Open Collections

UBC Graduate Research

Transportation Network Companies & Accessibility : How Other Jurisdictions are Navigating Accessibility… Ward, Daniel Feb 27, 2017

Your browser doesn't seem to have a PDF viewer, please download the PDF to view this item.

Item Metadata

Download

Media
310-Ward_Daniel_Transporation_companies_accessibility_2016.pdf [ 13.41MB ]
Metadata
JSON: 310-1.0342994.json
JSON-LD: 310-1.0342994-ld.json
RDF/XML (Pretty): 310-1.0342994-rdf.xml
RDF/JSON: 310-1.0342994-rdf.json
Turtle: 310-1.0342994-turtle.txt
N-Triples: 310-1.0342994-rdf-ntriples.txt
Original Record: 310-1.0342994-source.json
Full Text
310-1.0342994-fulltext.txt
Citation
310-1.0342994.ris

Full Text

How Other Jurisdictions are Navigating Accessibility Issues in an Evolving Vehicle-For Hire Industry & Ideas for B.C. Transportation Network Companies & Accessibilty:  Prepared by Daniel Wardfor the B.C. Passenger Transportation Branch.This report stands as my capstone project: the culmination of 24 consecutive months of studying community planning. This project would not have been possible without the openness and interest of the B.C. Passenger Transportation Branch, specifically, Registrar Kristin Vanderkuip, to receive this information and provide assistance along the way. I would also like to acknowledge SCARP colleague, Victor Ngo, whose past research on TNC regulatory frameworks sparked this project idea, and whose initial encouragement motivated me to stick with it, and Riley Iwamoto, for helping my report design process progress smoothly. Finally, thank you to my project and academic supervisor, Professor Jordi Honey-Rosés, for his feedback on the upcoming pages, assistance in helping me develop previous project proposals, and excellent support and guidance throughout my time at SCARP. I am indebted to my friends and family, who have been a source of immense support through my time at SCARP. In no particular order, thank you to my parents, Doug and Jennifer, for your endless encouragement, Frances, for helping me spark my initial interest in planning and policy; my sisters, Ariel and Anna for sticking with me so long; and to Brad and Kajsa for helping me relax. I also want to thank Vancouver’s most generous landlord, Karen, for slashing my rent during school, allowing me to live within the city; my neighbours, Matt, Dani and Frankie, for being some of the best; and to my part-time roommate, Stanley, for making the water-saving switch from drinking from the toilet to the shower, showing me that even cats can adopt more sustainable behavior. Finally, to my partner Holly, whose support with this project and all others is a constant reminder of how fortunate I am. Daniel Ward is a Masters Student at the School of Community and Regional Planning (SCARP) located at the University of British Colum-bia (UBC), Vancouver, Canada. Prior to attending SCARP, Daniel worked in the outdoor education field, combining his passions for the environ-ment, education and working with youth. He completed his Bachelors at Concordia University in Montreal, Canada, studying political science and urban studies. After graduation, Daniel worked for the City of Van-couver and the Vancouver School Board, where he helped expand rec-reational opportunities for persons with disabilities and support this population academically in school. Daniel’s current research interests include: sustainable transportation, community-based social market-ing as a means to encourage sustainable behaviors, and how technolo-gy can foster greater public engagement in planning decisions. Daniel is also a member of the Persons with Disabilities Advisory Committee at the City of Vancouver.• Cover (modified): Peter Sinclair, Flickr• New Port Mann Bridge (modified): Waltersenff (Accessed via Flickr• Skytrain Platform: Andrew  Ferguson (Accessed via Flickr)• Orange Wheelchair Accessible Taxi: Accessed via "Wheelchairtravelling.com"ii iiiTransportation Network Companies and Accessibility Transportation Network Companies and AccessibilityAbout the Author AcknowledgementDisclaimerThis report was prepared for the British Columbia Passenger Transportation Branch under the advice and interest of the Registrar, Kristin Vanderkuip. All elements have been produced by a graduate student at the School of Community and Regional Planning located at the University of British Columbia. All policy suggestions and opinions do not necessarily reflect the views of the Passenger Transportation Branch, the School of Community and Regional Planning or the University British Columbia.All feedback should be directed to Daniel Ward at dannward@gmail.com.Photo Credits6. Transportation Network Companies and Accessibility.................................................14 6.1The Accessibility Challenge.......................................15 6.2 What are TNC's Doing?...........................................15 6.2.1 App Accessibility Features.....................................16 6.2.2 Employment for People with Disability....................16 6.2.3 Accessible Platforms..............................................16 6.3 What are Other Cities Doing....................................17  6.3.1 City of Ottawa...............................................17  6.3.2 City of Portland..............................................17  6.3.3 City of Toronto...............................................19  6.3.4City of Seattle.................................................21  6.3.5 City of Edmonton...........................................21  6.3.6 City of Austin................................................227. The Accessibility Challenge in Vancouver...24 7.1 Challenges..............................................................25 7.2 Strengths................................................................268. Analaysis and Recommendations..............27 8.1 Suggested Actions...................................................30  8.1.1 Policy (PO)....................................................30  8.1.2 Process (PR)...................................................319. Conclusion...............................................34Table of ContentsAbout the Author...................................................................IIDisclaimer.............................................................................IIAcknowledgements...............................................................III1. Executive Summary.....................................62. Introduction................................................7 2.1 Purpose of the Report.................................................8 2.2 Scope.......................................................................8 3. Research Design..........................................................8 3.1 Methodology.............................................................8  3.1.2 Literature Review...............................................8  3.1.3 Interviews.........................................................9  3.1.4 Focus Group.....................................................9 3.2 Research Questions....................................................9 3.3 Limitations................................................................104. Context.....................................................10 4.1 Uber in Vancouver....................................................10 4.2 Accessibility Concerns...............................................11 4.3 B.C. Vehicle For-Hire Regulatory Context ..................12 4.4 Taxi VS TNC Driver Training......................................125. Transportation Network Companies...........13iv vTransportation Network Companies and Accessibility Transportation Network Companies and Accessibility2. INTRODUCTION Within the last decade, the modern “sharing economy” has developed a ubiquitous presence in our everyday lives. People rent nearby cars to get from A to B, tourists book a stranger’s studio apartment for the weekend through Airbnb, and hobbyists crowdsource funding for their latest en-deavor through Kickstarter. While the sharing economy is not new (Craigslist and other non-digital forums have facilitated the exchange of goods and services for many years), technological change has allowed it to evolve into something entirely different and at a rapid pace. Between 2015 and 2025, the valuation of the sharing economy is expected to grow by USD $320 billion to a total of $335 billion.2 This new iteration of the sharing economy is being driven by the rapid adoption of mobile technologies and the seamless transactions facilitated by companies such as Airbnb and Uber. A changing consumer culture and corresponding shift in how many people access goods and services has fundamentally transformed the power dynamics between consumers, companies and government.3 This means traditional regulatory approaches are challenged in intervening and addressing what government agencies have determined to be in the public interest. This is most prominently exemplified by jurisdictions’ response to the spread of ride-sourcing services such as UberX around the globe and Lyft in the United States. The regulatory approach that has long ap-plied to the taxi industry to help maintain sufficient service levels, safety, fairness and—in some cities—accessibility to persons with disabilities, has proven difficult to transfer over to the new peer-to-peer transportation platforms, e.g. UberX. As public opinion continues to lean in favour of an expanded vehicle-for-hire industry that includes TNCs, such as Uber, and technology continues to transform our transportation sys-tem, governments are feeling pressure to examine the topic. In British Columbia, the Ministry of Transportation, and major cities, such as the City of Vancouver, have initiated a regulatory review. Amongst the several public interest considerations, accessibility to persons with disabilities in the vehicle-for-hire market has been an important issue on the agenda. Regionally, both the City of Burnaby4 and the City of Vancouver5 have outlined this issue as a crucial consideration moving forward. Indeed, it has been a fundamental consideration in regulatory reviews across Canada, such as in the City of Edmonton6, London7, Waterloo8, Toronto9 and Ottawa10. Major concerns have been raised regarding the potential impacts the entrance of TNCs could have on accessible vehi-2  PWC, The Sharing Economy—Sizing the Revenue Opportunity. Accessed May 14: http://www.pwc.co.uk/issues/megatrends/collisions/sharingeconomy/the-sharing-economy-sizing-the-revenue-opportunity.html3  Sunil Johal and Noah Zon, (2015), "Policy Making for the Sharing Economy: Beyond Whack-A-Mole", The Mowat Centre,  p.4 . Accessed on March 20, 2016: https://mowatcentre.ca/wp-content/uploads/publications/106_policymaking_for_the_sharing_economy.pdf4  City of Burnaby , (Oct. 22, 2014), "Uber Ride-sharing Service", Memo. Accessed June 1, 2016: https://burnaby.civicweb.net/document/15149/2014%2010%2027%20-%20Uber%20Ride%20Sharing%20Service%20(2).pdf?handle=-0D3A2835E0894B86ABC9677C427A620B5  City of Vancouver. (Oct. 15, 2015), "Taxi Service Review and Report Back", Council Report. Accessed March 17. 2016: http://council.vancouver.ca/20151020/docume6  City of Edmonton, (2016), "Bylaw 17400-Vehicle for Hire Bylaw, Further Revisions", p. 2. Accessed June 1, 2016: http://webdocs.edmonton.ca/siredocs/published_meetings/91/519956.pdf7  City of London.  G. Kotsifas. P. Eng.. "Vehicles for Hire, New Technologies, 2015", Accessed March 13. 2016: https://www.london.ca/newsroom/Documents/Uber-sept2915.pdf8  Regional Municipality of Waterloo, (March 29, 2016). Licensing and Hearings Committee. Accessed June 16, 2016: http://www.regionofwaterloo.ca/en/regionalGovernment/resources/License/RM2016-0329.pdf9  City of Toronto, (2015), Ground Transportation Review, http://www.toronto.ca/legdocs/mmis/2015/ls/bgrd/back-groundfile-83268.pdf10  City of Ottawa, (2015) Taxi and Limousine Regulation Service Review, Accessed June 3, 2016: http://app05.ottawa.ca/sirepub/cache/2/n5o3pop1qhirlv5uplikps42/35380506242016113333622.PDF 1. EXECUTIVE SUMMARYThe vehicle-for-hire industry has undergone dramatic change in very short order. Advances in mobile technologies and the corresponding ascent of the smart-phone have opened up new innovations that allow digital platforms to dynamically connect spare capacity with those who need it.1 These changes have spawned com-panies like Uber and Lyft (also known as transportation network companies or TNCs) and their growing array of services, which have been well received by consumers. For persons with disabilities, however, for whom on-demand transportation options are critical for their engagement in regular activities many non-disabled people take for granted, these new services have received mixed reviews and governments have been challenged with how to address these concerns in their regulatory overhauls.In recognition of this challenge, the B.C. Passenger Transportation Branch (PTB)—an administrative unit that supports activities relating to the regulation of commercial passenger transportation—partnered with a graduate student (herein referred to as “the researcher”) at the University of British Columbia’s School of Com-munity and Regional Planning to study the issue of accessibility and the associated challenges with the emergence of transportation network companies. As part of the PTB’s mandate for policy research, the PTB directed the researcher to survey regulato-ry changes that have occurred in other jurisdictions in light of the technological and economic changes taking place in the vehicle-for-hire sector and report back regard-ing how these jurisdictions have addressed issues associated with accessibility to persons with disabilities. The researcher examined six jurisdictions: three in Canada and in from the United States. In helping frame the issue for B.C. and—more specif-ically—the Vancouver metropolitan area context, the researcher conducted primary research to understand the accessibility challenges in the regional context and to help frame the topic of accessibility within the for-hire sector. This report found a range of approaches and actions in the six cities that were studied. Here are some key findings:• Five out of six cities had policies that included the establishment of a publicly administrated accessibility fund, which would receive revenues from the vehicle-for-hire sector that would be used to improve accessible transportation options.