The Accessible Canada Act and the Accessible Transportation Planning and Reporting Regulations: A Guide on Accessibility Plans

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Plain language Summary

A plain language summary of the Accessible Canada Act and the Accessible Transportation Planning and Reporting Regulations: A Guide on Accessibility Plans is available.

Introduction

An accessibility plan is a plan that sets out a comprehensive roadmap that transportation service providers (TSPs) will use to improve accessibility during a three-year period. They describe the actions a TSP will take to prevent and remove barriers during that three-year period.

The purpose of this guide is to explain TSPs' obligations under the Accessible Transportation Planning and Reporting Regulations (ATPRR) with respect to accessibility plans. In particular, this guide explains:

  • The principles of accessibility and key terms;
  • The preparation of accessibility plans, including consulting persons with disabilities;
  • The contents of accessibility plans;
  • The requirements for the publication of accessibility plans; and,
  • Best practices related to accessibility plans.

For information on progress reports and feedback processes, please see:

For information on who the ATPRR applies to, classes of entities, and the corresponding publication timelines for each class, please see the guidance on Who Does the ATPRR Apply To?, and Publication Timelines.

This is not a legal document. The explanations and definitions it provides are for general guidance purposes only. The obligations for accessibility plans are established in the Accessible Canada Act (ACA) and the ATPRR. In case of differences between this guide and legislation or regulations, the legislation and regulations prevail.

Principles of Accessibility & Key Terms

Principles of Accessibility

Section 6 of the ACA sets out a series of principles that must be recognized and followed when the requirements of the ACA are carried out.

TSPs should therefore act in accordance with the following principles when preparing their accessibility plans, feedback processes, and progress reports:

  1. all persons must be treated with dignity regardless of their disabilities;
  2. all persons must have the same opportunity to make for themselves the lives that they are able and wish to have regardless of their disabilities;
  3. all persons must have barrier-free access to full and equal participation in society, regardless of their disabilities;
  4. all persons must have meaningful options and be free to make their own choices, with support if they desire, regardless of their disabilities;
  5. laws, policies, programs, services and structures must take into account the disabilities of persons, the different ways that persons interact with their environments and the multiple and intersecting forms of marginalization and discrimination faced by persons; and,
  6. persons with disabilities must be involved in the development and design of laws, policies, programs, services and structures.

Key Terms

The ACA defines a barrier as “anything – including anything physical, architectural, technological or attitudinal, anything that is based on information or communications or anything that is the result of a policy or a practice – that hinders the full and equal participation in society of persons with an impairment, including a physical, mental, intellectual, cognitive, learning, communication or sensory impairment or a functional limitation.”

A barrier may be systemic; it may result from the absence of a policy or the application of an existing policy that has adverse impacts on persons with disabilities; and it may result from an isolated act or omission, such as the failure to apply a policy.

Furthermore, a difficulty encountered during travel does not become a "barrier" merely because it was experienced by a person with a disability: there must be some nexus between the disability and the barrier.

The ACA defines disability as “any impairment, including a physical, mental, intellectual, cognitive, learning, communication or sensory impairment – or a functional limitation – whether permanent, temporary or episodic in nature, or evident or not, that, in interaction with a barrier, hinders a person’s full and equal participation in society.”

This definition is based on the social model of disability, which understands disability as resulting from the interaction between an impairment or functional limitation and the social and physical environment.

It is important for TSPs to have a good understanding of these two terms before creating or updating an accessibility plan.

Making an Accessibility Plan: Recommended Steps

The ACA and the ATPRR do not set out comprehensive requirements in terms of content that TSPs must include in their accessibility plans (please see Contents of an Accessibility Plan for more information on this). This flexibility allows TSPs to develop their accessibility plans and policies in a way that works best for their organization. This section provides some useful steps and information for consideration as TSPs develop their accessibility plans.

