Staff Report #15
August 27, 2025
To All Commissioners
Re: Secondary School Student Transit Pass Pilot Program
Recommendation
The Commission CONFIRM participation in the Secondary School Student Transit Pass Pilot Program scheduled to launch in September 2026.
Background
The concept of a Secondary School Student Transit Pass Pilot program has been the topic of discussion for a number of months. This report provides an overview of the actions taken, and recommendations stemming from discussion between the parties in response to direction from Council at their April1, 2025 meeting as set out below.
At its meeting on April 1, 2025, Council resolved that the following actions be taken:
a) the report dated March 25, 2025 BE RECEIVED;
b) the Civic Administration BE DIRECTED to continue the conversation with the London Transit Commission and Thames Valley District School Board representatives and report back to a future meeting of Strategic Priorities and Policy Committee, with a specific focus on addressing concerns expressed around metrics for success that include the following:
i) metrics for the Thames Valley District School Board, including:
A. Student surveys – capturing direct feedback on their transit experience;
B. Attendance data – is the applicable grade(s) experiencing increase in student attendance compared to prior years;
C. Student achievement data – are the applicable grades showing increased academic achievement result;
D. Experiential data – including increased ability to match co-op placements, increased student participation in extracurricular school activities, and any use of transit for class trips;
ii) metrics for the London Transit Commission, including:
A. Increased ridership – tracking how student usage materializes, grows, or does not over time;
B. Trip patterns – showing when students board and clustered travel times based on card use;
Since April, Civic Administration, TVDSB, and London Transit administration have refined metrics to evaluate the success and impact of the proposed pilot. Additionally, all three parties have provided additional information on available data, limitations, and suggestions for the design and implementation of evaluation activities.
The remainder of this report provides an overview of the discussions and outcomes on each of the points referenced in Council’s direction with respect to program metrics.
Pilot Program Evaluation Plan
The utility of available data is an essential component of the proposed pilot program evaluation. Data utility is defined and described below, to support interpretation and accurate analysis of the proposed evaluation plan.
Definitions of Data Utility for the Pilot Program Evaluation
This is defined as very low, low, medium, or high, according to data availability, validity, and reliability. The definitions of data utility include:
- Very low: Data is not available and/or would be prohibitively difficult to obtain. The data is not valid because it is not relevant, appropriate, or suitable for the evaluation metrics of interest. The data may not be reliable if there are small numbers of respondents, which may yield a biased or non-representative sample. The data available may not be appropriate to be used for the questions that the evaluation aims to answer.
- Low: Data is available but is difficult to obtain. The data has limited validity because there are numerous factors that negatively impact its utility. Data has limited reliability due to the likelihood of errors and is unlikely to produce consistent results over time.
- Medium: Data is available and/or likely can be obtained. The data has acceptable validity and can reasonably be expected to measure the variables of interest. The data is reliable enough to be reflective of the evaluation components of interest.
- High: Data is available and easy to obtain. The data has high validity and is able to reflect the variables of interest. The data is highly reliable because it is free from errors, bias, and is consistent over time.
London Transit Commission Metrics
Ridership
| Description | Measure student ridership over the period of the pilot program |
| Data Utility | Medium |
| Method of Collection | Smart Card tap data |
| Recommendation | Include Ridership assessment in evaluation metrics |
Proposed Methodology
Prepare and provide aggregate, group-level data on the number of pilot-program participants using the transit system during the pilot period.
TVDSB will issue smart card stickers to students broken into two distinct groups; those who are eligible for yellow school bus service, and those who are not. LTC would use smart card data to report on the two groups and identify any difference that may occur with respect to usage of the transit pass.
LTC would track boarding times at the group level, including total number of riders for a given time period, which enables analysis of ridership by time of day and day of week as well as the routes being accessed.
LTC and the City can assess and report on changes in youth bus pass sales from previous years and can compare total number of pass holders for the pilot program time period, to assess whether pilot participants were previously youth bus pass users.
Limitations
There are limitations to the data that is recorded by the smart card system, including:
- Distinguishing between new and previous users: Won’t have access to the necessary data to assess whether pilot program participants were previously youth bus pass users or new users. Can assess this indirectly through student surveys but will not be able to verify through smart card data.
- Inferring causality from pass sales: Will not have sufficient information or data to infer causal link between changes in youth pass sales and the availability of the pilot program.
- Tracking data between grades: Won’t have data to track if same or different students are using free passes between Grades 9 and 10.
