Staff Report #6 – Secondary School Student Transit Pass Pilot Program

Staff Report #6

May 29, 2024

To All Commissioners

Re: Secondary School Student Transit Pass Pilot Program


That the report be NOTED and FILED.


At the April 23, 2024 meeting, Municipal Council passed the following motion:

That the following actions be taken with respect to establishing a secondary school student transit pass pilot project:

  1. The Civic Administration in collaboration with the London Transit Commission BE DIRECTED to initiate the development of a Memorandum of Understanding (MOU) with the Thames Valley District School Board (TVDSB), for the purpose of partnering to deliver a pilot project to provide annual transit passes to secondary school students at Clarke Road Secondary School, including the following:
  2. The pilot project BE LIMITED to school years beginning in September 2024 for all Grade 9 students and September 2025 for all Grade 9 and 10 students attending Clarke Road Secondary School;
  3. The current post-secondary student annual transit pass agreements between the City of London, Western University and Fanshawe College and the current Children Under 12 Ride Free program BE CONSIDERED as templates to establish the framework for the pilot program;
  4. The Civic Administration BE DIRECTED to report back to Council with the MOU, an appropriate source of financing, and metrics reporting for the pilot program;

It being noted that the TVDSB has written the Minister of Education to ask for consideration for provincial funding support for a bussing pilot. Additionally, continuing the program beyond the pilot project would require a permanent source of ongoing operating funding from a variety of sources, including reallocation of funding or funding from senior levels of government that would need to be investigated.

At the Commission’s April 24, 2024 meeting, a verbal update was provided which outlined a number of outstanding questions and potential issues with respect to this initiative that would need to be answered/addressed prior to completing a Memorandum of Understanding (MOU) for Commission consideration. The remainder of this report provides commentary on these items.

Pilot Program Objective

The standard structure for a pilot program requires a number of key elements in order for the program to run as expected and collect the appropriate data/metrics required to measure success against the program objective. Neither the report approved by the TVDSB nor the motion approved by Municipal Council’s articulate the underlying objective of the pilot program. Until such time as a clear objective is identified, it is impossible to determine the metrics that will be measured and reported on to determine whether the pilot has been successful. Potential benefits of the program have been communicated; however, not to the extent that provide the clarity required to develop actual measures.

By way of example, one of the potential benefits discussed is an increase in transit ridership; is this an increase in usage rates measured against the usage rate of other high school students who purchase a $72 monthly pass which would provide insight into whether the provision of a free pass results in higher usage; or is it to measure whether students provided with a free pass will use transit where they hadn’t previously? Another potential benefit is that attendance at school will improve as students with this pass will have another option should they miss the yellow bus; will this be measured against historical data from a similar sample group at the same participating school (e.g. previous year’s grade 9 cohort), and if so, what other factors could impact attendance rates in the comparison years? Finally, another potential benefit is improved access to the community for students with the free pass; will this be measured against what access the participating group would have had without the free pass, and if so, how will this be measured?

Reference has also been made to other programs of this nature that have been successful in other municipalities; however, it is important to understand the varying elements of these programs as well as the operating conditions of the transit system. In the case of the Kingston program, it was established at a time when ridership on the conventional service was extremely low. The program was launched under the pretence that the service in operation had significant capacity, so additional ridership generated from the program would potentially fill empty buses, but not be such that additional service hours would be required. While the program has been successful in increasing ridership, the limited transportation revenue that is collected from the paying riders places increased reliance on the municipality for funding of any growth in services. In addition, the school boards in Kingston have continued to offer yellow bussing twelve years after the introduction of the pilot, resulting in a duplication of service for the cohort group, both at a cost to taxpayers. It is the understanding of administration that the Kingston program is currently under review given issues with the funding model and the ability to respond to service demands within available budgets.

While it has not been confirmed, it is the understanding of administration that the TVDSB has no intention of adjusting yellow bussing during the period of the pilot program and as such there will be no ability to determine whether a shift to a city-wide transit pass program for high-school students could result in a reduction in the requirement for yellow bussing. In other municipalities, agreements have been set between school boards and transit systems for the provision of “school specials” which are essentially additional buses running before and after school to transport students instead of yellow bussing. In these agreements, the school board provides funding for the additional transit service rather than directing the funding to yellow bussing. In the event that a school board is able to reduce the costs of yellow bussing, but do not contribute in any way to the cost of the public transit delivery or any reduced fares associated with the program, the municipality would be taking on transportation costs that are currently covered by the Provincial government, in effect accepting downloading of costs to the municipal tax base.