Step 1: Determine what you have to do

Learn what the law says

Learn about accessibility

  • learn about the various accessibility-related regulations in Canada
  • get in touch with disability- and accessibility-related organizations and take advantage of their resources
  • read the definition of disability and barrier, per the ACA and ATPRR
  • read the principles of accessibility, set out in section 6 of the ACA

Identify who will be responsible for ATPRR requirements

  • Identify who will be responsible for preparing the accessibility plan and who will be designated to receive and respond to feedback on barriers. This does not have to be the same person; however, if these responsibilities are handled by different individuals, it is strongly recommended that mechanisms are established to ensure that all feedback received is shared with those working on the accessibility plan.

Best practices:

  • TSPs may wish to assemble a team to work on the accessibility plans, progress reports and feedback process. These team members should represent different areas of a TSP’s organization or operation in order to provide different points of view and experiences (e.g., call centre personnel, frontline staff providing direct services, personnel responsible for handling mobility aids and other assistive devices, etc.).
  • Include employees with disabilities

Step 2: Assess your level of accessibility

Review existing policies, programs, practices and services

TSPs should review the accessibility of their organization’s policies, programs, practices, and services. TSPs should be looking for potential barriers to remove, and for ways to prevent new barriers in the future. This step can help TSPs set accessibility priorities and develop strategies that maximize the efficient use of resources.

Consulting to inform the development of an accessibility plan

TSPs are required to consult persons with disabilities in the preparation of their accessibility plans and set out how they consulted persons with disabilities in its accessibility plan.

As part of this consultation, TSPs should seek input from disability organizations. These organizations can not only assist TSPs with identifying potential barriers and methods of removing them, but also assist TSPs with connecting with persons with disabilities that can be directly consulted.

Furthermore, in order to obtain a full picture of the accessibility of their organization, TSPs should reach out to the public, customers or clients, and employees for ideas about how accessibility can be improved and where barriers may exist.

It is important to keep in mind that some persons may be reluctant to participate in consultations due to concerns about repercussions. To address such concerns, TSPs should consider developing a mechanism that allows for persons to participate anonymously in consultations.

For best practices and examples related to consulting persons with disabilities, please see the section titled Consultations in this Guide.

Step 3: Developing and updating an accessibility plan

Developing a multi-year accessibility plan

Accessibility plans should set out a comprehensive road map that TSPs will use to improve accessibility during a three-year period. They should include specific action items with associated timelines and be written in a succinct and simple manner. The accessibility plan template provided in Annex B reflects content requirements set out in the ACA and ATPRR and the guidance provided in this document.

The ATPRR do not prescribe a minimum or maximum number of pages for accessibility plans.

Best practices:

  • TSPs are encouraged to include specific actions in the accessibility plan that can be measured by target deadlines or quantities to be met. For example:
    • Consult persons with disabilities on the accessibility of new automated self-service kiosks by [insert date here];
    • Install new automated self-service kiosks by [insert date here];
    • Implement or address any necessary changes resulting from the consultation by [insert date here];
    • Purchase [insert quantity here] new wheelchairs to assist with boarding and disembarking passengers by [insert date here] to address increased demand.
  • Choose specific statements and measurable actions (avoid vague or aspirational statements). For example, be specific by setting out which aspects you will improve, the steps you will take to do so, and a clear timeline with a deadline that the work will be completed by, instead of general statements of plans to “improve accessibility”.

Reviewing and updating the accessibility plan

The ATPRR and ACA requires that TSPs publish an updated accessibility plan every three years. Please see Publication of an Accessibility Plan for more details on publishing an accessibility plan.

Like initial accessibility plans, updated plans should set out a comprehensive roadmap that TSPs will use to improve accessibility during a three-year period and include specific action items with associated timelines. Updated accessibility plans may also highlight achievements and how TSPs have successfully implemented their previous accessibility plan. TSPs may also note challenges they have encountered in implementing their previous accessibility plan and how they plan to address those challenges.

Best practices:

  • TSPs should actively evaluate the implementation of an accessibility plan and impacts of its individual elements throughout its three-year lifecycle. This can be a useful exercise to help prepare progress reports as well as updated versions of an accessibility plan.

Note: A plan's lifecycle consists of three years – the plan is published, followed by two years during each of which the TSP publishes a progress report. Following this, a TSP will publish an updated accessibility plan, which initiates a new lifecycle.