• Half of the cities require TNC’s to provide accessible service.• Utilization of taxi wheelchair accessible vehicles (WAVs) is important to success of TNC’s WAV service. 1  PWC, Consumer Intelligence, The Sharing Economy. Consumer Intelligence Series. Accessed March 3, 2016: https://www.pwc.com/us/en/technology/publications/assets/pwc-consumer-intelli-gence-series-the-sharing-economy.pdf6 7Transportation Network Companies and Accessibility Transportation Network Companies and Accessibilityongoing and rapid pace jurisdictions around North America have been working to revamp their regulations to better respond to the new challenges presented by TNCs, news reports and commentaries from news websites were given more attention and found more relevant to this review. Local laws that set the regulatory context in cities reviewed were, of course, also critical in this survey.3.1.3 Interviews Interviews with jurisdiction officials and disability community representatives were fun-damental in understanding the policymaking process, what the major issues were affecting people with disabilities, and the effectiveness of policies seeking to address accessibility con-cerns within the TNC regulatory framework. The interview subjects fell into two main groups: 1) jurisdiction officials, and 2) disabili-ty community advocates. Jurisdiction officials were primarily local government bureaucrats closely involved in the creation of their local TNC regulations. These individuals provided clarity regarding their rules and gave insights into their policy development process.  Dis-ability community advocates were individuals who work professionally as advocates in orga-nizations that seek to represent the interests of persons with disabilities, for example, the Coali-tion of Texans with Disabilities. The individuals helped provide context into the local private-for-hire transportation challenges faced by those with disabilities, as well as insights regarding the efficacy of local TNC regulation in address-ing accessibility.3.1.4 Focus Group Information was also collected during a disability forum in Vancouver, hosted by Uber Canada and Spinal Cord Injury BC (SCI-BC), titled “Improving Accessible Transportation in Metro Vancouver” (herein referred to as “the forum”). The event included opening presentations from representatives of Uber, SCI-BC, and the Ontario College of Art and Design’s (OCAD) Inclusive Design Institute, followed by three breakout discussions focused on specific sub-questions to ultimately help address the main question: “What does “great” accessible transportation look like in Metro Vancouver over the medium- (one year) and long-term (two-plus years), keeping in mind cost, time, design, availability, reliability, safety and how might Uber or other private companies fit in?”  The author’s observations from this event are used to help characterize the accessible transportation challenges within the local Metro Vancouver context. While the results of the breakout groups are the main sources used from this event, presentations from Uber staff were also used to help ground the author’s under-standing of accessibility within their business, especially within the Toronto context. Issues raised at this event are summa-rized in section 7 of this report.3.2 Research Questions This report seeks to address one central question and several sub-questions. The main research question: In jurisdictions where TNC’s operate, what strategies to address equity and accessibility con-cerns are being used?In addition to the main research question, this report seeks to address several sub-questions. Through conversation with the Passenger Trans-portation Branch (PT Branch) and the disability community, several specific challenges associ-ated with the peer-to-peer ride-sourcing mod-el were identified. These are reflected in the sub-questions:• How have other jurisdictions addressed Uber and SCI-BC co-hosted a discussion on the future of accessible transportation in Vancouver.cle-for-hire service. Change can impact groups in very un-equal ways. For disadvantaged groups, such as people with disabilities, individuals can be more susceptible to negative impacts. Take, for ex-ample, the event of a broken elevator at a Sky-Train station. For a younger, more able-bodied individual travelling with a bike, this is a minor annoyance, requiring them to carry their bike up the stairs. For someone with significant mobility challenges, the station is rendered completely inaccessible. In transportation, vulnerable and disad-vantaged groups, such as persons with disabil-ities, typically have fewer options to utilize for mobility. Many are unable to drive or, indeed, are unable to afford access to a personal vehicle. While public transit services such as TransLink are required to accommodate passengers with disabilities, transit often does not meet the needs of a person with a disability. In the same way an able-bodied rider may opt for booking a Car2Go on their phone over taking the SkyTrain, someone with a disability also requires on-de-mand transportation options. Translink does not fill this need. For many people with a disability, taxis are the only option for on-de-mand transportation. Within this group, only the much smaller pool of wheelchair acces-sible vehicles (herein referred to simply as “WAVs”) are available to many of these pas-sengers.  So the question is: How can the acces-sibility issue be most effectively addressed as the vehicle-for-hire industry undergoes its latest major transformation?2.1 Purpose of this Report This report looks to examine the im-plitions of transportation network company (TNC) services on transportation outcomes for persons with disabilities. It seeks to deep-en and inform an understanding concerning this issue for the Passenger Transportation Board and other British Columbia regulators by studying policy responses to TNC services in other jurisdictions. This report will pro-vide insight into to what extent persons with disabilities may be impacted by TNC services and outline what actions other jurisdictions have taken to address accessibility concerns. 2.2 Scope In addressing the central research theme, this report focuses only on the experience of select North American jurisdictions, excluding other examples throughout the world. This is justified by the fact that TNC’s services have existed in North America longer than anywhere else, and carry greater relevance and grounds for comparison than most international examples.  While the U.S. cities examined may have several rideshare companies in operation in their jurisdictions, Uber and Lyft stand out, accounting for the vast majority of the TNC ser-vices. Among these two companies, Uber is the only one to have expanded internationally and has gained a significant presence in the Cana-dian cities it operates in. As such, and given the company’s ongoing efforts to expand into British Columbia, references to TNC’s will be focused primarily on Uber. 3.1 Methodology This report is based on a mixed-research methodology comprised of a literature review, interviews and focus-group observations. 3.1.2 Literature ReviewThe literature review includes academic and gray literature, as well government pol-icy reports, local laws and news articles. As transportation network companies have only been operating for a few years, little academic research exists on how the emergence of these services have impacted transportation outcomes for persons with disabilities. What writing does exist centers on the “sharing economy” at large and the implications it has for governments, business and consumers. This broad focus on the sharing economy was the subject of much of the grey literature reviewed as well. Given the 3. RESEARCH DESIGN8 9Transportation Network Companies and Accessibility Transportation Network Companies and Accessibilitytors. While some of the obstacles attributed to TNC services also exist in the local traditional taxi-cab sector, the accessibility challenges presented by TNCs are unique. The peer-to-peer nature of app-based services like UberX and Lyft present a fundamental problem to riders seek-ing wheelchair accessible service: drivers use their own cars and very few people have WAVs. There have also been several accounts in other North American cities of drivers discrim-inating against passengers with disabilities. In these cases, drivers would allegedly cancel trips via the apps upon seeing that their prospective rider was disabled. Other times drivers would re-fuse to take passengers in manual wheelchairs, despite the fact that these chairs can be easily folded and stowed into any sedan. While these incidences appear to be rare, they have high-lighted for policymakers and TNCs the discrim-ination and barriers faced by some people with disabilities looking to use these services. Passen-gers with service animals have also been refused rides from TNC drivers.13 Incidences like these have resulted in several lawsuits against Uber and Lyft in communities across the U.S.14  Below are the main concerns disability communities have expressed realting to TNC services:Wheel-chair accessible vehicles (WAV)This issue is by far the most widely dis-cussed concern for people with disabilities. Because TNCs are a peer-to-peer service, indi-viduals are driving their personal vehicles which are seldom wheelchair accessible. The lack of WAVs offered by TNCs has limited the ability for people who use wheel chairs to use the services offered by companies such as Uber. Driver Training People with disabilities often have special needs that drivers may have to assist with in 13 Salvador Rodriguez.( Aug. 13, 2015), "For Uber. Lyft Riders with Disabilities. Discrimination Often Comes Included." International Business Times. Accessed June 1, 2016: http://www.ibtimes.com/uber-lyft-riders-disabili-ties-discrimination-often-comes-included-205267514 Jen Wieczner, (May 22, 2015), “Why the Disabled are Suing Uber and Lyft”. Time. Accessed June 1. 2016: http://time.com/3895021/why-the-disabled-are-suing-uber-and-lyft/order for passengers to have a safe and comfort-able trip. The minimal training provided to the vast majority of TNC drivers about assisting peo-ple with disabilities is a concern to many. While critics acknowledge that specialized paratransit services are the best fit for some individuals with disabilities, they argue the majority of peo-ple with disabilities can be served quite easily in conventional ground transportation. Disability advocates in B.C. have pointed to the training required by the City of Vancouver and delivered by the Vancouver Taxi Association, “Ask, Listen, Act” (ACT), as a straight forward and effective training program.Dispatching + Payment One of the defining features of TNC ser-vices is the exclusive use of apps for summoning a vehicle. Payment is also cashless and is co-or-dinated through the dispatching company’s app. The credit card linked to the profile that sum-moned the vehicle is debited upon completion of the ride. This system presents many barriers for people with disabilities. Firstly, individuals who have cerebral palsy, arthritis or multiple sclerosis, for example, have dexterity challeng-es that can make dispatching a vehicle through the app by hand a challenge. People who are partially sighted or blind may use the voiceover in iOS and TalkBalk in the Android OS, which has varying functionality depending on the app being used. Secondly, due to lower and often fixed incomes, people with disabilities are less likely to have a smartphone or use a credit card. At present, the use of cash and TaxiSavers are common methods of payment for people with disabilities using HandyDart and taxi services in B.C.. Dynamic Pricing During busy periods, ride-sourcing com-panies commonly increase their prices for short periods of time to entice more drivers to pick up fares. This dynamic pricing event is called “surge pricing” by Uber and “PrimeTime” by Lyft. Dy-namic pricing has drawn concern from many people in the disability community who say it unfairly and disproportionately impacts people with disabilities, who may not have the same flexibility to travel outside peak travel times or the challenges of fluctuating fare rates (i.e Uber’s “surge pricing” or Lyft’s “PrimeTime”)? • TNCs reliance on smartphone apps can disadvantage persons with disabilities who generally have lower incomes, may not have a credit card, and/or may face challenges operating a smartphone. How have other jurisdictions addressed these challenges relating to dispatching a TNC vehicle? Are there examples where traditional phone-call- based dispatching services exist for TNCs? Are they effective?• Given the high-cost and degree of specialization of wheelchair-accessible vehicles (WAVs) and the fact that TNCs drivers are independent drivers using their personal cars, WAVs are not naturally present in TNCs services, how have TNCs or other jurisdictions managed to provide or coordinate WAV services? 3.3 Limitations A desire to deliver findings in step with the Government of British Columbia’s policy- development process for the evolving vehicle-for-hire industry limited the project’s timeline. The cities and regulatory frameworks examined do not represent a comprehensive survey of how accessibility has been addressed in North America’s entire TNC industry. This limited sample was due to constrained timeline and resources. As well, the voluntary nature of this survey resulted in many jurisdictions not re-plying or declining to participate in the research.  Secondly, interviews with individuals who work in disability advocacy were surpris-ingly difficult to obtain. A desire to speak with advocates both familiar with disability issues and ongoing transportation reviews in their respective cities often directed the researcher to council advisory groups, the members of which were most often uncomfortable or unwilling (some are prohibited from engaging with any-one other than council or city staff on these matters) to discuss the topic. Lastly, little research exists cataloguing the different approaches to addressing accessi-bility in the TNC sector. Specifically, there is no academic or grey literature documenting these issues in this way. As such, data collection was limited to primary sources—bylaws, ordinances, interviews—and references in news articles.  