Compliance Report: Terminal Code
Table of contents
The Agency found that the majority of federally-regulated transportation terminals are now fully compliant with provisions of the Code of Practice: Passenger Terminal Accessibility.
I. Background
The Canadian Transportation Agency (Agency) is responsible for ensuring that undue obstacles to the mobility of persons with disabilities are removed from federally regulated transportation services and facilities, which include air, rail, and extra-provincial ferry and bus transportation. It seeks to remove such obstacles by developing regulations, codes of practice and standards; communicating with the transportation industry and the community of persons with disabilities; resolving individual accessibility-related disputes; and by ordering corrective measures as required.
The Agency follows the federal government's policy of setting standards using alternatives to regulations, and therefore develops voluntary codes of practice and other standards. In June 2007, the Agency released its Code of Practice: Passenger Terminal Accessibility (Terminal Code), which was developed in consultation with the Agency's Accessibility Advisory Committee and other stakeholders. The purpose of the Terminal Code is to ensure a minimum level of accessibility for passenger terminals across Canada, thereby improving the accessibility of terminals for persons with disabilities on a systemic basis as they use the federal transportation system.
The Terminal Code is applicable to operators of air terminals within the National Airports SystemFootnote 1 and certain rail terminal operatorsFootnote 2 and ferry terminal operatorsFootnote 3. Those covered by the Terminal Code were expected to have implemented its provisions by June 2009. Interprovincial bus operations are covered by a code of practice administered by Transport Canada and, as such, are not subject to the Terminal Code.
The Agency actively monitors compliance by transportation service providers with its regulations and codes of practice. A risk-based approach to prioritizing its monitoring activities is used and Agency staff works with transportation service providers to address deficiencies identified during monitoring exercises. The Agency publicly reports on the results of its compliance initiatives.
II. Scope of the Agency's compliance initiative
The Terminal Code contains provisions concerning information regarding ground transportation (Subsection 2.7.3), customer service (Subsections 3.3.1 and 3.3.2), and awareness of facilities and services (Subsection 3.5), which is to be made available to the public in advance of travel. The following are the relevant provisions of the Terminal Code contained in this report:
Subsection 2.7.3 – Ground transportation
Terminal operators are to have means to inform the public of the types of ground transportation available at the terminal and resource information for these services, including accessible ground transportation, in advance of travel.
In addition, terminal operators are to ensure that information is available to the public about the procedures for the provision of ground transportation services to persons with disabilities. For example, passengers should be made aware of any need to make advance reservations for accessible ground transportation.
As previously stated, terminal operators are expected to ensure that accessible ground transportation is available from the terminal. Where accessible ground transportation is, however, not available at the terminal for persons using larger mobility aids, terminal operators are to include this fact in public information on ground transportation.
Subsections 3.3.1 and 3.3.2 – Customer Service
Terminal operators are to have a process in place to deal with public concerns or complaints. This process is to include a designated person or group to deal with accessibility related concerns.
Terminal operators are to have a means to inform the public of the availability of this service, including how to voice a concern or make a complaint. Terminal operators' Web sites are to provide information about this service.
Subsection 3.5 – Facility and Services Awareness Program
Terminal operators are to have a means available to make terminal accessibility features and services known to travellers.
This allows travellers with disabilities, including passengers who may travel infrequently or are uncomfortable travelling, to be aware of what accessibility features and services are available at terminal facilities prior to travel.
This also allows passengers to familiarize themselves with any required accessibility information independently, prior to travel. In addition, it helps to ensure that if terminal operators expend resources to provide accessible features and services, the intended users will be aware of their existence and be able to make use of them.
At a minimum, information on the following features and services are to be made available to the public, where applicable:
- hours of operation;
- location of designated parking areas;
- location of designated drop-off and pick-up areas;
- passenger assistance information, including telephone numbers for accessibility information;
- wheelchair or electric cart service;
- location of designated relieving areas for service animals;
- accessible inter-terminal transportation;
- accessible ground transportation;
- complaint resolution service;
- escort passes; and
- any other relevant information.