Contents of Accessibility Plans

Accessibility plans must set out the TSPs policies, programs, practices and services to identify, remove and prevent barriers in six priority areas and include some other content. They must also include the following headings, which correspond to required content:

This Guide provides information on each of these topics, including best practices, examples, and sources that TSPs may consult. The examples provide content ideas for each of the priority areas (i.e. information and communication technologies, communication, procurement, etc.) and reflect Canadian Transportation Agency (CTA) accessibility-related regulations and standards listed below.

The CTA encourages TSPs to exceed minimum requirements wherever possible. The references to best practices, examples and sources may also inspire regulated transportation entities to go farther in eliminating barriers to accessibility.

Furthermore, the CTA has prepared an accessibility plan template and checklist, which can respectively be in found in Annexes A and B.

Different organizations have different resources, needs and capabilities. As such, the ACA and the ATPRR do not mandate overly specific content that a TSP must include in its accessibility plan beyond the headings. This flexibility allows TSPs to develop their accessibility plan and policies in a way that works best for their organization.

Accessibility-Related Regulations and Standards

General

In this section of their accessibility plan, a TSP must include the following information:

  • the name of the person designated to receive feedback on behalf of the entity, or the position of the person who is designated to receive feedback on behalf of the entity;

    and

  • how the public can provide feedback, request an alternate format of the accessibility plan, and request an alternate format of the description of the feedback process. This must include a:
    • mailing address
    • telephone number, and,
    • an email address.

Information and Communication Technologies (ICT)

In this section of their accessibility plan, a TSP must set out its policies, programs, practices and services designed to identify, remove, and prevent barriers in ICT.

ICT includes the accessibility of all telecommunication systems, computer systems and networks owned, operated or controlled by the TSP. This also includes websites and mobile applications owned, operated or controlled by the entity, as well as announcements made in terminals and onboard.

Examples of ICT as it relates to the transportation network:

  • Ensuring information made available in an electronic format is compatible with adaptive technology;
  • Providing alternative means of communication in addition to telephone systems, such as an email or a telephone relay;
  • Ensuring that websites made available to the public are accessible to all persons, including persons using adaptive technology;
  • Public announcements in terminals are provided in both audio and visual formats in all passenger service areas inside terminals. These announcements include information concerning departure delays, gate or track assignments and schedule or connection changes.

Communication, Other Than ICT

In this section of their accessibility plan, a TSP must set out its policies, programs, practices and services designed to identify, remove, and prevent barriers with respect to non-ICT aspects of communication. Stated differently, it must set out information about how it addresses communicating, in language that is informed, respectful and accessible to persons with disabilities. This includes spoken, written, signed, and other forms of communication.

This section should address how a TSP communicates information about the following using non-ICT methods (i.e., communicating information without the use of technology, such as providing information verbally or by using signage):

  • information and communication technologies;
  • the procurement of goods, services and facilities;
  • the design and delivery of programs and services; and,
  • transportation.

Examples of communication, other than ICT, as it relates to the transportation network:

  • Ensuring that members of a TSP’s personnel who interact with passengers in the course of carrying out their functions take into account:
    • the nature of person’s disability;
    • whether the person uses an assistive device to assist them to hear, see or communicate; and,
    • whether there are methods of communication that may be used by the person or that may assist with communication with the person, such as an augmentative or alternative communication system, sign language or clear, concise and plain language;
  • Seeking information from a person with respect to their preferred method of assistance when providing physical assistance;
  • Engaging in a conversation with a person if they identify the nature of their disability when making a reservation, for the purpose of identifying their needs in relation to their disabilities and the services offered by the TSP in relation to those needs;
  • Describing, if requested, the services that a TSP can provide to persons, and any conditions in respect of those services.
  • Public announcements are of a good quality, in plain language, with clear enunciation and spoken slowly enough to be easily understood. In addition, messages should be repeated, and prerecorded messages are to be used as often as possible to improve the clarity of announcements.

