June 7, 2011
SUMMARY
Even though the new Integrated Accessibility Regulation has finally been enacted under the Accessibility for Ontarians with Disabilities Act, will Toronto transit passengers face new barriers in the future when paying fares to ride the TTC?
On June 6, 2011, the media reported that the City of Toronto was working out, or had worked out, an agreement for the Toronto Transit Commission to adopt the Ontario Government’s Presto Smart Card for paying TTC transit fares. Yet we have no word that the Ontario Government has removed the serious accessibility barriers in the Presto Smart Card that can impede transit patrons with disabilities from fully using it on a footing of equality.
We have waged an ongoing campaign to ensure that public money is never used to create new barriers against persons with disabilities. As part of this, last year, the AODA Alliance made public serious concerns about barriers against persons with disabilities in the Presto Smart Card technology, which was custom-designed with public money. We caused the Transportation Minister to revisit this technology, because of these concerns. However, the McGuinty Government did not commit to our request that it halt the roll-out of the Presto Smart Card until the barriers were removed.
Now, on learning of the recent developments in Toronto, the AODA Alliance wrote to the Toronto Mayor, the TTC Chair, and Ontario’s Transportation Minister. We asked them to commit that the Presto Smart Card will not be rolled out in the TTC until those barriers are removed and the Presto Smart Card is fully accessible to transit passengers with disabilities. We reminded them of the requirements for ensuring accessibility under the Human Rights Code, the Canadian Charter of Rights, and the new Integrated Accessibility Regulation enacted last Friday under the Accessibility for Ontarians with Disabilities Act. We set out that letter below.
Write your Member of the Legislature about this, to support our position. If you are in Toronto, write the TTC Chair, the mayor and your councillor to raise this issue. Let the media know about it. Everything you need to know is set out in this letter, and the web pages to which its links point.
Send us your feedback. Write us at: aodafeedback@gmail.com
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ACCESSIBILITY FOR ONTARIANS WITH DISABILITIES ACT ALLIANCE
1929 Bayview Avenue,
Toronto, Ontario M4G 3E8
Email: aodafeedback@gmail.com
Visit our website at https://www.aodaalliance.org
(Fax) 416-480-7014
June 6, 2011
VIA Email
Hon. Kathleen O. Wynne, Minister of Transportation – kwynne.mpp.co@liberal.ola.org
Ferguson Block, 3rd Floor
77 Wellesley Street West
Toronto, Ontario
M7A 1Z8
Karen Stintz, Chair, Toronto Transit Commission – councillor_stintz@toronto.ca
Toronto City Hall
100 Queen Street West, Suite B32
Toronto, Ontario
M5H 2N2
Mayor Rob Ford – mayor_ford@toronto.ca
Office of the Mayor
Toronto City Hall,
100 Queen St. West, 2nd Floor
Toronto, Ontario
M5H 2N2
Dear Minister Wynne, Chair Stintz and Mayor Ford:
Re: Barriers to Accessibility of Presto Smart Card Technology to Public Transit Passengers with Disabilities
I write on behalf of the Accessibility for Ontarians with Disabilities Act Alliance. We are the non-partisan, voluntary province-wide coalition that leads the campaign to make Ontario fully accessible to over 1.7 million Ontarians with disabilities.
The media is today reporting that a deal is being worked out, or has been worked out, for the Toronto Transit Commission to adopt the Presto Smart Card for passengers to pay TTC transit fares. We write to ask for your commitments that this technology will not be adopted and implemented, until barriers to its full use by passengers with disabilities are removed.
Last year we raised with the Presto Smart Card project (a project of the Ontario Government) our serious concerns regarding barriers to accessibility in this new technology, created with taxpayers’ money. The Presto Smart Card team assured us that they were committed to ensuring that this Smart Card technology was fully accessible to public transit passengers with disabilities.
