AODA Alliance Calls on Ontario Government to Halt Deployment of PRESTO Public Transit Smart Card System Until Disability Barriers are Removed

August 12, 2010

SUMMARY

The AODA Alliance has called on the Ontario Government to halt deployment of the Government-financed Presto System Smart Card technology for paying public transit fares in Ontario, until disability barriers that the AODA Alliance identified in this new technology are removed. The August 12, 2010 Toronto Star includes a prominent article reporting on this, set out below.

Presto Systems, a part of the Ontario Government, has designed a Smart Card system to let public transit passengers load their money on one Smart Card and then use the Smart Card for paying fares on different public transit systems in Ontario. On June 21, 2010, we revealed that the Presto System Smart Card technology was not properly designed to be barrier-free for transit passengers with disabilities, even though Presto says it undertook some consultations on accessibility when designing it. You can see the details of this, including our correspondence with various Government agencies between November 2009 and June 2010 at:
http://www.www.aodaalliance.org/whats-new/newsub2011/mcguinty-government-uses-public-tax-dollars-to-develop-public-transit-smart-cards-with-barriers-against-people-with-disabilities/

A barrier we identified is in the new Smart-Card reading machines that are part of the Presto System. The Government aims that in transit stations there will be a machine into which you can insert your Presto card, to find out how much money you still have on the card. The card-reading machine that Presto designed only provides your card’s balance on a video screen.

People with vision loss and dyslexia cannot read that screen. The machines for checking your Smart card balance, designed and financed with taxpayers’ money, include no alternative interface for those persons with disabilities to use.

On July 20, 2010, the AODA Alliance received a troubling email from Presto Systems, set out below. It does not properly justify the presence of barriers in the new Presto Systems Smart Card technology, created with public money. On August 10, 2010, we have written three key letters, each set out below, to call for prompt Government action to rectify this situation:

We wrote to Presto Systems to call for a halt in the deployment of their Smart Card technology until it is made fully accessible. We also ask Presto Systems to make public important information, to help us and the public understand how the Government could create new barriers against persons with disabilities with public money.
We wrote to Transportation Minister Kathleen Wynne asking the Government to look into this, and asking it not to press any public transit authorities to implement the Presto Systems Smart Card until it is made fully barrier-free for passengers with disabilities.
We wrote to Community and Social Services Minister Madeleine Meilleur asking her to intervene, to stop the deployment of the Presto Systems Smart Card until it is made fully accessible. We also urge her to ensure that the forthcoming new accessibility standards under the Accessibility for Ontarians with Disabilities Act include strong measures to ensure that electronic kiosk technology such as this are fully accessible to persons with disabilities.

The existence of these barriers is not news to the Ontario Government. We first made this issue public back on June 21, 2010. Also, in our June 22, 2010 brief to the Ontario Government on the final proposed Information and Communication Accessibility Standard, we again raised the need for accessibility standards to require electronic kiosks like the Presto System to be fully accessible to persons with disabilities. We referred to the Presto issue in that brief. You can see the brief at: http://www.www.aodaalliance.org/whats-new/newsub2011/aoda-alliance-submits-its-brief-to-the-ontario-government-on-the-final-proposed-information-and-communication-standard/

WHAT YOU CAN DO

Please circulate this information widely.
We urge you to write to Premier McGuinty, Transportation Minister Kathleen Wynne, and Community and Social Services Minister Madeleine Meilleur. Urge them to halt deployment of any new electronic kiosk technology like the Presto Smart Card, until it is made fully accessibility to persons with disabilities. Urge them to ensure that the forthcoming accessibility standards under the AODA will impose mandatory accessibility requirements on electronic kiosks. Their email addresses and fax numbers are included in the letters set out below.
Alert your local media to this issue.
Send the AODA Alliance your feedback at: aodafeedback@gmail.com

The Toronto Star
August 12, 2010

Disability rights activist calls for shutdown of Presto

Graphic: Lawyer David Lepofsky says Presto cards lack accessibility features.

The man who brought you talking transit stops is now taking on the Presto smart card system.

Disability rights activist David Lepofsky is calling on the Ontario government to shut down Presto until what he says are barriers to visually impaired and dyslexic people are removed.

Sighted Presto users can view their card balance on a screen as they tap the card reader when boarding a train or bus, or at a subway turnstile. The machines beep when successfully tapped, but there is no audio option to check the balance.