 

Best practices for communication, other than ICT:

  • TSPs should ensure that all members of personnel who interact with passengers receive training on how to communicate in a language that is informed, respectful, and accessible to persons with disabilities.
  • If TSPs have personnel who are able to communicate in American Sign Language (ASL) or langue des signes québécoise (LSQ), they should consider having them available to assist when needed.
  • TSPs are responsible for ensuring that persons with visual or hearing disabilities can receive publicly available information about the TSP’s services or facilities (including equipment) in ways that are accessible to those travellers. This means offering that information in alternative formats – in addition to conventional print and video formats – such as:
    • accessible electronic formats
    • large print
    • audio formats
    • braille
    • providing information in clear, short sentences, and avoid speaking too fast
    • break instructions into small parts
    • ask the person if they would like key information in writing
    • consider moving to a quiet or private location, especially if you’re in a public area with many distractions
  • For more information on best practices for interacting with a person with a disability, please see Best Practices for Interacting with Persons with Disabilities: A Guide.
  • For more information on creating accessible documents, you could consult the following resources: the Digital Accessibility Toolkit and the Canada.ca Content Style Guide.

 

Procurement of Goods, Services and Facilities

In this section of its accessibility plan, a TSP must set out its policies, programs, practices and services designed to identify, remove, and prevent barriers in its procurement of goods, services and facilities.

Procurement refers to the act of purchasing, including the overall evaluation process leading up to the purchase. The procurement of goods, services and facilities can include purchasing equipment (e.g., lifts, wheelchairs, or aircrafts and rail cars), putting contracts or arrangements in place for the provision of services (e.g., ground handlers who package, load and unload mobility aids, ground transportation service providers, such as taxi drivers, who provide service to and from terminals), and for specifications and requirements related to newly built or renovated terminals and any related facilities.

TSPs are expected to include accessibility as a key criteria during the procurement process when evaluating goods and services that will be used by, or to assist, persons with disabilities.

Best practices for procurement of goods, services and facilities:

  • Accessibility should be included as a criteria or a requirement for proposals of goods, services and facilities.
  • It is often easier and more cost-effective to include accessibility at the beginning than to retrofit or alter something to include accessibility at a later date, and it will ensure the good or service is accessible to all upon delivery.
  • In addition to including accessibility as a criteria, TSPs should consult persons with disabilities prior to investing in new purchases in order to evaluate accessibility from the perspective of a person with a disability. Consulting persons with disabilities can help establish the best accessibility criteria to assist with the removal of existing barriers, and avoid the creation of new and unforeseen barriers as existing barriers are removed. For example, new technology that scans the eye (retinal scans), may be more accessible to many people with mobility limitations, but may create a barrier for some persons who are blind or have reduced vision because the technology can requirements.

Design and Delivery of Programs and Services

In this section of its accessibility plan, a TSP must set out information about how it identifies and removes barriers, and prevents new ones by the way it designs and delivers its programs and services.

This includes the details about how a TSP considers and includes accessibility when designing and delivering its services and programs to its clients, such as assisting with check-in, boarding and disembarking, the transportation of support persons or service dogs, the transportation of mobility aids, curbside assistance, training provided to personnel, etc. Additionally, this also includes feedback received from TSP personnel on the design and delivery of the TSP’s programs and services.

Best practices for design and delivery of programs and services:

  • TSPs should consult persons with disabilities in the development of services directed to them, as well as in the development of training programs to support a TSPs services.
  • TSPs could look into establishing an advisory committee which would include representatives from the disability community, ideally providing representations of various disabilities and experience. In addition to providing insight and feedback on a TSP’s accessibility plan, an advisory committee could provide feedback on a TSPs accessibility-related programs and services based on their lived experience.

Transportation

In this section of its accessibility plan, a TSP must set out its policies, programs, practices and services designed to identify, remove, and prevent barriers in transportation used to access the TSP’s services. For some TSPs, this would include the provision of accessible transportation to and from a terminal, such as wheelchair accessible taxis or shuttle buses. This would also include any transportation provided between terminals at some airports.

Best practices for transportation:

  • TSPs who enter into an agreement or arrangement with a service provider for the provision of ground transportation from the terminal should ensure that the transportation is accessible to persons with disabilities. This includes taxis, limousines, bus or rental vehicles;
  • TSPs who enter into an agreement or arrangement with any service providers for the provision of rental vehicles from a terminal should ensure that the service provider provides rental vehicles that are equipped with hand-control systems.

