Staff Report #1
November 7, 2019
To All Members of the Accessible Public Transit Service Advisory Committee
Re: Accessibility Plan Update
Recommendation
That the recommendations set out below be RECOMMENDED to the Commission for consideration when approving the 2020-2025 Accessibility Plan.
- Include a section in the updated plan that specifically addresses the removal and prevention of barriers.
- Create a specific area on the corporate website dealing with accessibility where all information is housed and/or links to other areas of the site are provided. This will provide easier navigation on the site for people seeking information specific to accessibility.
- Ensure that development of the actions plans relating to increased marketing and enhanced corporate communication include consultation with the Accessible Public Transit Service Advisory Committee.
- Consider additional methods of communicating information with respect to policies and procedures to the public.
- Seek additional information from the public with respect to what could be improved with the methods of communication in regard to temporary disruptions.
- Prioritize the implementation of smart card readers on specialized service prior to the removal of paper tickets from use.
- Provide the City of London, on an annual basis, a list of transit stops with no connecting sidewalks for inclusion in their accessibility plan.
- Work with the Ontario Public Transit Association on the communications campaign regarding priority seating and implement the campaign as soon as it is available.
- Utilize the additional service hours included in the multi-year budget to extend the service day to match the conventional transit service.
- Undertake an assessment of the impacts and issues associated with a move to a shorter booking window. This assessment would include customer consultation and feedback from the Accessible Public Transit Service Advisory Committee.
- Undertake an assessment of the issues and impacts associated with the implementation of on-line trip booking.
- Continue to ensure that all major retrofits are assessed to ensure that the removal of any existing barriers is considered a priority piece of the project.
- Undertake an assessment of the periods of highest non-accommodated on the specialized service to identify areas that would see the additional service hours best utilized. Consult with Accessible Public Transit Service Advisory Committee on the implementation of additional hours on the specialized service included in annual budgets, noting the conventional transit service planning process includes presentation to the Committee as well as a number of opportunities for feedback to be provided.
- Consult the Accessible Public Transit Service Advisory Committee with respect to initiatives under consideration as part of the Integrated Services program.
Background
Consistent with the requirements of the Accessibility for Ontarians with Disabilities Act (AODA) regulations, the Commission’s Accessibility Plan is scheduled for update. At the September 10, 2019 meeting, the Committee received a report providing an overview of the various initiatives included in the previous multi-year accessibility plan in an effort to begin discussion on initiatives that should be included in the next plan. Subsequent to the meeting, an online survey was posted to allow the public to provide feedback and a public drop in session was held. Summary details of the feedback received from the survey and drop in, in addition to that gathered from customer contacts are set out in Enclosure I.
The remainder of the report will be broken down by each section of the Integrated Accessibility Regulation as it relates to the provision of public transit services. Each section will provide a recap of the status of compliance, public feedback received and recommendations for items to be included in the next Five Year Accessibility Plan.
Accessibility – General
The general requirements included in the Integrated Accessibility Regulation (IAR) are set out in the table below with commentary regarding compliance.
| Standard Requirement | Status of Compliance |
| Accessibility Plan | In progress – will be completed by Dec 2019 |
| Procurement of Goods | Compliant |
| Training for Employees | Compliant |
A comment received regarding the accessibility plan in general pointed out that the previous plan had no defined section that outlined plans to prevent and remove barriers. While the initiatives set out in the plan were all intended to remove/prevent barriers, the intent was not spelled out specifically.
With respect to the training requirement, all employees at London Transit have been trained on the AODA legislation as well as the Ontario Human Rights Code. While the satisfaction level with the training requirement from survey respondents was low, given the comments provided in this section of the survey, most dealt with training on specific issues such as the policy on service animals, which is dealt with later in the report.
Recommendations for Accessibility Plan
- Include a section in the updated plan that specifically addresses the removal and prevention of barriers.