The Agency identified these specific provisions of the Terminal Code as priorities for monitoring purposes due to the important role that the communication of information has on accessibility and on promoting the mobility of passengers with disabilities within the federal transportation network.
This report sets out the results of monitoring done by the Agency with respect to communication-related provisions contained in the Terminal Code. More specifically, its purpose is to:
- gauge the overall level of compliance with these provisions in advance of the implementation of the Terminal Code as well as following its implementation;
- identify issues to determine where additional attention may be required;
- reinforce the importance of providing information to travelers in an accessible format (websites, telephones, TTY, and other alternative communications systems); and
- identify "best practices" in the transportation industry, which go beyond the minimum requirements for these identified provisions.
As a reflection of the importance of travel-related information in March 2009, the Agency released Take Charge of Your Travel: A Guide for Persons With Disabilities (Guide), which contains information for persons with disabilities that will help plan their travel, make it easier to get from point A to point B, and describes accessible services and features for travellers with disabilities who use airplanes, trains, as well as passenger ferries and buses that cross a Canadian or provincial border. A significant part of the Guide focuses on the importance of planning and finding information for a trip ahead of time. The successful planning and execution of a trip is fundamental to barrier-free travel in the federal transportation network.
The release of the Guide as well as the monitoring and compliance initiative relating to the Terminal Code are two of several Agency initiatives aimed at reinforcing the importance of providing access to information to travellers with disabilities, as well as the successful planning and execution of a trip.Footnote 4
The Agency decided to focus its compliance efforts on the following key transportation service providers operating services in the three modes of transportation (i.e., air, rail and ferry):
Air
- Calgary International Airport
- Charlottetown Airport
- Edmonton International Airport
- Fredericton International Airport
- Gander International Airport
- Halifax Robert L. Stanfield International Airport
- Iqaluit International Airport
- Kelowna Airport
- London International Airport
- Greater Moncton International Airport
- Montréal-Pierre Elliott Trudeau International Airport
- Ottawa International Airport
- Prince George Airport
- Québec City Jean Lesage International Airport
- Regina International Airport
- Saint John Airport
- Saskatoon John G. Diefenbaker International Airport
- St. John's International Airport
- Thunder Bay International Airport
- Toronto Lester B. Pearson International Airport
- Vancouver International Airport
- Victoria International Airport
- Erik Nielsen Whitehorse International Airport
- Winnipeg International Airport
- Yellowknife Airport
Rail
- VIA Rail (Kingston, London, Montréal, Oshawa, Ottawa, Québec, Toronto, and Windsor terminals)
Ferry
- Marine Atlantic (Argentia, North Sydney, and Port aux Basques terminals)
- Northumberland and Bay Ferries (Caribou, Digby, Saint John, and Wood Islands terminals)
III. Methodology of the Agency's compliance initiative
The Terminal Code compliance initiative consisted of multiple steps designed to evaluate and encourage compliance by terminal operators with the above-mentioned provisions of the Terminal Code.
The monitoring project consisted of a series of measures, with an initial focus on terminal operators' Web sites in order to assess compliance with the sections of the Code regarding the provision of information on accessibility to the public.
- In May 2008, the above-noted air, rail, and ferry terminal operators were contacted by Agency staff to advise them that the Terminal Code would come into effect in June 2009 and that during the summer of 2008, Agency staff would be reviewing their Web sites to determine whether they contained the information set out in the relevant sections of the Terminal Code. The purpose of this initial review was to assist terminal operators in targeting deficient areas prior to the formal implementation of the Terminal Code on June 30, 2009.