If an objective is to determine whether the provision of free transit to a specific group will result in a future transit rider, consideration will need to be given to a follow up survey in 2026 with the two participating cohorts to determine whether they have chosen to purchase a Youth transit pass in the year subsequent to the pilot program. This undertaking would need to be done by the school board as they would have direct access to the students involved in the pilot program.

Determining the underlying objective(s) of the pilot program will be a key initial step in the discussions between the parties in order to ensure the program is structured around measuring success against the objective and to provide clear expectations for each of the parties involved as to the role they will be expected to play for the duration of the program.

Pilot Program Funding

The motion from Council requires a report back which includes the identification of an appropriate source of funding for the program. Prior to identifying a source of funding, the “cost” of the program needs to be determined. The motion from Council stipulates two agreements that should be utilized as templates for the MOU; however, the templates provided operate in very different manners. The tuition pass programs in place with Western University and Fanshawe College require every full time student that is registered at either institution to pay an annual fee for a transit pass whether they use it or not. This type of program is referred to as a “universal” program in that the pricing is established based on the collective transit usage (i.e. those that do not use transit are offsetting those who use it very frequently as they are all paying the same price). From a revenue perspective, the goal of a program of this nature is to balance the percentage of transit usage (ridership) of the group with the percentage of revenue collected from the universal fees. In 2023, tuition pass holders represented approximately 54% of ridership and the revenue collected from the program represented approximately 45%. These contracts are established in a manner that includes annual increases to the fee and are typically re-negotiated every three years providing the opportunity for adjustments required to maintain the ridership to revenue balance. Estimating usage levels and impact on revenue for the high-school pilot will be extremely difficult given the limited available information regarding the participating cohort; however, regardless of the manner in which the cost of the program is determined, a survey of participating students with respect to prior transit usage will be required in order to establish baseline data.

The agreement in place between the City of London and London Transit regarding the free transit for children 12 and under requires the City of London to provide a “grant” to London Transit of $1.53 for every ride taken by a child 12 and under. This program is similar in nature to the other grant programs provided by the City of London (free rides for blind, discounted youth and low income passes, and discounts for youth and senior tickets), in which the grant is established in an effort to make London Transit whole on the fare collected. The basis of these programs is to recognize that the cost associated with subsidizing a specific group of transit riders with a reduced/free fare is a social service cost versus a cost of delivering transit. As such, all requests for discounted fares are referred to Social Services/Municipal Council for consideration during budget deliberations. Should this model be utilized for the MOU, the City of London would provide a grant of $2.12 per trip taken, which is the current youth ticket fare.

In addition to the lost revenue associated with the pilot program, additional costs will be incurred for the establishment of a ridership tracking mechanism. London Transit will require the smart card contractor to establish a new fare category for the pilot cohort in order to be able to track the usage levels specific to this group. The costs associated with this initiative cannot be determined until such time as the manner in which the passes will be created has been determined.

London Transit administration will be recommending a pass identification program similar to that which is in place for those participating in the tuition program for fare payment. Photo ID cards that are capable of interfacing with the smart card system will need to be issued to all participants and include the participating school and student name. This approach will mitigate potential fare fraud associated with students sharing/selling the free pass with others that are not part of the pilot program. Should the Operator question whether the rider is misusing the pass, the pass holder will be asked to show the ID card with the photo.

Pilot Program Impact on Provincial Gas Tax for Transit Allocations

Assertions have been made in relation to the potential for the ridership generated from a program of this nature to increase the annual allocation of Provincial Gas Tax for Transit (PGT) that London receives, which will help to offset the cost of the program.

The PGT program provides an annual allocation of funds ($0.02 from every litre of fuel sold in the Province in the previous year), which is split between all transit systems in the province based on a formula of 30% population in the municipality being served and 70% on the ridership from the transit system. Given this methodology, the only way in which a municipality can receive a higher share of the fund, is to have the combination of population and ridership increase at a higher rate than those municipalities currently receiving a greater share of the total allocation. The table below provides a summary overview of the allocations received for the 2023/24 PGT program in terms of percentage.

