Alliance for Equality of Blind Canadians
L’Alliance pour l’égalité des personnes aveugles du Canada
Janet Hunt, Chapter President
Response to Discussion Paper on AAC Recommendations for the Transportation Accessibility Standard
The Winnipeg Chapter of the Alliance for Equality of Blind Canadians (AEBC) is pleased to provide feedback and comments on the AAC recommendations for the Transportation Accessibility Standard.
AEBC is a national grassroots, peer support organization that is comprised of Canadians who are blind, deafblind or partially sighted and our supporters from the public at large.
Overall we are pleased with the Councils recommendations. We do have a few areas of concern, and as you will see by our comments, there are several areas where we would appreciate further clarification. As our organization is made up of persons who are blind, deafblind and partially sighted, we will limit our comments to areas we feel are of particular relevance to our community.
Throughout the discussion paper, it states that information is to be provided in alternate format such as large print or posted online upon request. As per the Customer Service Standard, all information posted online is required to be in accessible formats. We recommend that this be stated in the Transportation Accessibility Standard as well, and that alternate formats such as large print or Braille be made available upon request in a timely manner.
As the standard addresses making transit infrastructure more accessible, we recommend it also address bus stop poles. Currently it is difficult for a vision impaired person to differentiate between a bus stop sign and a parking sign. We recommend a tactile mark be used consistently to identify bus stop poles
We have reviewed the proposed Transportation Accessibility Standard in its entirety, and our comments and questions are as follows:
2. Purpose and Application
(1) This Regulation applies to all public transportation service providers and municipalities with vehicles for hire that operate in Manitoba.
(2) Designated public sector organizations that are not primarily in the business of transportation, but that provide transportation services, shall provide accessible vehicles or equivalent services upon request.
Comment: Does this apply to school boards or private organizations such as assisted living facilities?
(1) All organizations identified in section 2 must comply within three years of this Regulation coming into force.
Question: Is this an adequate timeframe considering that new vehicles may need to be purchased, older vehicles retrofitted, or potential changes needed to transportation infrastructure?
Comment: This timeframe seems reasonable.
MEASURES, POLICIES AND PRACTICES
4. Barrier-free access to transportation
Every obligated organization must develop and implement measures, policies and practices respecting barrier-free access to the transportation services or infrastructure it provides to meet the requirements set out in this Regulation.
Comment: We recommend including the consultation of service users in this process.
5. Documentation of accessible policies and information
Comment: As stated previously and as per the Customer Service Standard, all information posted online is required to be in accessible format. We recommend that this be reflected here, and that alternate formats such as large print or Braille be made available upon request in a timely manner.
6. Accessibility training
(1) In addition to the training requirements set out in the Customer Service Standard Regulation, conventional transportation service providers and paratransit service providers must ensure that accessibility training is provided to the following persons:
· a person who provides front line service directly to the public on behalf of the provider, including employees, agents and volunteers;
· a person who participates in or is responsible for the development or implementation of the transportation providers measures, policies and practices;
· a person involved in the procurement of transportation equipment on behalf of the provider.
Comment: We are pleased that front line staff and those involved in the procurement process are specifically included to receive training.
We recommend that web designers be included for training as well to ensure ongoing website accessibility
(2) The training must include instruction on
· the safe use of accessibility equipment and features;
· acceptable modifications to procedures in situations where temporary barriers exist or accessibility equipment on a vehicle fails; and
· emergency preparedness and response procedures that provide for the safety of persons with disabilities.
Comment: We recommend (as per the Customer Service Standard) reinforcing in this section that persons with disabilities have the right to be treated with dignity and respect.
(3) The design of training tools must include consultation with disability organizations and key industry stakeholders, and training modules should be updated according to policy and equipment changes.
Comment: we recommend consultations include service users as well as stake holders and disability organizations.
(4) A provider must ensure that
· training is provided to a person as soon as reasonably practicable after the person is assigned the applicable duties; and
· on-going training is provided in connection with changes to the providers related measures, policies and practices.
Comment: We endorse the practice of on-going training.
(5) Conventional transportation service providers and paratransit service providers must document their training policy, including a summary of the content of the training and when training is to be provided.
Comment: We recommend including accountability in the training module. Currently service users are subject to rules and policies with penalties for non-compliance. In our experience, paratransit service providers are not adequately holding drivers accountable for not following policies and procedures. For example, vision impaired clients rely on paratransit drivers to make their presence known. When drivers refuse to enter a building or knock on a door, vision impaired clients are not only stranded without a ride, but are usually penalized for being a no show.
We also recommend that training information be made available to the public upon request in the interests of accountability.
