1. Do you support the…

1. Do you support the removal of market entry controls of the intercity bus industry? Why or why not?

Perhaps, if sufficient controls are instituted to ensure that all communities are continually provided with inter-community services.

2. What are the benefits of removing market entry controls? What are the drawbacks?

It may encourage more services to be provided. However it seems as likely that without adequate controls, there would be a flush of services, over competition, bankruptcies and a loss of services.

3. A system needs to be in place to ensure that all vehicles, including those carrying less than 10 passengers, are safe and properly insured when being used to transport people between municipalities for a fee. What do you think the minimum safety and insurance requirements should be for these vehicles?

Same as for vehicles carrying 10 or more passengers.

4. How much of your business is currently attributed to non-urgent medical transfer (patients, supplies, etc.)?

Inappropriate question.

5. Could municipalities and social and health organizations better partner with transportation providers to serve the public? If so, how?

It should be a responsibility of the carrier to make the links; after all it is to their benefit. 6. Are there any innovative services or policies currently in operation in Ontario or in other jurisdictions that you think provide a good model for how transportation networks can develop in the future?

BC seems to have a good system

7. Is there any other feedback you would like to provide on the issues and/or proposal outlined in this discussion paper?

There needs to be a 4th principle, all municipalities will be served by an inter city service. If there is no such service, the province should guarantee such a service. There is the classic problem faced by one LHINS which reconfigured hospital services based on available inter city transportation only to have the service close.

Rural communities like ours have lost services in recent years where routes have become unprofitable. Perhaps licences that served a catchment area rather than just a particular route with a legal requirement for cross-subsidization would be helpful. Reducing the currently monopoly on routes and making it easier for new companies to entry the market place may help but again, if these routes are being dumped because they’re unprofitable (due to distance and density), it’s unlikely that this will generate new opportunities for alternatives to be offered at a scale and price that is affordable.

Without municipal public transit services communities like ours depend on private operators. However, it is clearly more costly to provide service in rural and northern communities. It might be helpful if companies providing services to communities without any public transit could receive some subsidy to ensure that service continues. This might be an alternative or compliment to cross-subsidization.

A more open, innovative, and dynamic market may be helpful. However, allowing market forces alone to influence the provision of service, as has been the case thus far, will likely not benefit our community and could result in a further loss of services, a possibility ignored in this paper. Unless a company is legally obligated to provide service on routes that are not profitable they won’t, as experience has shown.

When a carrier is licensed for a route, which could be flexible and allow as in some American jurisdictions deviations of up to 1km, they must guarantee service for 5 years. To drop a service or line the company would need a 2 year period in which others could investigate taking over the route.

There is a rather charming optimism on the benefits of competition and a complete lack of understanding of the failures of competition. It is the failures need regulation.

As transporting several people in a vehicle is a small but real contribution to the fight against climate change, such services should have a reduction in or payback based on passenger kms. There should be some diminution in the proposed climate change surcharge.

[Original Comment ID: 194632]