4. CONTEXT4.1 Uber in VancouverUber began operating in May 2012 as a luxury sedan service in the City of Vancouver and continued for six months until enforcement by B.C. Passenger Transportation Branch (PTB) in November for violating commercial pas-senger transportation rules.11 These violations included not having a vehicle-for-hire licence, suffcient insurance coverage required of private-for-hire vehicles and not charging board-ap-proved rates. Again, in 2014, rumours surfaced that Uber was planning to relaunch, this time throughout Metro Vancouver and on Halloween. During this time, Transportation Minister Todd Stone reaffirmed the province’s position and said that an unauthorized entry would result in legal action.12 The City of Vancouver had also expressed concern over the unregulated entry of Uber into the city. Officials with the City of Vancouver and other B.C. transportation authorities have since been studying the issue to better understand the challenges and opportunities presented by the proliferation of peer-to-peer ride-sourcing services in major cities across the world.4.2 Accessibility Concerns The issue of accessibility to people with disabilities remains one of the most significant challenges for TNCs and transportation regula-11 Stephen Chelling, (Nov. 28, 2012), "Uber Town-Car Service Shut Down in Vancouver by B.C. Passenger Trans-portation Board." The Georgia Straight. Accessed June 18. 2016: http://www.straight.com/news/uber-town-car-ser-vice-shut-down-vancouver-bc-passenger-transportation-board12 Sam Cooper, (Nov. 2, 2015), "How Vancouver Taxi Companies are Beating Uber." The Province. Accessed May 25, 2016: http://www.theprovince.com/business/Vancou-ver+taxi+companies+beating+Uber/11490241/story.html10 11Transportation Network Companies and Accessibility Transportation Network Companies and Accessibility This clear difference in training, required versus voluntary, in person and assessed ver-sus a simple video one can watch at home, has understandably raised concern amongst gov-ernment officials and others concerned with broader public safety issues. 15 Uber claims its rating system—whereby users and drivers rate each other (and give additional feedback if they desire) after each ride—serves as powerful incentive that supports a service that is supe-rior in customer service, including to people with disabilities. This is supported by a focus group-based survey commissioned by the City of Ottawa where Uber products had “resoundingly higher customer service and customer experi-ence ratings” over taxis.16 While the survey did not address specific disability issues nor is it clear whether any participants had a disability, it speaks to the effectiveness of Uber’s (and TNCs’ in general) rating system and its potential as a responsive system that can benefit all custom-ers.15  TNC’s, such as Uber, offer several products. Uber-ASSIST, a product geared to older adults and people with disabilities does require more comprehensive in-person training. Sub-section 4.3 describes the training of UberX drivers, Uber’s main and most widely available product.16  City of Ottawa, (2015), "Customer Experience", Taxi and Limousine Regulations and Services Review, p. 1.Ac-cessed May 24, 2016. http://documents.ottawa.ca/files/documents/otlrsr_customer_exp_en.pdf5. TRANSPORTATION NETWORK COMPANIES (TNCS)DefinitionIn 2013, the State of California became the first jurisdiction to create a legal framework under which so-called ride-sharing services (i.e., UberX, Lyft, Sidecar) would operate within. The California Public Utilities Commission created a new category of business, “Transportation Network Company,” which has now become the standard legal term for app-based dispatchers that use a peer-to-peer model, such as Uber, across most U.S. states. The State of California defines TNCs as the fol-lowing: “[A company] that provides prearranged trans-portation services for compensation using an online-enabled application (app) or plat-form to connect passengers with drivers using their personal vehicles.”While “TNC” has become established in the reg-ulatory lexicon across the U.S., varying terms areaccess affordable alternatives. 4.3 BC Vehicle-for-hire Regula-tory Context The B.C. Passenger Transportation BoardIn British Columbia, the licensing of private commercial passenger transportation rests with the B.C. Passenger Transportation Board (PTB), an independent tribunal created under the Pas-senger Transportation Act. Taxis, limousines, bus charters and interregional buses need to ap-ply and obtain licenses from the board in order to legally operate in the province. 4.3 Taxi VS TNC Driver Training  There are significant differences between local taxi driver training and the training Uber’s drivers are subject to. What is considered one of the greatest strengths of TNCs, its low barrier to entry, which includes minimal to no train-ing requirements, is also regarded as a major weakness for those concerned with the indus-try’s ability to provide service to persons with a disability (see Table 1 for summary comparison of training). There are several fundamental differenc-es between taxi driver training and TNC driver training (see Table 1). Firstly, regular Uber driv-ers (UberX) are not required by the company to undertake any training. There are no required readings or videos. Only where jurisdictions require TNC drivers—through a licensing scheme—do drivers actually have to receive any training. Taxi drivers, on the other hand, in many B.C. municipalities, are required to have passed exams and taken a designated taxi driver training program, which in the Vancouver met-ropolitan area, is one-week long. Secondly, while taxi driver training is an in-person and assessed, UberX driver training is comprised of a short video.TAXI DRIVERS* UBER DRIVERSTaxiHost Pro (offered through the Justice Institute of B.C.).Uber training video (not mandatory unless jursidiction requires it)5 day training program including modules on: driver safety, customer service, serving custom-ers with disabilities and collision avoidance driving.The basic training video, “The Complete Uber Partner Guide” includes sections that cover the following general topics: customer service, how to properly use the app, navigation tips, how payment through the app works, how to return lost items, safety.The video makes clear that service animals MUST be accepted.ICBC Commercial Drivers License Road Test, Knowledge Test and Inspection Test.“Ask-Listen-Act”- Enhanced taxi driver training for people with disabilities and seniors (City of Vancouver only).Table 1: Driver Training Comparison: Lower Main-land cdsand   * : Refers to Taxi Driver training that exists in jurisdic-tions in the BC Lower Mainland, not province-wide.12 13Transportation Network Companies and Accessibility Transportation Network Companies and AccessibilityA cursory read of news and government reports on the topic of TNC regulation is quick to highlight accessibility as a major issue in the vehicle-for-hire sector. The City of Ottawa, for example, held up “accessibility” as a “guiding principle” in the development of its new vehi-cle-for-hire regulation. In the United States, the National Federation for the Blind’s class-action lawsuit against Uber (settled April 201617) has also been heavily reported, as have numerous reports highlighting instances of service denial of people with disabilities and other issues.The main challenge is rooted in the fact that TNCs have an entirely different relationship to fleets than do traditional taxi companies. The TNC has no real relationship to those who drive for them nor the vehicles that their drivers drive, other than that which is mediated through their app. Because the standard TNC service model is entirely reliant on independent driv-ers, connected to the TNC through their driver app, the availability of WAVs is equivalent to the amount of non-commercial WAVs seen on the road today. Additionally, the part-time status of the vast majority of TNC drivers and the high cost of operating and obtaining a WAV leaves no commercial rationale for drivers offering wheelchair-accessible service. TNCs reliance on non-professional drivers has also raised concern regarding the ability of drivers to safely stow passengers’ mobility aids and treat passengers with respect and dignity.   6.2 What are TNC’s doing?Legal challenges, negative press and a desire serve a wider market has resulted in TNC’s enhancing some aspects of accessibility in their products. Given the primacy of technology in TNCs service delivery, most of these enhance-ments have been through the app. 17 Chris Danielson, (April 30, 2016), "Groundbreak-ing Settlement to End Discrmination Against Blind Uber Riders Who Use Guide Dogs" (Press Release), National Federation for the Blind. Accessed May 14. 2016: https://nfb.org/groundbreaking-settlement-end-discrimination-against-blind-uber-riders-who-use-guide-dogs6.2.1 App accessibility features18• VoiceOver (iOS) TalkBalk (Android) compatibility (can be used in conjunction with wireless braille display). ◊ These features are essential for visually impaired users. Description of buttons are read aloud when touched and users can dictate information into required fields, such as the destination. Users can also hear the estimated prices and summon their ride through these features.• High contrast colour scheme.19 • Option for inputting additional instructions to driver (Uber presentation, iCord)• For deaf or hard-of-hearing drivers◊ “Beethoven”20, a special feature for drivers who are hearing impaired › Uber Partner app (app for drivers) delivers a flashing LED light to alert drivers of new trip request. › Uber Partner app can be configured to allow riders to only text driver special instructions, as opposed to calling, allowing hard of hearing drivers to ensure they receive information from riders.◊ Delivers additional prompt to riders informing their driver is deaf or hard of hearing. 18  The following represent features present in Uber’s driver and partner apps. Many of these features may also be present in other TNCs’ and apps.19 Jon Rempel, (June, 2014), "A Review of Uber. the Growing Alternative to Traditional Taxi Service." Prod-uct Evaluations and Guides. AFB Access World Magazine, American Federation for the Blind. 15 (6). Accessed June 10. 2016: http://www.afb.org/afbpress/pub.asp?DocID=aw-1506toc&All#aw150602)20 Uber, (Mar. 16, 2016), "A new way to explore the Uber app for our deaf or hard-of-hearing partners", Uber. Accessed July 2. 2016: https://newsroom.uber.com/can-ada/a-new-way-to-explore-the-uber-app-for-our-deaf-or-hard-of-hearing-partners/contend with at least one or two fundamental barriers: 1) Can the vehicle physically accommo-date them (for example: Can the taxi accommo-date their motorized wheel chair?); and 2), Can the operator sufficiently provide service to the passenger in a safe and dignified manner. This first barrier has been reduced through licensing a greater percentage of WAV vehicles in taxi fleets. The second has been addressed (with varying degrees of suc-cess) by some jurisdic-tions and taxi companies who have incorporated disability training in their driver training programs. As TNCs become a major provider of passenger transportation, how can these accessibility challenges be ad-dressed? Media coverage on the topic.The photo illustration below is from a story published in The Daily Beast. It highlighted legal challenges against Uber from disability groups, including the National Federation of the Blind, who Uber recently settled with.6. TRANSPORTATION NETWORK COMPANIES AND ACCESSIBILITYstill used in different jurisdictions to refer to peer-to-peer transportation services such as UberX.  The evolving regulatory frameworks emerging across municipalities in Canada, like Edmonton, Toronto and Ottawa, have thus far opted for the term “private transportation com-panies” (PTCs) or “private transportation provid-er” (PTP), as is the case in Edmonton, to refer to the app-based services.6.1 The Accessibility Challenge A person with a disability who uses a taxi has to contend with at least one or two funda-14 15Transportation Network Companies and Accessibility Transportation Network Companies and Accessibilitypersons with disabilities have a variety of differ-ent needs, UberASSIST provides an accessible option for those who do not need a WAV. This training is not standardized, however. Training for UberASSIST is always developed in partner-ship with a local disability advocacy organiza-tion resulting in different training which vary from place to place. 