August 31st, 2016…

August 31st, 2016

Melissa Evers
Team Lead
Ministry of Transportation
Policy and Planning Division
Transportation Planning Branch
Environmental Policy Office (Toronto)
777 Bay Street
Suite 3000
Toronto Ontario
M7A 2J8

RE: EBR 012-7896 Intercity Bus Modernization Proposal

Dear Ms. Melissa Evers,

Thank you for this opportunity to comment on the Intercity Bus Modernization: Creating Opportunities and Connecting Ontario Communities Discussion Paper.

The Region of Peel recognizes the evolving transportation landscape and how it has changed the way people travel and access important services. The Region also recognizes the value of intercity transportation services as well as supporting passenger travel between communities.

Region of Peel staff have prepared a collection of comments in response to the EBR posting (Registry Number 012-7896). Our comments are organized according to the Key Questions posed by the Ministry of Transportation. This is followed by more general comments on the issues and proposal outlined in the Discussion Paper.

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

The removal of market entry controls of the intercity bus industry is supported in principle with the understanding that Governments and other road safety stakeholders (including all road users) share the responsibility for protecting the safety of the travelling public, and ensuring that the industry remains an attractive, integrated, equitable, and health promoting choice for residents. Governments also have a role in fostering an economic environment which is attractive to the private sector in offering services that support the mobility needs of Ontarians while adequately addressing public safety, equitability and liability.

The removal of market entry controls could also provide an opportunity to increase connectivity and access to better meet the transit needs of the community. Some long distance providers have scaled back routes to lower served areas. Removing market entry controls can provide an opportunity to increase connectivity within communities. The removal is also supported in principle provided that the reforms are integrated with other transit plans such as the Metrolinx Regional Transportation Plan, and that other forms of publicly funded transit remain supported and viable.

Q: What are the benefits of removing market entry controls? What are the drawbacks?

Benefits

The removal of market entry controls could allow the private sector to identify and pursue opportunities to offer and sustain intercity transportation services within the marketplace based on sound and innovative business plans and practices. Initiatives allowing carriers to enhance the viability of their services while enhancing or preserving the quantity and quality of services available to intercity bus users is a key consideration for addressing consumer and community needs.

Market control removal also has the potential to foster the pursuit of partnerships with the other modes of intercity passenger transportation (passenger rail, passenger air, and transit) in order to promote multi-modalism, connectivity, and integration in the Ontario transportation system. Stronger transit and connectivity can be achieved in areas where it does not currently exist or is changing. This can benefit users and support the sustainability for all modes of travel.

Drawbacks

The most significant challenge for communities and individuals that live in them could be either reductions in inter-city transit services or complete elimination of services due to route profitability considerations. Reducing the current monopoly on routes and making it easier for new companies to enter the market place may help however, if these routes are being eliminated because they’re unprofitable (due in part 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. Consideration could be given to structure licences that serve a catchment area rather than a particular route with a legal requirement for employing cross-subsidization of routes as a business accounting practice.

Q: What do you think the minimum safety and insurance requirements should be for vehicles being used to transport people between municipalities for a fee?

* Noted in the EBR posting: 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.

There is general agreement with the statement concerning a need for vehicle safety inspections and insurance. It is suggested that safety and service quality assurance requirements be extended to vehicle operators. Vehicle safety inspections should apply to all passenger carrying vehicles (regardless of size) that charge a fee for their services, and that appropriate vehicle insurance should also be required.

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

Not applicable to Peel Public Health and the Peel Region’s TransHelp services.

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

Municipalities and social and health organizations can better partner with transportation providers to serve the public through the sharing and pooling of resources and technology. They can also better partner with transportation providers through the development of ‘Community Mobility Plans’. These types of plans can help highlight challenges, gaps, and opportunities to providing health supportive and sustainable transportation options for residents and clients, which can then enhance collaboration and partnership opportunities among municipalities, social and health organizations, and transportation providers.

Further, individual jurisdictions that provide fiscal programs targeted at specific routes and/or carriers on a case by case basis to sustain services that are determined to be needed in the public interest should be encouraged. In addition new/emerging carriers, alternative service providers and existing carriers could be permitted to use smaller vehicles where economically feasible to provide intercity passenger service that meets localized community/niche market needs while ensuring that all Federal safety standards and Provincial safety laws and regulations are adhered to.

