TTC ridership data suggests that since the outset of the pandemic, low-income people using the Fair Pass Program (who may be less likely to have a job that is conducive to working from home or access to a personal vehicle) have returned to transit use at significantly higher rates than others.
In other words, the OHRC is concerned that many of the people and Code-protected groups who most need access to Toronto’s public transit are the same people experiencing the greatest barriers with the PRESTO fare system.
The TTC and Metrolinx both have obligations under the Code to make sure their services do not discriminate or impose barriers that disproportionately impede access for Code-protected groups. As you continue working together to implement and operate PRESTO on the TTC, it is imperative that you take steps to identify and address human rights issues, such as those described above.
The TTC’s current work to develop a five-year Fare Policy and 10-year Fare Collection Outlook – both of which we understand will inform the future implementation and operation of PRESTO – presents an ideal opportunity to address these issues. We urge you to make sure that Code considerations are central to this work.
Metrolinx must also make sure it has established its own internal mechanisms to identify and address any Code issues linked with PRESTO. This is necessary for PRESTO use on the TTC – and also for every other Ontario transit system where PRESTO is used. Indeed, the barriers Code-protected groups encounter with PRESTO on the TTC may well be surfacing on the other Ontario transit systems using PRESTO.
The OHRC will continue to follow these issues and is looking forward to both the TTC and Metrolinx taking steps to meet their Code obligations and make sure that all Ontarians are able to access transit systems without discrimination.
Sincerely,
Ena Chadha, LL.B., LL.M.
Chief Commissioner
cc: John Tory, Mayor, City of Toronto
Shelagh Pizey-Allen, Executive Director, TTC riders
Hon. Doug Downey, Attorney General
OHRC Commissioners