3.1 Jurisdiction and Administration
The Federal Government has jurisdiction over inter-provincial transportation services and sets new vehicle standards, while provincial legislatures have authority over intra-provincial bus and train lines. The province, through the Ministry of Transportation, reviews contracts and proposed service provisions, and ensures the safety standards of vehicles. Local municipalities have jurisdiction over taxis and limousines, and are primarily responsible for transit services, including paratransit services.
In areas where several transportation modes converge, it is not unusual to find several authorities with jurisdiction over a single area. For example, Union Station in Toronto is the hub of Toronto's passenger train service, which is federally regulated. It is also a station for the GO Train service, which is operated by the Greater Toronto Services Board (“GTSB”), and for the subway, which is operated by the Toronto Transit Commission ("TTC").
Today in Ontario, municipalities organize transit systems or delegate this function. There are some coordinated efforts to merge systems and to create efficiencies between transit services. As well several small-scale partnerships exist in Ontario between municipal authorities and not-for-profit or other organizations such as hospitals, called community transportation action programs ("CTAP's"). CTAPS receive small amounts of government funding to support these partnership initiatives.
Many transit service providers in Ontario maintain the legal responsibility for administration of transit services within the municipal structure. This is done either through direct delivery or by subcontracting specialized services to private not-for profit entities. In other regions, the responsibility for the administration of transit services has been delegated to a separate legal entity with statutory powers, such as a transit commission. The TTC and the London Transit Commission are examples of this structure.
3.2 Funding for accessible transit
Historically, the province contributed significant funds “to assist municipalities to provide service to those individuals who are unable to climb or descend stairs or walk 175 m”. Provincial funding used to be the largest source of both capital and operating funds for transit services. Transit service providers received a percentage of capital costs from the province, which were then subdivided into basic operating costs and passenger-based costs. When purchasing vehicles, the province subsidized a percentage of eligible operating costs.
Between 1992 and 1999, the government operating subsidy for conventional transit declined. By 1999 all operational funding for transit became a municipal responsibility. For example, the City of Toronto is the only source of operating subsidies for the TTC, while passenger revenues now constitute about 80% of the TTC's operating budget. The City of Toronto is also the TTC’s only source of capital funds. Documents recently provided by the TTC indicate that 96% of Wheel-Trans funding comes from the City of Toronto and 4% from registration fees and fares.
In August 1996, the Ministries of Transportation, Health, Community and Social Services, and Education and Training along with the Ministry of Citizenship, Culture, and Recreation partnered to form the Community Transportation Action Program (CTAP). The joint initiative provides transitional assistance to communities in order to
coordinate services. The project’s aim is to maximize resources while addressing transportation problems. The total amount of money available was $3 m with grants to ten reported municipalities ranging between $10,000 and $40,000. The idea behind CTAP appears to be based on the much more extensive (but unaffiliated) U.S. program of the same name, which is involved in restructuring, coordination and funding of transit services.
3.3 History of accessible transit services in Ontario
In the1970s, several Ontario authorities began to introduce segregated services to accommodate passengers whose disabilities did not permit them to use conventional transit systems. These paratransit services offered planned trips by accessible lift-equipped vans with trained drivers offering door-to-door service. This service is now supplemented in many regions with taxi services, community buses and/or service routes.
In 1981, during the International Year of the Disabled Person, the Ontario Ministry of Transportation began providing a 75% subsidy to transit service providers to improve conventional mass transit systems for ambulatory disabled persons. Ambulatory disabled persons were defined as persons who were able to walk with varying degrees of difficulty.
In the Throne Speech of April 28, 1987, the government announced the expansion of eligibility requirements from “inability to board … to persons unable to use.” In 1989, the standard was set to provide funding for those who were physically unable to climb or descend stairs on conventional transit systems or unable to walk a distance of 175 metres.