However, our investigations revealed that that commitment had not been turned into practical action. The Presto technology indeed has barriers that impede its full and equal use by passengers with disabilities. See https://www.aodaalliance.org/strong-effective-aoda/06212010.asp
We made our concern public to the media last August. See: https://www.aodaalliance.org/strong-effective-aoda/08122010.asp
As one striking example, the Presto technology includes a stand-alone “card reader,” to be deployed in public transit stations, so passengers can check their card balance. The balance is only displayed on a video screen. That is entirely inaccessible to people with vision loss or dyslexia. It would have cost very little for the Presto project to include in these devices an option for an audio output of one’s balance via earphones. Many bank machines have this feature. The Chicago Transit system has had this feature in its card readers in transit stations for several years.
These card readers were custom designed for the Presto system, using public money. Presto’s excuses for deliberately not including this feature were hollow, and disrespectful of the right to accessibility of persons with disabilities. For example, they claimed persons with disabilities can line up to talk to a sales person at a transit stop to check their card balance. Yet passengers without disabilities don’t have to do this. That is not equality, nor is it true accessibility.
It has been our strong position that no new barriers against persons with disabilities should ever be created, especially when they are created with public tax money. When we made our concerns public, the Ontario Government initially responded by claiming they had consulted with persons with disabilities. We then learned that one or more persons with disabilities whom the Ontario Government had consulted in fact had forewarned them of such barriers months or years before, and that the Ontario Government created this new technology, replete with those barriers, despite that early warning. See https://www.aodaalliance.org/strong-effective-aoda/08272010.asp
In the face of adverse publicity about this, the Minister of Transportation committed to revisit the accessibility problems with the Presto Smart card last fall. However, the Government did not act on our proposal that in the meantime, the Government should stop deploying any Presto Smart card technology that has barriers impeding persons with disabilities. The Government has not given that commitment.
Ten months have now passed since the media publicized our concerns. That has been more than enough time for this problem to be fixed. According to the Toronto Star’s June 6, 2011 report on possible TTC acquisition or adoption of the Presto Smart Card system, the final date for the roll-out of this technology in Toronto has not yet been set.
Last year, in the face of the adverse publicity on this issue, the Ontario Government committed that it would obey any accessibility regulations enacted under the Accessibility for Ontarians with Disabilities Act. Last Friday, the McGuinty Government enacted the Integrated Accessibility Regulation under the Accessibility for Ontarians with Disabilities Act. Among other things, that new regulation sets requirements regarding barriers impeding persons with disabilities in getting access to transportation and to information and communication. See more about this at: https://www.aodaalliance.org/strong-effective-aoda/06032011.asp
As designed last year, the Presto Smart Card system would violate a number of provisions of that new regulation. That regulation includes provisions on the accessibility of electronic kiosk technology (see section 6) and more generally, of technology procured by public sector organizations like TTC for use in delivering services to the public (see section 5).
It is very important for both the Ontario Government and the City of Toronto to lead by example. They should now fully comply with the letter and spirit of the new Integrated Accessibility Regulation, as well as the accessibility requirements of the Ontario Human Rights Code and the Canadian Charter of Rights and Freedoms. The Accessibility for Ontarians with Disabilities Act requires Ontario to become fully accessible by 2025, less than 14 years from now. To deploy a new fare technology that has any accessibility barriers would impede the attainment of that mandatory goal.
We therefore ask for a firm and clear commitment from the City of Toronto, the TTC and the Ontario Government that the Presto Smart Card technology will not be rolled out in Toronto until and unless it is fully accessible to passengers with disabilities.
We would be pleased to discuss this with you at your convenience, and look forward to your reply.
Sincerely,
David Lepofsky
Chair Accessibility for Ontarians with Disabilities Act Alliance
cc: Premier Dalton McGinty – dmcguinty.mpp.co@liberal.ola.org
Madeleine Meilleur, Minister of Community and Social Services – madeleine.meilleur@ontario.ca
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UNITED FOR A BARRIER-FREE ONTARIO