Staff Report #1
October 14, 2025
To All Members of the Accessible Public Transit Service Advisory Committee
Re: Draft Accessibility Plan (2026-2030)
Recommendation
That the report be RECEIVED for information
Background
Consistent with the requirements of the Accessibility for Ontarians with Disabilities Act (AODA) regulations, the Commission’s Accessibility Plan is scheduled for update. There are a number of specific requirements set out in the AODA regulations regarding Accessibility Plans, those which apply to the Commission are set out below.
Excerpts from Regulation 191 – Integrated Accessibility Regulation
Accessibility plans
4. (1) The Government of Ontario, Legislative Assembly, designated public sector organizations and large organizations shall,
(a) establish, implement, maintain and document a multi-year accessibility plan, which outlines the organization’s strategy to prevent and remove barriers and meet its requirements under this Regulation;
(b) post the accessibility plan on their website, if any, and provide the plan in an accessible format upon request; and
(c) review and update the accessibility plan at least once every five years. O. Reg. 191/11, s. 4 (1).
(2) The Government of Ontario, Legislative Assembly and designated public sector organizations shall establish, review and update their accessibility plans in consultation with persons with disabilities and if they have established an accessibility advisory committee, they shall consult with the committee. O. Reg. 191/11, s. 4 (2).
(3) The Government of Ontario, Legislative Assembly and designated public sector organizations shall,
(a) prepare an annual status report on the progress of measures taken to implement the strategy referenced in clause (1) (a), including steps taken to comply with this Regulation; and
(b) post the status report on their website, if any, and provide the report in an accessible format upon request. O. Reg. 191/11, s. 4 (3); O. Reg. 413/12, s. 3 (1).
(3.1) An upper-tier municipality and any lower-tier municipalities that form part of it for municipal purposes may prepare a joint accessibility plan and a joint annual status report. O. Reg. 413/12, s. 3 (2).
(3.2) A joint accessibility plan and a joint annual status report prepared in accordance with subsection (3.1) are deemed to be the accessibility plan and annual status report of each municipality to which they apply and subsections (2) and (3) apply, with necessary modifications, where municipalities prepare a joint accessibility plan and a joint annual status report. O. Reg. 413/12, s. 3 (2).
Accessibility plans, conventional transportation services
41. (1) In addition to the accessibility plan requirements set out in section 4, in their accessibility plan, conventional transportation service providers shall identify the process for managing, evaluating and taking action on customer feedback. O. Reg. 191/11, s. 41 (1).
(2) Every conventional transportation service provider shall annually hold at least one public meeting involving persons with disabilities to ensure that they have an opportunity to participate in a review of the accessibility plan and that they are given the opportunity to provide feedback on the accessibility plan. O. Reg. 191/11, s. 41 (2).
(3) If the provider of conventional transportation services also provides specialized transportation services, the transportation service provider shall address both types of transportation services in its accessibility plan. O. Reg. 191/11, s. 41 (3).
Accessibility plans, specialized transportation service
42. (1) Specialized transportation service providers shall, in their accessibility plans,
(a) identify the process for estimating the demand for specialized transportation services; and
(b) develop steps to reduce wait times for specialized transportation services. O. Reg. 191/11, s. 42 (1).
Accessibility plans, conventional and specialized transportation services
43. (1) Conventional transportation service providers and specialized transportation service providers shall, in their accessibility plans, describe their procedures for dealing with accessibility equipment failures on their respective types of vehicles. O. Reg. 191/11, s. 43 (1).
The following provides a brief overview of the initiatives that were included in the previous plan and the status of each, noting that status updates were also provided to the Commission and posted on the corporate website annually in compliance with the AODA regulations.