The Built Environment

In this section of its accessibility plan, a TSP must set out its policies, programs, practices and services designed to identify, remove, and prevent barriers in the built environment.

The built environment refers to human-made structures, features, and facilities. For the purposes of the ATPRR, the built environment includes:

  • passenger aircraft
  • passenger trains
  • passenger buses
  • passenger vessels (ferries)
  • aerodrome passenger terminals (airports)
  • railway passenger station
  • bus passenger station, and
  • marine passenger terminals

With respect to foreign air, rail, ferry and bus carriers, the accessibility of the built environment can include:

  • passenger aircraft, passenger trains, passenger buses, and passenger vessels (ferries) used to provide services to and from Canada, and ancillary services provided in relation to such transportation; and,
  • programs that foreign carriers may have in place to ensure accessibility of Canadian and foreign airports, if applicable.

Examples of the built environment as it relates to the transportation network:

  • signage and wayfinding in and around a terminal;
  • washroom accessibility;
  • accessibility of passenger aircraft, passenger trains, passenger buses and passenger vessels, including the means to board and disembark from such modes of transportation and any equipment that may be necessary to facilitate this;
  • service animal relief areas; and,
  • access to accessible parking and an accessible path of travel to and from a terminal.

 

Best practices for the built environment:

  • TSPs should aim to follow universal design standards where possible when making modifications or new additions to the built environment.
  • Accessibility criteria should be considered at the beginning of a built environment project, as it is often easier, more efficient and cost effective to do so, and it will ensure the built environment is accessible to all from the outset.
  • TSPs should consult persons with disabilities when making modifications or new additions to the built environment which might relate to or impact accessibility.

 

Provisions of CTA Accessibility-Related Regulations

In this section of its accessibility plan, a TSP is required to set out a plan respecting the provisions of the CTA regulations made under ss. 170(1) of the Canada Transportation Act (Act) that apply to them, or the CTA accessibility-related regulations which apply to them.

This means that a TSP must, at a minimum, identify or list all provisions from the CTA accessibility-related regulations that apply to it. TSPs have flexibility to determine how this content is organized and the level of detail included.

TSPs are encouraged to use this section of their accessibility plan as an opportunity to explain what they are doing to comply with, or exceed, their accessibility-related requirements.

The regulations that the CTA has made under ss. 170(1) of the Act are:

Consultations

This section must set out information on how a TSP consulted with persons with disabilities in the preparation of its accessibility plan.

Best practices:

  • TSPs could look into establishing an advisory committee which would include representatives from the disability community, ideally providing representations of various disabilities and experience. In addition to providing insight and feedback to assist in developing an accessibility plan, an advisory committee could provide feedback on a TSPs accessibility-related programs and services based on lived experience.
  • Consulting with disability rights organizations.

Examples of other information that could be included under the consultation section:

  • whom you consulted
    • the names of any disability organizations, advocates, or experts who participated

  • the number of participants

    Note: The names of other participants and their identified disabilities should be omitted to protect privacy

  • when you consulted
    • the dates or period of time during which the consultation(s) took place
  • how you consulted
    • a description of the consultation process and activities (for example, whether you used in-person events, virtual meetings, group discussions, digital surveys, or other means)
  • what you consulted on
    • description of questions asked and answers received
    • specific details of how those questions and answers informed decisions made about your accessibility plan

Publication of an Accessibility Plan

For information relating to the timelines for publishing an accessibility plan, please see the guidance on Publication Timelines.

General Requirements for Publication

TSPs must publish their most recent accessibility plan in clear, simple and concise language. This means that sentences should be short, grammar should be simple, and technical words, jargon and acronyms should be avoided where possible, such that the text is easily understandable. For more information on creating accessible documents, you could consult the following resources: the Digital Accessibility Toolkit and the Canada.ca Content Style Guide.

TSPs who use a digital platform must electronically publish their accessibility plans on the main digital platform that the TSP owns, operates or controls and that it uses to communicate information to the public. In most cases, this will be a TSP’s website.

A TSP must publish this information in a manner that makes the accessibility plan accessible on the digital platform either directly on the homepage or home screen, or by way of a hyperlink from that homepage or home screen.

