The Canadian Transportation Agency is preparing to introduce accessible transportation regulations for small and medium-sized businesses in Canada. These regulations are currently intended to apply to charter operators that cross provincial and international borders. Motor Coach Canada has previously made submissions to the Canadian Transportation Agency and will continue to do so, however, your feedback is critical to ensuring that the impact on your business is mitigated.
THE CTA IS SEEKING FEEDBACK FROM YOU BEFORE MARCH 31, 2021.
The discussion paper can be found here: https://otc-cta.gc.ca/eng/discussion-paper-accessible-transportation-guidelines-medium-and-small-transportation-service
The ATPDR (Accessible Transportation for Persons with Disabilities Regulations) can be found here: https://otc-cta.gc.ca/eng/consultation/accessible-transportation-consultation
The questions that the CTA is asking members of the industry are below. Please provide responses to firstname.lastname@example.org and please send a CC to email@example.com so that MCC can echo your concerns in the association submission.
QUESTIONS FOR TRANSPORTATION SERVICE PROVIDERS
- For medium TSPs – which are currently expected to be in compliance with the ATPDR – please explain what specific provisions, if any, may be difficult to continue implementing if and when your customer volumes drop below those that trigger coverage by the ATPDR. Please provide clear substantiation for your position, taking into account the requirement under Part V of the Act to remove barriers to travel by persons with disabilities and to accommodate their disability-related needs up to the point of undue hardship.
- For small TSPs, please explain what technical and operational challenges might make it difficult to implement provisions of the ATPDR. What specific areas or provisions of the ATPDR are a challenge? What alternatives can be offered to be able to reach the same outcome in terms of the level of accessibility?
QUESTIONS FOR ALL INTERESTED STAKEHOLDERS
- What practices are working well to deliver accessibility with Canada’s small Transportation Service Providers? Are there any practices that might be considered as a model for other Transportation Service Providers?
- What further suggestions do you have for the accessible transportation guidelines applicable to medium and small Transportation Service Providers?