Lepofsky says the failure to include an audio option contradicts the goals of the Accessibility for Ontarians with Disabilities Act and violates human rights obligations.

“We are talking about the government creating new barriers against people with disabilities,” says Lepofsky, a blind lawyer who led the campaign to force TTC drivers to call out all stops.

“We have enough problems with old barriers, like steps down the subway stations that were built 50 years ago. Now we’re talking about them using our tax money to build new barriers into new technology that could have been prevented.”

Presto executive director Ernie Wallace says the new tap system is far more accessible than a token or cash one. Wallace says the alternatives – an audible balance announcement via speaker or plug-in – weren’t deemed viable.

Wallace points out that visually impaired transit users can check their balance online or by phone. But Lepofsky says they should be able to get their balance as they enter, “just like everyone else.”

Katherine King, spokeswoman for Transportation Minister Kathleen Wynne, said the Presto system meets accessibility standards.

“Presto has been working with an Accessibility Advisory Group, including representatives from the visually impaired community, as the Presto card was developed.

“Now that the devices are in service, Presto has been soliciting feedback on using the devices in the real transit environment,” she said, adding that consultation will continue as the system moves forward.

Amy Dempsey
Toronto Star

July 20, 2010

Email from Presto Systems to David Lepofsky

Dear Mr. Lepofsky,

Thank you for your email of June 18th noting your concerns with respect to the PRESTO System’s overall accessibility. We appreciate your interest in the continual development of PRESTO.

In response to your March 9th, 2010 letter, the PRESTO system design, devices, and operational deployment are approved by the individual municipal transit agencies and GO Transit.

As we have demonstrated, PRESTO has been designed with accessibility in mind from its beginning. Like most new technology and information systems, PRESTO program will continue to develop and improve with new technology, policies and processes over time. Your insights will assist us in ensuring PRESTO is an operationally effective system and one that provides convenience and accessibility to all.

PRESTO provides more options and convenience to customers in managing public transit fare payments compared to existing fare media. Checking the balance of a card is one clear example of the multi-channel approach used by PRESTO to provide equivalent services. Customers wanting to know the balance on their card can check this information on the web, by telephone, with a customer service agent or through the use of the Balance Checker device. In the future, there will be other options as well to provide this information such as mobile applications and Self Serve Kiosks.

Customers can also select the autoload feature to ensure their card never runs out of funds and thereby avoiding any concern with a card’s current balance. In this way PRESTO provides multiple equivalent channels to all, including those with accessibility limitations, to load their card, pay a transit fare and use the transit system.

You also asked about the type of feedback to customers at the point of payment. Customers ‘tap on’ to pay a fare before they begin their transit trip. To communicate a successful or unsuccessful fare payment, three separate but coordinated channels were developed: lighting; sound bites or tones and on-screen messaging. The tones or sound bites to be used on the Fare Payment devices were chosen through a lengthy process. The PRESTO Accessibility Advisory Group reviewed the sound bites and the Canadian Hearing Society confirmed the effectiveness of the selections. There are 4 distinct sounds each accompanied by corresponding text and light signals each with its own distinct meaning:

The sound bites or tones will be reviewed regarding their overall usability once the e-fare system has fully launched and customers are able to interact with PRESTO devices in multiple live environments.

Regarding the website, the initial PRESTO website was designed to be accessible and meet the Web Content Accessibility Guidelines (WCAG) level 1.0, which was the standard at the time PRESTO was designed. You have noted that WCAG 2.0 AA is the current standard. As you were advised, PRESTO is committed to achieving the WCAG 2.0 AA standard and work is underway.

In summary, PRESTO is an accessible system for fare payment and is designed to meet the usability of all customers, including persons with a physical, sensory, visual or cognitive disability. PRESTO has industry leading features to accommodate users with a wide range of abilities and has a plan for on-going continuous improvement:

A contact-less card that does not need to be taken out of a wallet, purse or bag to be read by devices;
Three different message channels when interacting with a system device: screen messaging, lights, and clearly audible sounds;
The ability to load a card or check a card balance in four different ways: autoload, PRESTO website, Call Centre and in-person;
A website designed with current accessibility standards; and
American-Sign Language videos with audio commentary on the website to assist customers in using the card.

We appreciate your interest and feedback on PRESTO and your insight on how we can make the future e-fare system even more accessible for the people of Ontario and visitors to the province. As in the past, we will continue to seek advice and input from our Accessibility Advisory Group, the equivalent Transit Advisory Committees and specifically focused organizations like the CNIB.