2023/24 Provincial Gas Tax for Transit Allocations

System 2022 Ridership 2023/24 PGT Allocation % of PGT Allocation
Toronto 318,752,997 $ 178,222,229 47%
Ottawa 50,193,632 33,061,834 9%
Mississauga 35,672,982 23,363,091 6%
Brampton 31,314,940 21,064,218 6%
York Region 16,027,350 17,776,683 5%
Waterloo Region 17,783,913 13,772,622 4%
Hamilton 15,216,361 12,389,845 3%
London 13,366,417 10,158,287 3%
Durham Region 7,304,593 9,633,396 3%
All Others 70,759,289 57,809,187 15%
Total 576,392,474 $ 377,251,392 100%

The ridership in all systems for 2022 was still negatively impacted by the pandemic, and significant increases have occurred in all systems in 2023 (which will be utilized for the next round of PGT allocations). Assuming population growth across the municipalities in the table above remains consistent, London would need to see growth in ridership exceed rates in Hamilton, Waterloo Region, York Region, Brampton and Mississauga, all of whom have seen incremental investments in service at rates 3 to 7 times that which has been approved for London for 2024.

Pilot Program Impact on Ridership

The other potential costs to London Transit from a revenue perspective is any ridership/revenue losses that may occur as the result of the additional pressure placed on routes that will potentially be utilized by students attending Clarke Road Secondary School, resulting in current paying riders being unable to rely on transit to get them to their destination when they need to be there. This is particularly problematic during morning and afternoon peak periods when many transit riders are utilizing the service to get to and from work.

Subsequent to the approval of the council motion, London Transit administration reached out the TVDSB representatives for further information with respect to the catchment area for Clarke Road Secondary School in an effort to gain a better understanding of what routes may be impacted by the ridership generated from this pilot program. Based on the catchment maps provided the following heat maps have been created to illustrate the current load levels during morning and afternoon peak periods on routes which have the potential to be impacted by students participating in this pilot program (see Enclosure I). The pink highlighted area on the maps represents the English catchment area for Clarke Road Secondary School, and the grey area represents the Tech-Emphasis catchment area, both of which it could be expected that students would travel from to attend school.

It is important to recognize that students will be attempting to utilize routes near their home to start/finish their day, and ridership from this program will not be limited to the routes/buses directly adjacent to Clarke Road Secondary School. Routes that could be impacted by this pilot program include Routes 1, 2, 3, 4, 5, 6, 7,10, 13,15,16,17, 20, 24, 35, 38, 90, 91, 92, 94, 95, 102, 104, and 106.

Based on the assessments outlined in the maps, the routes that are most concerning with respect to available capacity are routes 2, 10, 13, and 17; however, it should be noted that regardless of the routes impacted, there are no available resources in the 2024 budget to implement any service adjustments to address issues in the short term.

While it is not possible to predict when and where the actual ridership relating to the pilot program will occur, it is important to recognize that there will be no ability to respond to increased crowding/schedule adherence issues on impacted routes for the first year of the pilot noting that service changes are implemented in the fall of each year and consideration of changes to existing service levels/schedules is based on the previous year’s data.

While the maps in the enclosure illustrate the state of service during morning and afternoon peak periods, many routes are experiencing issues on weekends. Given this pilot program would provide access to London Transit during all operating hours, there is also the potential for this program to place additional pressure on already crowded routes with students utilizing the service for weekend activities.

The Toronto Transit Commission (TTC) just approved a pilot program for free transit for Grade 7 to 12 student field trips. In light of concerns with respect to capacity, the program will be limited to Monday through Friday between 9am and 3pm on routes operating at frequencies of 10 minutes or better, with some additional restrictions based on group size. This is an example of a pilot program that has given consideration to the state of the service in operation and has put parameters in place in an effort to mitigate negative impacts of the pilot on other riders. The pilot program at TTC will be assessed after one year and it will be determined whether to extend the program based on any service, financial and operational implications.

Given the uncertainty with respect to ridership impacts of this program, the MOU should provide the opportunity to amend/cancel the second year of the program based on experience in the initial year.

Pilot Program Start Date

The motion from Municipal Council sets out expectations for the pilot program to begin in September 2024 to commensurate with the beginning of the academic year. Given the number of program elements that need to be clarified, coupled with the time and resource requirements to put them in place, it may be prudent for the parties to consider a later start date. Given the understanding that there are no plans on behalf of the TVDSB to reduce access to yellow bussing for the students involved in the pilot program, there will be no negative impact to the students participating in the program if the program were to start later in the academic year. This will be an important consideration of the parties as discussions progress, noting from an LTC perspective, resources that would be dedicated to this initiative are currently working on other critical issues on the Commission’s annual work program including the rollout of smart cards on the specialized service.

