Dear TTC Board members,
TTCriders is a membership-based organization of transit users. We published a report in June 2023 that shares perspectives from Wheel-Trans users who will be impacted by the “Family of Services” program, which seeks to shift up to 50% of Wheel-Trans users onto conventional TTC buses, streetcars, and subways for parts of their trips.
Wheel-Trans users who have relied on door-to-door service for decades will now be eligible for this service only under limited conditions. Instead, “conditional” users will get picked up at home by a Wheel-Trans vehicle, then dropped off on the side of the road to complete their trip using conventional TTC streetcars, subways, or buses.
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Image description: A TTC “Shared Wheel-Trans Stop” at Midland and Ellesmere that has a note stuck on top that says “We Missed You”, indicating a Wheel-Trans trip was missed by the rider who booked it. Photo by TTCriders, April 2022.
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Seniors and people with disabilities say that they will lose independence and become more isolated, and fearful about the barriers to taking the conventional TTC, including finding space on vehicles that are more crowded due to service reductions, issues with broken elevators at stations, and medical conditions that involve significant risks from falling or being jostled.
Wheel-Trans users need choice: Do not force people to use conventional TTC
According to the 2023 Wheel-Trans Transformation update, the TTC is preparing to make the “Family of Services” program mandatory for conditional users. Soon, Wheel-Trans users will be denied access to door-to-door service unless one of their conditions is present.
Although the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) mandates the creation of new eligibility categories for paratransit, the AODA does not require that transit agencies make it mandatory to use the conventional system.* This is a policy choice that will have grave consequences for the health and wellbeing of seniors and people with disabilities, and create new barriers. We urge you to protect Wheel-Trans service for all who need it.
The “Family of Services” is a plan to reduce costs, not enhance access
The TTC has a diversion target of shifting 50% of current unconditional Wheel-Trans users on the Family of Services model by 2025. The TTC has stated that the shifting Wheel-Trans riders on to the Family of Services is meant to “free up resources to serve riders with unconditional eligibility.”**
Operations funding from the provincial or other levels of government is needed so that Wheel-Trans can expand service to accommodate new users. This is the only way to ensure that the spirit of the AODA is upheld and enforced.
Many seniors and people with disabilities who have been re-categorized as “conditional” have reported to us that they are not able to use the conventional service, and that their appeals have been denied.
Barriers to re-registering and appealing “Conditional” status
Financial and other barriers prevent many Wheel-Trans users from re-registering for the service and from appealing their eligibility status: People only have 30 days from the date of their eligibility decision letter to submit an appeal. But some Wheel-Trans users have reported to us that after re-registering they received a decision letter about their new eligibility status too late to appeal. One person received a decision letter only 2 days before the appeal deadline, which is not enough time to obtain documentation from a doctor. The 30-day appeal period is not sufficient.
Gathering supporting documentation for re-registration or appeal may require booking appointments with specialists, paying for a doctor’s note, and paying for attendant support. Less than 0.02% of Wheel-Trans applicants appeal their status, based on information available from 2017 and 2018. Of the 17 appeals made to Wheel-Trans in 2017 and 2018, the original Wheel-Trans decision was upheld in 12 cases (71%).***
What if my health changes? Clarifying when Wheel-Trans users can re-apply
There is also no firm direction on when users can re-apply if their health status changes. Some health conditions can change rapidly and making Family of Services mandatory when there are no clear guidelines on how users experiencing changes in their disability or condition can reapply or appeal a status beyond the ‘30 day’ window is unacceptable.
Sincerely,
TTCriders Accessibility Committee
SAMPLE WHEEL-TRANS TRIP vs. “FAMILY OF SERVICES” TRIP
Trip examples provided by a Wheel-Trans user. The Family of Services trip time is estimated at 75-85 minutes, but this assumes an on-time Wheel-Trans pick-up from the York Mills Road shared TTC stop.
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Wheel-Trans trip: Vibrant Healthcare Alliance to Home
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| Family of Services trip: Vibrant Healthcare Alliance to Home
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References:
*“A specialized transportation service provider may deny requests for specialized transportation services to persons who are categorized as having temporary eligibility or conditional eligibility if the conventional transportation service is accessible to the person and the person has the ability to use it.” – O. Reg. 191/11, s. 63 (3). [emphasis added] https://www.ontario.ca/laws/regulation/110191
**The TTC has estimated that its operating budget was reduced by $65.33 million due to the Family of Services model between 2017 and 2021. In 2016, the TTC forecast Wheel-Trans operating budget reductions of $300 million over 10 years as a result of implementing the program.
***In 2017, 10 appeals were made out of 13,360 received applications to Wheel-Trans. In 2018, 7 appeals were made out of 5511 received applications: https://www.toronto.ca/legdocs/mmis/2018/ex/bgrd/backgroundfile-118165.pdf.