Sincerely,

Ernie Wallace
Executive Director PRESTO
130 Adelaide St West
Suite 1500
Toronto ,Ont M5H3P5
PH 647-789-0320 Ext 5112
FAX 647-789-0321

Ontario Government News Release
July 23, 2010

Minister Kathleen Wynne Stands By PRESTO

The TTC’s recent focus on a duplicate fare system is troubling and a complete waste of precious taxpayer dollars.

The PRESTO card allows transit riders around the GTA to transfer seamlessly with one card from GO Train to bus or streetcar or subway, anywhere in the GTA. And best of all, the PRESTO system is also being developed to accept other cards — like debit or credit cards.

It’s a smart system that connects us and makes the daily commute just a little easier. Already 7,600 commuters are using their PRESTO cards, and 500 more are joining every week.

The city and TTC made a commitment to PRESTO many times.

Gas Tax funding was provided to GTA Municipalities, including the City of Toronto, with the requirement that they participate in the PRESTO fare card system, provincial funding towards the cost of the City of Toronto’s replacement streetcars is also conditional upon the City’s full participation in PRESTO and we’ve communicated to the City that the 182 light rail vehicles for the four Transit City projects in Toronto must be PRESTO ready.

There are a lot of investments to make in public transit, and a lot of improvements to be made at the TTC. To waste money on a duplicate fare system makes no sense.

CONTACTS

Derek Luk
Minister’s Office
416-327-1815
derek.luk2@ontario.ca

Toronto Star July 26 2010

The man behind TTC’s card Consultant backs TTC; Guru says it’ll cost ‘fraction’ of Presto

David Rider
The Toronto Star

The New York-based transit guru behind the TTC’s controversial move toward “open payment” says he believes the electronic fare system would cost Toronto “a small fraction” of the cost of adopting the province’s Presto smart card.

Paul Korczak’s words are sure to further infuriate Transportation Minister Kathleen Wynne, who on Friday warned the TTC it risks losing hundreds of millions of dollars in subsidies if it doesn’t halt its open payment efforts and fully implement Presto.

She urged the TTC to scrap its plan to issue, in early August, a Korczak-developed request-for-proposal and called TTC chair Adam Giambrone’s touting of open payment “troubling and confusing” given that Ontario has already spent $200 million on a system with one card to get commuters into and around all the GTA transit systems.

Korczak, awarded a $1.3 million contract to lay groundwork for the next-generation system where riders pay with a tap of their debit or credit card on an electronic reader, said he doesn’t get mixed up in politics.

But, sitting on a bench in the Eaton Centre on Sunday, he didn’t mince words arguing that open payment, which he helped pioneer at the end of his 27-year career with New York’s transit utility, would be a better choice for Toronto than the smart-card technology he introduced to the Big Apple in 1999.

The savings, he said, come from the fact that the credit and debit technology, including tap-and-pay cards like Mastercard’s PayPass, is used in stores everywhere so the TTC could use off-the-shelf electronic readers and other equipment. Banks and credit card companies process the transactions, reducing the transit service’s operating costs.

Ontario has committed $173 million toward the estimated $400 million to $500 million cost of the TTC fully adopting Presto, now accepted at seven subway stations and soon to be at 12.

Korczak was asked how the cost of the open payment system would compare.

“It’s a little early to put a number on it but my experience says it would be a small fraction of that (total Presto) number …”

“Proprietary custom-built (smart card) fare systems are expensive to design, build and maintain and that’s why New York, Chicago, Philadelphia and Washington are moving from them to open payment,” added Korczak, whose two-man company is involved with the switch in each of those cities.

“But the main benefit is customer service.”

He estimated open payment could be used on the TTC within 30 months of a contract being signed.

But Wynne is far from alone in arguing the TTC is doing its riders a disservice by going back to the drawing board when it previously supported a regional system already working on GO and TTC.

The Toronto Board of Trade argued last week that the costs of open payment are bound to be higher than those of Presto because of the lost provincial subsidies.

Rob Prichard, chief executive of Metrolinx said, rather than criticizing Presto, the TTC should be rolling it out and helping make it better.

