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Without adequate and affordable transportation, a senior loses her independence, does not have the means to participate in activities outside her home, loses the chance to participate in social activities, and can actually take transportation means that are unsafe, or suffer isolation. - Ontario Society (Coalition) of Senior Citizens’ Organizations

Conventional Transit Systems and Human Rights Law

The OHRC’s Policy and Guidelines on Disability and the Duty to Accommodate highlights the importance of the right to integration and full participation for persons with disabilities. This requires barrier-free and inclusive designs and removal of existing barriers. Segregated treatment in services is less dignified, and is unacceptable, unless it can be shown that integrated treatment would pose an undue hardship, or that segregation is the only way to achieve equality[7].

In the context of public transit services, this means that the accessibility of the conventional transit system is essential, even where excellent paratransit services are available. Conventional transit services should be designed as inclusively as possible, from the outset, and barriers should be removed where they exist. This is the approach that most respects the dignity of persons with disabilities.

When planning new systems of transportation, we would all gain if attention were paid to the fact of an aging population ... It is more cost-effective to design the systems like this from the start, rather than having to retro-fit them at a later time.
- Ontario Society (Coalition) of Senior Citizens’ Organizations

Increasing the accessibility of conventional transit may also make good practical sense. It is possible that increased accessibility in conventional transit will decrease demands on paratransit services. The TTC noted in its submission that, as its conventional system becomes more accessible, there has been a movement by persons with disabilities towards using the conventional service and being less reliant on the paratransit service. This increases efficiencies: for example, the average public subsidy per passenger trip for Wheel-Trans in 1999 was $25.98, as opposed to $.35 on the conventional system. However, the submission from OCTA and the Canadian Urban Transit Association (“CUTA”) is sceptical on this point, stating that the majority of people who are eligible for door to door service would be reluctant to give up this higher level of service to ride on conventional fixed route transit, even though it would eliminate the need for advance reservations, and provide greater flexibility and spontaneity. Kingston Transit notes that the types of paratransit users in each community vary widely, so that the impact of increasing the accessibility of conventional transit may differ between communities.

In any case, many modifications that increase accessibility also lead to improvements for other riders. For example, a recent study conducted by the American Transportation Research Board found that, for most of the transit providers surveyed, the most important reason for improving communication methods for persons with disabilities was the benefit it provided to all riders[8].

Accessible Conventional Transit Services in Ontario

There are 58 conventional transit systems in Ontario. This includes commuter rail systems like GO Transit, and the subway system operated by the TTC. Public funding accounts for about 25% of the revenues, and in recent years has been contributed solely by municipalities[9].

Many of Ontario’s older public transportation systems were not designed to accommodate persons with disabilities, and face significant challenges in removing existing barriers. Progress towards maximum accessibility is continuing, but at a slow pace. While transit service providers express support for the principle of maximum accessibility in the conventional transit system, they also universally indicate that lack of funding is posing significant obstacles to progress.

As indicated by the transit surveys, most public transit systems are operating at least some lift-equipped or low-floor buses. However, the information provided to the OHRC indicates that there is a long way to go to achieve completely accessible fleets. While 90% of Ontario transit systems have a procurement policy in favour of low-floor buses[10], in many cases, these commitments are dependent on budget constraints. In recent years, accessibility initiatives have also focussed on improvements to bus stops and shelters. Several systems offer some “community bus” services.

While many accessibility improvements are relatively low cost (such as having drivers announce stops), others are very costly. For example, retrofitting subway or transit stations to add elevators costs millions of dollars per station. Modifications to streets and sidewalks to improve access to low-floor buses are also expensive.

The sections below outline some key areas of concern with respect to the accessibility of conventional transit systems that were raised in the submissions to the OHRC.

General Issues

Many submissions pointed out that older persons and persons with disabilities often face significant challenges simply getting to and from fixed route transit, particularly during the winter months, when snow creates major barriers in most parts of Ontario. Unless these issues can be addressed, no amount of improvements to conventional transit systems will make conventional transit truly accessible. Some issues include the lack of benches at bus stops where passengers can rest while waiting for transit, long distances to buses, and long waiting periods. Piles of snow at bus stops can also pose hazards for persons with disabilities.

I have been dropped off a streetcar or bus at the end of the sidewalk to face a mountain-like pile of snow. The streetcar would move away after I got off and then the cars would start to zoom by me before I managed to cross over the snow and reach the sidewalk. I felt like I was in the middle of a firing range.
-Individual submission

This concern was echoed in the submission of Canadian Pensioners Concerned.