In 1993, there were several initiatives to improve accessibility in Ontario. Municipalities were required to provide full accessibility transit plans to the province. All new transit vehicles leased or purchased after July 1, 1993 had to be low floor and/or equipped with Easier Access features. Coupled with provincial assistance to finance accessible transit, these initiatives resulted in significant improvements. In 1979, just five of Ontario’s municipalities had transit systems that could accommodate passengers with physical disabilities. By 1993, 93 of 94 municipalities were reported to have such systems.
These improvements generated a significant reported rise in demand for rides on paratransit systems. In some municipalities, there was also a high rate of inability to accommodate the growing requests for rides.
This created pressure to enhance the integration of conventional systems so that more persons with disabilities could use those systems and relieve pressure on paratransit. In the mid to late 1990s, these pressures were compounded by a sharp decline of direct funding for accessible transit from the Province. The result was that transit systems became entirely reliant on municipal funding and ridership revenues as provincial funding was eliminated altogether.
3.4 Transit accessibility survey
In July 1999, the OHRC wrote to twenty-five Ontario municipalities and transit service providers to survey the accessibility of their transit systems. Each one was asked about specific services to accommodate persons with disabilities, about the status of integrated transportation systems and any new initiatives being planned to accommodate patrons with disabilities. Nineteen authorities replied (“survey respondents”).
This Paper does not seek to review comprehensively the input of each survey respondent in detail, but rather seeks to identify major trends and issues relating to human rights issues, and to provide examples or illustrations of best practices or areas that appear to require improvement. It is based on the information provided by survey respondents and, in some cases, reports or studies that have been brought to the attention of the OHRC.
The following sections will discuss in some detail the outcomes of the survey responses. It is not the OHRC's intention to lay blame or criticize any transit authority or level of government. However, the survey shows a need to underscore several real gaps in the accessibility of Ontario's transit services and to suggest constructive options. It is hoped that these options may encourage both political will and operational capacity to comply with human rights laws and standards, while supporting transit service providers in the complex business of providing accessible services to the people of this Province.
3.4.1 Major Themes
Ontario has no legislation or technical or service benchmarks aimed at creating industry standards for accessibility in the broader public sector. In the absence of such service standards, there was a wide range among the survey respondents in terms, not only of actual services, but also of goals and objectives. Nevertheless, many survey respondents recognized that accessible transit services are fundamental to persons with disabilities and to participation in community life, as well as in society as a whole.
Many survey respondents recognized the importance of accessible systems to older persons and to children as well as to persons with disabilities. The implications of demographic trends related to an aging population were a concern for several survey respondents.
Only a third of survey respondents expressed a commitment to both fully accessible and integrated transit systems. Windsor, Thunder Bay, Peterborough, Burlington, Ottawa and London did identify full accessibility as an objective, with some financial caveats. In a submission to the Government of Ontario, the London Transit Commission identified the importance of removing barriers faced by persons with disabilities. It stated that “municipalities are to be encouraged and supported to continue to move toward providing an accessible conventional transit service, in addition to providing a quality specialized (paratransit) service”. While some municipalities expressed confidence that systems would be accessible in the near or foreseeable future, others did not even project full accessibility.
Some authorities described their services for persons with disabilities in generic terms. For example, Kitchener Transit described its objective as "reliable pick-up and return service" while St. Catharines’ accessible transit objective is to ensure that patrons are able to "travel from their homes to bus stops in a barrier-free environment." The Town of Markham wrote about the “dilemma” of how to achieve full accessibility. Sudbury and Timmins provided information about improvements in accessibility but did not disclose plans to achieve full accessibility.
Some survey respondents reported having planning tools, such as accessibility plans, a requirement that was stipulated by the Province of Ontario in 1993.
The cost of achieving accessibility was a theme mentioned by several survey respondents. The costs related to accessibility initiatives to make infrastructure and vehicles accessible are significant. Population size, coupled with an aging population, has heightened the need to accelerate accessibility projects as a way of meeting demand. Some of the survey respondents attributed delays or limited accessibility targets to lack of funding or to the fact that dedicated provincial funding to implement accessibility plans is no longer available. Seven survey respondents linked these changes in funding to the fact that accessibility initiatives have been affected, delayed or abandoned altogether.