7. Emergency preparedness and response policies
Question: Is it feasible for transportation providers to publicly display emergency preparedness and response policies in all service vehicles, or is it adequate to note where these can be found online?
Comment: We endorse that it is adequate to note where the information can be found in an accessible format online.
8. General responsibilities
(1) Conventional transportation service providers and paratransit service providers shall · give priority to persons with disabilities when loading the vehicle;
· deploy lifting devices, ramps or portable bridge plates upon the request of a person with a disability; · ensure that adequate time is provided to persons with disabilities to · safely board a transportation vehicle,
· be secured on a transportation vehicle, and
· exit a transportation vehicle.
· upon request, provide assistance to an individual with disability with · Safely boarding a transportation vehicle,
· Securing themselves to a transportation vehicle, and · Exit a transportation vehicle when safe to do so.
· assist with safe and careful storage of mobility aids or mobility assistive devices used by persons with disabilities; · allow a person with a disability to travel with medical equipment;
· conventional and on-demand transportation service providers shall, upon request, make this information available in an accessible format; and
· hold at least one accessible public meeting annually involving persons with disabilities to ensure that they have an opportunity to participate in a review of the providers measures, policies and practices and that they are given the opportunity to provide feedback.
Question: Should service providers (for example, bus drivers) be expected to assist passengers with disabilities?
Comment: We recommend that drivers provide reasonable assistance to disabled passengers.
We question whether it is appropriate to address in one section how to provide assistance on both Conventional and paratransit service providers as the type or extent of assistance would likely differ. We recommend they be dealt with separately.
While we endorse the responsibilities listed in this section, they do not address communication of information which is most important for vision impaired passengers. We recommend that drivers also offer verbal assistance such as whether all passengers have disembarked and it is safe to board the bus, locating an available seat, and announcing the stops if the automatic announcements are not working properly.
9. Non-functioning accessibility equipment
(1) All accessibility equipment used on conventional transportation and paratransit vehicles shall be functional at all times.
(2) Vehicles with non-functioning accessibility equipment shall not be placed in service.
(3) A preventative maintenance and testing program must be in place to ensure proper function of accessibility equipment.
(4) If the accessibility equipment on a vehicle is not functioning, conventional transportation service providers and paratransit service providers shall
· take reasonable steps to accommodate persons with disabilities who would otherwise use the equipment and the transportation service. Ramps must be deployed manually by vehicle operators when safe to do so. Where accessibility equipment is non-functional, alternative service shall be arranged; · repair the equipment as soon as possible; and
· describe their procedures for dealing with accessibility equipment failures on their respective types of vehicles and have this available upon request in an accessible format.
Question: Is it reasonable to expect vehicle operators to deploy equipment like ramps manually?
Comment: We feel it is reasonable for vehicle operators to be trained in the manual deployment of equipment in the case of an emergency. We assume that since vehicles with malfunctioning equipment are to be taken out of service, this should only occur if the equipment breaks down while in transit and passengers would need to disembark.
We recommend including the provision of drivers announcing the stops when automatic announcements malfunction on conventional transportation.
10. Transition, existing contracts and vehicles
Comment: We recommend a timeframe of 3 to 5 years.
11. Alternative accessible method of transportation
Question: How would this section impact rural areas?
Comment: In areas outside the city limits without para transit services, private companies and other organizations could be contracted to provide these services.
Comment: We support the sections referring to fare structure.
15. Transit stops, boarding and exiting
Comment: While we endorse the section on transit stops, we would like to draw attention to Winnipegs second bus policy.
Currently if one bus pulls up behind another, the second bus is not required to stop at the bus stop. This creates undue hardship for vision impaired passengers who may not be aware a second bus has pulled up. Even with external announcements, on busy streets they may not be heard amid traffic and other ambient noise. While drivers may be encouraged to watch for disabled persons waiting at the stop, a disabled person may be obscured from the drivers view if the stop is crowded.
We recommend that the standard include the policy that every bus be required to stop at the designated bus stop.
(1) When the official stop is not accessible, operators of a conventional transportation service provider may determine the closest available safe location along the same transit route for persons with disabilities to safely board or exit a transportation vehicle.
(2) In determining where a safe location may be situated, the conventional transportation service provider shall give consideration to the preferences of the person with a disability.
Comment: In this section as well, communication between drivers and vision impaired passengers is very important. If for any reason the driver cannot stop at the designated bus stop, the passenger needs to be informed. This would also apply to temporary bus stops regardless of how long the regular stop has been out of service.
We endorse that when a stop is unexpectedly inaccessible, the driver and passenger will mutually determine the best alternate location.