Via Email
To: Mr. Ernie Wallace, Executive Director
PRESTO
130 Adelaide St West, Suite 1500
Toronto, Ontario M5H 3P5
Phone: 647-789-0320 Ext 5112
Fax: 647-789-0321
Ernie.Wallace@prestocard.ca
From: David Lepofsky, Chair Accessibility for Ontarians with Disabilities Act Alliance
Date: August 10, 2010

Re: Accessibility of Presto Smart Card System for Transit Passengers with Disabilities

Thank you for your July 20, 2010 email. It answers some of our inquiries dating back to my March 9, 2010 email to you.

We write to ask Presto Systems to immediately halt deployment of its Smart Card system, until all barriers are removed from that system. We ask that any Presto System Smart Card technology that has already been deployed be promptly retrofitted, to remove any barriers in the technology that impede transit riders with disabilities from fully using that technology. We also ask Presto Systems to commit to ensuring that all future Smart Card and similar electronic Kiosk technology and infrastructure that it deploys in the future will in fact be barrier-free for transit passengers with disabilities, and will be designed in accordance with universal design principles.

We respectfully disagree with your claim, in your July 20, 2010 email to us, that “… PRESTO is an accessible system for fare payment and is designed to meet the usability of all customers, including persons with a physical, sensory, visual or cognitive disability,” and that “PRESTO has industry leading features to accommodate users with a wide range of abilities.” In fact, your email shows that Presto has taken a regrettably impoverished approach to its duty to provide barrier-free new technology under the Ontario Human Rights Code and the Charter of Rights.

You acknowledged during our March 8, 2010 telephone call that your new Presto system includes card-reading machines, to be deployed in transit stations, which show a customer how much money remains on their card on a video screen. These card-reading machines have no accessible alternative interface, such as spoken-word audio output, for people who cannot read printed text due to a disability like vision loss or dyslexia. I confirmed this in my March 9, 2010 email to you. You have not disputed the accuracy of my March 9, 2010 email to you in any of your subsequent emails to us.

We pointed out both during our March 8, 2010 telephone call with you and in our subsequent correspondence that this is a clear, obvious new technological barrier against persons with disabilities like vision loss and dyslexia. It is being created by Government, using public money.

You have not disputed that this technology was custom designed for the Government. It is not off-the-shelf technology. As such, it would have been readily open to Presto to incorporate an accessible spoken word, audio output feature into these card-reading machines. Such a feature would let passengers who cannot read printed text on a video screen (e.g. due to vision loss or dyslexia) check their card balance on their own while in a transit station, just like all other passengers.

The technology for spoken-word output has existed for many years. You have not claimed that it would be difficult or impossible to have incorporated it into the design of the Presto Systems card-reading machine. Far from ensuring that Presto includes “industry-leading” measures for accessibility as you claim, the Presto Systems card-reading machine is missing widely-used technology for ensuring accessibility.

Every time a new Presto Systems card-reading machine is deployed, this constitutes the creation of a new barrier against persons with disabilities. To date, you have not committed to alter the design of your card-reading machines after we alerted you to this new barrier several months ago.

You stated in your July 20, 2010 email to us that: “PRESTO provides more options and convenience to customers in managing public transit fare payments compared to existing fare media.” Even if this had been true, this does not justify a failure to incorporate a spoken-word voice output system in the new card-reading machines.

You have claimed, in substance, that it is sufficient for passengers who cannot use the new Presto card-reading machines to use one of the other avenues to check their card balance. You appear to have misunderstood the Government’s duty not to create new barriers against persons with disabilities. We do not agree that the Government can design inaccessible new electronic kiosk technology, and then argue that there are other ways to check one’s balance.

Some persons with disabilities do not have computers, or cannot access them at a subway or bus station. Some people with vision loss may not know where a pay phone is in a bus or subway station, to phone in and check their balance. None may wish to line up behind passengers buying tickets, just to check their balance. If it was sufficient for passengers to check their card balance without using a card reading machine, the government would not have invested public funds to invent and deploy these card-reading machines. At bottom, the Presto Systems technology denies passengers with disabilities such as vision loss or dyslexia the opportunity that other passengers will enjoy – the chance to quickly check their Smart Card balance at a transit station at an electronic kiosk – that was designed, constructed and deployed by the Government with public money. That is not true equality and accessibility.