Many survey respondents indicated that senior citizens and persons with disabilities form a significant or growing proportion of the population. This creates an increased demand for improved accessibility.
In the City of Hamilton, for example, the historical industrial base has created a relatively high population of persons with physical disabilities in a region with significant geographic barriers. Fifteen per cent of the population is age 65 or more. The Hamilton Street Railway Company reports that 8,000 persons, or 1.7% of the regional population, are registered for specialized services. This may be contrasted with the TTC’s Wheel-Trans registrant base, which is about 22,000 people (of whom 70% are seniors) 0.6% of the population served by the TTC.
Similarly, Niagara and Burlington reported a higher proportion of older persons requiring accessible services.
3.4.3 Planning Tools
In Eldridge, the Supreme Court of Canada indicated that public authorities are required to take positive steps to ensure that disadvantaged groups benefit equally from services offered to the general public. The planning tools shared by the transit authorities outline the positive steps transit services intend to take to promote accessibility. Many of the plans shared by transit service providers show commitment to improve and some progress, but others do not. As part of the Ministry of Transportation's 1993 Policy Directive, all municipalities were required to submit "full accessibility plans" in that year. Since that time, many authorities have reviewed their services and embarked on reviews or projects for coordinated services in order to promote and enhance accessibility. However, several of these plans date from 1993-4 and need to be updated. The lack of benchmarks has an impact on the consistency, service levels and standards set out in the various plans.
Transit Accessibility Plans (“TAPS”) or similar planning tools were reported by several survey respondents, with a wide range of goals, as well as timeframes for achieving the identified goals. Commitments to accessibility projects are in some cases qualified by the words “where funds permit” or by similar language. For example, Thunder Bay qualified its plans to have a fully accessible transit fleet by the words “depending on budgetary allowances”.
There was little accountability mentioned in survey responses for failing to meet targets, presumably because of the lack of control over budgets from year to year. As a result, despite good intentions, there is no incentive to meet, or real consequence for not meeting, accessibility objectives. There is, consequently, little real accountability for or incentive to municipalities to dedicate funds to accessible transit, especially at a time when many needed services are competing for resources.
Many plans do require approval and periodic review by municipal councils, but no general reporting to the greater public. These factors limit transparency and public awareness of progress.
Even without any legal oversight of accessibility implementation plans, most authorities have established a range of committees and advisory bodies to oversee accessible transit systems:
- Kingston Transit has established an Access Advisory Committee to develop a full accessibility implementation plan.
- Responsibility for GO Transit has been transferred from the Province to the Greater Toronto Services Board (GTSB). Accessibility plans were to be determined by the GTSB’s policy direction subject to funding availability in the year 2000.
- The London Community Transportation Brokerage was created to address a variety of transportation services.
- Ottawa-Carleton (OC Transpo) has a steering committee, which has assisted in the development of its recent transit review.
- The TTC Task Force on Accessible Transportation developed a 5-year Accessible Transit Plan in 1997 to address new and increased services and improved service efficiencies.
The creation of planning tools that are current and set clear goals and timelines is a first step towards achieving a fully accessible system. As well, without structures of accountability for the implementation of plans, progress is likely to be slow.
3.4.4 Integration Of Conventional Transit Services
As discussed earlier, human rights principles indicate that public services, such as transit services, should be structured for inclusiveness, in preference to modifying the rules or removing barriers while maintaining the status quo. Few survey respondents identified integration of transportation systems as a planning priority, with some notable exceptions such as London and Ottawa-Carleton. Nonetheless, survey respondents
have undertaken a wide range of initiatives to make conventional systems more accessible. For example, the TTC reports improvements in lighting on subways and buses, and public announcements of bus and subway stops. Other features, such as warning lights in the doorways of subway cars and chimes may also assist individuals with hearing and sight impairments.