Information and Communications
The information and communications requirements included in the Integrated Accessibility Regulation (IAR) are set out in the table below with commentary regarding compliance.
| Standard Requirement | Status of Compliance |
| Options to provide your feedback | Compliant |
| Formats of public reports | Compliant |
| Website and Web contents | Compliant |
| Information about emergency plans | Compliant |
While all areas of this section are identified as compliant, a number of comments provided through public feedback were assessed for consideration.
With respect to the formats of public reports available, a suggestion to include large font and braille versions of public reports was included in the feedback. Any report that is posted publicly can be made available, upon request in Word format, which can easily have the font resized. Further, upon request, administration will work with customers to provide a format of a report that can readily be converted to braille.
Feedback with respect to the website indicated that information with respect to accessibility is difficult to find on the current site. The manner in which the corporate website is currently laid out does not include a general section on accessibility, rather, information is spread over a number of areas.
Commentary has also been received with respect to the manner in which various public information sessions are advertised to the general public, and whether they can be expanded upon.
Recommendations for Accessibility Plan
- Create a specific area on the corporate website dealing with accessibility where all information is housed and/or links to other areas of the site are provided. This will provide easier navigation on the site for people seeking information specific to accessibility.
- Ensure that development of the actions plans relating to increased marketing and enhanced corporate communication include consultation with the Accessible Public Transit Service Advisory Committee.
Customer Service
The customer service requirements included in the Integrated Accessibility Regulation (IAR) are set out in the table below with commentary regarding compliance.
| Standard Requirement | Status of Compliance |
| Accessible customer service policy | Compliant – posted on Website |
| Policy re: service animals | Compliant |
| Policy re: support persons | Compliant |
| Notice of temporary disruptions | Compliant |
Commentary was received with respect to the contents and awareness of both the service animal and support person policies. Recommendation 2 above would include these policies in the accessibility section on the corporate website.
Temporary disruptions generally relate to conventional service routes that have to be detoured as the result of road construction, accidents, etc. In these cases, temporary notices are installed at all affected bus stops, and bus Operators will notify customers as they board of the disruption. In addition, this information is available on the LTC real-time information and is communicated via the corporate Twitter account and on the LTC website. The automatic stop announcements on-board cannot be reprogramed to respond to disruptions of this nature given their immediacy. Commentary was provided that indicated improvements could be made, however no details were provided.
Recommendations for Accessibility Plan
- Consider additional methods of communicating information with respect to policies and procedures to the public.
- Seek additional information from the public with respect to what could be improved with the methods of communication in regard to temporary disruptions.
Employment
The employment requirements included in the Integrated Accessibility Regulation (IAR) are set out in the table below with commentary regarding compliance.
| Standard Requirement | Status of Compliance |
| Recruitment ads and options | Compliant |
| Recruitment selection process | Compliant |
| Informing employees of supports | Compliant |
| Workplace emergency information | Compliant |
| Individual accommodation plans | Compliant |
| Return to work process | Compliant |
| Career development and advancement | Compliant |
The requirements relating to employment are all considered compliant, however as issues arise with employees, processes and procedures are modified to ensure that the employee’s requirements are being met in a manner that is acceptable to all parties.
There are no recommendations with respect to the employment standards.
Public Transit Service – General
The public transit service general requirements included in the Integrated Accessibility Regulation (IAR) are set out in the table below with commentary regarding compliance.
| Standard Requirement | Status of Compliance |
| Information on accessibility equipment | Compliant |
| Policy – non-functioning accessibility equip | Compliant |
| Free support person fares | Compliant |
The feedback received with respect to all three of the policies above centred around a lack of awareness of same. Recommendation number 2 above would see these policies, all of which are compliant with regulations, included in the accessibility section of the corporate website. Additionally, recommendations number 3 and 4 would see an increased focus on raising public awareness regarding these policies.
There are no additional recommendations for inclusion in the accessibility plan relating to this section.