Additionally, consideration should be given to postponing the launch of this pilot program until such time as improvements on the conventional service have been implemented that will address the current crowding and schedule adherence issues.

Other Issues/Items to be Addressed

A number of transit systems that have implemented programs with this age group have experienced issues on board buses with respect to behaviour and fare compliance which have resulted in negative experience for other transit users. The problem has become so significant that it was the topic of a session at the recent Ontario Public Transit Association conference, with systems sharing experiences and best practices with respect to dealing with the issues. The recent pilot program approved by the TTC incorporates expectations for the participating school boards to provide an education module to develop student skills, confidence, etiquette and fare compliance when riding the TTC. This material must be reviewed by teachers/students prior to accessing the TTC for field trips. London Transit administration will be seeking a similar commitment from the TVDSB for all students participating in the pilot program. London Transit has first-hand experience with issues of this nature going back to when the free transit for children 12 and under program was launched. Rider behaviour while on board was a significant issue in addition to many utilizing the service for extremely short distances (boarding at one stop and alighting at the next), resulting in operational slowdowns. Both of these behaviours resulted in numerous complaints from other transit riders and required significant London Transit resources to be stationed at problem areas to speak with offenders as well as to have multiple meetings with school principals in the most affected areas in an effort to seek assistance in mitigating the poor behaviours.

Additionally, unsanctioned sharing/use of the student pass by others who are not part of the pilot program will need to be closely monitored and managed. The expectation will be that a student card issued for the purpose of the pilot program that is used by anyone other than the student pictured on the card will be confiscated by London Transit, and repeated offences will result in the student being banned from the program.


Increasing transit ridership is a key objective in London Transit’s Business Plan as well as in the City of London Strategic Plan and the current work underway in updating the City of London Mobility Master Plan. A key consideration in any ridership growth program assessment is the ability of the service to accommodate any increased ridership resulting from the program. A long standing and well supported fact about transit riders is that they will pay for and utilize a service that is affordable, safe and reliable and operates at frequencies that allow them to complete their trip in relative close comparison to that made by other modes. It is also proven that riders who have a poor experience on transit are less likely to try it again, and further, once a rider has made an alternative travel arrangement due to unreliable transit service, it is extremely difficult to get them back on transit. As such, it is imperative that programs intended to increase transit ridership are carefully planned to coincide with the capacity of the service to accommodate the growth.

In addition, the financial sustainability of new programs must be considered prior to implementation. The establishment of a pilot program with a one-time temporary source of funding is not ideal in that, should it be successful, a permanent source of funding will need to be identified to keep it in place. A program that increases overall ridership through waiving fares will, if successful, place additional burden on the tax base as any growth in service required to accommodate the new riders will need to be funded in part by the municipality. In the case of free ridership, this growth is subsidized at a higher rate by the municipality given there is no source of revenue associated with the trip.

Public transit services in Ontario have three main sources of funding; revenue from the rider, PGT allocations, and the municipal tax base. As this report set out earlier, increased revenue from the PGT is unlikely given the rates at which other municipalities are investing in growth in their services, and as such, when fares are waived for a specific group, the rate of contribution from the municipality must increase. Pressures on the municipal tax base are not anticipated to diminish over the coming years, and as such, considerations should be given to whether the dollars available for investment in public transit services should be directed toward overall service improvements that will benefit all riders or to offset fares for a select group of riders in efforts to increase ridership.

As mentioned earlier in the report, there are a number of issues/concerns that need to be discussed between the parties relating to this pilot program, perhaps the most concerning being the capacity for the system to accommodate the new ridership without negatively impacting other riders who are paying a fare. While it has been proven in other jurisdictions that programs of this nature can be successful, they have been in cases where the transit system had demonstrated capacity to accommodate the new riders.

London Transit administration will be meeting with civic administration and representatives from the TVDSB in the coming weeks to begin discussions relating to a pilot program as set out in the recommendation approved by Municipal Council and will be raising the issues/concerns identified in this report. Updates will be provided to the Commission as they are available.


I – Average Load by Stop in Clarke Road Secondary School Attendance Area (AM and PM periods)

Recommended by:

Mike Gregor, Director of Finance

Katie Burns, Director of Planning

David Butler, Manager of Operations Administration

Concurred in by:

Kelly S. Paleczny, General Manager