6.3 What are othercities doing?As services such as UberX have taken up a role similar to taxis in cities they have begun op-erations in, policymakers have had to confront many of the accessibility issues outlined above and, in doing so, re-evaluate their regulatory regimes to account for this new business model. The remainder of this section will out-line aspects of new regulation in several North American cities and describe how each regula-tion has addressed issues concerning accessibil-ity to people with a disability within their vehi-cle-for-hire framework.6.3.1 City of Ottawa   Uber began operating in the City of Ottawa in October 2014. In recognition of ma-jor changes taking place in the vehicle-for-hire industry, council engaged KPMG to undertake comprehensive review of the city’s taxicab and limousine industries towards the development of a “sustainable and efficient” service that meets “the evolving needs of residents and vis-itors”. Notably, council included three guiding principles to guide KPMG’s review, one of which was “accessibility.”25 No Requirement for Accessible ServiceThe City of Ottawa’s regulations do not stipulate any requirement for PTCs to offer ac-cessible service. Council has accepted an accessi-bility recommendation made by KPMG that says where a PTC does not have at least 15 per cent of its service hours represented by accessible vehi-cles, the PTC must charge a surcharge to fund an “Accessible Services Support Fund.” The 15-per-cent accessible vehicle standard is the same reg-ulatory standard applied to city taxi companies, which currently exceed that standard at 15.7 per cent.26  At present, the City of Ottawa is not authorized to charge such a levy. As such, this surcharge will have to be implemented by Uber voluntarily, an action city staff say the company has agreed to do. SurchargeThe exact amount of the surcharge is still under negotiation with Uber. KPMG has rec-ommended 30 cents per trip, an amount equal to New York City’s equivalent PTC levy. This amount is much more than the 5 cent figure floated by MLA, Tim Hudak, in his “Sharing Economy” report, which made reference to Otta-wa’s accessibility fund.27 Council has directed the responsible of-fice, General Manager of Emergency and Protec-tive Services, to convene accessibility advisory groups and public paratransit providers to devel-op a strategy that includes how these revenues could offset costs for accessible transportation programs, “including but not limited to enhanc-ing the taxi coupon program.”2825  City of Ottawa, (2015), "Final Report", Taxi and Limousine Regulations and Services Review. p. 1. http://documents.ottawa.ca/sites/documents.ottawa.ca/files/documents/TLRSR_final_report_en.pdf26  City of Ottawa, (2015), "Accessibility", Taxi and Limousine Regulations and Services Review. p. 6. Accessed June 3, 2016: http://documents.ottawa.ca/sites/docu-ments.ottawa.ca/files/documents/otlrsr_accessibility_en.pdf. 27  Personal interview. City of Ottawa28  City of Ottawa, "Final Report", p. 3 Some of these features have been around for several years, for example, Voiceover iOS compatibility, whereas other features, such as improvements to the Uber Partner app, were established in early 2016.6.2.3 Employment for People with Disabilities Transportation network companies have highlighted their value as employers for people with disabilities.21 The flexible and relatively low barriers to entry (no interview, easy to appli-cation process, see Appendix D for a summary of the steps needed to become an Uber driver) and the app accessibility features the driver app (outlined above) make it a viable opportunity for some people with a disability to generate addi-tional income. Individuals who are deaf or hard of hear-ing appear to account for the largest group of drivers who have disabilities. A group 80 deaf and hard of hearing Uber drivers from Montréal have been vocal about their support of compa-nies like Uber. These drivers say not having to obtain a commercial license and Uber’s accessi-ble app features put a job that was otherwise out of reach within reach.226.2.2 Accessible PlatformsIn addition to app accessibility enhance-ments, Uber has established additional prod-ucts geared towards providing more accessible service. These include a wheelchair-accessible service, usually known as UberWAV, and Uber-ASSIST, a “door-to-door service” “designed to provide additional assistance to seniors and peo-ple with disabilities.”23 UberASSIST drivers also receive additional accessibility-related training.  21 Uber, (Dec. 2, 2015), "Inclusion Matters: Access and Empowerment for Riders and Drivers with Disability in Australia", Uber, Accessed June 1, 2016: https://news-room.uber.com/australia/inclusion-matters-au/ ; Uber, (Sept. 22, 2015), "Uber & Enabled Employment: A New Kind of Mobility," Uber, Accessed June 10, 2016: https://newsroom.uber.com/australia/uber-enabled-employ-ment-a-new-kind-of-mobility/22 CTV Montreal, (May 29, 2016), "Deaf Uber drivers hope the Quebec gov't will consider their livelihoods." CTV Montreal. Accessed June 2. 2016: http://montreal.ctvnews.ca/deaf-uber-drivers-hope-the-quebec-gov-t-will-consider-their-livelihoods-1.292214323  Uber. "Uber Assist". Uber. Accessed July 10 2016: http://ubermovement.com/uberassist/Notably, these services are only offered in a mi-nority of markets.UberWAV While the standard UberX platform can accommodate passengers using conventional manual wheelchair (chairs that can be easily folded and secured in trunk), motorized wheel-chairs or riders who need to stay seated in their wheelchair require specialized vehicles to be transported. The launch of UberWAV in 2014, which followed months of legal challenges in Califor-nia, Arizona and Texas where plaintiffs chal-lenged Uber alleging they were in violation of the American Disabilities Act,24 has brought WAV service to customers. The reliability and availability of this service, however, varies city to city.The vast majority of UberWAV vehicles are wheelchair-accessible taxis registered on the UberWAV platform. As such, the existence of UberWAV and the number of vehicles on the platform in cities it is offered is often positively correlated to the number of wheelchair-acces-sible taxis in the region.  In many cases, Uber also partners with organizations that operate WAV vehicles, such as Dignity Transportation in Toronto or First Transit in Portland. UberASSIST UberASSIST bills itself as a service for those needing extra assistance, such as “seniors and people with disabilities.” With training beyond what typical Uber drivers have, Uber-ASSIST drivers offer door-to-door service. As 24 Nina Strochlic. (May 21, 2015). "Uber: Disabil-ity Laws Don’t Apply to Us." The Daily Beast. Accessed March 5. 2016: http://www.thedailybeast.com/arti-cles/2015/05/21/uber-disability-laws-don-t-apply-to-us.html16 17Transportation Network Companies and Accessibility Transportation Network Companies and AccessibilityAccessible Transportation Fund Similar to many other cities that have recently overhauled their vehicle-for-hire reg-ulations, Portland “will establish an Accessible Transportation Fund with revenue generated by a mandated, minimal fare fee on all taxi and TNC trips.” Revenue is planned to be “used as an incentive to help ensure that the highest cost of providing WAV trips is not a barrier to providing WAV service.”30 Nickole Cheron, Program Coor-dinator in Portland’s Office of Equity and Human Rights, and someone closely involved with the development of this regulation, says the sur-charge has been planned to be 25 cents. Once in place, this would be one of the highest per trip accessibility surcharges, just below New York City’s 30 cent surcharge.6.3.4 City of Toronto On May 3, 2016, the City of Toronto in-troduced new regulations to be included in an updated vehicle-for-hire bylaw that comes into effect July 15, 2016. Following suit with other Canadian cities such as Edmonton and Ottawa, the regulation includes a new licensing category, “private transportation company” (PTC), under which both PTC drivers and the PTC companies, such as Uber, will be required to obtain an annu-30  City of Portland, (Oct. 29, 2015), "New Rules for Private For-Hire Transportation", Bureau of Transportation, p. 1. Accessed April 15, 2016al license. Uber began operating its peer-to-peer service UberX in Toronto in 2014. Within a year, it quickly grew, capturing approximately 17,000 trips per day and drawing the attention of the local taxi industry and government officials concerned about the approximately 10,000 un-licensed vehicle-for-hire drivers operating in the city.31 In July 2015, city staff conducted a Ground Transportation Review32, which examined the implications of TNCs for the public interest, as well as the existing taxi and limousine indus-tries.UberWAV and UberASSIST in Toronto On the heels of Toronto’s Ground Trans-portation Review, Uber launched its main accessible service platforms—UberWAV and UberASSIST -- in October 2015.33 It is important to understand that, given the different regula-tory environments and strategies Uber uses to procure drivers for UberWAV and ASSIST across North America, these services may vary slightly city to city. The following paragraphs describes the service as it has been established in Toronto. 31 City of Toronto, Ground Transportation Review, p. 10.32  "Ground Transportation Review".33  Uber, (Oct. 30, 2015), "Improving Accessible Transportation Options in Toronto", Uber. https://news-room.uber.com/canada/accessible-transportation-in-to-ronto/6.3.2 City of Portland In December 2014, the City of Portland convened a citizen task force to examine and provide guidance and recommendations to council regarding how the private for-hire vehicle regulatory framework should evolve in response to changes in the industry. One major proposal was that the city run a pilot program, temporarily permitting Lyft and Uber under cer-tain conditions. Pilot program Commencing in April and running to August 2015, the pilot program took place for four months and required both taxis and TNCs to share significant amounts of data during set intervals of the trial. An interim set of rules was created to outline service and operational requirements for TNCs. These included:• TNC vehicles were required to pass safety tests and receive standardized safety certificates from professional mechanic.• TNCs had to certify driver background checks.• Drivers had to complete knowledge, safety and customer-service training through Transportation Bureau-approved tests.• TNCs were required to provide service 24 hours a day and accept any request received anywhere within the city.The pilot also outlined specific “equity and in-clusion principles.” Among them: • “TNCs will implement service performance measure to provide timely and equitable service to persons with disabilities”• “Equitable service is defined as responding to requests for wheelchair-accessible vehicle service within the same amount of time as comparable requests for non-wheelchair accessible vehicle service.”29During the pilot, TNCs were given some leniency as they worked to come into compliance with the equitable service performance measures.  29 City of Portland, "Private for For-Hire Transporta-tion Innovation Pilot Program: Transportation Network Service Guiding Regulatory Principles", Bureau of Transpor-tation, p. 9-10. Accessed May 4. 2016: https://www.portlan-doregon.gov/transportation/article/526684For the first 30 days, TNC’s only had to reach requests for WAVs with “reasonably prompt ser-vice.” For the next 30 days, “reasonably prompt service” became defined as service no greater than 30 minutes above non-WAV requests. As the pilot went on, these performance measures became more stringent, eventually requiring TNCs to serve WAV requests in a time no greater than 10 minutes over non-WAV service.Accessible Service Results The pilot saw TNCs provide 15 per cent of all WAV trips provided by TNCs and taxis. This was achieved through the TNC companies part-nering with organizations that have WAVs as well as using taxi drivers with operating WAVs.  TNCs provided consistently shorter wait times for on-demand WAV requests when com-pared to taxis (see Figure 1).New Regulation Based on the analysis of 120-day pilot, council passed a new set of vehicle-for-hire rules in December 2015 where TNCs would be per-mitted. The regulations maintain many of the requirements outlined in the pilot.Regulations state that TNC’s:• “must operate a fleet of wheelchair-accessible vehicles or partner with a WAV transportation operator to accommodate all WAV requests.”• Are prohibited from applying dynamic pricing, like Uber’s surge pricing, to WAV trips.• Maintain a local customer service office.Additionally, the ordinance states that the Bu-reau of Transportation will establish an “Ac-cessible Transportation” fund. Revenue will be generated from fee added to all taxi and TNC trips and will be used to offset the higher costs of providing WAV service.Portland’s prohibition on dynamic pricing for WAV trips has not been observed in any other jurisdiction and is a clear reflection of a regula-tion that has an emphasis on equitable transpor-tation outcomes.Figure 1: Average Monthly WAV Wai-times during the City of Portlands TNC Pilot. Source: City of Portland. 18 19Transportation Network Companies and Accessibility Transportation Network Companies and Accessibilityaccessible vehicles are available when requested within wait times that are comparable to non-accessible services and at fares that are the same as basic non-accessible services.”• “ ‘Comparable wait times’ means no more than the average industry wait time for non-accessible service, as determined by the Executive Director of Municipal Licensing and Standards” (MLS). • The PTC has to report on its accessible service delivery, including the wait times of accessible PTC vehicles, regularly as directed by the Executive Director of MLS.2. Accessibility FundThe second method is the development of an accessibility fund, which is to be funded by a 10-cent trip levy that applies to all non-WAV vehicle-for-hire trips, including taxis, PTCs and limousines. Revenues would be used to subsi-dize PTC, taxi or limousine drivers wishing to purchase a WAV.356.3.5 City of Seattle In 2013, major TNCs such as Lyft and Uber, as they have in most US jurisdictions, be-gan operating their peer-to-peer services before local county and city authorities had regulations in place. Regulation came in 2014, codifying many of the conditions other cities have introduced. For example, Seattle introduced the need to obtain a TNC license, which is contingent on successful vehicle inspection from a city-ap-proved mechanic and the completion of a train-ing module.Customer ServiceAmong the cities whose regulations have been studied in this research, the topic of customer service, while present and articulate on fundamental principles, such as the require-ment of taking the most direct route as possible or transporting someone who has a wheelchair if it can be folded and secured in the vehicle, 35  City of Toronto, (May 3, 2016), "A New Vehi-cle-for-Hire Bylaw to Regulate Toronto's Ground Transpor-tation Industry" S99. Accessed May 10, 2016: http://app.to-ronto.ca/tmmis/viewAgendaItemHistory.do?item=2016.LS10.3has been limited. This is because one of main features of TNC apps—the rating system—is expected to naturally provide incentive and feedback to drivers (and customers, for that matter) to be courteous and respectful. Seattle’s regulations are notable for their more expansive approach in this category, listing several stan-dards TNC drivers are required to uphold. Nota-ble examples: • “must help passengers by placing luggage or packages that weigh less than 50 pounds in and out of the vehicle.”• “must not refuse to transport groceries, packages or luggage when accompanied by a passenger.”Accessibility Fund As other cities have done, Seattle’s 2014 ordinance that legalized TNCs also brought in a new per-trip surcharge whose funds will go into an account designated for improving the avail-ability of wheelchair-accessible service. Seattle’s “Wheelchair Accessible Services Fund” will be based on a surcharge of 10 cents per trip. 36 Here are the key details:• Applies to all vehicle for-hire trips, including taxicab and TNCs, WAV and non-WAV.