To support your claim that this smart card system is fully accessible, your earlier December 2, 2009 correspondence with us stated that the Presto System is committed to meet the requirements of the Ontarians with Disabilities Act and Accessibility for Ontarians with Disabilities Act. As we pointed out in our December 22, 2009 email to you, there are no accessibility standards governing electronic kiosks like these under the Ontarians with Disabilities Act or the Accessibility for Ontarians with Disabilities Act. As such, you are merely stating that you are committing at present to be in compliance with no standards at all. We have been urging the Ontario Government to adopt accessibility standards to govern electronic kiosks to prevent conduct such as those in which you have engaged in this situation.

We pointed out in earlier correspondence with you that it is necessary to comply with the Ontario Human Rights Code and the Charter of Rights. None of your correspondence has acknowledged this, or shown that it would cause the Government undue hardship to have incorporated a voice-output system in the Presto card-readers you are deploying.

You have emphasized the extent to which you have consulted to ensure the accessibility of the Presto Systems Smart Card technology. It is of course commendable to consult on accessibility before designing a new system such as this. However, the fact that such clear and obvious barriers were evident to us, after talking to you for just a few minutes back on March 8, 2010, calls into question the sufficiency of your earlier consultation efforts and deliberations on accessibility.

We are eager to know whether any of those you consulted raised the issue of the inaccessibility of video screens to people who have vision loss or dyslexia. Was the Presto project team unaware of the inaccessibility of this technology when it went ahead with it? Did it explore the option of including an accessible spoken-word audio output on the card readers, akin to that found in many automatic bank machines and on GPS devices used by many drivers?

In our March 9, 2010 email to you, we had asked who was responsible for approving the design and funding of this smart card system without ensuring its full accessibility. In your July 20, 2010 email to me, you stated:

“In response to your March 9th, 2010 letter, the PRESTO system design, devices, and operational deployment are approved by the individual municipal transit agencies and GO Transit.”

Does that mean that the Ontario Government agreed to take part in this project without ensuring its full accessibility, and delegated that issue to the municipal transit authorities and GO Transit? Did any Ontario Government official scrutinize this expenditure of public funds to ensure that it is not used to create new barriers against persons with disabilities? If there was an Ontario Government public official or officials who scrutinized this project to ensure that no new barriers were created with public funds, we are eager to know who they were, and how they could approve this creation of new barriers with public funds. We are also eager to know whether the municipal transit authorities involved, as well as GO Transit (which is owned by the Ontario Government) specifically approved the omission of a voice-output feature in the Presto system, and whether this was the subject of discussions between Presto and those transit authorities.

In our March 9, 2010 email to you, we identified another barrier as follows:

“The third issue we identified concerns the feedback that a passenger receives when they use their Smart Card to get admission to a transit system. You advised that one would go through a turnstile and get feedback on a screen confirming payment. There would also be an audible tone.

You said there were two possible tones that could sound. The first is akin to a green light if the card successfully paid for the ride. The second is a negative or red light message, if the card cannot pay for the ride.

When we spoke, I noted two concerns with this. First, there is a need for a third tone, akin to a yellow light. It would be needed to warn the passenger that they must put more money on the card or else they will not be able to take another ride after the current one which the Smart Card account can cover. You said you would look into this.

We noted that it would be helpful for the system to also make an automated verbal announcement for the benefit of those passengers who do not know the meaning of the tones. This is especially important if there are three possible tones that could be sounded. You expressed concerns for passenger privacy. Yet if the public can hear one of the tones that are sounded, that privacy is already lost.

In your July 20, 2010 email to us, you responded:

“You also asked about the type of feedback to customers at the point of payment. Customers ‘tap on’ to pay a fare before they begin their transit trip. To communicate a successful or unsuccessful fare payment, three separate but coordinated channels were developed: lighting; sound bites or tones and on-screen messaging. The tones or sound bites to be used on the Fare Payment devices were chosen through a lengthy process. The PRESTO Accessibility Advisory Group reviewed the sound bites and the Canadian Hearing Society confirmed the effectiveness of the selections. There are 4 distinct sounds each accompanied by corresponding text and light signals each with its own distinct meaning:

We find your response confusing. In our March 8, 2010 telephone conversation, confirmed in our March 9, 2010 email to you, you clearly stated that there were only two possible audio tone signals when a person goes through the turnstiles. In contrast, in your July 20, 2010 email, you stated that there would be four. Which is correct? Moreover, you have not answered our proposal that there also be a spoken word response, not just a beep tone, to assist those who are unfamiliar with the system and who do not know what each beep tone means, such as infrequent transit riders or tourists.