16. Storage of mobility aids and medical devices
Question: The Ontario Accessible Transportation Standard review found that the size of mobility devices was an issue and recommended coordinating outreach to ensure mobility device consumers are aware of the space limitations on public transportation vehicles. Is this something for Manitoba to consider?
Comment: We recommend consumers of mobility devices be made aware of space limitations. We also recommend that if persons using strollers and mobility aids are given the same priority for seating, they also be made aware of space limitations.
17. Priority seating and mobility aid spaces
(1) Every conventional transportation service provider shall ensure that all of its transportation vehicles (a) have clearly marked priority seating for persons with disabilities; and
(b) have two or more allocated mobility aid spaces, with each having space as defined by CSA D435 Accessible Transit Buses, and are equipped as appropriate with securement devices.
(2) The priority seating for persons with disabilities, and mobility aid spaces, shall be located as close as practicable to the entrance door of the vehicle.
(3) Passengers without disabilities shall vacate the priority seating if its use is required by a person with a disability. Mobility aid spaces may be used for other passenger purposes (such as strollers, baggage, etc.) if not required for use by a person with a disability who uses a mobility aid and who would not have access to the transit vehicle otherwise.
(4) When necessary, vehicle operators will assist if other passengers are refusing to vacate the priority seating and mobility aid spaces. Other passengers are not required to vacate transportation vehicles to accommodate passengers with disabilities.
(5) If all priority seating and mobility aid spaces are occupied, and a passenger with a disability is not able to board the transportation vehicle, the vehicle operator shall inquire when the next vehicle will arrive. If another transportation vehicle is not scheduled to arrive in 25 minutes or less, the conventional transportation service provider must arrange alternative transportation that best meets the needs of the passenger with a disability. If a passenger has already waited for a second transportation vehicle, the conventional transportation service provider must immediately arrange alternative transportation.
(6) Every conventional transportation service provider shall develop a communications strategy designed to inform the public about the purpose of priority seating and mobility aid spaces.
(7) Conventional transportation service providers may have courtesy seating for seniors, expectant mothers, or passengers with small children. Courtesy seating is in addition to and not the same as priority seating, which is seating specifically designated for people with disabilities.
Questions: Should persons with disabilities be given priority when boarding? Should transit buses have an area solely for the use of passengers with mobility aids? Should all other passengers be expected to vacate this area when necessary?
Comment: We support the need for priority seating although we decline to comment on the specifics of priority seating vs. courtesy seating.
In subsection 5, if the conventional transportation service provider is required to arrange alternative transportation, the passenger should not be required to pay more than the regular transit fare.
19. Pre-boarding announcements
Comment: We support the use of external announcements and find them helpful, however, as they are often difficult to hear in high volume traffic situations, we recommend that drivers also communicate with a disabled person waiting at the bus stop.
20. On-board announcements
Comment: The standard stipulates that visual announcements be legibly and visually displayed through electronic means.
We recommend the standard stipulate that audible announcements be at a reasonable volume level given traffic and ambient noise, and that drivers have the ability to adjust the volume level accordingly.
We again recommend that if the on-board automated system is not working properly, drivers verbally announce the stops.
24. Lighting features
Comment: We support the recommendations in the lighting section.
Comment: We support the recommendations in the signage section.
30. Categories of eligibility
(1) Providers of paratransit shall have categories of eligibility to qualify for paratransit services:
· Unconditional Eligibility: for individuals unable to reasonably use conventional services under any circumstances (all trips);
· Conditional eligibility: for individuals who can reasonably be expected to take some trips on conventional services;
· Temporary Eligibility: for individuals who are unable to reasonably use conventional services for a limited period of time.
(2) A provider of paratransit services may deny requests for services if the conventional transportation service is accessible to the person and the person has the ability to use it.
(3) Paratransit service providers shall meet the requirements of this section within three years of the date this Regulation comes into force.
Comment: In subsection 2, when a person is expected to use conventional transit services for some trips, what criteria will be used to make this determination? We recommend that when assessing vision impaired users for paratransit services, mobility skills, familiarity with the location, and difficulty of the trip be considered.
31. Eligibility Application Process
Question: Is this an adequate timeline for determining eligibility?
Comment: We support this as a reasonable timeline for a thorough review.
We recommend that the interval between reassessments consider an individuals disability and whether it has been established as episodic, progressive or permanent. Is it necessary to regularly reassess a person who has a permanent disability?
33. Eligibility, Visitors
Comment: We are pleased to see that the service will be available to eligible visitors.
(1) Every paratransit service provider shall, where the paratransit services require reservations, · provide same day service to the extent that it is available; and
· where same day service is not available, accept booking requests up to three hours before the published end of the service period on the day before the intended day of travel.