• Funds will be directed towards offsetting the “higher operational costs of wheelchair accessible taxi services”• Funds will be issues through reimbursement.• The Director of Finance and Administrative Services has considerable powers regarding how funds are distributed and for what costs they are applicable towards.• After one year, the director may adjust the surcharge rate based on certain conditions. During an interview, a Seattle spokesperson ex-plained that it is still unclear how this fund will be deployed. She also described how staff are ex-ploring other avenues for improving accessible service in ways that give funds to riders instead of operators. Such a method would be outside 36  City of Seattle, Municipal Code, "Wheelchair Ac-cessible Services Fund", S 6.310.175. Accessed July 3, 2016: https://www.municode.com/library/wa/seattle/codes/municipal_code?nodeId=TIT6BURE_SUBTITLE_IVNELI-CO_CH6.310TAFREVE_IGEPR_6.310.175WHACSEFUAccording to Uber, their Toronto UberASSIST service is de-livered by over 1,000 of the compa-ny’s top-rated affiliated drivers. The company states this Toronto service is readily available, with wait times of less than six minutes.34 I examined this claim through the app during several periods of the day, over multiple weeks and found average wait times to be within 2 minutes of Uber’s stated wait time 75% of the time with an average wait time of 6.9 minutes (Table 2). Unlike UberX drivers, Uber-ASSIST drivers must receive special in-person training to support their ability to serve seniors and persons with disabilities. In Toronto, this training has been developed with an advisory committee consisting of several Ontario disability advocacy organizations.To provide UberWAV in To-ronto, Uber utilizes two different groups: 1) drivers operating accessi-ble taxis and 2) drivers with Dignity Transportation, a specialized accessi-ble transportation provider.New Bylaw Toronto’s new bylaw looks to enhance accessible service through the inclusion of general public-safe-ty-related requirements, consum-er-protection-related rules, and also specific accessible-service require-ments.  Toronto’s bylaw uses two main strategies to support accessible vehicle for-hire service: 1) Accessible Service Requirements, and 2) Utili-zation of revenue from Accessibility Fund.1. Accessible Service requirements Toronto’s bylaw outlines accessible ser-34 Uber Presentation at Disability Forum, Van-couver, B.C..vice requirements for PTCs:•  “Any PTC that has more than 500 vehicles affiliated with or registered to provide transportation services [is] required to provide wheelchair-accessible service to the public.”• “Accessible PTC services means that wheelchair-TORONTO# Of Ober-vationsTime (00:00)WAV Assist Taxi UberX1 2015 5 7 3 32 1600 2 9 3 33 1745 4 7* 2 4*4 1400 3 7* 2 2*5 1610 2 9 2 26 1700 6 7* 2 2*7 1600 4 7 2 58 2134 7 11 4 39 2320 5 10 3 510 1110 5 4 2 211 1230 7 5 3 312 1545 3 8 2 313 1722 5 N/A 3 514 1036 2 2 2 115 1505 3 8 2 316 1720 4 8* 2 2* 17 1909 5 7* 2 2*18 1348 3 7* 3 4*19 1230 6 10 3 520 2020 7 7 2 521 1720 4 6 2 222 950 5 5 3 223 1217 3 3 2 224 1440 16 2* 5 4*25 1850 5 10 2 4Avg. wait time (minutes)4.84 6.9 2.52 3.12% of time within 2 minutes of 6 minute benchmark75%*= a period of higher than normal fares (aka: "Surge")Table 2: Summary of wait times from the Uber Toronto app20 21Transportation Network Companies and Accessibility Transportation Network Companies and AccessibilityUnlike the City of Portland, Austin did not complete an official summary of results from its pilot program.Accessibility  Both the previous and the latest TNC ordinance in Austin feature a section on accessi-bility. These two ordinances are notable in how they differ on fundamental accessibility-relat-ed regulations. While Austin’s first ordinance (which is the one preferred by major TNCs such as Uber and Lyft) includes a small per-trip fee to fund accessible service improvements, a feature of TNC regulations in many other jurisdictions, the latest ordinance has removed this, instead, inserting a requirement that the TNC implement an “Accessibility Plan” within 6 months. The ordinance continues and says that if “a TNC has an existing accessibility plan on field in another jurisdiction, the TNC must adapt that plan for use in the City [of Austin]”. 41 The ordinance does not define what is included in an “accessibility plan”.Additional accessibility regulations:• “Within three months of obtaining a TNC operating authority, an accessible- service-request indicator must be available on the app. If a driver cannot provide a passenger a requested accessible ride, the TNC must identify an alternative transportation arrangement for the passenger.”• “A TNC shall conduct outreach events to community organizations with ADA [American Disabilities Act]-compliant vehicles to publicize the TNC’s need for ADA vehicles and drivers with the goal of providing services to all passengers. A TNC shall report back to the City on the results of this outreach quarterly.”• “A TNC shall conduct outreach events to communities that are of lower social economic strata without adequate transit options with the goal of increased access 41  City of Austin, (Feb. 1, 2016) "An Ordinance Amending City Code Chapter 13-2 Relating to Transporta-tion Network Companies (TNCs) and Terminating Operat-ing Agreements", Ordinance No. 20151217-075. Accessed June 3. 2016: https://www.austintexas.gov/edims/docu-ment.cfm%3Fid=245769to transportation options: The TNC shall report to the City the effectiveness of this outreach quarterly.”Austin’s requirements to conduct and report back on specific outreach activities are unique among the cities examined in this re-port. In particular, the explicit inclusion of an action that seeks to address socioeconomic in-equality relating to transportation sets Austin’s accessibility language apart from other cities whose equivalent sections—with the exception of Portland’s prohibition on dynamic pricing for accessible service—have been agnostic to socio-economic issues. UberWAV and UberASSIST Prior to suspending operations in May, Uber operated its WAV and ASSIST platforms in Austin. In contrast to other cities, these ser-vices were only visible on the app to users once they had entered a specific promo code within the app. Uber provided these services through a partnership with a non-emergency medical transport (NEMT) company.the conditions of the WASF, which is limited to subsidizing “owners and operators,” but could be explored through other funding methods.6.3.6 City of EdmontonOn January 27, 2016, the City of Edmon-ton became the first Canadian city to legalize Ube2r under a new bylaw that brought what Edmonton calls Passenger Transportation Pro-viders (PTPs), such as Uber, and traditional regulated vehicle-for-hire groups under one bylaw.37 UberX had been operating in Edmonton since late 2014 when council directed staff to create a new bylaw in response to the evolving vehicle-for-hire industry. Uber continued to operate in Edmonton until March 1, 2016, the day Edmonton’s bylaw came into force and its op-erations fell out of compliance. This is because the province of Alberta has not yet approved the type of insurance product Uber has stated its business model requires.Edmonton’s bylaw makes an important distinction between two types of PTPs: regional and commercial. Regional PTP’s are smaller, dispatching fewer than 200 vehicles. Commer-cial PTPs are larger companies, such as Uber, which dispatch 200 vehicles or more. Fees vary depending on which of these categories a PTP falls under.AccessibilityThe central tool the City of Edmonton has estab-lished for improving accessible service in the vehicle-for-hire industry is an annual $20,000 accessibility surcharge that applies to commer-cial PTP’s. Regional PTPs will also be required to contribute to this fund, to the amount of $50 per vehicle. According to Garry Dziwenka, Direc-tor of Business Licensing and Vehicle-For-Hire at the City of Edmonton, the fund will be used to “develop a program to facilitate the further provision of accessible taxi service.” How this money will be distributed or the number of dollars this surcharge is expected to generate is 37  Elise Stolete, (Jan. 28, 2016), " Edmonton becomes first city in Canada to pass Uber-friendly bylaw", National Post. Accessed May 1, 2016: http://news.nationalpost.com/news/canada/edmonton-becomes-first-city-in-canada-to-pass-uber-friendly-bylawunclear, however, as the City has no idea how many commercial and regional PTPs may enter the market. The accessibility surcharge is waived for PTPs that offer WAV service that meets standards required of taxicab companies. The accessible-service standard required is that the company must operate enough WAV vehicles so that at least one vehicle is always available for dispatch.DispatchEdmonton also allows PTPs to provide a telephone-based dispatch service. The option to use this traditional dispatch method has been highlighted by persons with disabilities as an important feature to removing barriers for those wanting to summon an app-based vehicle for-hire services but who may not have the smart-phone required to do so. 6.3.7 City of Austin  In May 2014, the City of Austin initiated a process to develop a stakeholder group that would prepare a framework for a TNC pilot program.38 Before this process was complete, council approved an interim TNC program, which began in October 2014. Council replaced these regulations by passing a new controversial ordinance in December 2015, 39 which brought in fingerprinting requirements for TNC drivers. After a local ballot to amend Austin’s new ordi-nance failed to land in Lyft and Uber’s favour in May 2016, the companies temporarily suspend-ed their service.40 38 City of Austin, (Aug. 3, 2015), "Transportation Network Companies-ATD Staff Recommendation Up-date", Austin Transportation Department. Accessed June 3. 2016: http://www.austintexas.gov/edims/pio/document.cfm?id=235539 City of Austin, (Dec. 2015), Municipal Code, "Transportation Network Company Service", S 13-2, A4. Accessed May 21. 2016. https://www.municode.com/library/tx/austin/codes/code_of_ordinances?no-deId=TIT13TRSE_CH13-2GRTRPASE_ART4TRNECOSE40 Associated Press, (May 9, 2016), "Uber and Lyft halt service in Austin, Texas, after voters embrace back-ground-check rules", published in Los Angeles Times. Accessed May 9, 2016: http://www.latimes.com/business/la-fi-tn-uber-lyft-suspension-austin-20160509-snap-story.html22 23Transportation Network Companies and Accessibility Transportation Network Companies and Accessibility7.1 ChallengesSuburban areas have less accessibility While Translink’s bus fleet is now univer-sally wheelchair accessible, lower densities in suburban areas mean larger distances between bus stops and declining levels of service. Par-ticipants said that lower service levels were not just a challenge for bus riders, but also Handy-Dart riders. For example, HandyDart operates only two trips from the Tri-Cities to the City of Vancouver each day.42 This provides significant barriers for riders who may have to work down-town, attend appointments and complete other errands in the metro core.  Given these challeng-es, on-demand vehicle-for-hire services take on elevated importance for people with disabilities in suburban areas. “The Last Mile” The “last mile” (or “first mile”) refers to the challenge—one that is especially pro-nounced in suburban areas—of getting passen-gers to and from the departure points of public transit. If these distances appear too great or inconvenient to prospective riders, they may opt to drive. For people with disabilities who have limited mobility, the “last mile,” due to a lack of appropriate sidewalks, a lack of a “walkable” and connected grid, or simply being too great a distance, can render transit inaccessible.Group Travel A lack of options for people in groups who use wheelchairs was identified as another major challenge. The problem is not necessarily that there is a lack of vehicles they can all travel together in. Rather, it was that it was virtually impossible for them to all obtain rides and to travel to particular destination within a similar window of time. One participant gave the exam-ple of a group of people at the Blussom Spinal Cord Centre in Vancouver looking to travel to BC Place for an event. They said it would not be pos-sible to receive enough wheelchair spots from WAV taxis within a window comparable to what 42 Paul Gowan, (nd),"HandyDart Service Bumps Across Borders", Disability Foundation. Disability News. Accessed June 5. 2016: http://www.disabilityfoundation.org/news/040305_handydart.htmla group of able-bodied individuals would be able to receive. This example demonstrates a trans-portation barrier some people with disabilities face when engaging in social activities. Vehicle-For-HireTraining Participants discussed concerns around driver training, both for HandyDart drivers—which include the contracted accessible taxi providers and the HandyDart minibuses oper-ators—and for taxi drivers, saying they need more training in securing passengers safely. There was significant discussion regard-ing the need for improved taxi-driver training. Participants acknowledged that drivers operat-ing in the City of Vancouver were better trained (the City of Vancouver delivers its own acces-sible-taxi driver-training program through the Vancouver Taxi Association) but that training across suburban municipalities was not the same and stressed this needed to be harmonized across the Lower Mainland.   Availability of Wheelchair Accessible Vehicles The goal of taxi regulation has long been to ensure that passengers are safe, service is reliable and the industry is economically sus-tainable. Limiting the supply of taxis has been one strategy used to achieve an economically sustainable industry. In the Vancouver metro-politan area, the number of taxis is capped and taxis are restricted to specific service areas. As a result, wait times become longer during regu-lar peak times, like rush hours, and even longer during infrequent and irregular peak periods, such as during cruise-ship arrivals in the City of Vancouver, and other events that take place that make the rush hour an even busier period. Forum participants stated that the wait times for people needing a WAV were excessive and twice as long as those not requiring a WAV. This claim is not unfounded. According to a Hara and Associates study, wait times for accessible taxis are twice as long compared to regular taxis. The study also reports that 30 per cent of passengers requiring a WAV taxi wait longer than 15 min-utes, exceeding the PT Board’s metric for reason-able service of no more than eight per cent of 24 25Transportation Network Companies and Accessibility Transportation Network Companies and AccessibilityAddressing accessibility within the vehi-cle-for-hire sector requires an understanding of the local context in which they operate. As such, this section will report on accessi-bility in the Vancouver met-ropolitan area context.  