We appreciate your commitment in your July 20, 2010 letter that your website will be upgraded to meet internationally-recognized website accessibility standards, namely WCAG 2.0 Level AA. We note that your July 20, 2010 email incorrectly states that you had previously told us that you would be doing this. As our March 9, 2010 email to you confirmed, you had only told us that you would consider this. In any event, we appreciate your accepting our recommendation on this. We would like to know when the retrofit of your website will be completed.

In light of all these developments, we are eager to know what specific steps you will take to ensure that no other technology that Presto System designs, such as the forthcoming electronic self-service kiosks for putting money on to a Smart Card, will have any barriers against persons with disabilities. Will you commit that this new electronic kiosk technology will in fact be fully barrier-free and will be designed using universal design principles? In your July 20, 2010 email to us, you stated that Presto “…has a plan for on-going continuous improvement.” What is that plan? Could you please send us a copy of it, in an accessible format.

The accessibility of new electronic kiosk technology on public transit systems is a very important issue. The technology that is designed and deployed now will be in place for years to come. Ontario is uniquely positioned now to ensure that that new technology is fully barrier-free.

It appears that the Ontario Government intends to use its formidable resources and power to pressure public transit authorities to implement the Presto System. It is therefore essential that the Presto System be designed to be entirely barrier-free from the outset.

We look forward to hearing from you as soon as possible.

ACCESSIBILITY FOR ONTARIANS WITH DISABILITIES ACT ALLIANCE
1929 Bayview Avenue
Toronto, Ontario M4G 3E8
New Email Address: aodafeedback@gmail.com
Visit: www.aodalliance.org

August 10, 2010

The Honourable Kathleen Wynne, Minister of Transportation
Ferguson Block
77 Wellesley Street West, 3rd Floor
Toronto M7A 1Z8
Fax (416) 327-9188
Kathleen.Wynne@Ontario.ca

Dear Minister Wynne,

Re: Inaccessibility for Passengers with Disabilities of Ontario Government-Sponsored Presto System Public Transit Smart Cards

The Ontario Government, with your Ministry in the lead, is urging municipal transit authorities to adopt the new Presto System Smart Card technology for paying public transit fares. We are very concerned that this new fare-paying technology is not barrier-free for transit passengers with disabilities. We ask you to immediately intervene to prevent the deployment of the Government-financed Presto System Smart Card in any Ontario public transit systems until this new technology is corrected to make it fully barrier-free for transit passengers with disabilities. We also ask that any Presto Systems Smart Card technology that has been deployed to date be promptly fixed to ensure that it is barrier-free for transit passengers with disabilities.

Presto Systems, a part of the Ontario Government, has designed a Smart Card system to enable public transit passengers to load their money on one Smart Card and then use that Smart Card for paying fares on different public transit systems in Ontario. We were very troubled when our investigation revealed that the Presto System Smart Card technology was not properly designed to be barrier-free for transit passengers with disabilities, even though Presto says it undertook some consultations on accessibility when designing it.

We have learned from Presto Systems that part of their Smart Card technology includes deploying card-reading machines at transit stations. These let a transit passenger check to see how much money he or she has on their smart card. Those machines display the results on a video screen for the passenger to see and read. These card-reading machines for transit passengers do not include readily-available technology that lets a passenger who cannot read print (such as people with vision loss or dyslexia) check their balance (e.g. by an automated voice).

This creation of new technological barriers against persons with disabilities in Ontario-financed infrastructure flies in the face of Ontario’s commitment to become fully accessible by 2025, enshrined in the Accessibility for Ontarians with Disabilities Act. As well, the Ontario Human Rights Code and Canadian Charter of Rights and Freedoms entitle public transit passengers to equality, without barriers due to their disabilities.

It is especially important that any new technology such as this be fully accessible for all transit passengers with disabilities. We are a large and growing segment of the Ontario public. Once created, these barriers will be in place in Ontario’s public transit system for years.

The Ontario Government has said it would lead by example in the area of accessibility. To create such inaccessible technology using taxpayers’ dollars, and to then press public transit authorities in Ontario to implement it, is not the example by which the Ontario Government should lead. Instead, the Ontario Government should develop fully accessible electronic kiosk technology. It should be pressing other organizations in Ontario, such as public transit providers, to ensure that any electronic kiosk technology also be fully barrier-free for customers with disabilities.