A TSP must ensure that its accessibility plan meets the requirements of Level AA conformance that are set out in the Web Content Accessibility Guidelines (WCAG) in the most recent version that has been published in both French and English by the World Wide Web Consortium.

No Digital Platform

TSPs who do not use a digital platform to communicate information to the public must publish a print copy of the most recent accessibility plan. Same as the accessibility plans that are published on digital platforms, print copy of accessibility reports must also be published in clear, simple and concise language.

The hard copy publication must be displayed in a conspicuous location in the main reception area of each of its publicly accessible business locations.

Feedback Process

Don’t forget! – a TSP must publish a description of its feedback process with its accessibility plan or progress report, in a format that meets the requirements of Level AA conformance that are set out in the WCAG version 2.0. The ATPRR reference the most recent version of WCAG that has been published in both French and English by the World Wide Web Consortium.

Notice to the Agency

A TSP must notify the CTA by electronic means (e.g., email) within 48 hours of publication of each version of its accessibility plan, and include in the notice:

  • a hyperlink to the URL of the plan;

    OR

  • the addresses of the publicly accessible business locations where a print copy of the accessibility plan is available.

TSPs should submit their notice to the CTA using the following email address: OTC.REPRTA-ATPRR.CTA@otc-cta.gc.ca.

Alternate Formats

A person can request that a TSP make its accessibility plan available to them in the following alternative formats:

  • print
  • large print
  • braille
  • audio format, or
  • an electronic format that is compatible with adaptive technology that is intended to assist persons with disabilities.

A person may make the request for an alternative format of a TSP’s accessibility plan through any means by which the regulated transport entity communicates with the public, including by mail, by telephone, or via electronic means, such as email.

A TSP must make its accessibility plan available to the person in the alternate format requested as soon as feasible after the request is received, but no later than:

  • For braille or an audio format: 45 days after the day that the request is received;
  • For any other format:
    • for Class 1 and Class 2 TSPs: on the 15th day after the day that the request is received, and
    • for Class 3 TSPs: on the 20th day after the day that the request is received.

Alternative formats

Large print usually refers to 16 point font and sans serif (for example, Arial or Calibri are both sans serif fonts).

Information provided in an electronic format must be compatible with adaptive technology, including software that converts text voice (screen readers) for persons who are blind or have low vision.

Best practices for alternative formats:

  • If the type of alternative format needed has not been made clear in the request, it is always best to discuss with the person as to what format is accessible to them. For example, some persons may require 24 point font instead of 16 point font for large print, and other persons may find a plain text or html document reads better with a screen reader than a PDF version.

How the ATPRR Relates to the ATPDR and Other CTA Regulations (ATR and PTR)

The provisions set out in the Accessible Transportation for Persons with Disabilities Regulations (ATPDR) and the planning and reporting requirements set out in the ACA and the ATPRR are complementary.

Though some provisions of the ATPDR are forward looking, it includes an extensive range of specific provisions with which large domestic and international transportation service providers are required to comply. This sets a specific threshold that transportation service providers must meet in their provision of accessible transportation for persons with disabilities.

There are also the Personnel Training for the Assistance of Persons with Disabilities Regulations and Part VII of the Air Transportation Regulations that set specific accessibility requirements and apply to TSPs who are not captured under the ATPDR.

The ACA and the ATPRR complement the provisions in the ATPDR, the PTR and Part VII of the ATR, by requiring transportation service providers to fulfill planning and reporting requirements that will enable them to take substantive steps to eliminating any remaining barriers, and preventing new barriers, that persons with disabilities may face when accessing their transportation services.

We're here to help

For more information and guidance about accessible travel and the CTA's dispute resolution services, please contact us at info@otc-cta.gc.ca.

Annex A: Template

ATPRR Accessibility Plan Template

Note: The below template sets out the headings or sections that the ATPRR requires a Transportation Service Provider (TSP) to include in its accessibility plan. The text below each heading are intended as notes to set out what information a TSP is required to include in each respective section.

Prior to drafting the initial accessibility plan, or updating an existing accessibility plan, TSPs should review and familiarize themselves with the Principles of Accessibility, as a TSP’s accessibility plan must be in accordance with these principles.