On April 18, 2016, members of the disabili-ty community convened to discuss “Improving accessi-ble transportation in Metro Vancouver.” The event was hosted by Spinal Cord Injury BC (SCI-BC) and Uber Can-ada and drew approximately 60 people, including many participants who depend on accessible transportation options in the region. During the discussions, several issues came up nu-merous times and received wide acknowledgement within the group as chron-ic challenges for accessible transportation in the region. Participants also agreed on features that were good. These are all described below.7.0 THE ACCESSIBILITY CHALLENGE IN VANCOUVERa sample of the measures taken by jurisdictions to address the accessibility challenges in their respective vehicle-for-hire markets. Because these regulations have been in place for such a short period of time it is not yet possible to assess how successful they have been. Other factors, such as the limited amount of publicly available data on key accessibility indicators such as wait times and number of fulfilled and unfulfilled requests, as well as more qualitative feedback on areas such as the level and sufficiency of care and service being experienced by customers have made it difficult to draw conclusions. The outlier in this regard is the City of Portland, which did collect and has released significant amounts of data, some of which was summarized and shared above. For the other cities, interviews with policy-makers and disability advocates can help enhance our understanding of how policies have played out thus far. Additionally, interviews with indus-try stakeholders like Uber can provide insights into how regulations have specifically been met on the operations side.This section will expand on select top-ics touched on in previous sections and, based on data collected from interviews and online sources, focus particularly on how accessible TNC services have been rendered in jurisdictions included in this report. Accessible ServiceAmong the cities that were examined, the ones that have objectively greater levels of accessibility in their vehicle-for-hire markets are those that permitted TNCs on the condition that they provide such services. This is the case in Portland and Toronto. It is critical to note that in both of these cities, Uber’s WAV service is contingent on the availability of a pre-existing pool of WAV vehicles. As well, taxis play a major role in providing this service through the Uber platform. Other cities have been at a disadvan-tage. As staff from the City of Ottawa explained in an interview, “We can’t do the same thing as Toronto. In Ottawa, taxis are unionized. They’re not allowed to drive for other companies.” While B.C. does not have this same barrier, it is unclear how willing B.C. taxi companies and taxi WAV 8.0 ANALYSIS AND RECOMMENDATIONSpassengers waiting more than 15 minutes. 43Lack of on-demand transportation options The lack of opportunity to access on-demand transportation is an overarching challenge connected to many of issues above. Participants with disabilities emphasized their need and desire for spontaneous trips, stating “that this is not available to us as it is for everyone else.” Whereas most non-disabled people have access to a range of transportation options, disabled passengers, for many reasons, depend on taxis almost exclusively for their on-demand transportation needs and therefore require a system that can serve them.7.2 Strengths While there are ongoing struggles for those in need of accessible transportation op-tions across the Vancouver metropolitan area, focus group participants highlighted some aspects that are working. These are described below.TaxiSaver Pro-gram People with a perma-nent disability are eligible for Translink’s Taxi Saver program which provides riders with cou-pons that give them 50 per cent off taxi fares. Participants were unanimous in their support for this program. This program gives persons with disabilities greater access to what is can often be their only on-demand transportation 43  Hara and Associates,(2014), “Assessment of Pub-lic Need for 78 Vancouver Accessible Taxi Licences”, cited in "Vancouver Taxi Service Review and Report Back", City of Vancouver, 2015, p.14option: taxis. Though HandyDart and taxi trips utilized with Taxi Saver coupons are not directly com-petitive (HandyDart is not an on-demand service like a taxi is), it is reasonable to assume that some trips taken using the Taxi Saver program are trips that might have otherwise been booked through HandyDart. Participants highlighted the fact that given the higher per trip cost of HandyDart, a trip diverted from HandyDart to taxi may represent a cost savings to government and a preferred trip for the passenger—a win-win.Accessible Public Transit System In general, participants regard public transit in the Vancouver metropolitan area as relatively accessible. A universally accessible bus fleet, SkyTrain and Seabus system position the region ahead of other cities when it comes to public transit accessibility.The cases highlighted in this report represent A wheelchair accessible taxi in Vancouver.26 27Transportation Network Companies and Accessibility Transportation Network Companies and Accessibilitycan accommodate wheelchairs—many individ-uals with a disability do not use a wheelchair or require a ramp. In recognition of this, Uber of-fers UberASSIST in many cities, which the com-pany has described in letters to governments as an “option that is designed to provide additional assistance to seniors and people with disabilities that do not require a vehicle with a hydraulic lift/ramp.”47 This program was also highlighted at the forum as a key option for people with dis-abilities who do not need a WAV vehicle. This emphasis and focus on Uber-ASSIST as the “accessible” option for people with disabilities who do not need a WAV vehicle, however, problematically suggest that the company’s ubiquitous (and most available) product, UberX, is not for people with a disability and that a person with a disability should choose “ASSIST” if they need a ride. While Uber and other TNCs advise all their drivers that they cannot discriminate against riders with a disability, encouraging peo-ple with a disability to connect with their specialized services, instead of the basic service, can foster a two-tiered system where one is for “easier” fares and people who do not require any extra assistance, while the other is for those that do need an “extra hand,” as Uber’s Assist product puts it. People with a disability want the same options that people without disabilities have. This has been a common refrain, one that was repeated by stakeholders from the forum, and one that has been observed in summaries of other similar stakeholder meetings in other regions.48 Indeed, the idea that TNCs may enhance this choice for people with disabilities is central to people with disabilities that support the entrance of TNCs.  If TNCs basic services are to be accessi-ble for those who can access conventional vehicles, careful attention needs to be given to ensuring TNC’s are providing sufficient disability-related training to all of their drivers—not just for drivers with their specialized services, such as UberAs-47  City of Mississauga, (Mar. 2, 2016), "Appendix G: Response to Uber Comments", in agenda package for "General Committee", Accessed on June 4, 2016: http://www7.mississauga.ca/documents/agendas/commit-tees/general/2016/03_02_2016_GC_Agenda.pdf48 City of Mississauga, (Feb. 2, 2016), "The Study of Regulations of Transportation Network Companies", prepared by Windels Marx, p. 3., Accessed on June 5, 2016: http://www7.mississauga.ca/documents/agendas/committees/general/2016/03_02_2016_GC_Agenda.pdfTable 3: Summary of Wait time Observations for WAV vehicles in Portland and Toronto (in minutes)drivers would be to make their vehicles available through the Uber platform.  Even if taxi companies in the Vancouver area were willing to make their services avail-able through the Uber platform, geo-fencing—a practice employed by regulators that restricts where certain vehicles can pick up fares—may complicate the ability for WAV taxis on the Uber platform to provide service across the region.  In addition to taxis, UberWAV has been reliant on other accessible transportation pro-viders. This includes non-emergency medical transport (NEMT) companies such as Dignity Transportation in Toronto and First Transit in Portland, as well as non-affiliated individuals who have WAVs and register their vehicles through the Uber platform. These partnerships with NEMT companies are a major benefit to on-demand accessible transportation as they increase the availability of these vehicles and bring consumer costs down significantly. Private Subsidy for Accessible ServiceIt is important to remember, however, that accessible services have higher costs. The basic costs of running an accessible vehicle are more higher. They are more expensive to buy, to insure, to maintain, and to fuel. Then there is also time both before the fare starts and after the fare ends where drivers must assist disabled pas-sengers. For example, passengers may require more time to get from their door to the vehicle and may need more assistance getting settled before the vehicle can leave—all parts of the trip that are not usually part of the fare.  To ensure drivers accept these more costly fares, many jurisdictions, like Seattle, offer a subsidy, which gives taxi drivers operating accessible vans a per-trip ($15) and per-shift ($20) bonus.44To ensure the availability of accessible services, TNC’s have subsidized accessible trips. Trips with Dignity Transportation in Toronto, for example, start at around $30 but are available through UberWAV at costs equal to UberX—the company’s basic service.45 Peer-to-peer partners, 44 Personal Interview, City of Seattle45 Jessica Smith Cross, (Jan. 17, 2016) "Accessibility advocates welcome UberWAV service in Toronto". Metro News Toronto. January 17. 2016. Accessed May 27. 2016: http://www.metronews.ca/news/toronto/2016/01/17/that is, regular independent drivers not under contract to Uber, are also receiving financial subsides to provide accessible services. Accord-ing to Bryce Bennett, Uber operations manager in Oregon, peer-to-peer drivers on the Uber-WAV platform receive a per-trip incentive from Uber.46   Has UberWAV decreased wait times for Acces-sible Vehicles?While data from Portland’s pilot reveals a decrease in wait times for on-demand WAV trips, Toronto has not released information on how, if at all, wait times have changed for WAV trips since Uber launched its WAV service in the city. During the forum, however, an Uber repre-sentative in the Uber focus group said Toronto’s UberWAV platform was providing an average ETA of eight minutes. This number is corrobo-rated by data collected by the researcher in June 2016 (see Appendix C) based on ETAs observed through the Uber app in downtown Toronto.  As shown in Table 3, these low wait times in Toronto contrast with times observed in Portland. Average TNC-dispatched wait times during the latter stages of Portland’s pilot hov-ered around 18.5 minutes and appear to have only dropped slightly during data collected this month. Perhaps the most significant factor in Toronto’s lower ETAs for WAV vehicles is Uber Toronto’s significant utilization of WAV taxis in its local UberWAV service. While Portland has partnered with one taxi company that offers WAVs, Toronto has a large number of WAV-driv-ing taxi operators who have made their vehicle available on the UberWAV platform. With 550 accessible taxis operating in Toronto, many of these are now available for dispatch through the Uber app. This may partially explain why the UberWAV ETAs closely track taxi ETAs and remain quite low (Table 3).   While discussions concerning on-de-mand accessible transportation have an obvious focus on vehicles that are “accessible”— that, is those that have a ramp or a hydraulic lift that uberwav-service-applauded-by-toronto-accessibility-advo-cates.html46 Personal Interview, Uber  OregonPORTLAND TORONTOUberX WAV WAV UberX8 15 5 3- 21 2 35* 14 4 4*3 NTL 3 2*5 8 2 24 12 6 2*3 13 4 55 25 7 34 14 5 53 16 5 22 27 7 35 13 3 35 NTL 5 53 29 2 13 21 3 32 9 4 2*7 NTL 5 2*2 11 3 4*4 10 6 53* NTL 7 5*5 7 4 2*1 30 5 2*3 24 3 25 15 16 4*6 - 5 4*= a period of higher than normal fares (aka: "Surge")NTL = No time was listed.28 29Transportation Network Companies and Accessibility Transportation Network Companies and Accessibilitywould therefore also require a phone-based mechanism of dispatching.     2) Organization-linked dispatch: This approach has already been used in Toronto. Ac-cording to Jared Schachter, operations manager at Uber Toronto, the company has partnered with an assisted-living facility where staff are able to dispatch Uber vehicles to the facility on behalf of their residents. Such an approach could be expanded to other institutions, such as community centres, where customers may already have a membership and an account for the services they access there. In this case, front-desk staff could order a TNC vehicle for their account on behalf of eligible patrons. Once the rider’s trip is complete, the community centre would see the total price charged and could ap-ply it to their client’s account. PO 3. Prohibit Dynamic Pricing for Accessi-bility Focused Products Transportation Network Companies regularly temporarily increase the price of their services during periods of high demand. By do-ing so, companies can adjust both the demand, by forcing others to opt for a cheaper alternative, and the supply, by incentivizing more drivers to activate their driver apps and make themselves available to prospective riders. Disability advo-cates have expressed concern over this feature as it has a disproportionately negative impact on people with disabilities. Among adults of working age, people with disabilities are more likely to be under the poverty line than non-disabled individuals.50 Furthermore, people with disabilities have fewer opportunities for on-demand transportation and also face for more obstacles in administering their day-to-day activities than the population at large. From an equity and social-justice per-spective, subjecting people with disabilities to dynamic pricing is unjust. This is why the City of Portland has prohibited dynamic pricing for wheelchair-accessible vehicle trips. In developing such a regulation, policy-50  Council of Canadians with Disabilities. (nd), "As a Matter of Fact: Poverty and Disability in Canada". Council of Canadians with Disabilities. Accessed May 20,. 