As well, some submissions pointed out that priority seating for older persons and persons with disabilities is not always respected, particularly when transit is overcrowded.

Concerns were also raised that drivers on the conventional transit system may not receive sufficient training regarding assisting passengers in need. As a result, even where accessibility features are in place, passengers may not always be receiving the full benefit. For example, drivers may not give passengers with mobility or sensory impairments sufficient time to take their seats prior to moving the vehicle. As well, because of tight schedules, drivers are sometimes reluctant to take the time to lower the floor of kneeling buses or to ask other passengers to make way, or are uncertain as to how to operate lift-equipped buses. Further, breakdowns of elevators or lifts, or non-functioning escalators are not uncommon.

As well, ongoing sensitivity and anti-discrimination training for transit staff is essential. Several submissions identified lack of sensitivity and discriminatory attitudes among transit personnel as barriers to access.

ARCH has received complaints about lack of training and discriminatory attitudes of the staff of these transit service providers. In these cases, even though the equipment is accessible, the staff have not been knowledgeable or willing to assist to accommodate the person. The requirement for accommodation with dignity embodied in the duty to accommodate is nullified when an individual has to fight to be able to access equipment which is already accessible.
-Advocacy Resource Centre for the Handicapped

A number of submissions pointed out the need for a broad understanding of accessibility. The focus of accessibility initiatives has most often been on mobility impairments. However, persons with sensory impairments, or invisible disabilities such as environmental sensitivities or mental disabilities, also have needs that should be taken into account when designing public transportation services, or in barrier removal.

Access for Persons with Mobility Impairments

As noted above, 90% of Ontario transit systems now have a procurement policy in favour of low-floor buses, and lift-equipped and low-floor buses now make up 15% of Ontario’s total bus fleet. There are Easier Access features on the majority of the Ontario transit industry’s 5600 buses, and there are a growing number of fully accessible bus routes in many Ontario cities. As well, many bus and subway stations have been made more accessible to persons with disabilities through the addition of elevators, accessible washrooms, modified rest benches, and other accessibility features.

However, there is still a long way to go. Information from the transit surveys indicates that maximum accessibility may be 15 years or more away in many urban centres in Ontario, even if all accessibility plans currently in place are implemented. This is partially due to the high costs of renovating transit stations and purchasing accessible vehicles, and partially due to the long life span for capital equipment: for example, in the city of Windsor, over half the bus fleet is over 25 years old. Procurement policies in favour of low-floor vehicles will therefore produce results only slowly.

Accessibility Features for Persons with Sensory Impairments

In its submission, the Canadian National Institute for the Blind recommended a number of measures to increase accessibility for persons who are blind or visually impaired, including making all information, including maps, available in alternative formats; consistently and clearly announcing all stops along subway, bus and streetcar lines; placing colour-contrasted, appropriately-sized signage in convenient locations; and using tactile ground surface indicators to indicate stairs, platform edges, and way finding. Although some transit systems have made advances in this respect, many have not.

The Discussion Paper appears to primarily focus on the accessibility needs of those with ambulatory disabilities and persons who use wheelchairs and stress the importance of accommodating persons with mental disabilities. The accessibility needs of persons who are blind and visually impaired must also be addressed. The TTC ... has undertaken a number of initiatives to accommodate the needs of persons who are blind and visually impaired, however, other Transit Authorities have yet to do so.
-Canadian National Institute for the Blind

Individual submissions also emphasized the importance of providing announcements of stops, and training for transit staff.

The Centre for Independent Living in Toronto (“CILT”) recommended coin operated TTYs at bus and subway stations, using existing moving LCD signs on subway platforms to make public announcements, and installing LCD signs in buses and subway cars.

Other Issues

Accessibility features that would benefit persons with environmental sensitivities include implementing no-scent policies for drivers and passengers; prohibiting buses and taxis from idling at pick-up stops, in order to reduce chemical exposures; installation of benches at bus stops; and ensuring that elevators and escalators are not only available, but in good repair. OC Transpo has recently undertaken two marketing campaigns dealing with environmental sensitivity issues, the first of which was undertaken in partnership with the Environmental Health Association of Canada.

[7] Ontario Human Rights Commission, Policy and Guidelines on Disability and the Duty to Accommodate (March 2001), at section 3.1.3, available online at
[8] Transportation Research Board, Communicating with Persons with Disabilities in a Multimodal Research Environment: A Synthesis of Transit Practice, (2001) .
[9] Canadian Urban Transit Association, Transaction 2001.
[10] Canadian Urban Transit Association and Ontario Community Transportation Association submission to the OHRC.

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