Staff Report #4
September 15, 2026
To All Members of the Accessible Public Transit Service Advisory Committee
Re: Service Animal Policy
Recommendation
That the Committee RECOMMEND the updated Service Animal Policy to the Commission for approval.
Background
The Accessibility for Ontarians with Disabilities Act Integrated Standards Regulation includes a requirement for organizations providing service to the public to accommodate the use of service animals and support persons. The specific section of the regulation is set out below.
Use of service animals and support persons
80.47 (1) This section applies if goods, services or facilities are provided to members of the public or other third parties at premises owned or operated by the provider and if the public or third parties have access to the premises. O. Reg. 165/16, s. 16.
(2) If a person with a disability is accompanied by a guide dog or other service animal, the provider shall ensure that the person is permitted to enter the premises with the animal and to keep the animal with him or her, unless the animal is otherwise excluded by law from the premises. O. Reg. 165/16, s. 16.
(3) If a service animal is excluded by law from the premises, the provider shall ensure that other measures are available to enable a person with a disability to obtain, use or benefit from the provider’s goods, services or facilities. O. Reg. 165/16, s. 16.
(4) If a person with a disability is accompanied by a support person, the provider shall ensure that both persons are permitted to enter the premises together and that the person with a disability is not prevented from having access to the support person while on the premises. O. Reg. 165/16, s. 16.
(5) The provider may require a person with a disability to be accompanied by a support person when on the premises, but only if, after consulting with the person with a disability and considering the available evidence, the provider determines that,
(a) a support person is necessary to protect the health or safety of the person with a disability or the health or safety of others on the premises; and
(b) there is no other reasonable way to protect the health or safety of the person with a disability and the health or safety of others on the premises. O. Reg. 165/16, s. 16.
(6) If an amount is payable for a person’s admission to the premises or in connection with a person’s presence on the premises, the provider shall ensure that notice is given in advance about the amount, if any, payable in respect of the support person. O. Reg. 165/16, s. 16.
(7) If, under subsection (5), the provider requires a person with a disability to be accompanied by a support person when on the premises, the provider shall waive payment of the amount, if any, payable in respect of the support person’s admission to the premises or in connection with the support person’s presence on the premises. O. Reg. 165/16, s. 16.
(8) Every provider, other than a small organization, shall prepare one or more documents describing its policies with respect to the matters governed by this section and, on request, shall give a copy of any such document to any person. O. Reg. 165/16, s. 16.
(9) Every provider, other than a small organization, shall notify persons to whom it provides goods, services or facilities that the documents required by subsection (8) are available on request. O. Reg. 165/16, s. 16.
(10) The notice required by subsection (9) may be given by posting the information at a conspicuous place on premises owned or operated by the provider, by posting it on the provider’s website, if any, or by such other method as is reasonable in the circumstances. O. Reg. 165/16, s. 16.
“guide dog” means a guide dog as defined in section 1 of the Blind Persons’ Rights Act; (“chien-guide”)
“service animal” means an animal described in subsection (4); (“animal d’assistance”)
“support person” means, in relation to a person with a disability, another person who accompanies him or her in order to help with communication, mobility, personal care or medical needs or with access to goods, services or facilities. (“personne de soutien”). O. Reg. 165/16, s. 16.
(4) For the purposes of this Part, an animal is a service animal for a person with a disability if,
(a) the animal can be readily identified as one that is being used by the person for reasons relating to the person’s disability, as a result of visual indicators such as the vest or harness worn by the animal; or
(b) the person provides documentation from one of the following regulated health professionals confirming that the person requires the animal for reasons relating to the disability:
(i) A member of the College of Audiologists and Speech-Language Pathologists of Ontario.
(ii) A member of the College of Chiropractors of Ontario.
(iii) A member of the College of Nurses of Ontario.
(iv) A member of the College of Occupational Therapists of Ontario.
(v) A member of the College of Optometrists of Ontario.
(vi) A member of the College of Physicians and Surgeons of Ontario.
(vii) A member of the College of Physiotherapists of Ontario.
(viii) A member of the College of Psychologists of Ontario.
(ix) A member of the College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario. O. Reg. 165/16, s. 16.
In compliance with this regulation, London Transit has the following policy in place.
Service animals are permitted on buses if working in aid of the person making the trip.
Service animals on buses must remain in the care and control of the owner at all times. The owner must be prepared to demonstrate to the Operator how this requirement will be achieved (i.e. leash, cage, etc.).
This applies as follows:
- the animal can be readily identified as one that is being used by the person for reasons relating to the person’s disability, as a result of visual indicators such as the vest or harness worn by the animal; or
- the customer provides documentation from a health professional confirming that the person requires the animal for reasons relating to the disability.
As the result of issues relating to service animals on-board that had not been trained on behaviour in public places, this policy was updated to include the requirement that service animals on buses must remain in the care and control of the owner at all times. For the most part, this addition has mitigated issues on-board transit vehicles with respect to service animals.
Over the past summer a transit customer formally complained about the fact that her service animal (large black dog), was not being allowed to sit on the seat next to her while she rides the bus. While it is an LTC expectation that large animals that cannot be accommodated on the lap of the rider would remain on the floor, this expectation is not clearly articulated in the policy.
This issue highlighted the need for a review of the current service animal policy to ensure expectations are clear to all parties. Administration undertook a review of the service animal policies in place at other Ontario transit systems in an effort to identify best practices that may be incorporated into an updated Service Animal Policy for London Transit services.
In addition to the review, Administration received a communication from a previous member of APTSAC who asked that their commentary be shared as part of this report (see Enclosure II).
A number of provisions included in other policies are being suggested for inclusion in the revised London Transit Service Animal Policy, each of which is discussed in greater detail below.
- All animals travelling on London Transit services must:
- Be up to date on all necessary vaccinations and be free of any communicable diseases; and
- Be non-aggressive, well-behaved and respond to the instructions of the customer
The addition of this requirement will provide greater assurance to customers with guide dogs that the other animals on board the vehicle will not interfere with their trained dog.
- Seats are allocated for customers, service animals/guide dogs/emotional support animals are welcome to sit on the floor beside the customer, or on the customer’s lap.
The addition of this requirement will provide greater clarity with respect to the expectation that animals remain on the floor and do not take up a seat on transit vehicles.
- Animals showing signs of aggression and those who cause disruption will not be allowed to board London Transit vehicles.
This provision provides London Transit with the ability to ban a service animal from the service in the event they are not compliant with these expectations.
- Exceptions to these requirements will be considered by London Transit on a case-by-case basis.
This clause provides the flexibility required for accommodation of a specific need that may be presented. In this case, supporting medical documentation would be required to demonstrate the rationale for why the exception is required. Details with respect to who to contact for an exemption will be included on the corporate website.
The updated Service Animal Policy, including the aforementioned additions is set out in its entirety in Enclosure I. Feedback from APTSAC will be incorporated into the report to the Commission recommending the amendments.
Enclosures
I – Updated Service Animal Policy
II – Contact Regarding Current Service Animal Policy
Recommended by:
David Butler, Director of Operations – Conventional
Shawn Wilson, Director of Operations – Specialized
Concurred in by:
Kelly S. Paleczny, General Manager