2020-2025 Accessibility Plan Initiatives
| Initiative | Status |
| General | |
| Ensure compliance with AODA | Ongoing |
| Include section in Plan on removal and prevention of barriers | Complete |
| Information & Communications | |
| Ensure compliance with AODA | Ongoing |
| Create an Accessibility section on corporate website | Complete |
| Consult with Advisory Committee on communication initiatives | Ongoing |
| Customer Service | |
| Ensure compliance with AODA | Ongoing |
| Consider additional communication methods for policies | Complete |
| Consult public regarding communication of temporary disruptions | Complete |
| Employment | |
| Ensure compliance with AODA | Ongoing |
| Public Transit Service General | |
| Ensure compliance with AODA | Ongoing |
| Conventional Transit Service | |
| Ensure compliance with AODA | Ongoing |
| Provide City with list of bus stops requiring sidewalk access | Ongoing |
| Communications campaign on priority seating and service animals | Complete |
| Assessment of ride hailing options | Ongoing |
| Specialized Transit Service | |
| Ensure compliance with AODA | Ongoing |
| Implementation of Smart Card readers on specialized service | Complete |
| Reallocation of service hours to match conventional service | Complete |
| Assessment of booking window options | Deferred |
| Assessment of trip booking options | Complete |
| Utilize non-accommodate trip data to plan for service growth | Complete |
| Consult advisory committee on service integration | Deferred |
| Public Spaces | |
| Ensure compliance with AODA | Ongoing |
| Ensure major retrofits include removal of barriers | Ongoing |
A review of the initiatives included in the previous plan is the first step in the creation of the next plan, noting that any initiatives that were deferred or not completed will be carried forward into the next plan. As set out in the table above, only two initiatives from the previous Accessibility Plan remain outstanding, both of which will be included on the next Accessibility Plan covering the period 2026-2030.
In addition to the review of the previous Plan, stakeholder engagement sessions for the 2024-2027 Business Plan included discussion around the accessibility of the conventional and specialized services, and a number of recommendations for initiatives for the next Accessibility Plan were identified. The following section provides a list of initiatives recommended for inclusion in the 2026-2030 Accessibility Plan, including a general description of the initiative to assist with Committee discussion.
Overarching
- Participating in Standard Review Processes – consistent with past practice Administration will work with the Accessible Public Transit Service Advisory Committee (APTSAC) to assess proposed changes to Accessibility Standards stemming from mandatory reviews (each standard is required to undergo a review every five years). Should concerns be identified, recommendations will be made to the Commission to formally respond through the defined process.
General Requirements
- Ensuring Compliance with AODA Regulations and Supporting Standards – Administration will continue to monitor any changes to regulations, as well as respond to inquiries with respect to compliance with the AODA. Additionally, administration will participate in any desk audits undertaken by the Ministry of Seniors and Disability relating to compliance monitoring. It should be noted that London Transit was subject of a desk audit earlier in 2025, the result of which confirmed no compliance issues.
- Employee Training Material Review – The training materials relating to the AODA are reviewed and updated as needed in response to specific issues or legislative changes. This initiative is intended to provide a comprehensive review of the entire training framework to identify best practices in both content and delivery, and incorporate same going forward.
Customer Service
- Monitor final updates to standards resulting from mandatory review (feedback process, requests for documents, use of service animals and use of support persons) – Significant concerns were shared with respect to compliance implications for a number of the proposed changes stemming from the review of the Customer Service Standard. Administration will continue to monitor progress on finalizing the updated standards and will share reports on compliance implications as appropriate.
Employment
- Employment Accommodation Program Review – This initiative is intended to provide a comprehensive review of the entire Employee Accommodation framework to identify best practices in both content and delivery, and incorporate same going forward.
Conventional Transit
- Assessment of Conventional Transit Bus Stop Design – While conventional transit bus stops currently incorporate features to ensure accessibility, this review is intended to provide a comprehensive review of current designs in comparison to those in use in other Ontario jurisdictions in an effort to identify any changes to design features going forward. As an example, a question has been raised with respect to whether there should be a cement pad at the rear-door exit of the bus to ensure a flat and secure location for those leaving the bus via the rear door.
- Accessible Conventional Transit Stops (Connecting Sidewalks) – When transit stops are added or relocated, they are accessible noting each includes a cement pad to accommodate the ramp on the low-floor buses as well as a curb cut where applicable. In some cases, there is no connecting sidewalk to the stop as it is located in an area where the sidewalk infrastructure has not yet been built. Administration shares a list of these stop locations with the City of London to ensure these locations are included in their sidewalk program.
- Assessment of Ride Hailing Options (Multi-Use Stops) – Issues relating to the functionality of multi-use stops resulted in this review being placed on the previous Accessibility Plan. The primary concern relates to customers with visual disabilities who rely on the external announcement to identify the bus they wish to board. There are a number of stops, primarily in the core, that are utilized by multiple buses, which have caused challenges in the past. A number of initiatives have been undertaken in an effort to address these concerns, including the following:
- reminders to all London Transit Operators that they must pull up, stop and open their doors at the front-most position of the multi-use stop in order to ensure that customers waiting at the stop can hear the external announcement
- splitting the multi-use stop in the core to two locations, which reduces the number of buses utilizing each of the stops, which reduces the queuing of buses and the wait times associated with each bus pulling up to and stopping at the stop location
While these efforts have reduced the number of issues at multi-use stops, they do still occur albeit far less frequently. Administration will continue to work with APTSAC to identify other possible solutions to address this issue.