Typically, transit service providers developed accessibility initiatives in consultation with community organizations and users. Survey respondents reported on using a variety or combinations of the following strategies:
- Improved vehicle accessibility;
- Community bus services and/or service routes;
- Improved fixed bus routing and scheduling;
- Accessibility guidelines and standards for future building initiatives;
- Improved barrier removal at bus stops, such as snow removal;
- Accessible bus terminals, stations and platforms; and
- Combining or integrating local or regional services horizontally to achieve coordinated programs, reduce costs and improve responsiveness.
Ottawa-Carleton and the Hamilton Street Railway Company have an interesting “family of services” approach to meeting the needs of a wide range of customers. London has adopted a range of overlapping and complementary services to achieve efficiencies. This approach appears to offer flexibility for patrons, lowered costs across the system and improved integration of the conventional system. OC Transpo has released plans to introduce a fixed route paratransit bus system, which would significantly increase the integration of the conventional system, although it would not address the needs of those who, by reason of their disability, require door-to-door service.
In 1989, following in the steps of the Ottawa-Carleton, St. Catharines, Hamilton, and Oakville transit commissions, the TTC experimented with service routes, using them in place of some fixed-routes during off-peak hours. A TTC survey conducted at that time found that 12 percent of service route passengers were paratransit users and as many as an additional 7 percent might also have been paratransit patrons. Using the 12 percent figure, a U.S study shows that the cost of transporting paratransit riders via service routes was $33/trip versus $30/trip on paratransit; however, at 19 percent, service routes reduced costs to just $21/trip.
Service routes appear both useful and economical in Ontario’s larger cities during off-peak hours. However, their utility during rush hours in these locations remains uncertain. Given the volume of passengers and other traffic, passenger-requested diversions and flag-stop policies may prove both unsafe and unreasonable during peak-hour service. In Toronto, for example, the use of service routes has been restricted to four community bus routes that serve seniors and persons with disabilities who wish to have access to particular facilities. Community buses are used in several areas in Ontario, but appear to be less popular as transit providers move towards fully accessible low floor buses on conventional routes.
Despite these and other positive steps, there remain many serious gaps in integrated conventional transit services. As discussed in the following section, only a fraction of the TTC subway system and bus routes is currently accessible. Only ten of the TTC’s 69 subway stations and one fifth of TTC bus routes are partly or fully accessible. There are only four community bus routes in operation at this time. None of the 250 streetcars are accessible and there are no plans to make them accessible. The TTC's accessibility targets for buses and subways will not be achieved for at least another eleven to twelve years.
GO Transit also faces barriers to accessibility, which, because of its close links to the TTC and other systems in the Greater Toronto area, has serious implications across the entire GTA. GO Transit reports accessible rail service at 29 of its 49 rail stations. None of the Go Transit buses were accessible in 1999, although by 2000, about 10% of buses were to be accessible. In its submission, GO Transit stated that there is “no funding” to make terminals accessible and has no current plans to modify the remaining nineteen inaccessible stations. 
Accessible bus services are a function of the accessibility of the vehicles themselves, as well as the availability of low floor buses on all routes.
Several transit service providers have tested easy access, lift-equipped and low floor (fully wheelchair accessible) buses on their routes. Lift-equipped buses are reported to require heavy maintenance and most transit service providers in Ontario are gradually replacing current fleets of buses with low floor buses.
Low floor buses were reported to be available on several routes in most municipalities, but are more expensive to operate compared to standard high floor vehicles due to higher capital costs, operating costs and factors related to usage and frequency of use by passengers. They are also more costly to repair. Lift-equipped buses also have high repair costs, and easy access buses, while preferable to standard high floor buses, are not wheelchair accessible.
As a result, many transit service providers are planning to buy only low floor buses in future. Currently, most of today's bus fleets range from a quarter to one-half accessible. For example, Burlington reports that about half of its fleet includes easier access and low floor buses, and OC Transpo reports that about half of its fleet will be low floor by 2003. Markham's fleet is about 25% accessible and Mississauga is about one-third accessible.