Trip patterns
| Description | Analyze when students board and common travel time clusters |
| Data Utility | Medium |
| Method of Collection | Smart Card tap data |
| Recommendation | Include Trip Pattern assessment in evaluation metrics |
Proposed Methodology
Prepare and provide aggregate, group-level data on the routes used and the date/time of boarding. Provide heat maps that would indicate what routes are being utilized by participants.
Limitations
See limitations of smart card system data described above. The most significant limitation to the ridership data is that sharing and using ridership data that is disaggregated to the individual level would contravene LTC policies on data privacy, which do not allow the use of smart card technology or data to track the usage of individual system users. Because of this, the ridership data that LTC is able to share is limited to aggregate data on route usage and date/time of boarding only.
Thames Valley District School Board Metrics
Student surveys
| Description | Collection and analysis of direct feedback from students and caregivers on their transit use and experience. |
| Data Utility | Medium |
| Method of Collection | Pre- and post implementation surveys with students and caregivers |
| Recommendation | Include Pre and Post implementation surveys in evaluation metrics |
Proposed Methodology
The proposed surveys would be designed to answer:
- Whether students report taking transit more often during the Pilot Project and/or more than they would have without a free transit pass.
- The nature of transit use (i.e. regular school day, extra-curricular activities, employment, volunteer activities, social events and activities, shopping or other errands)
- Whether students’ reported attitudes towards city transit are more positive at the end of the Pilot Project.
- Whether students’ reported feelings towards transportation independence are higher at the end of the Pilot Project.
- What barriers students report related to their use of public transit
Limitations
Response rate: The proposed surveys would be voluntary. If the response rate is low, there may be limitations to how the feedback can be presented and utilized. A low response rate may increase the risk of bias, introduce a larger margin of error, and decrease the statistical power of results, meaning that results may not be generalizable to the population as a whole.
Reliability: Survey data is not the most objective way to measure transit usage, compared to methods such as ridership data. If the survey has a low response rate, it may not accurately reflect all riders.
Voluntary response bias: Students/caregivers who choose to respond to the surveys may not be representative of all students/caregivers. For example, those who choose to respond may already ride public transit, have strong opinions, be present at school to participate, or may have more flexibility and time to respond to the survey.
Attendance data
| Description | Monitor whether attendance improves in the applicable grade(s) compared to previous years |
| Data Utility | Low |
| Method of Collection | Student records and survey responses |
| Recommendation | Do not include Attendance data as an evaluation metric due to the limitations in the quality and validity of available data |
Proposed Methodology
Review student attendance in conjunction with the pre- and post-surveys to see whether students who report taking the bus to attend school more often also have increased attendance rates (as demonstrated through attendance records) during the Pilot Project.
Limitations
Lack of valid comparator data: Due to the proposed design of the pilot program, a comparator group (i.e., a group of similar students at a school similar to Clarke Road with similar transportation options) does not exist. Without a comparator (i.e. a “control” group), attendance rates cannot be compared to determine what attendance rates would have been in the absence of the pilot program. Comparator data includes:
- Comparisons to previous years: Comparisons to attendance in previous years is problematic because it is unknown whether current students are similar in key characteristics to students from previous cohorts. Attendance can be affected by many factors that vary from year to year, such as weather, illnesses, program changes, and other variables.
- Comparisons to other schools: Similar to above, comparing attendance of Clarke Rd students who participate in the pilot to students in the same grade at a different school who are not in the Pilot would involve comparing different groups of students with different experiences and circumstances (e.g., socioeconomic and demographic factors, commute times, bus routes, program offerings, etc.).
- Comparisons across the school year: Comparing attendance rates from September (before the Pilot) to later in the year (during the Pilot) would be undermined by differences in the time of year and the fact that students would be taking different courses and have different schedules across semesters, which also influences attendance rates.
- Comparisons to other grades: Comparing attendance rates across grades would involve comparing different groups of students with different experiences. At a district level attendance rates vary across grades. This may be due to additional responsibilities, class schedules (spare periods, co-op placements, etc.), and other factors.
Confounding factors: Other confounding factors will make it difficult to accurately assess the influence of the pilot program on attendance rates. These factors include:
- Attendance improvement programs: The Ministry of Education’s Student Achievement Plan and TVDSB’s Multi-Year Strategic Plan both focus on attendance. Other, concurrent initiatives aiming to improve attendance will be underway at the same time as the pilot program. This will make it difficult to determine the impact of the Pilot on attendance.