2016: http://www.ccdonline.ca/en/socialpolicy/poverty-citizen-ship/demographic-profile/poverty-disability-canadamakers would have to address important con-siderations around the scope of such a policy. Would it apply to all people with a disability or just individuals accessing a wheelchair-accessi-ble service? If such a regulation would apply to all individuals with a disability seeking a trip, how would their eligibility be defined? By ap-plying this regulation only to people taking TNC WAV trips, Portland simplifies and reduces the definition to people who use wheelchairs. More specifically, because people in manual chairs can also receive service from regular sedans (the wheelchair can be folded and go in the trunk) Portland’s regulation reduces this policy to a specific segment of population who use mo-tor-assisted wheelchairs. A policy like Portland’s, while making strides to advance equity for peo-ple with disabilities, effectively ignores a large group of people with disabilities who do not use wheelchairs and who would therefore be subject to dynamic pricing. Given the above, two specific options area highlighted:1) Adapt Portland’s “no dynamic pricing for wheelchair-accessible service” policy and apply it to UberASSIST or oth-er companies’ equivalent services. Pro: This would be a relatively straightforward way to ensure a larger percentage of riders with disabilities are not subject to dynamic pricing. Con: It would exclude people with disabilities who do not book a wheelchair accessible service or services specifically designed for people seniors and people with disabilities (eg. UberASSIST)2) Prohibit dynamic pricing for people with disabilities registered with HandyCard. This approach would only be possible if TNC providers were able to eliminate dynamic pricing on their apps for certain riders. In this case, registered HandyCard users with Translink would receive a unique code that could be in-putted into the “promo” field of their TNC app. Once entered, the code would verify sist and UberWAV, for example.  Regulators have an important role to play in making sure TNC products can properly serve people with disabilities no matter which options they choose to hire. A policy approach to this is discussed in the recommendations (see Policy 5 below). 8.1 Suggested Actions Suggested actions have been prepared based on the research methods outlined at the beginning of this report. Specifically, these rec-ommendations are derived through two central areas of information: 1) transportation con-cerns and challenges expressed by the disability community in the Vancouver metropolitan area, as well as through interviews with advocates in other cities; and 2) the TNC regulations of other jurisdictions. These actions have been divided into two categories: 1) Policy: These are specific regulations that could be explored and incorporated into regulatory documents.2) Process: These are suggested actions to pursue and deemed necessary to better under-stand the challenges and develop policy op-tions around accessibility in the evolving vehi-cle-for-hire industry. Each recommendation also includes a suggestion for which organization should take the lead on implementation. These actions are summarized in Appen-dix A.  8.1.1 Policy (PO)PO 1. Require large TNCs to provide wheel-chair accessible service  The provision of wheelchair-accessible services by TNCs is critical if accessibility is to improve in the vehicle-for-hire sector. Cost and wait times are a critical aspect to this. Regula-tion should help reduce the much longer wait times people requiring WAVs are subject to and should ensure—as all cities examined have done—that people requiring WAV service do not pay more for the service than people using similar non-WAV options, despite the higher operational costs of offering this service.  Here is an example of how this might be phrased:  "That WAV service dispatched by TNCs are at comparable wait times and at the same price as the company’s non-accessible, non-pre-mium service, i.e. UberX."Consider using performance standards that fo-cus on the result and not how it is achieved. The “command and control” paradigm of regulation has been highlighted as a potentially ineffective approach to regulation in the “sharing econo-my.”49 In the case of the policy suggestion above, rather than requiring X number of accessible vehicles, require that the appropriate service be provided within set amount of time a specific percentage of the time.PO 2. Require large TNCs to explore partner-ships with appropriate public facilities, like libraries, universities, community centres, and other facilities, like healthcare facilities, stadiums and arenas, major transportation hubs, hotels, and so on, and find opportuni-ties to centrally dispatch TNC vehicles for disabled customers. This recommendation looks to support people with disabilities who have limited access to a smartphone by increasing their opportuni-ties to connect with accessible app-based dis-patchers. Companies such as Uber require riders to register with their app and create a credit-card linked profile. This limits access to people with disabilities who may not have a credit card or a smartphone. In facilities that interface regular-ly with people with disabilities, there could be ways these facilities could book a TNC vehicle on behalf of their disabled patrons. Two potential opportunities:   1) TNC Phone: Similar to the taxi phones  that have been long established in places  like hotels and hospitals, TNCs could provide phones in key institutions that directly connect  with a dispatcher who may connect users with an accessible TNC service. For this to exist, TNCs 49  Sunil Johal and Noah Zon, (2015), "Policy Making for the Sharing Economy: Beyond Whack-A-Mole", The Mowat Centre, 30 31Transportation Network Companies and Accessibility Transportation Network Companies and AccessibilityBoth major North American TNCs, Uber and Lyft, offer corporate accounts, Uber Business and Lyft Business. According to Michael van Hemmen, Uber’s B.C. operations manager, Uber Business allows the initiating entity to set a percentage it wishes to cover the cost of as well as which service may be selected (eg. UberAS-SIST or UberWAV). Utilizing a version of these services, a subsidizing entity (government or NGO) could simply set a subsidy rate through their corporate account that would be applied to linked users’ trips.PR 2. Engage TransLink in Accessible Transpor-tation Dialogue Due to TransLink’s central role in the pro-vision of accessible transportation in the Van-couver metropolitan area and the importance of on-demand vehicle-for-hire services in the accessible transportation system, major changes to vehicle-for-hire regulations need to be done in consultation with TransLink.Lead: Ministry of Transportation and Infrastruc-tureOther: TransLinkAccessibil-ity LevyAustin Edmonton Ottawa Portland Seattle TorontoYes or No ---✓ ✓ ✓ ✓ ✓Frequency --- per year / per vehicleper trip per trip per trip per tripAmount --- $20k for "com-mercial" PTC/ $50 p. vehicle for "regional" PTCTBD TBD 10 cents 10 centsAlocation --- TBD TBD TBD Partial reim-bursment for higher opera-tional costsGrants to-wards WAV vehicle pur-chaseTable 4: Accessibility Fund Comparisonthem as a registered HandyCard user and eliminate occurrences of dynamic pricing on their apps.Pro: Riders would have access to full spectrum of services available to other users and without being subject to dynamic pricing.Con: Would not capture people with disabilities who are not registered with HandyCard.Con: HandyCard is TransLink program and is therefore restricted to the Vancouver metropolitan area. Such an approach could not easily be applied across other B.C. jurisdictions. PO 4. Establish an accessibility levy for vehi-cle-for-hire trips One of the most common outcomes of jurisdictions’ vehicle-for-hire regulatory re-views has been the institution of an accessibility fund with revenues generated from the vehicle for-hire industry. Regulators clearly like the accessibility levy. This approach links the fund’s revenues to TNCs economic activity and can be designed as very flexible tool able to be allocated to programs that improve accessibility. Trans-portation network companies seem to appreci-ate this tool too. It is easy to implement, can be easily passed onto the consumer, and is a policy tool they are now used to and familiar with. In Austin, TNCs counter-proposal to the city’s proposed operating framework is a testament to their preference to the accessibility levy, which they lobbied for as an alternative to an “accessi-bility plan.” Most cities have adopted a per-trip charge, often 10 cents, that applies to all for-hire trips or all non-accessible trips. While improv-ing accessible transportation has been a consis-tent goal of these funds, jurisdictions differ in how this is best achieved. In deciding where and how this money is distributed, regulators need to consider what the objectives are, as this will guide decisions about the most appropriate action. For example, if the objective is to improve the availability of on-de-mand accessible transportation services, then funds should go towards improving WAV for-hire services rather than supporting a service like HandyDart which, while accessible, does not provide on-demand service. See Table 2 for summary of how other cities have set up funds like this. PO 5. Require TNC’s deliver training that enables them to provide sufficient service to passengers with disabilities Sufficient driver training for riders with disabilities includes safety issues, such as do-ing a proper tie-down of a rider’s wheelchair or securing other mobility, and customer-service issues, such as having the requisite sensitivity training that allows drivers to assist and interact competently and effectively with riders with a disability.  While municipalities play a larger role in determining training that drivers have through their permitting schemes, the PT Board also plays a role in ensuring high standards for companies that operate accessible vehicles. The companies must provide an Accessible Services Plan, which must include descriptions con-cerning the training that operators receive. The Accessible Services Plan requirement could be adapted for TNCs and be a mechanism through which the PTB could receive information and ensure training is sufficient to serve people with disabilities using TNC services.8.1.2 ProcessPR 1. Examine ways people with disabilities can access all vehicle-for-hire (including future TNC platforms) services at subsidized rate.Lead: Translink, Ministry of Transportation  Currently, Taxi Savers offer eligible riders 50 per cent off taxi services. In anticipation of an expanded vehicle-for-hire system, regula-tors should explore how this program might be expanded so that people with disabilities can have access to the full range of appropriate vehi-cle-for-hire options.  32 33Transportation Network Companies and Accessibility Transportation Network Companies and Accessibility10. APPENDICES Appendix A: Summary of Suggested ActionsCode Action Rationale Level of implemen-tation diffi-culty PO1 Require large TNC’s to provide wheelchair accessible service at no extra cost to rider• Wheelchair access is critical component to accessibilityLow• TNC’s in many other cities have shown an ability to provide WAV service• Ensures people that use wheelchairs are not subject to increase costs in on-demand transportation and synchronizes this policy across vehicle for-hire system i.e. taxis, and TNCsPO2 Require large TNC’s to explore partnerships with appropriate public facilities (eg. libraries, universities, commu-nity centers) and other facilities (eg. healthcare facilities, stadiums and arenas, major transpor-tation hubs, hotels, etc.) and find opportunities to centrally dispatch TNC vehicles for dis-abled customers.• Allows people with disabilities, who may not have a smartphone or may have limited capacity to use it, to still receive service from certain locations. Medium• Public facilities have unique responsibility to assist in delivery of important public services.• Some private facilities (eg. Large hotels) have a history of provide a public service in the past (eg. payphones, washrooms, direct taxi lines) and therefore may be amenable to partnering for this type of service.• Limited precedent already exists between Uber and assisted living facility.   