In 1998, the TTC tested the natural gas-powered Orion VI true low floor buses (manufactured by the Mississauga-based Orion Bus Industries) along the Dufferin 29 route. The tests suggested that converting their fleet to low floors would increase yearly operating costs by $110 million since the low floors needed maintenance that was more frequent and expensive than conventional buses.
Reduced seating capacity in low floor buses would mean adding 180 buses to maintain current levels of service. The TTC found the buses were not economical but planned to test 50 additional diesel low floor buses manufactured by New Flyer Industries of Winnipeg. More recently, the TTC has confirmed that the cost of new low floor buses on conventional fixed-route bus services is estimated at $110 million and is moving towards a completely accessible bus fleet with all future bus purchases being planned as low floor.
The TTC reports that 339 of its fleet of 1473 buses consist of lift- equipped or low floor buses. Another 425 are easy access buses. Thirty-four of the TTC's 144 regular routes have accessible buses, and on these routes, the standard is at least 50% accessible buses during peak times and 100% accessibility in non-peak hours. Future bus replacements are expected to be low floor accessible buses and a new route guide is being developed to include reference to the low floor accessible service.
GO Transit was relatively lower than others in levels of accessibility, reporting that only 10% of its fleet will have been made fully accessible by the end of 2000, with no targets for future increases in accessibility.
The only subway registered in Ontario is run by the TTC.
Since 1995, when a subway crash resulted in highly publicized fatalities, the TTC reports that capital spending has been increased to replace or upgrade aging equipment and infrastructure in the subway system. This has increased pressure on a system that was already straining to make needed capital improvements. Nevertheless, despite the increased funding that had to go towards these general safety features, the TTC also states that it has increased capital spending to accommodate greater number of persons with disabilities on conventional routes during this same period.
The TTC subway car fleet is accessible to customers who use mobility devices. About half the fleet is comprised of T-1 cars, which have wide doors, no center poles (which block mobility) and flip-up seats with wheelchair/scooter tie downs.
Subway stations were reported to have brightly-coloured tactile markings and tactile wayfinding tiles to assist in customers safety for those with sight impairment. Designated waiting areas have increased lighting, tactile markings and information markings in Braille, as well as emergency telephone connection to the collectors’ booth. Upgraded public announcement loudspeakers improve communications particularly for the hearing-impaired. Signs with high-contrast lettering and pictograms improve communications and assist customers with limited reading capabilities and visual disabilities. Other accessible features include powered doors and wider turnstiles.
Despite these positive developments, given that the self-described “backbone” of the TTC is its subway, it is disheartening that only ten of its sixty-nine stations are or will have been made fully accessible by the end of the year 2000. Even by 2004, only twenty-eight stations will be accessible, less than half the entire system. Moreover, the fact that the bus system is so closely integrated with the subway means that the inaccessibility of large areas of the subway system has repercussions far beyond the subway itself to the accessibility of the entire service.
The TTC has advised that if the Olympic Toronto bid is successful, it will have to change is plans to update stations from residential areas to downtown areas that will be heavily used during the Olympics. It was not clear whether this would impede the plans for fully accessible subway stations by the stated date of 2011-2012.
3.4.5 Integrated and Combined Systems
Several transit service providers have responded to the need expressed by public and service organizations to coordinate, combine and integrate transit services across different regions or even within regions. The Hamilton "family of services approach" is one approach to combining or rationalizing services with a region. The mix of services offering different choices and enabling trips to be made without booking several days in advance has reportedly resulted in improved services and a more efficient program in Hamilton and in other areas such as Markham and London.
Within regions, several service providers have gotten involved in CTAPs. Burlington has launched a CTAP, funded by the government, to partner with the Red Cross, a hospital and the regional paratransit service to develop a demonstration project for persons with disabilities.