For many months, we have been urging the Ontario Government to ensure that new accessibility standards enacted under the Accessibility for Ontarians with Disabilities Act require new electronic kiosk technology (such as the Smart Card system) be fully barrier-free. The barriers in the Presto Smart Card system are a pointed example of why we need such mandatory accessibility standards.

With this letter, we enclose the text of our correspondence with Presto Systems on this issue. As a result of that correspondence, we respectfully suggest that:

The Presto Systems Smart Card technology, including the card-reading machines, was custom-designed. It is not pre-existing off-the-shelf technology. As such, the Government could readily have included spoken-word output in the specifications for the card-reading machines, to make it fully accessible.
Presto Systems has offered no compelling technical or cost justification showing that it was essential to create new card-reader machines that cannot be used by persons with disabilities such as vision loss or dyslexia. They have not denied the existence and availability of easy-to-use voice-output technology that could be added to these card reading machines. That existing technology is commonly found in bank automated teller machines and GPS devices for use in passenger cars.
Presto Systems has not acknowledged the applicability of the Human Rights Code and the Charter of Rights here, even though we raised these with Presto Systems.
Presto Systems claims it is committed to comply with the Ontarians with Disabilities Act and Accessibility for Ontarians with Disabilities Act. Yet there are no applicable accessibility standards governing such electronic kiosk technology under the ODA or AODA. Thus, this claim is effectively worthless at this time.
Presto Systems in substance claims that there is no accessibility problem, because passengers can check their Smart Card balance over the phone or internet, or by lining up at a point-of-sale counter. This reflects a regrettably impoverished approach to equality and accessibility for persons with disabilities. Passengers who can read printed information on a video screen do not need to go on the internet, or find a phone, or pay for a payphone, or incur cell phone charges, or go on the internet or line up at a point-of-sale counter, in order to find out how much money is on their Smart Card. If those other options were sufficient, Presto Systems would not have spent public funds on developing and deploying new card reading-machines. Presto Systems seems to not fully recognize the Government’s duty not to create new barriers against persons with disabilities, especially when using public money.
Presto Systems says it consulted with others on disability accessibility. It would be obvious to Presto Systems that people with vision loss or dyslexia cannot read information from a video screen on a card reading machine.

This spring, the Government made public the report of the Government-appointed Charles Beer Independent Review of the implementation of the Accessibility for Ontarians with Disabilities Act. That Report found that there is a need for a revitalization of the Government’s implementation of the AODA, and for new Government leadership in promoting accessibility. According to a July 23, 2010 news release posted on your website, your Ministry is pressing public transit authorities to adopt the new Presto Systems Smart Card. For the Ontario Government to use its formidable might to press public transit authorities to adopt new technology which is not barrier-free is not leading by a good example. It is the opposite.

We ask you to immediately take these steps:

1. Please direct Presto Systems to stop any further deployment of its Smart Card technology until it is corrected to ensure that it is fully barrier-free for transit passengers with disabilities.

2. Please now take steps to ensure that GO Transit and municipal transit authorities do not deploy the Presto Systems Smart Card until the barriers in that system have been removed.

3. Please direct Presto Systems to ensure that any new technology developed for use in public transit systems will be barrier-free for passengers with disabilities, designed in accordance with universal design principles, to ensure that Presto Systems does not take an impoverished approach to accessibility.

4. Please investigate how Government funds were improperly used to create these new technological barriers against persons with disabilities, especially when Presto Systems claims to be committed to accessibility, and to have consulted with some persons with disabilities in developing this system.

We are eager to meet with you to discuss this issue, and welcome a chance to do so at your earliest convenience.

Sincerely,

David Lepofsky, CM, O. Ont,
Chair, AODA Alliance

cc: Hon. Dalton McGuinty, Premier, fax 416-325-9895, email mcguinty.mpp.co@liberal.ola.org
Madeleine Meilleur, Minister, Community & Social Services, fax (416) 325-3347, email madeleine.meilleur@ontario.ca
Brad Duguid, Minister of Energy and Infrastructure fax (416) 327-6754 email brad.duguid@ontario.ca
Marguerite Rappolt, Deputy Minister, Community & Social Services, fax (416) 325-5240, email marg.rappolt@ontario.ca
Ellen Waxman, Assistant Deputy Minister, Accessibility Directorate, fax (416) 325-9620, email Ellen.Waxman@ontario.ca
Ernie Wallace, Executive Director PRESTO fax 647-789-0321 email Ernie.Wallace@prestocard.ca