This report has characterized how governments have sought to address accessibility-related challenges amidst an industry under rapid changes. To increase understanding of how other ju-risdictions have sought to address accessibility-related challenges in their evolving transportation industry, this reported examined 6 cities, outlining their specific regulations to address the present and prospective challenges faced by persons with disabilities. Following research from around North America, interviews with stakeholders and review of the context in the B.C. lower mainland, this report presents 5 policy actions and 2 process actions to be considered by the Passenger Transportation Branch in its ongoing assessment and research towards a new regulatory framework that addresses TNC’s. As the reader is likely aware, vehicle for-hire policies are changing and being reworked at an ongoing and rapid pace. As such, this report has only been able to capture a portion of the policy responses that have occurred, some of which will undoubtedly be refined and modified in light of the outlined policies’ effectiveness. While the presence of strong consumer support for TNC’s is a positive indication that they provide a quality service to the consumer, the existence of significant approval should not necessar-ily be taken as a sign that the nascent sector does need a careful assessment. As always, there are many other experiences and those from disadvantaged groups can be easily overlooked amidst the chorus of praise from mainstream consumers. The longstanding pres-ence of public oversight in the vehicle for-hire industry is a testament to the important public inter-est implications that need to be considered. As discussed in this report, on-demand transportation options are critical to persons with disabilities to have meaningful social and economic opportuni-ties and carry out their day-to-day activities. Because of this, the PTB and other regulatory agencies and governments in B.C. need to give special attention to ensuring these services meet the needs to persons with disabilities in a fair and equitable manner.9. CONCLUSION34 Transportation Network Companies and AccessibilityName Title Affliation/ Ju-risdictionInteraction Interview DateAdam Blinick Public Policy Lead, Uber Can-adaUber EmailBryan Hockaday Policy and Com-munciations Advisor, Office of Commissioner Steve NovickCity of Portland Phone interview, email22-March-16Bryce Bennett Operations Man-agerUber Portland Phone interview, email3-May-16Carlton Thomas Infrastructure Operations Divi-sion ManagerCity of Austin Phone interview 14-June-16Carolyn Bauer General Manager, Yellow Cab Van-couverYellow Cab, Vancouver Taxi AssociationIn person discus-sion6-July-16Chase Bearden Director of Ad-vocacy, Coalition of Texans with DisabilitiesPhone interview 21-April-16Christine Hartig Strategic Support Coordinator, General Manag-er’s Office, Emergency and Protective Ser-vices City of Ottawa Phone Interview 6-June-16Doris Sundquist Deputy Registrar, B.C. Passenger Transportation BranchProvince of B.C. In persons dis-cussion (project scoping)6-Jan.-16Garry Dziwenka Director of Busi-ness Licensing and Vehicle for-hireCity of Edmonton Phone interview, email11-April-16Appendix B: Informants PO4 Establish an accessibility levy for vehicle for-hire trips• Providing accessible service, whether it be through the use of WAV or not, is more expensive due to extra unbilled time and/or higher operating costs. Levy-funded revenues can be used to offset this cost.Low• Relativley simple to implement with many examples from other jurisdictions.PO5 Require TNC’s deliver trai-ning that enables them to provide sufficient service to passengers with disabi-lities• Accesible service encompasses more than accessible vehicles; to provide accessible  vehicle for-hire system, TNC drivers need to have disability training at par with taxi drivers.• Strengthen accessiblity beyond TNC’s “accessible” products (eg. Uber’s ASSIST and WAV) by ensuring solid baseline of disability-related training.PR1 Examine ways people with disabilities can access all vehicle for-hire (including future TNC platforms) ser-vices at subsidized rate.• Would improve opportunities for people with disabilities to travel and enhance their opportunities. Medium37Transportation Network Companies and AccessibilityAppendix C: Portland and Toronto Wait Time ObservationsDate Time WAV Assist WAV UberX Time WAV Assist (Taxi) UberXJune 8 1542 10 None NTL 41715 15 16 NTL 8 2015 5 7 3 3June 9 1300 21 17 23 1600 2 9 3 31445 14 10* NTL 5* 1745 4 7* 2 4*June 10 1100 NTL 2 9 3 1400 3 7* 2 2*1310 8 N/A 10 5 1610 2 9 2 2June 11 1400 12 9 NTL 4 1700 6 7* 2 2*June 14 1300 13 12 5 3 1600 4 7 2 51834 25 10 19 5 2134 7 11 4 32020 14 8 NTL 4 2320 5 10 3 5June 15 810 16 7 NTL 3 1110 5 4 2 2930 27 5 NTL 2 1230 7 5 3 3June 20 1245 13 16 5 5 1545 3 8 2 3June 21 1422 NTL N/A 6 5 1722 5 N/A 3 5June 22 736 29 N/A NTL 3 1036 2 2 2 1June 23 1205 21 10 NTL 3 1505 3 8 2 31420 9 N/A NTL 2 1720 4 8* 2 2*1609 NTL N/A NTL 7 1505 5 7* 2 2*June 24 1048 11 7 NTL 2 1348 3 7* 3 4*June 26 930 10 15 NTL 4 1230 6 10 3 5(major event) 1720 NTL 13* NTL 3* 2020 7 7* 2 5*June 27 1420 7 N/A NTL 5 1720 4 6* 2 2*June 28 650 30 5 5 1 950 5 5 3 2*July 5 917 24 8 NTL 3 1217 3 3 2 2July 6 1140 15 15 10 5 1440 16 2* 5 4*July 8 1550 13 6 NTL 6 1850 5 10 2 4Surge = higher than normal pricesNTL= the screen shows a button that says “Request Now” but does not display approx. None= Screen simply displayed”unavailable” or “no cars available”James Wiseman President, United Spinal AssociationPhone interview 18-March-16Kristin Vanderkuip Registrar and Direc-tor, B.C. Passenger Transportation BranchProvince of B.C. In person discussion (project scoping); Email, draft feed-back6-Jan-16 to Aug-16Michael von Hem-men Public Policy Man-ager, Uber CanadaUber EmailNickole Cheron Program Coordina-tor, Office of Equity and Human Rights (Formerly Disability Coordinator)City of Portland Phone interview, email23-Mar-16Vanessa Fletcher Policy and Planning Advisor, Office of the Executive Direc-tor Municipal Licensing & Standards City of Toronto Phone interview, email21-Apr-1638 39Transportation Network Companies and Accessibility Transportation Network Companies and Accessibility  City of Austin, Austin Transportation Department, Transportation Network Companies-ATD Staff Recommendation Update, August 3, 2015, Accessed June 3, 2016: http://www.austintexas.gov/edims/pio/document.cfm?id=235537 ____________, Municipal Code, Transportation Services, Ground Transportation Passenger Services, Transportation Network Company Service, 13-2, 4. Accessed May 21, 2016. https://www.municode.com/library/tx/austin/codes/code_of_ordinances?nodeId=TIT13TRSE_CH13-2GRTR-PASE_ART4TRNECOSE ____________,  Ordinance No. 20151217-075, An Ordinance Amending City Code Chapter 13-2 Relating to Transportation Network Companies (TNCs) and Terminating Operating Agreements, February 1, 2016. Accessed June 3, 2016: https://www.austintexas.gov/edims/document.cfm%-3Fid=245769 City of Burnaby, Uber ride-sharing service (Council Report). Accessed, June 4, 2016: https://burnaby.civicweb.net/ document/15149/2014%2010%2027%20-%20 Uber%20Ride%20Shar-ing%20Service%20(2).pdf City of Edmonton, Bylaw 171400, Vehicle for Hire Bylaw, p. 2, Accessed May 13, 2016. http://webdocs.edmonton.ca/siredocs/published_meetings/91/519956.pdf City of London,  G. Kotsifas, P. Eng., Managing Director of Development and Compliance Services and Chief Building Official, Vehicles for Hire, New Technologies,2015, Accessed March 13, 2016 https://www.london.ca/newsroom/Documents/Uber-sept2915.pdf City of Mississauga, Commissioner of Transportation and Works, Regulation of Transporta-tion Network Companies, Appendix G., March 2, 2016. Accessed June 1-, 2016: http://www7.missis-sauga.ca/documents/agendas/committees/general/2016/03_02_2016_GC_Agenda.pdf City of Ottawa, Taxi and Limousine Regulation Service Review, December 31, 2015, http://app05.ottawa.ca/sirepub/cache/2/n5o3pop1qhirlv5uplikps42/3696700714201609391041.PDF____________, Taxi and Limousine Regulation Service Review: Accessibility, http://app05.ottawa.ca/sirepub/cache/2/n5o3pop1qhirlv5uplikps42/36969207142016094335787.PDFCity of Portland, Bureau of Transportation, Portland’s Private for-Hire Transportation Market: Sum-mary Report of the PFHT Innovation Pilot Program, October, 2015. Accessed April 20, 2016: http://www.portlandmercury.com/images/blogimages/2015/10/19/1445275712-pbot_tnc_data.pdf ___________, Bureau of Transportation, Private for For-Hire Transportation Innovation Pilot  Program: Transportation Network Service Guiding Regulatory Principles, Accessed, May 4, 2016: https://www.portlandoregon.gov/transportation/article/526684 City of Seattle, Municipal Code, Taxi Cabs and Vehicle For-Hire, Wheelchair Accessible Services Fund, 6.310.175, Accessed June 15, 2016: https://www.municode.com/library/wa/seattle/BIBLIOGRAPHYAppendix D: How to Become an Uber Driver*• This comprises of a criminal record check completed at no cost to the applicant and which can be done online.Image Source: Uber Canada * = this is the basic process for drivers in On-tario, Quebec and Alberta. Government and Grey Literature40 41Transportation Network Companies and Accessibility Transportation Network Companies and Accessibilitycodes/municipal_code?nodeId=TIT6BURE_SUBTITLE_IVNELICO_CH6.310TAFREVE City of Toronto, A New Vehicle-for-Hire Bylaw to Regulate Toronto’s Ground Transportation Industry Section, City Council Decision, May 3, 2016, Section 3, 46., Accessed June 2, 2016: http://app.toronto.ca/tmmis/viewAgendaItemHistory.do?item=2016.LS10.3 ____________, Executive Director of Municipal Licensing and Standards, 2015 Ground Trans-porta tion Review, Taxis Limos and Uber, 2015, September 8th. Accessed June 1, 2016. http://www.toronto.ca/legdocs/mmis/2015/ls/bgrd/backgroundfile-83268.pdf City of Vancouver, Taxi Service Review and Report Back (Council Report), October 15, 2015. Accessed March 17, 2016: http://council.vancouver.ca/20151020/documents/rr3.pdf Hara and Associates, “Assessment of Public Need for 78 Vancouver Accessible Taxi Licences”, 2014,  as cited in City of Vancouver, Taxi Service Review and Report Back (Council Report), October 15, 2015. Accessed March 17, 2016: http://council.vancouver.ca/20151020/documents/rr3.pdf PWC, The Sharing Economy, Consumer Intelligence Series, April, 2015. Accessed March 3, 2016, https://www.pwc.com/us/en/technology/publications/assets/pwc-consumer-intelligence-se-ries-the-sharing-economy.pdfhtml Rempel, Jon. “A Review of Uber, the Growing Alternative to Traditional Taxi Service,” Product Evaluations and Guides, American Federation for the Blind, June, 2014, 15 (6). Accessed June 10, 2016: http://www.afb.org/afbpress/pub.asp?DocID=aw1506toc&All#aw150602) Rodriguez, Salvador. “For Uber, Lyft Riders with Disabilities, Discrimination Often Comes In-cluded,” International Business Times, August 13, 2015. Accessed June 1, 2016: http://www.ibtimes.com/uber-lyft-riders-disabilities-discrimination-often-comes-included-2052675 Schelling, Stephen. “Uber Town-Car Service Shut Down in Vancouver by B.C. Passenger Transportation Board,” The Georgia Straight, November 28, 2012. Accessed June 18, 2016: http://www.straight.com/news/uber-town-car-service-shut-down-vancouver-bc-passenger-transportati-on-board Stolte, Elise. “Edmonton becomes first city in Canada to pass Uber-friendly bylaw,” National Poast, January 28, 2016. Accessed June 3, 2016: http://news.nationalpost.com/news/canada/edmon-ton-becomes-first-city-in-canada-to-pass-uber-friendly-bylaw Strochlic, Nina. “Uber: Disability Laws Don’t Apply to Us,” The Daily Beast, May 21, 2015. Ac-cessed March 5, 2016: http://www.thedailybeast.com/articles/2015/05/21/uber-disability-laws-don-t-apply-to-us.html Wieczner, Jen. “Why the Disabled are Suing Uber and Lyft”, Time, May 22, 2015. Accessed June 1, 2016: http://time.com/3895021/why-the-disabled-are-suing-uber-and-lyft/News Media and Advocacy Groups Uber Associated Press. "Uber and Lyft halt service in Austin, Texas, after voters embrace back-ground-check rules", published in Los Angeles Times, May 9, 2016. Accessed May 9, 2016: http://www.latimes.com/business/la-fi-tn-uber-lyft-suspension-austin-20160509-snap-story.htmlAssociated Press. "Uber and Lyft halt service in Austin, Texas, after voters embrace back-ground-check rules", published in Los Angeles Times, May 9, 2016. Accessed May 9, 2016: http://www.latimes.com/business/la-fi-tn-uber-lyft-suspension-austin-20160509-snap-story.html Cooper, Sam. “How Vancouver Taxi Companies are Beating Uber,” The Province, November 2, 2015. Accessed May 25, 2016: http://www.theprovince.com/business/Vancouver+taxi+companies+-beating+Uber/11490241/story.html Cross, Jessica Smith. “Accessibility advocates welcome UberWAV service in Toronto”, Metro News Toronto, January 17, 2016. Accessed May 27, 2016: http://www.metronews.ca/news/toron-to/2016/01/17/uberwav-service-applauded-by-toronto-accessibility-advocates.html CTV Montreal, “Deaf Uber drivers hope the Quebec gov’t will consider their livelihoods,” CTV Montreal, May 29, 2016. Accessed June 2, 2016: http://montreal.ctvnews.ca/deaf-uber-drivers-hope-the-quebec-gov-t-will-consider-their-livelihoods-1.2922143 Danielson, Chris National Federation for the Blind, “Groundbreaking Settlement to End Discrmination Against Blind Uber Riders Who Use Guide Dogs” (Press Release), April 30, 2016. Accessed May 14, 2016: https://nfb.org/groundbreaking-settlement-end-discriminati-on-against-blind-uber-riders-who-use-guide-dogs Gowan, Paul. “HandyDart Service Bumps Across Borders,” Disability Foundation, Disability News, (nd). Accessed June 5, 2016: http://www.disabilityfoundation.org/news/040305_handydart. Uber, “A New Kind of Mobility,” Uber, June 24, 2015. Accessed June 20, 2016: https://news-room.uber.com/a-new-kind-of-mobility/ Uber, “A new way to explore the Uber app for our deaf or hard-of-hearing partners,” March 16, 2016. Accessed July 2, 2016: https://newsroom.uber.com/canada/a-new-way-to-explore-the-uber-app-for-our-deaf-or-hard-of-hearing-partners/ Uber, “Inclusion Matters: Access and Empowerment for Riders and Drivers with Disability in Australia,” Uber, December 2, 2015. Accessed June 5, 2016: https://newsroom.uber.com/australia/inclusion-matters-au/ Uber, “Uber & Enabled Employment: A New Kind of Mobility,” Uber, September 22, 2015. Accessed June 10, 2016: https://newsroom.uber.com/australia/uber-enabled-employment-a-new-kind-of-mobility/ Uber, “Uber Assist”, Products. Accessed July 10: http://ubermovement.com/uberassist/42 43Transportation Network Companies and Accessibility Transportation Network Companies and Accessibility

Cite

Citation Scheme:

        

Citations by CSL (citeproc-js)

Usage Statistics

Share

Embed

Customize your widget with the following options, then copy and paste the code below into the HTML of your page to embed this item in your website.
                        
                            <div id="ubcOpenCollectionsWidgetDisplay">
                            <script id="ubcOpenCollectionsWidget"
                            src="{[{embed.src}]}"
                            data-item="{[{embed.item}]}"
                            data-collection="{[{embed.collection}]}"
                            data-metadata="{[{embed.showMetadata}]}"
                            data-width="{[{embed.width}]}"
                            async >
                            </script>
                            </div>
                        
                    
IIIF logo Our image viewer uses the IIIF 2.0 standard. To load this item in other compatible viewers, use this url:
http://iiif.library.ubc.ca/presentation/dsp.310.1-0342994/manifest

Comment

Related Items