(2) A paratransit service provider to whom subsection (1) applies shall provide accessible means to accept reservations.
Question: Does three hours before the end of the service seem reasonable for requesting a ride?
Comment: We support this as being a reasonable amount of time.
37. Trip restrictions
(1) No paratransit service provider shall limit the availability of paratransit services to individuals by · restricting the number of trips an individual is able to request; · prioritizing trips requested by individuals; or
· implementing any policy or operational practice that unreasonably limits the availability of paratransit services.
(2) Service cannot be denied if requested by an individual within city limits or the geographical boundaries of a town or rural municipality.
Questions: Do these parameters seem reasonable and fair? Are there any other aspects of booking a ride that should be included?
Comment: We recommend prioritizing medical appointments as an individual can wait many months for such appointments and they are difficult to reschedule.
38. Service delays
(1) Every paratransit service provider that requires reservations shall provide information on the duration of service delays to affected passengers by a method agreed to by the paratransit service provider and passenger.
(2) For the purposes of this section, a service delay is a delay of 30 minutes or more after the scheduled pick-up time.
(3) This section does not apply in respect of delays in service that arise during the trip.
Comment: We recommend clarification of this section.
Will clients receive notification of a delay at the time of their scheduled pickup? Or will notification be received 30 minutes after the scheduled pickup time? Currently clients are allowed to contact the service provider 10 minutes after the scheduled pickup time to request a status update. To expect a client to wait 30 minutes before being notified of a delay seems excessive.
39. Companions, support persons and children
(1) Every paratransit service provider shall allow companions to travel with persons with disabilities if this will not result in the denial of service to other persons with disabilities.
(2) Every paratransit service provider shall allow dependents to travel with a person with a disability who is the parent or guardian of the dependent if appropriate child restraint securement systems and equipment, if required, are available.
(3) If a person with a disability declares a need for a support person while travelling on a conventional transportation or paratransit vehicle, the transportation provider must comply with this need and develop the appropriate procedures for documenting the support person.
Comment: While support person is defined in the list of definitions, companion is not. We recommend that companion be defined as it pertains to accessible transportation, and specifically whether a companion can be both disabled and ablebodied
When defining a companion, we recommend implementing a policy for situations where two disabled clients wish to travel together. Currently if a disabled person is booked as another clients companion, they are not entitled to receive assistance. If the trips are booked separately, there is no guarantee clients will ride in the same vehicle.
42. Duties of municipalities, accessible vehicles for hire
(1) Every municipality that regulates vehicles for hire must consult with the public, including individuals with disabilities, to determine the ratio of accessible vehicles for hire to inaccessible vehicles for hire required in the municipality.
(2) Obligated municipalities must identify what progress they have made in meeting the need for accessible vehicles for hire, including any steps that will be taken to meet the need. This information must be included in every obligated municipalitys accessibility plan. (3) An owner or an operator of a vehicle for hire shall not
· charge a higher fare or an additional fee to a person with a disability than they would normally charge a person without a disability for the same trip;
· charge a fee for the storage of mobility aids or mobility assistive devices;
· refuse or deny service based on a persons disability or need for reasonable assistance; or · deny a ride to a person using a service animal.
(4) Obligated municipalities that license vehicles for hire must make sure that vehicle owners and operators display vehicle registration and identification information on the rear bumper of their vehicles for hire. For consistency, and to allow for easier recognition for people with disabilities, the information must meet the requirements for signage, as outlined in section 25 of this Regulation.
(5) Obligated municipalities that license vehicles for hire must make sure that vehicle owners and operators make vehicle registration and identification information available in an accessible format to passengers with disabilities. How accessible vehicle registration and identification information is provided to passengers is at the discretion of the municipality.
(6) An obligated municipality should comply with the Customer Service Standard Regulation, including training those that provide transportation services to the public.
(7) Obligated municipalities shall ensure that operators of vehicles for hire are adequately informed on the requirements of safety and securing mobility devices as per the Highway Traffic Act.
(8) Obligated municipalities shall ensure that all operators of vehicles for hire (including accessible vehicles for hire) meet minimum background check guidelines as determined by the municipality.
Questions: Do these parameters seem reasonable for rural municipalities? Should municipalities have a different timeline for implementation?
Should owners and operators of vehicles for hire be required to have specialized training related to providing accessible transportation?
Comment: We recommend that a tactile mark be displayed in the vehicle so that vision impaired passengers can identify it as a registered vehicle for hire.
In Section 3b we would like clarification that this means there would be no loading fee charged to passengers with disabilities.
We recommend that owners and operators of vehicles for hire be required to have specialized training related to providing accessible transportation.
End of submission.