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Letter re: Final Proposed Accessible Transportation Standard

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April 14, 2009

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For immediate publication

Toronto -
Sent - March 31, 2009

Hon. Madeleine Meilleur
Minister of Community and Social Services
Hepburn Block
6th Flr
80 Grosvenor St
Toronto ON M7A 1E9

Dear Minister:

Please find attached the Ontario Human Rights Commission’s public submission regarding the Final Proposed Accessible Transportation Standard.

The Commission is pleased with the progress that has been made since we first commented on the 2007 initial proposed standard. In its current submission, the Commission is recommending a number of modifications be made before the standard is drafted into regulation to ensure it is understood and applied in a harmonized manner consistent with obligations under human rights law including:

  • Relevant human rights principles should be set out for interpreting the overall standard including the obligations to: remove existing barriers, design inclusively, create no new barriers, implement interim solutions, ensure progressive realization, and maximize integration and dignity for persons with disabilities
  • Transportation providers shall continuously strive to move away from segregated para-transit services towards maximizing accessibility of available conventional systems
  • Definition of accessible fixed route transit should include streetcars and subways
  • Fare and fee parity shall be immediately put into practice upon passing of the regulation
  • Information available to passengers shall be accessible in alternate formats
  • Audible announcements for all stops, and pre-boarding announcements, shall be undertaken within 30 days of passing of the regulation
  • No fare charge for accompanying support person shall be implemented within one year to allow time for certification procedure
  • Accessible equipment failure announcements shall be made to passengers in timely and alternate formats
  • Any contract for inaccessible fixed route and para-transit vehicles (all forms of conveyances including bus and train) shall be prohibited from the date the regulation is passed
  • Any retrofit or purchase of vehicles shall immediately abide by relevant standards to ensure progressive realization within the timeline set for entire fleet accessibility
  • Retrofit or purchased para-transit vehicles shall be equipped with necessary restraints for dependent children
  • Develop an additional standard and set out a timeline for achieving what is an acceptable minimum delay for para-transit service
  • Accessible taxis shall be sufficient in number so as to provide comparable average wait time service
  • Develop an additional standard for municipal taxi licensing to give priority to applications offering wheelchair accessible vehicles

The Commission will have similar human rights principles in mind as we review the newly released Proposed Employment Accessibility Standard as well as the forthcoming Accessible Built Environment Standard. And in order to ensure harmonization among standards, the Accessible Built Environment Committee will need to give consideration to the accessibility of transit service facilities and station / route stops that were outside the scope of the accessible transportation standard.

The Commission would be pleased to meet with you or members of your staff as well as members of the standards development committees to discuss these matters or offer other forms of assistance.

Yours truly,
Barbara Hall, B.A, LL.B, Ph.D (hon.)
Chief Commissioner

Copy Al Cormier, Chair
Accessible Transportation Standards Development Committee

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