- Assessment of Service Integration Options – This initiative was included on the previous Accessibility Plan, however was placed on hold due to the impacts of the global pandemic. It is anticipated that this assessment can take place during the horizon of the next Accessibility Plan period given the planned service growth occurring on both the conventional and specialized services.
- Rapid Transit Station Accessibility Review – As set out in Staff Report #2 dated October 14, 2025, APTSAC has raised concerns with respect to the rapid transit station configurations, and the lack of clear delineation of where customers should stand to board the bus. As discussed in an earlier bullet, LTC Operators will pull up to the front-most position at the station for boarding and alighting. Unlike the multi-use stops, the rapid transit stations do not have a bus stop pole to identify this location to customers with visual disabilities. Administration will work with APTSAC to identify possible solutions to this issue which will be shared with the City of London for consideration (noting the City of London is the owner of these stations).
- Annual Customer Surveys – Undertake annual customer satisfaction surveys and include initiatives to address any concerns/trends that are identified to address accessibility related issues.
Specialized Transit
- Assessment of Demand for Specialized Service – This initiative will see the monitoring and assessment of daily booking requests in order to identify the periods of time with the highest non-accommodated rates. This information is used to determine where the additional growth hours for the service will be applied (time of day, day of week, etc.).
- Booking Window Review – During consultation on the 2024-2027 Business Plan, the booking window on the specialized service was identified as something that should be reviewed once again. Given the implementation of the new scheduling software in 2025, this initiative has been scheduled to be included in the next 2026 – 2030 Accessibility Plan.
- Policy and Procedure Review – This initiative calls for a review of the current policies and procedures which guide the delivery of the specialized service. Administration will work with APTSAC to review various policies and procedures against other transit providers in an effort to identify and implement best practices where they are identified while continuing to ensure compliance with the AODA.
- Eligibility Review including Application – During consultation on the 2024-2027 Business Plan, a review of the current Eligibility Criteria and related application form were identified as an initiative for the 2026-2030 Accessibility Plan. Similar to the policy and procedure review, this would entail a review of practices at other transit providers in an effort to identify and implement best practices, while continuing to ensure compliance with the AODA.
- Improved Communications with Specialized Registrants – This initiative will undertake to determine additional communication options with registrants of the specialized service. Assessment will include consideration of utilizing email to provide registrants with service updates, noting registrants would have to agreed to be included on the list and be provided with an option to unsubscribe.
- Assessment of Specialized fleet options – APTSAC has requested that consideration be given to diversifying the fleet of vehicles utilized to provide the specialized service. This assessment will look at fleet make up at other specialized transit providers, as well as the manner in which trips are assigned to various vehicle types. Final consideration will need to be given to the availability of various vehicles options in London.
- Annual Customer Surveys – Undertake annual customer satisfaction surveys and include initiatives to address any concerns/trends that are identified to address accessibility related issues.
Public Spaces
- Accessibility Review of Detailed Design of new Highbury facility – the detailed design phase of the Highbury facility rebuild project is scheduled to begin in 2026, and this will include a review of the design concepts against current accessibility standards as well as the City of London Facility Accessibility Design Standard.
Members of APTSAC will be encouraged to discuss and recommend any additional items for consideration and inclusion in the 2026-2023 Accessibility Plan at the October 14, 2025 meeting. Subsequent to the meeting, a survey will be shared with the public which will seek additional recommendations as well as ask respondents to prioritize the items currently under consideration.
One of the specific requirements in the AODA standards requires obligated organizations to hold an annual public meeting, at which members of the board (Commission) are in attendance. The annual drop in session has been scheduled for November 6 at the Downtown Library, with an afternoon session from 2pm to 4pm and an evening session from 6pm to 8pm. The 2026-2030 Accessibility Plan will be one of the topics for discussion at these sessions.
Subsequent to Committee and public feedback with respect to items for inclusion in the next Accessibility Plan, administration will prepare a Draft 2026-2030 Accessibility Plan for Commission review and approval at the November 17, 2025 meeting.
Recommended by:
Katie Burns, Director of Planning
Shawn Wilson, Director of Operations
Joanne Galloway, Director of Human Resources
Concurred in by:
Kelly S. Paleczny, General Manager