Conventional Transit Service
The conventional transit service requirements included in the Integrated Accessibility Regulation (IAR) are set out in the table below with commentary regarding compliance.
| Standard Requirement | Status of Compliance |
| Alternative service | Compliant – Specialized Service |
| Fare parity with specialized service | Compliant – with exceptions |
| Accessible transit stops | Compliant – with exceptions |
| Priority seating area | Compliant |
| Policy regarding service disruptions | Compliant |
| Pre-boarding announcements | Compliant |
| On-board announcements | Compliant |
| Accessible buses | Compliant |
The requirement for fare parity is classified as compliant with exceptions given the ability to utilize smart cards on the specialized service has not been fully implemented. The vendor for the smart card system is in the late development stages of a hand-held interface to the smart card system that will be tested in 2020. Subsequent to testing, the most appropriate method of allowing smart card use onboard specialized service vehicles will be implemented.
Accessible transit stops are listed as compliant with exceptions given there are approximately 171 conventional service stops that have cement pads and curb cuts, but no connecting sidewalks. Administration shares a list of these stop locations with the City of London to ensure these locations are included in their sidewalk program.
Priority and Courtesy seating continue to cause confusion and frustration for customers. The requirement for a priority seating area on board conventional buses is set out in the AODA regulation. While the required seating area is provided on every bus, London Transit, consistent with transit systems across the province, operates on a first come first served basis, meaning there are no “reserved” seats on the service. This has led to frustration with respect to strollers and passengers crowding the priority seating area on busy routes such that the bus is unable to accommodate a passenger utilizing a mobility device. LTC Operators are trained to ask, in a general manner, if passengers are able to move from the priority seating area, however, they are not expected to ask a customer directly, or order a customer to move. Given concerns with respect to the crowding in the priority seating area, London Transit retrofitted the entire fleet to have perimeter seating all the way to the back doors of the bus, which opens up more area for strollers to move toward the back of the bus. This has alleviated some of the issues, however conflict continues to occur. Additionally, the Ontario Public Transit Association is working in cooperation with the Accessibility Directorate on a communications campaign intended to raise awareness of a number of requirements including priority seating. It is anticipated this campaign will be finalized by the spring of 2020 for implementation.
The policy regarding service disruptions is another that would be included in the accessibility section of the corporate website.
In addition to the specific regulations, feedback included several comments with respect to training for LTC Operators relating to when to lower the bus and deploy the ramp, waiting until customers are seated prior to leaving the stop, etc. The operating procedures with respect to these issues are further examples of those that would be included in the accessibility section of the corporate website as well as the marketing and communications campaigns referenced in recommendations 2, 3 and 4 above.
Recommendations for Accessibility Plan
- Prioritize the implementation of smart card readers on specialized service prior to the removal of paper tickets from use.
- Provide the City of London, on an annual basis, a list of transit stops with no connecting sidewalks for inclusion in their accessibility plan.
- Work with the Ontario Public Transit Association on the communications campaign regarding priority seating and implement the campaign as soon as it is available.
Specialized Transit Service
The specialized transit service requirements included in the Integrated Accessibility Regulation (IAR) are set out in the table below with commentary regarding compliance.
| Standard Requirement | Status of Compliance |
| Clear eligibility criteria/temporary eligibility | Compliant |
| Application process | Compliant |
| Fare parity with conventional service | Compliant – with exceptions |
| Access to service for visitors | Compliant |
| Service hour parity with conventional | Compliant – with exceptions |
| Booking process | Compliant |
The eligibility application and process are included on the corporate website under the specialized service section, however would be subject to recommendation 2, which would see links to this information also included under the newly created accessibility section of the corporate website.
The fare parity requirement was discussed earlier under the conventional transit section, with recommendation 6 calling for the implementation of smart card readers on-board specialized vehicles to allow for the use of smart cards.