Horizontal integration of services across areas or services between areas has also been reported. In August 2000 the York Region Transit Implementation Project announced public consultations on the integration of five municipal conventional transit systems and seven special needs operations into a single system. York region reported strong public support for the combination of services into a single system in that Region. The GTSB will also be seeking to achieve efficiencies in its planning and delivery of transit services for the GTA.
3.4.6 Paratransit Services
Even where the accessibility of conventional transit systems has been maximized, there will always be those who are unable to use it. Paratransit services will always be essential to ensuring the accessibility of transit services.
A 1993 report identified operating costs for specialized transportation for the entire Province to be about $21 million per annum. By 1999, this figure was less than the budget for Wheel-Trans in the City of Toronto alone.
A brief summary of the paratransit services offered by each survey respondent is set out below for ease of reference:
- Hamilton’s family of services approach combines wheelchair accessible van service providing door-to door service with contracted taxi /livery service providing door-to-door services. Taxi scrip services provide discounted coupons for purchase of commercial taxi services and accessible low floor buses on regular bus routes provide services to persons in wheelchairs and easier access to ambulatory disabled passengers.
- Kingston Access Bus (K.A.B). is a specialized bus service established in 1967 to provide transportation for persons with physical disabilities.
- Kitchener’s Project Lift is a paratransit service providing door-to-door service for individuals with special needs.
- London’s “Community Bus” service is available on routes heavily populated by seniors and persons with mobility disabilities. It operates during the off peak periods and takes patrons to medical facilities, hospitals, downtown and shopping areas.
- Markham Mobility Bus service has operated since 1983 and is supplemented by a connector fixed bus route and a taxi scrip service.
- Mississauga referred to Peel Transhelp in its submission, but did not report its own paratransit services.
- Ottawa-Carleton’s OC Transpo has a paratransit service and includes three Communibus routes.
- Niagara’s Chair-A-Van is an alternative to conventional transit and provides quality transportation in an efficient and cost-effective manner to members of the disability community.
- Peterborough’s Handi-Van is a parallel service that exists for persons with physical disabilities.
- St. Catharines’ Transit has initiated the Adult Accessibility Project in partnership with the St. Catharines’ Association for Community Living to encourage people with disabilities to learn to use the public transit system and build their confidence for independent travel by relying on the bus operators to act as facilitators when necessary.
- Timmins’ Handi-Trans provides services to residents who are unable to use conventional transit services.
- The Town of Whitby funds the operation of Whitby Handi-Transit. It provides a demand responsive door-to-door service to the residents of Whitby who cannot access regular transit services either permanently or temporarily due to disability.
- Toronto’s Wheel-Trans provides door-to-door accessible transit service by Wheel-Trans buses or contracted accessible and sedan taxis. Spontaneous door-to-door service dedicated to short-term trips within a specified area was recently introduced into high-service demand areas.
Access to paratransit services is generally limited in Ontario to patrons who are registered and therefore meet pre-established eligibility requirements. Criteria for eligibility vary across the province, with some specialized services offering paratransit service to ambulatory or temporarily disabled persons. Some systems also provide services to frail seniors. Others services are more restrictive. Registration fees and fares vary significantly across the province. Inconsistencies in criteria were also apparent in terms of assessment. The TTC has the most rigorous program, with an in-person interview and extensive, detailed criteria. In 1996, the TTC sought to address the issues of eligibility and high unaccommodated ride rates by restricting access to costly paratransit systems through tighter eligibility criteria. It recommended new criteria for determining eligibility from its Advisory Committee on Accessible Transport, which recommended the following:
An individual's need to accessible transit is based upon an individual's level of physical functional mobility in the home, within the area immediately surrounding the home and in the community at large as well as permanency of disability. Eligibility is not based on particular disabilities.
The resulting changes to the criteria in 1996 involved much more elaborate screening processes and an in-person interview (as opposed to a paper-only application) in the TTC. Ottawa-Carleton appears to be planning for more rigorous selection criteria as well.