- Using survey data to assess impact on attendance: Comparing attendance rates for students who report on the survey that they take transit the most compared to those who report taking transit the least would be confounded by other factors impacting attendance rates. For example, students with high attendance rates not taking transit may have a parent/caregiver who drives the student to school as needed.
Student Achievement data
| Description | Track academic performance in the applicable grade(s) to identify increases in student achievement. |
| Data Utility | Very Low |
| Method of Collection | Student records |
| Recommendation | Do not include Student Achievement data as an evaluation metric due to the limitations in the quality and validity of available data |
Proposed methodology
Review student achievement in conjunction with responses on the pre- and post-surveys to see whether students who report taking the bus to attend school more often also have higher student achievement (as demonstrated through report card records) during the Pilot Project.
Limitations
Similar to the limitations of attendance data, the validity and quality of student achievement data would be comprised by lack of comparator data. Limitations include:
- Comparisons to previous years: As above, comparisons may be influenced by other factors including different courses, different teachers/teaching strategies, changes in programming, and other factors.
- Comparisons to other schools: As above, comparisons may be influenced by other factors. These may include differences between schools such as teachers/teaching strategies, programming, and other factors.
Experiential Data
| Description | Assess use of transit passes for participation in extracurricular activities, volunteer activities, employment, and class trips. |
| Data Utility | Medium |
| Method of Collection | Pre- and post- implementation surveys with students and caregivers, student records |
| Recommendation | Include Experiential data as an evaluation metric |
Proposed Methodology
Collect experiential data as part of the Student Surveys (see above). The proposed surveys would ask whether students who receive transit passes use them to participate in school extra-curricular activities, external extra-curricular activities, employment, volunteer activities, social events and activities, and shopping or other errands. The proposed surveys will also be designed to assess whether students think the pilot program helped them participate in these activities more often, and if so, how. TVDSB would also collect data related to the use of transit for class trips from school administration.
Limitations
Same limitations apply as for the student surveys (see above). Small numbers of students participating in some experiential activities in Grades 9 and 10 may make a potential increase in the use of transit for these activities difficult to see. For example, students starting Grades 9 and 10 tend to be 14-15 years old and the number of students with part-time jobs is significantly lower than for students in higher grades. Co-op courses are not available until Grade 11 and 12, so participation in Co-op placements cannot be measured for this population.
Next Steps
Subsequent to approval to proceed by the LTC and the TVDSB, a report will be presented to the Strategic Priorities and Policy Committee which will include the recommended evaluation criteria for the pilot program, the estimated financial impacts, and a Memorandum of Understanding (MOU) between the three parties for execution subsequent to Council approval of the pilot program.
The following provides a high level summary of the responsibilities of each party, with greater discussion following specific to the roles and responsibilities of London Transit.
Responsibilities of the City of London:
- funding the two-year pilot project and executing the Funding agreement;
- reporting to City Council on the progress of the Pilot Project;
- cooperating with the TVDSB in identifying sustainable funding sources for the program if necessary.
Responsibilities of the TVDSB:
- identifying program participants;
- distributing transit passes to program participants;
- designing and implementing evaluation activities;
- managing communications with secondary school students, caregivers, and/or guardians on how to use the passes and the public transit system in London;
- managing transit pass distribution and protocols for dealing with lost or damaged passes;
- identifying sustainable funding sources for the program, if necessary.
Responsibilities of the London Transit Commission:
- establishing a new fare category through the Smart Card system for the purpose of the pilot;
- managing the administration and operation of the Smart Card system;
- providing regular reporting to the City of London and TVDSB on ridership and usage of passes in this program;
- co-operating with and supporting the TVDSB with its training and education for students, caregivers, and/or guardians on how to use the public transit system in London.
Once the MOU is executed, the following specific actions will be required from London Transit, and will be incorporated into the Commission’s annual Work Programs:
- arranging for the update to the smart card system to allow for the tracking of the defined groups participating in the pilot program;
- arranging for the procurement of stickers capable of interface with Smart Card readers, which will be adhered to Student ID cards of those students participating in the program;
- testing stickers in advance of program launch to ensure they perform in the manner required;
- providing TVDSB with materials relating to expected behaviour while riding public transit that can be disseminated to students participating in the pilot program; and
- ensuring that all required reporting capabilities are in place prior to the launch of the program in September 2026
Administration will continue to provide updates on this program as applicable going forward.
Recommended by:
Mike Gregor, Director of Finance
David Butler, Manager of Operations Administration
Katie Burns, Director of Planning
Concurred in by:
Kelly S. Paleczny, General Manager