- A review of airport Web sites was carried out in May 2009 and, in the following month, airport operators were contacted to inform them of any continued deficiencies and to offer assistance to address any such deficiencies. Airport terminal operators were also advised that Agency staff would carry out a further review of their Web sites prior to publishing the monitoring results in a public report. This comprehensive Web site review took place in December 2009.
- A review of the Web sites of passenger rail stations and ferry terminals was also carried out. Operators of these terminals were contacted in October 2009 and were also offered assistance in complying with the applicable sections of the Terminal Code. A comprehensive Web site review took place in December 2009.
- Finally, a review of Web sites that were less than fully compliant as of December 2009 was carried out just prior to the release of this report in order to ensure that the results being reflected in the report were as current as possible. In cases where air, rail and ferry terminal operators did not have the required information on their Web sites, Agency staff verified whether an equivalent level of information was available by telephone, TTY or an alternative communications system. The results of the final review are reflected in Appendices A, B and C.
Given the importance of Web site communication in matters related to transportation, the Agency has given special consideration to terminal operators' use of their Web sites to provide the information required in the Terminal Code. Giving reflection to the focus on Web sites for air terminals in the May and December 2009 reviews, and with respect to the rail and ferry terminals in the December 2009 review, the focus was on Web site compliance.
IV. Findings
Air terminals
While only three of 25 air terminal operators appeared to be fully compliant with the relevant provisionsFootnote 5 of the Terminal Code in May 2009, all air terminal operators were able to achieve full compliance by September 2010, as a result of discussions between Agency staff and air terminal employees to provide updates to their Web sites.
As noted above, the Terminal Code does not require terminal operators to provide the information via Web site and therefore allows for alternative means of communication. In case where the Web sites did not provide the public information required by the Terminal Code, Agency staff verified whether the information was provided via an alternative means, such as by telephone, TTY, e-mail or online queries. As of September 2010, 25 out of 25 of air terminal operators demonstrated full compliance.
Although all air terminals have been found to be in full compliance with the Terminal Code provisions, the Agency has noted that three of the 25 air terminal operators had not yet updated their Web sites to include the relevant Terminal Code provisions. They are:
- Calgary International Airport
- Toronto Pearson International Airport
- Vancouver International Airport
Several air terminal operators improved their level of compliance significantly over the period of May 2009 to September 2010:
| Terminal | May 2009 | September 2010 |
|---|---|---|
| Thunder Bay International Airport | 8% | 100% |
| Saint John Airport | 31% | 100% |
| Eric Neilsen Whitehorse International Airport | 38% | 100% |
| Gander International Airport | 46% | 100% |
| St. John's International Airport | 50% | 100% |
| Québec City Jean Lesage International Airport | 54% | 100% |
| Montréal-Pierre Elliott Trudeau International Airport | 69% | 100% |
| Charlottetown Airport | 75% | 100% |
| Greater Moncton International Airport | 77% | 100% |
The detailed compliance results are reflected in Appendix A as follows:
- Page 1 of Appendix A shows the Overall Compliance Ranking for all airports surveyed in both May 2009 and in September 2010.
- The publication/methodology used for staff's analysis is described at page 2.
- Pages 3 to 7 contain a detailed analysis, by airport, of compliance with each element of the relevant sections of the Terminal Code in both May and September 2010.
Rail terminals
As noted above, the following eight terminals account for approximately 75 per cent of VIA Rail's traffic. They are Toronto, Montréal, Ottawa, London, Kingston, Windsor, Québec City and Oshawa.Footnote 6 The Web sites for these stations, as well as VIA Rail's general Web site, were examined by Agency staff in order to assess VIA Rail's compliance with the relevant provisions of the Terminal Code.Footnote 7
Where the information required by the relevant provisions in the Terminal Code was not indicated on VIA Rail's Web site, Agency staff verified whether an alternative method of providing the information (e.g. by telephone, TTY or alternate communications systems) was available.