Levels of access for different types and severities of disability vary. Persons with mental disabilities (that is, who suffer from cognitive disabilities alone) cannot register for Wheel-Trans. There are also restrictions on use by persons with temporary disabilities. However, the St. Catharines Transit Commission advised the OHRC of its Adult Accessibility Project, which is being piloted for persons through the Community Living program to build confidence for independent travel for patrons, including those with cognitive/developmental disabilities. Other transit service providers permit use by persons with temporary disabilities. Persons who are disabled but ambulatory cannot be registered in Toronto unless they are dependent on some type of equipment, such as a cane or walker.
There are also variances in booking times that are available or required.
Eligibility criteria for paratransit services are generally based upon the level of physical functional mobility in the home, within the area immediately surrounding the home, in the community at large, as well as permanency of disability. Eligibility is not based on particular disabilities, although the TTC excludes persons with mental disabilities from its Wheel-Trans program. The courts have upheld this on the ground of cost.
To conclude, the variances in access to paratransit services across the province raise human rights issues. In particular, lack of access to transit services for persons with mental disabilities is of great concern.
 The Town of Markham, for example.
 The D.A.R.T.S. service in Hamilton, for example.
 Canadian Urban Transit Association, Specialized Transit Services Factbook (1993), at p. 6.
 Ibid. For example, about 50% of operating funds and 75% of capital funds came from the province in the early 1990's.
 Pleadings of the Toronto Transit Commission in Odell et al. v. TTC (Board of Inquiry (Human Rights) No. BOI-0336/336/337/338/340-00).
 Ibid. at para. 5.
 See CTAP official website, <http://www.ctap.gov.on.ca>and related links. While comparisons to the U.S. program are difficult because the large programs are not exclusively dedicated to transit funding, the U.S. programs with specific funding for public transportation exceed $1 billion U.S. dollars.
 Turvey & O’Brien, “A “Family of Services” Approach to Special Needs Transit” presented to UITP- International Union (Association) of Public Transport, 53rd Congress and City Transport Exhibition for the Regional Municipality of Hamilton-Wentworth (Toronto, 26 May 1999) at 1. Kingston Transit reports that the “Kingston Access Bus” was established in 1967.
 Ontario Transportation Association, A Report to the Ministry of Transportation Task Force on Improved Accessibility to Conventional Transit Services for Frail and Ambulatory Disabled Persons (1998) at p. 43.
 Ontario Ministry of Transportation and Communications, Directive B-9 as found in Ontario Transportation Association, A Report to the Ministry of Transportation Task Force on Improved Accessibility to Conventional Transit Services for Frail and Ambulatory Disabled Persons, 1998, p. 43.
 Specialized Transit Services Factbook 1993, supra note 30 at p.5.
 The following authorities were contacted: Ajax Transit, Barrie Transit, Brampton Transit, Burlington Transit, GO Transit, Guelph Transit, The Hamilton Street Railway Company, Kingston Transit, Kitchener Transit, London Transit Commission, Town of Markham, Mississauga Transit, Niagara Transit, Oakville Transit, Oshawa Transit, Ottawa-Carlton Regional Transit Commission, Peterborough Transit, Pickering Transit, St. Catharines Transit, Sudbury Transit, Thunder Bay Transit, Timmins Transit, Toronto Transit Commission, Transit Windsor, Whitby Transit.
 Unfortunately, the following authorities did not respond: Ajax Transit, Barrie Transit, Brampton Transit, Oakville Transit, Oshawa Transit, Pickering Transit; this report therefore can not assess or offer any comment on their progress in addressing the transit needs of persons with disabilities.
 Children were specifically mentioned by Markham, for example.
 Letter to Berwyn Sheer, Parliamentary Assistant to Ministry of Citizenship, Culture and Recreation, 28 August 28 1999.
 The TTC reports estimated costs of the complete accessibility package to the TTC to be $781 m.
