Dear Ms. Evers;…

Dear Ms. Evers;

RE: Intercity Bus Modernization Proposal

The City of Guelph is a single tier mid-sized city of 126,000 residents. Social and health services offered in Guelph serve residents of both the municipality and Wellington County. Transportation is an important component of our Official Plan policies and our Community Energy Initiative goals. Changes to intercity bus services are of interest to our community. We therefore submit the following responses to the relevant guiding questions.

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

The City of Guelph supports measures that facilitate the diversification of intercity transportation services in Ontario. Reducing market entry controls, without fully removing them, may facilitate the expansion of passenger travel routes and services and still permit the Province to properly oversee issues such as safety.

Diversifying and increasing the market offer of intercity bus service will be important in achieving the Province’s climate change objectives within the transportation sector. For example, the 2011 Transportation Tomorrow Survey data estimates that there are 16,700 work-based trips per day between the Guelph and the Region of Waterloo. Assuming these are return trips, a 10% mode shift to public transportation could eliminate 800 vehicles from the road network and provide a net emission reduction potential of 19 tonnes of CO2 per day (23 kg/day x 800 vehicles, based on carpool.ca estimates for a typical compact car.).

The current intercity bus options include GO bus and Greyhound, with minimal non-peak hour service between communities.

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

Allowing new innovative business models to provide intercity mobility, including taxi-buses, shuttles, ride-sharing services and traditional bus service models, would be a step toward more equitable mobility between communities that are presently underserved by transportation options. This has important benefits to several demographics, including the elderly, youth and individuals who do not have a driver’s licence. Communities may also benefit economically by attracting new tourism dollars from a market of visitors who otherwise would not be able to access local attractions and events.

A disadvantage is the potential for oversaturation of services for certain priority routes such as 401 corridor, and the challenges of attracting services to smaller communities and cities or lower-demand routes. This would be detrimental to Guelph: the TTS results of traffic from Peel, Toronto and Halton Regions that are likely using the 401 corridor represent comparable statistics to trips to and from Wellington County. We recommend that moderate regulation of the market should seek to incentivize service provision to meet these latent demand areas and improve non-GTA intercity connectivity.

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?

With the emergence of new ride-sourcing and ride-sharing services such as Uber, there is a need for the Province to coordinate with municipalities so that provincial regulation and municipal bylaws of these services can be aligned. Service Providers should be held to the same standard as all other commercial vehicle operators (passenger) and the appropriate class of vehicle as it varies by vehicle type.

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

Approximately 4% of transports are attributed to non-urgent medical transfer, based on the lowest acuity of transport.

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

Wellington County is the Consolidated Municipal Service Manager (CMSM) for the provision of social services program for both Wellington County and the City of Guelph. Guelph is a separated city from the County.

The County, as CMSM, funds a rural transportation program, administered by the Community Resource Centre of North and Centre Wellington. This program is a collaborative network of community service providers providing transportation services for residents of Centre, North or East Wellington who do not have access to transportation and meet eligibility criteria for service. Target populations for this service include: seniors, adults with a disability, low income families and individuals. This service operates separately from the City’s transit system.

Wellington County hired a consultant Dillon Consulting to review opportunities for shared services and coordination over a year ago as part of a pilot program with the ministry. It was determined that there was very little application for the City of Guelph as we already provide conventional and mobility transit.

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?

No comments.

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

It would be helpful to have more transparent access to intercity transportation data. Publicly-available data is limited to census and national household survey data. The Transportation Tomorrow Survey is paid for by municipalities and not all Ontario municipalities have opted in; furthermore, it faces challenges with collecting accurate public transit ridership data. Private transportation services are often reluctant to release their ridership data. As a result, it is difficult for emerging companies or interested municipalities to accurately estimate the potential demand for intercity transportation and to propose services to areas in need. The Province should require transparency in reporting basic data metrics that support transportation data analysis and GHG measurements. This could include requiring service providers to release average daily trips with origins and destinations.

It would be an added benefit if the permitting/licensing mechanisms worked to ensure that all communities can attract services. For example, setting a cap on licenses may be helpful to ensure a geographic balance in routes offered. License fees could be structured to incentivise operators in under-serviced areas; or applicants can be required to demonstrate how revenue from highly profitable regions will be redistributed to provide services in low-serviced areas.

Thank you for the opportunity to comment on the Intercity Bus Modernization proposal. We hope these and other comments will strengthen and improve the intercity bus industry so as to provide more convenient, safe and flexible transportation options to Ontarians.

Sincerely,

Jennifer Juste, TDM Coordinator
Engineering Services, Infrastructure, Development and Enterprise
Location: City Hall
T 519-822-1260 x 2791
E jennifer.juste@guelph.ca

[Original Comment ID: 194650]