In December 2009, overall compliance ratings ranged from 50 per cent to 63 per cent, depending on the individual station. At that time, VIA Rail was considered "somewhat compliant" with the relevant provisions of the Terminal Code. Nevertheless, certain sections of VIA Rail's Web site were found to be quite good with respect to the provision of information regarding accessibility matters. In particular, there is a dedicated "Special Needs" section with extensive information regarding booking tickets, "One Person One Fare" considerations, priority boarding, checked baggage (including wheelchairs and electric scooters), services available on board, and other relevant information.
However, the Agency noted that information in respect of individual stations is not available on VIA's Web site. For example, there appeared to be no indication of whether accessible taxis are available at any rail station. Similarly, no information was found on VIA Rail's Web site regarding the availability of accessible rental cars, designated parking areas, designated drop-off and pick-up areas, or designated relieving areas for service animals.
Despite this lack of information, it is important to note that such services and facilities may, in fact, be provided at some or all of these rail stations. In June 2010, Agency staff confirmed with each station that the above-noted information which does not appear on VIA's Web site can be obtained by contacting VIA's general information and booking line by telephone, TTY, or by submitting an online request form. Via Rail has a dedicated TTY number for people who are deaf or hard of hearing, which can be found on its main Web site in the "Contact Us" section.
VIA Rail is considered to be fully compliant with the relevant provisions of the Terminal Code. A detailed summary of results is provided in Appendix B – Terminal Code: Compliance by VIA Rail with Public Information Requirements.
Ferry terminals
As reflected above, Agency staff examined the Web sites of Canada's two principal ferry terminal operators: Northumberland and Bay Ferries (Northumberland) and Marine Atlantic. Northumberland operates terminals in Caribou, Nova Scotia, Digby, Nova Scotia, Saint John, New Brunswick, and Wood Islands, Prince Edward Island, while Marine Atlantic operates terminals in Argentia, Newfoundland, Port aux Basques, Newfoundland, and North Sydney, Nova Scotia. A detailed summary of the results can be found in Appendix C – Terminal Code: Compliance by Ferry Terminal Operators with Public Information Requirements.
Similar to the approach taken in monitoring the compliance by air and rail terminals with the Terminal Code provisions, where Agency staff were not able to obtain the information on Northumberland's or Marine Atlantic's Web sites, staff verified whether an alternative method of providing the information (e.g., by telephone, TTY or alternate communications systems) was available.
Marine Atlantic
In December 2009, Agency staff monitored Marine Atlantic's Web site and found it to be highly compliant with an overall compliance rating of 86 per cent. The only information missing on the Web site was with respect to information concerning service animal relief areas, which pertains to Subsection 3.5.2 of the Terminal Code.
Agency staff contacted Marine Atlantic's three terminals to verify whether they could provide this information via an alternate means and determined that passengers can obtain this information by contacting Marine Atlantic via telephone, TTY or by submitting an e-mail request. Marine Atlantic has a dedicated TTY number, which can be found on its main Web site under "Contact Us." In July 2010, Agency staff confirmed that information concerning service animal relief areas was included on Marine Atlantic's Web site. Marine Atlantic is considered to be fully compliant with the relevant provisions of the Terminal Code.
As well as the specific information requirements of the Terminal Code, Marine Atlantic provides a considerable amount of additional information regarding accessibility matters in the "Persons with Disabilities" section of its Web site, such as information on the Agency's Communications Code and on Marine Atlantic's Advisory Committee on Accessibility.
Northumberland and Bay Ferries
In December 2009, the overall compliance rating for Northumberland's Web site was 29 per cent. The only information found on its Web site, which related to the information requirements of the Terminal Code, was contact information for customer service. A follow-up review in June 2010 revealed that Northumberland's compliance rating did not change. Although its Web site does not contain the necessary information to meet the minimum requirements of the Terminal Code, Agency staff contacted each of the four Northumberland terminals and determined that the information could be obtained by contacting the terminals directly by telephone, TTY, or by submitting a query online. Northumberland has a TTY number, which can be found on its main Web site, under "Terminal Parking Area & Fees."