For further information on accessibility plans and the specific sections identified below, as well as suggestions on additional information that could be included in an accessibility plan and best practices, please see the Accessible Canada Act and Accessible Transportation Planning and Reporting Regulations: A Guide on Accessibility Plans.

General - Annex A

This section must include the following information:

  • the name of the person designated to receive feedback on behalf of the TSP or the position of the person who is designated to receive feedback on behalf of the TSP;

    and

  • how the public can provide feedback, request an alternate format of the accessibility plan, and request an alternate format of the description of the feedback process. This must include a:
    • mailing address
    • telephone number, and,
    • an email address.

Areas described under section 5 of the ACA - Annex A

Information and communication technologies (ICT) - Annex A

This section must set out a TSP’s policies, programs, practices and services designed to identify, remove and prevent barriers in ICT.

Communication, other than ICT - Annex A

This section must set out a TSP’s policies, programs, practices and services designed to identify, remove and prevent barriers in communication, other than ICT. Stated differently, this section must set out information about how a TSP addresses communicating in language that is informed, respectful and accessible to persons with disabilities.

It should include details about how information is communicated to the public where the information is conveyed via methods not using technology.

This section should address how a TSP communicates information about the following using non-ICT methods:

  • information and communication technologies;
  • the procurement of goods, services and facilities;
  • the design and delivery of programs and services; and,
  • transportation.

Procurement of goods, services and facilities - Annex A

This section must set out a TSP’s policies, programs, practices and services designed to identify, remove and prevent barriers in its procurement of goods, services and facilities.

Design and delivery of programs and services - Annex A

This section must set out information about how a TSP identifies and removes barriers, and prevents new ones by the way it designs and delivers its programs and services.

Transportation - Annex A

This section must set out a TSP’s policies, programs, practices and services designed to identify, remove, and prevent barriers in transportation used to access the TSP’s services, such as the provision of accessible transportation to and from a terminal.

Built environment - Annex A

This section must set out a TSP’s policies, programs, practices and services designed to identify, remove and prevent barriers in the built environment.

The built environment includes:

  • passenger aircraft
  • passenger trains
  • passenger ferries
  • passenger buses
  • airport or aerodrome passenger terminal
  • railway passenger station
  • ferry or marine passenger terminal, and
  • bus passenger station.

Provisions of CTA accessibility-related regulations - Annex A

This section must set out a TSP’s plan respecting the provisions of the CTA accessibility-related regulations which apply to them.

This means that a TSP must identify or list all provisions from the CTA accessibility-related regulations that apply to it.

In addition, a TSP must set out how its plan respects the provisions that apply to the TSP. TSPs have the flexibility to determine how the content of the plan is addressed, and what level of detail is included.

Consultations - Annex A

This section must set out information on how a TSP consulted with persons with disabilities in the preparation of its accessibility plan.

Annex B: Checklist

The following checklist is intended to assist Transportation Service Providers (TSPs) in completing their initial and updated accessibility plans. The below items are set out in the order in which it is suggested that TSPs approach their accessibility plans in order to meet all requirements.

This is not a legal document. The explanations provided are for general guidance purposes only. The obligations for accessibility plans are established in the ATPRR and the Accessible Canada Act (ACA), and in Annex A of this guide. In case of differences between this guidance material and legislation or regulations, the legislation and regulations prevail.

Step 1: Review the principles set out in the ACA

Include the following headings in the progress report:

  • Confirm that you have reviewed the following principles, set out in the ACA, which are intended to guide the interpretation and application of the ACA and the ATPRR in the preparation of an accessibility plan, or an updated version of an accessibility plan:
    1. all persons must be treated with dignity regardless of their disabilities;
    2. all persons must have the same opportunity to make for themselves the lives that they are able and wish to have regardless of their disabilities;
    3. all persons must have barrier-free access to full and equal participation in society, regardless of their disabilities;
    4. all persons must have meaningful options and be free to make their own choices, with support if they desire, regardless of their disabilities;
    5. laws, policies, programs, services and structures must take into account the disabilities of persons, the different ways that persons interact with their environments and the multiple and intersecting forms of marginalization and discrimination faced by persons;
    6. persons with disabilities must be involved in the development and design of laws, policies, programs, services and structures; and