 For example, submissions from the TTC, Peterborough, Kingston, the London Transit Commission and Transit Windsor refer to the elimination of capital and operating assistance from the Province as factors that affect the pace of acquisition of low floor buses, or that prevent integration. Others, such as the St. Catharines Transit Commission refer to the financial pressures as the reason that certain services such as Mobility Niagara were to be discontinued. Burlington reported that one initiative in its Plan was deferred due to lack of funding.
 The following municipalities/authorities submitted or made reference to existing or current TAPS and/or subsequent reports or reviews of their services as part of the OHRC survey. These were Burlington "Full Accessibility Implementation Plan" (1993); “Community Transportation Action Program” (1999); Markham "Transit Accessibility Implementation Plan (1993); OC Transpo, "OC Transpo Comprehensive Review "The Way Ahead: Becoming the Best of the Best"” (1999); TTC "Five Year Accessible Transit Report" (1997); Hamilton "A ‘Family of Service' Approach to Special Needs Transit" (1999); Kingston "Full Accessibility Implementation Plan" (1993); Windsor "Full Accessibility Plan" (1994).
 Although several authorities did post their reports or plans on the Web, such as OC Transpo and TTC.
 Low floor wheelchair accessible buses, lift-equipped buses, kneeling features or other easier access features, low floor articulated buses; subway cars that are barrier-free i.e. wide doors, improved tie-downs in subway cars, removal of central poles that impede mobility, etc.
 Respondents mentioned strategies to maximize use of accessible bus services on a regular basis. Some have designated main bus routes as “fully accessible” or 80% accessible, as determined by factors such as passenger requests, proximity to major departure or destination locations for persons with disabilities and to seniors, and an analysis of the trip patterns of the paratransit service.
 Guelph reported its plan that new bus shelters will be wheelchair accessible.
 E.g., In August 2000 the York Region Transit Implementation Project announced consultations on the integration of their five municipal conventional transit systems and seven special needs operations into a single system.
 In Hamilton, these include wheelchair accessible vans, taxi-livery services, and low floor buses and taxi scrip services. In Ottawa-Carleton they include community buses, route deviation services, local routes and accessible sedans and taxis.
 OC Transpo "The Way Ahead: Becoming the Best of the Best" (Final Report, February 1999), online: OC Transpo Homepage <http//:www.octranspo.com/pi/KPMG_final_report_C_3.htm>.
 Transportation Research Board, National Research Council, Transit Operation for Individuals with Disabilities. (Washington, D.C.: National Academy Press, 1995), at p.12.
 E.g., OC Transpo has indicated that it will consider eliminating community buses if it implements more accessible conventional bus services.
 TTC submission.
 The TTC is projecting fully accessible bus fleets and subway stations by 2011-12.
 GO Transit submission to OHRC, 6 August 1999.
 OC Transpo reports that low floor buses have about 80% of the capacity of standard high floor buses. Reduced capacity is being redressed by articulated buses. See "The Way Ahead: Becoming the Best of the Best" supra note 52 at 25.
 Ibid. at 13.
 Paul Moloney, “Low Buses Too Costly, TTC Told.” The Toronto Star. September 14, 1998 p. E3.
 See pleadings of the TTC in Odell et al. v. TTC, supra note 32.
 Telephone interview held with TTC staff on 16 October 2000.
 See pleadings of the TTC in Odell et al. v. TTC, supra, note 32 at para. 17.
 That is, with elevators between street, subway platform and bus platforms.
 "Notice of Public Consultation Centres" -York Transit Implementation Project, Region of York (Toronto: August 2000), citing a 70% support for integration.
 Specialized Transit Services Fact Book, supra note 30.
 For example, some transit service providers impose one-time only registration fees, while others have an annual fee.
 Although the province used to set out basic eligibility requirements for paratransit users, most of this responsibility has been delegated to transit service providers.
 See pleadings of the TTC in Odell et al. v. TTC, supra, note 32, at para. 21.
 E.g., Whitby.
 See Cannella v Toronto Transit Commission, supra note 5 at para. 27.