March 26, 2019

From:
Barrier free Canada – Canada sans Barrières
Email: info@barrierfreecanada.org
Tel: 416 491 7711
Web: www.barrierfreecanada.org

To:
SSonia Gangopadhyay
Acting Director
Centre of Expertise for Accessible Transportation
Canadian Transportation Agency
15 Eddy Street
Gatineau, Quebec
K1A 0N9
Tel: 819?953?8961
Email: sonia.gangopadhyay@otc-cta.gc.ca

CC:
consultations@otc-cta.gc.ca

Reference

Canada Gazette, Part I, Volume 153, Number 10:
Accessible Transportation for Persons with Disabilities Regulations
March 9, 2019

Introduction

This document is a submission on behalf of Barrier Free Canada – Canada sans Barrières in response to calls for comments from the Canadian Transportation Agency with regard to the publication of their proposed Accessible Transportation for Persons With Disabilities Regulations on March 09.

We would like to take this opportunity to congratulate the Canadian Transportation Agency on this mountainous initiative and we hope that these proposed regulations could serve as a solid foundation for moving forward.

The following is a list of our comments.

Not Enough Time to Submit Comments

In the case of the proposed passenger rights bill, the submission time for feedback to be submitted was 60 days but in this case only 30 days have been allowed.
It would have been helpful if a bit more time could have been allowed for submissions.

Rights Under the Proposed New Regulations

For whereas there is an outline of economic rights under these proposed new regulations, there does not seem to be any mention of the respect for Human Rights.
We believe that these regulations should be required to recognize the Human Rights of complainants.

Curb Side Assistance

We congratulate the Canadian Transportation Agency for finally taking charge of these services. For too long, these services have been ignored and we look forward to enjoying the benefits of curb side assistance.

We believe that the regulations should be required to recognize the responsibilities of the appropriate parties with regard to curb side assistance.

Access to Training Regulations

Up until now, The Greater Toronto Airport Authority has consistently refused to provide access to these regulations.
We would like to suggest the following process:

  • The provision of contact information as to who should be contacted in order to receive these training regulations.
  • When applying for copies of these regulations, the length of time that it would take for them to be provided.
  • Publication of the above on all relevant websites.
  • Provision of copies of these training regulations in alternate formats.
  • The establishment of an informational phone line with live staff to answer questions.
  • Who was consulted during the course of the development of these training regulations.

We believe that the regulations should be required to provide the above as stated.

Additional Penalties

In addition to penalties handed down to companies and organizations, there should also be provisions made to monetarily and personally compensate successful complainants.

We believe that the regulations should be required to include personal and monetary compensation to successful complainants.

Consultations

As has been outlined in the proposed regulations that persons with disabilities be consulted with, we would also like to propose that there should be the setting up of advisory groups that would meet regularly to help monitor, provide feedback, and to assist with the provision of regular reports on a timely basis. These meetings could take place annually on a face to face basis but if there is a need to consult before this time then tele conferences could be held. We believe that the regulations should be required to include the setting up of advisory groups that would carry out tasks as outlined above.

The One Person One Fare Proposal

We would like to propose that this be made available to both domestic and international travelers. We believe that the regulations should be required to include this addition.

Respectfully submitted by:

Barrier Free Canada – Canada sans Barrières

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