Step 2: Required headings for your accessibility plan

Include the following headings in the accessibility plan:

  • General
  • Information and communication technologies (ICT)
  • Communication, other than ICT
  • Procurement of goods, services and facilities
  • Design and delivery of programs and services
  • Transportation
  • Built environment
  • Provisions of CTA accessibility-related regulations
  • Consultations

Step 3: Required contents for the headings of your accessibility plan

Required contents for the “General” heading

Under the “General” heading, include the following information:

  • The name of the position or person designated to receive feedback on behalf of the entity
  • The means by which the public can provide feedback

  • The means by which the public can request an alternate format of the accessibility plan or an alternate format of the description of the feedback process

    These "means" must include: a mailing address, telephone number, and an email address

Required contents for other headings of your accessibility plan

Include all relevant information under each heading as described in the Accessible Canada Act and Accessible Transportation Planning and Reporting Regulations: A Guide on Accessibility Plans. TSPs have the flexibility to determine how this content is addressed and what level of detail is included. Best practices and CTA-related examples of information to be included can also be found in the Guide.

  • Information and communication technologies (ICT)
  • Communication, other than ICT
  • Procurement of goods, services and facilities
  • Design and delivery of programs and services
  • Transportation
  • The built environment
  • Provisions of CTA accessibility-related regulations

Required contents for the “Consultation” heading

Step 4: Publishing your accessibility plan

Before publishing your accessibility plan, review and confirm:

  • it is written in clear, simple and concise language.

  • the document meets the requirements of AA conformance that are set out in the WCAG version 2.0.

    Note: The ATPRR reference the most recent version of WCAG that has been published in both French and English by the World Wide Web Consortium.

When publishing the accessibility plan and any updates, confirm:

For TSPs who use a digital platform:

  • Publish the accessibility plan on the main digital platform, either directly on the homepage or home screen, or by way of a hyperlink from that homepage or home screen.

For TSPs who do not use a digital platform:

  • Publish a print copy of your most recent accessibility plan and display it in a conspicuous location in the main reception area of each of its publicly accessible business locations.

Feedback process – don’t forget!

Publish a description of your feedback process together with your accessibility plan, in a format that meets the requirements of AA conformance that are set out in the WCAG.

Step 5: Notice to the Agency

  • Within 48 hours of publication, notify the CTA by electronic means that a new version of the accessibility plan has been published.

    TSPs should submit their notice to the CTA using the following email address: OTC.REPRTA-ATPRR.CTA@otc-cta.gc.ca.


  • Include in the notice a hyperlink to the URL of the plan

    OR

    the addresses of the publicly accessible business locations where a print copy of the accessibility plan is available.

Step 6: Alternate formats

A TSP must provide its accessibility plan in an alternate format upon request. Please see the Accessible Canada Act and Accessible Transportation Planning and Reporting Regulations: A Guide on Accessibility Plans for additional information on alternate formats, including required response times and best practices.

Should you receive a request, confirm that you are prepared to make your accessibility plan available in the following formats and on time:

  • Print (for class 1 and class 2 TSPs – on the 15th day after the day that the request is received; for class 3 TSPs – on the 20th day after the day that the request is received)
  • Large print (for class 1 and class 2 TSPs – on the 15th day after the day that the request is received; for class 3 TSPs – on the 20th day after the day that the request is received)
  • Braille (45 days after the day that the request is received)
  • Audio format (45 days after the day that the request is received)
  • Electronic format that is compatible with adaptive technology that is intended to assist persons with disabilities (for class 1 and class 2 TSPs – on the 15th day after the day that the request is received for class 3 TSPs – on the 20th day after the day that the request is received)

A TSP must accept a request for an accessibility plan in an alternative format made through any means by which the TSP communicates with the public. This includes by mail, by telephone, or via electronic means, such as email.

As applicable, depending on the means by which you communicate with the public, confirm there is a mechanism in place to ensure all requests made:

  • by mail are met
  • by telephone are met
  • via email are met
  • via any other electronic means used to communicate with the public are met

Publication information

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