The service hour parity with conventional service is classified as compliant with exceptions, noting the exceptions relate to the changes in service hours on Sunday mornings (9 routes on conventional) and service to 1am (9 routes on conventional). Given the entire conventional service does not operate on these extended hours, changes to the operating hours on the specialized service have not yet been made.
A number of comments were received with respect to dissatisfaction with the ability to book trips and the time spent waiting in the queue when calling to book a trip. The multi year operating budget, approved by the Commission includes the addition of 6,000 annual hours of service to the specialized budget in an effort to continue to expand the availability of service.
The 2018 Voice of the Customer survey also identified dissatisfaction with the current three day booking window, noting customers would like to see a move to a shorter window.
Recommendations for Accessibility Plan
- Utilize the additional service hours included in the multi-year budget to extend the service day to match the conventional transit service.
- Undertake an assessment of the impacts an issues associated with a move to a shorter booking window. This assessment would include customer consultation and feedback from the Accessible Public Transit Service Advisory Committee.
- Undertake an assessment of the issues and impacts associated with the implementation of on-line trip booking.
Public Spaces
The public spaces requirements included in the Integrated Accessibility Regulation (IAR) are set out in the table below with commentary regarding compliance.
| Standard Requirement | Status of Compliance |
| Ticket office at 150 Dundas Street | Compliant |
| Office at 450 Highbury | Compliant |
| Parking at 450 Highbury | Compliant |
All requirements relating to the public spaces in operation by London Transit are compliant, noting that, in some cases, the requirement does not require retrofit but rather are tied to major renovations.
Comments with respect to the ticket office at 150 Dundas include the counter not being accessible to a customer in a mobility device as well as the lack of accessible door openers on both doors. Both doors at the ticket office have been equipped with accessible door openers subsequent to the issue being raised in the summer of 2019 by a customer. Should the ticket office undergo a major renovation, the counter height will be adjusted to meet the requirements, until then, ticket office representatives will continue the current practice which is to meet the customer on the other side of the glass to conduct the transaction.
Recommendations for Accessibility Plan
- Continue to ensure that all major retrofits are assessed to ensure that the removal of any existing barriers is considered a priority piece of the project.
Additional Non-Regulatory Items
In addition to those mentioned above, a number of initiatives are included in the 2019-2022 Business Plan that related to the accessibility of London’s public transit services, and as such are being recommended to be included in the Accessibility Plan as well.
Notwithstanding the significant investments in additional service over the past five years (13% increase in conventional hours and 30% increase in specialized hours), feedback from the public continues to include requests for additional service. The 2020-2023 multi-year operating budget calls for the addition of approximately 18,000 service hours each year to the conventional service, and an additional 6,000 service hours each year to the specialized service.
Another important initiative, which will in part address the demand on the specialized service is the assessment and implementation of programs intended to integrate the conventional and specialized services. Various programs are in place across the province that see the two systems being utilized together in an effort to increase the availability of service in the community. This initiative will include consideration of the role that alternative service delivery models being piloted may play in increasing the availability of accessible public transit services to difficult to serve areas.
Recommendations for Accessibility Plan
- Undertake an assessment of the periods of highest non-accommodated on the specialized service to identify areas that would see the additional service hours best utilized. Consult with Accessible Public Transit Service Advisory Committee on the implementation of additional hours on the specialized service included in annual budgets, noting the conventional transit service planning process includes presentation to the Committee as well as a number of opportunities for feedback to be provided.
- Consult the Accessible Public Transit Service Advisory Committee with respect to initiatives under consideration as part of the Integrated Services program.
Summary
Subsequent to review and discussion by the Accessible Public Transit Service Advisory Committee, the 2020-2025 Accessibility Plan will be updated to include the recommendations and forwarded to the Commission for review and consideration.
Enclosure
I – Summary of Public Feedback – AODA Accessibility Requirements
Recommended by:
Kelly S. Paleczny, General Manager