ACCESSIBILITY FOR ONTARIANS WITH DISABILITIES ACT ALLIANCE
1929 Bayview Avenue
Toronto, Ontario M4G 3E8
New Email Address: aodafeedback@gmail.com
Visit: www.aodalliance.org

August 10, 2010

Hon. Madeleine Meilleur, Minister
Community & Social Services
Hepburn Block
6th Floor, 80 Grosvenor Street
Toronto, Ontario
M7A 1E9

Facsimile: (416) 325-3347
Email: madeleine.meilleur@ontario.ca

Dear Minister,

Re: Inaccessibility for Passengers with Disabilities of Ontario Government-Sponsored Presto System Public Transit Smart Cards Systems

We write about the Ontario Government’s efforts to get GO Transit and municipal transit authorities to deploy the new Presto Systems Smart Card for paying transit fares. As our letter of today’s date to Transportation Minister Kathleen Wynne shows, that Smart Card system, developed by an agency of the Ontario Government with Ontario taxpayers’ dollars, includes troubling new technological barriers impeding its full and independent use by persons with disabilities.

We seek your assistance. First, we ask that you intervene with the Transportation Minister to get the Government to stop deployment of the Presto Smart Card system until it is corrected to make it barrier-free for transit passengers with disabilities.

Second, we ask you to ensure that the forthcoming Accessibility Standard, to be enacted under the Accessibility for Ontarians with Disabilities Act, includes strong measures to ensure that electronic kiosk technology such as this, to be used by members of the public when accessing public transit services and elsewhere, is designed to be fully accessible for persons with disabilities. We discussed the need for accessibility standards to effectively address electronic kiosk technology when we met with you back on October 6, 2009, and have discussed that general issue with your Ministry officials on a number of occasions. We also addressed that general issue in detail in our June 22, 2010 brief on the final proposed Information and Communication Accessibility Standard.

This troubling incident with Presto Systems provides powerful proof of the need to ensure that accessibility standards under the Accessibility for Ontarians with Disabilities Act effectively require the accessibility of electronic kiosk technology. You will see in our exchanges with Presto Systems, included in our letter to Minister Wynne, that Presto Systems has said it will comply with the requirements of the Ontarians with Disabilities Act and Accessibility for Ontarians with Disabilities Act when designing its electronic kiosks and Smart Cards. Right now, there are no accessibility standards under the Ontarians with Disabilities Act or the Accessibility for Ontarians with Disabilities Act that require electronic kiosks to be fully usable by persons with disabilities.

We would welcome the opportunity to discuss this important issue with you at your earliest convenience, and would be pleased to do whatever we can to assist you in addressing this issue.

Sincerely,

David Lepofsky, CM, O. Ont,
Chair, AODA Alliance

cc: Hon. Dalton McGuinty, Premier, fax 416-325-9895, email mcguinty.mpp.co@liberal.ola.org
Kathleen Wynne, Minister of Transportation fax 416) 327-9188 email kathleen.wynne@ontario.ca
Brad Duguid, Minister of Energy and Infrastructure fax (416) 327-6754 email brad.duguid@ontario.ca
Marguerite Rappolt, Deputy Minister, Community & Social Services, fax (416) 325-5240, email marg.rappolt@ontario.ca
Ellen Waxman, Assistant Deputy Minister, Accessibility Directorate, fax (416) 325-9620, email Ellen.Waxman@ontario.ca
Ernie Wallace, Executive Director PRESTO fax 647-789-0321, email Ernie.Wallace@prestocard.ca

SUMMARY

MORE ON THE TORONTO STAR ARTICLE

WHAT YOU CAN DO

Disability rights activist calls for shutdown of Presto

Email from Presto Systems to David Lepofsky

Minister Kathleen Wynne Stands By PRESTO

CONTACTS

The man behind TTC’s card Consultant backs TTC; Guru says it’ll cost ‘fraction’ of Presto

Re: Accessibility of Presto Smart Card System for Transit Passengers with Disabilities

Re: Inaccessibility for Passengers with Disabilities of Ontario Government-Sponsored Presto System Public Transit Smart Cards

Re: Inaccessibility for Passengers with Disabilities of Ontario Government-Sponsored Presto System Public Transit Smart Cards Systems