Q: 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?

• Town of Milton – Dynamic Transit Pilot Project: Launched on May 4th, 2015 to test the viability of an alternative service delivery concept to a fixed route transit service that addressed GO Transit and Milton Transit system integration needs with enhanced passenger connectivity. The approach used available technology from RideCo (the on-line application vendor) to provide a demand-responsive service application to connect passengers to/from Milton Transit to/from their desired GO Train in the am and pm peak periods. The pilot successfully tested a number of key parameters including: premium fares/premium service capabilities, demand-responsive logistics and other customer-facing application functions.

• Province of British Columbia: Vanpool commuter services that are an element of the transit system are available and allow groups to share the ride similar to a carpool, but on a larger scale with savings in fuel and vehicle operating costs. The Jack Bell Foundation in partnership with Translink (the Greater Vancouver Transportation Authority) operates this ridesharing service that provides businesses and their employees with more transportation choice.

General Comments

• Metrolinx’s the Big Move transportation and transit plan for the Greater Toronto and Hamilton Area includes two priority actions that offer insight into regulatory barriers present in the Public Vehicle Act that prohibit third parties from providing commuter rideshare services for employers and their employees as follows:

Priority Action 3.5

Continue to support the Smart Commute CarpoolZone online ride-Matching service, and identify and eliminate legal and liability barriers to ride-sharing.

Priority Action 3.6

Amend the Ontario Public Vehicles Act to allow third-parties such as nongovernmental organizations to provide vanpools to service major trip generators such as employers, post-secondary institutions and tourism destinations and to augment public transit service in low density or dispersed employment areas.

Consider reviewing the current definition of ‘carpool’ to permit;

• Third party operated car and vanpools
• A fee to be charged or paid to the driver OR link the reimbursement of expenses per passenger to Canada Revenue Agency – ‘Automobile allowance rates’ (http://www.cra-arc.gc.ca/tx/bsnss/tpcs/pyrll/bnfts/tmbl/llwnc/rts-eng.html)
• The owner/lessee of the vehicle to operate more than one carpool vehicle
• The driver to take passengers on more than one trip in a day.
• From the Transportation Demand Management (TDM) perspective, there is an interest in vanpool. The current Public Vehicle Act only allows employees employed by the same company to legally form a vanpool – employees from other companies are not able to enter into the same vanpool. A suggestion for MTO would be to reassess the Public Vehicle Act’s allowance of a 3rd party (e.g. Enterprise care rental) to run and operate vanpool. This would allow the 3rd party company to recruit vanpool participants between origins and destinations from different municipalities (e.g. Markham Civic Centre Area to Square One, Mississauga), and vanpool participants would pay a fee to join the vanpool for their daily commute. This interest in vanpooling and amending the Public Vehicle Act to allow for a 3rd party vanpool operator in part stemmed from a presentation by MTO to the TDM Coordinating Committee in December 2011. Priority Action 3.6 of Metrolinx’s The Big Move (referenced above) also speaks to this interest.
• It is suggested that health equity and links to personal and community mobility be considered during this policy review.
• Consider opportunities to align potential changes to the Public Vehicle Act with Provincial and Regional Climate Change Strategies. Recommend that considerations to connections to the Provincial Climate Change Strategy with specific reference to low carbon and zero emission vehicles.
• Ensure that any recommended changes to the Public Vehicle Act are in compliance with the Human Rights code definition of disability as well as the Accessibility for Ontarians with Disabilities Act.
• Review and consider allowing service fee structures that respond to service demand dynamics, i.e. peak and off peak period pricing, and that support improved load factors on routes.

Conclusion

Thank you for this opportunity to comment. The Region looks forward to the responses from the Ministry of Transportation on the results of these consultations involving intercity bus modernization.

If you have any questions, please feel free to contact me.

Sincerely,

Elizabeth Bang
Planner
Transportation System Planning
Transportation Division, Public Works
Tel: 905-791-7800, ext. 4694
E-mail: elizabeth.bang@peelregion.ca

[Original Comment ID: 195031]