As the relevant information in the Terminal Code can be provided by either telephone, TTY or by submitting a query online, Northumberland is considered to be fully compliant with the relevant provisions of the Terminal Code.
V. Best practices
A number of terminal operators have included features on their Web sites which go beyond meeting the minimum requirements of the Terminal Code. Such features are particularly helpful in assisting the travel of persons with disabilities. Some examples of these "Best Practices" are provided below.
i. Separate accessibility section
Many terminal operators have set up a separate "Accessibility", "Special Needs" or "Persons with Disabilities" section within their Web sites. Not only does this facilitate the search for accessibility information, but the establishment of such a section encourages the terminal to provide a greater breadth of information than simply that which is required by the Terminal Code. Terminals with a dedicated "Accessibility" Web site section include:
Air terminals
- Calgary International Airport
- Charlottetown Airport
- Edmonton International Airport
- Halifax Robert L. Stanfield International Airport
- Kelowna International Airport
- London International Airport
- Greater Moncton International Airport
- Montréal-Pierre Elliott Trudeau International Airport
- Ottawa International Airport
- Québec City Jean Lesage International Airport
- Regina International Airport,
- Saint John Airport
- Saskatoon John G. Diefenbaker International Airport
- St. John's International Airport
- Thunder Bay International Airport
- Toronto-Lester B. Pearson International Airport
- Victoria International Airport
- Erik Nielsen Whitehorse International Airport
- Winnipeg James Armstrong Richardson International Airport
- Yellowknife Airport
Rail terminal
- VIA Rail (main corporate website)
Ferry terminal
- Marine Atlantic (main corporate website)
ii. Web site links
Useful links to external Web sites that deal with accessible transportation issues are provided by a number of terminal operators:
- Beyond Ability International – Toronto-Lester B. Pearson International Airport
- Agency Home Page – Charlottetown Airport, Kelowna International Airport, St. John's International Airport, Victoria International Airport
- Agency "Air Travel Accessibility Regulations" – London International Airport, Montréal-Pierre Elliott Trudeau International Airport, Regina International Airport, Toronto-Lester B. Pearson International Airport
- Agency Web site "Persons with Disabilities" section – Erik Nielsen Whitehorse International Airport
- Agency Publication "Take Charge of Your Travel: A Guide for Persons with Disabilities" – Edmonton International Airport, London International Airport, Regina International Airport, Toronto-Lester B. Pearson International Airport, Victoria International Airport
- Transport Canada's "Access to Travel" Web site – Charlottetown Airport, Halifax Robert L. Stanfield International Airport, Kelowna International Airport, VIA Rail
iii. Terminal guides
The Web sites of Edmonton International Airport, Thunder Bay International Airport, and Winnipeg James Armstrong Richardson International Airport provide links to printable brochures with comprehensive information regarding the accessibility features and services at those terminals.
iv. Airport Customer Assistance Program – Toronto-Lester B. Pearson International Airport
Toronto-Lester B. Pearson International Airport initiated its Airport Customer Assistance Program (ACAP) to ensure that all passengers can travel throughout the airport without difficulty. Assistance can be pre-arranged by calling a toll-free number or by completing an ACAP request form online. In the online form, travellers are asked to specify the type of assistance they require, along with flight details and other relevant information. In addition, provision is made to allow travellers to make special requests.
VI. Future action
Given the value and importance of Web site communication with respect to the relevant Terminal Code provisions, Agency staff will continue to work with those terminal operators, who at the time of this report's release, were not yet able to update their Web sites, with a view to enhancing their compliance with the sections of the Terminal Code regarding the provision of information to the public on: ground transportation, customer service, and awareness of facilities and services. The Agency will provide periodic updated reports on its Web site as terminal operators modify their Web sites to include the required information or otherwise make the information available to the public.
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