1.             PETS ON PUBLIC TRANSIT - A PILOT PROJECT

 

LE TRANSPORT EN COMMUN ET LES ANIMAUX DE COMPAGNIE - PROJET-PILOTE

 

 

Committee Recommendation

 

No Committee recommendation.

 

 

Recommandation du comité

 

Aucune recommandation du Comité.

 

 

 

 

 

Documentation

 

1.   Pedestrian and Transit Advisory Committee report dated 11 August  2008 (ACS2008-CCV-PTA-0002).

 

2.   Extract of Draft Minute, 20 August 2008.

 


Report to/Rapport au :

 

Transit Committee

Comité des services de transport en commun

 

and Council / et au Conseil

 

11 August 2008 / 11 août 2008

 

Submitted by/Soumis par : Angela Connidis, Vice-Chair/vice-présidente
Pedestrian and Transit Advisory Committee/
Comité consultatif sur les piétons et le transport en commun

 

Contact Person/Personne ressource : Stephanie Brown Bellefeuille, Advisory Committee Coordinator/Coordonnatrice du comité consultatif

City Clerk’s Branch/Direction du greffe

(613) 580-2424 x16760, stephanie.brown@ottawa.ca

 

City Wide/à l'échelle de la Ville, City Wide/à l'échelle de la Ville

Ref N°: ACS2008-CCV-PTA-0002

 

 

SUBJECT:

 PETS ON PUBLIC TRANSIT – pilot project

 

 

OBJET :

LE TRANSPORT EN COMMUN ET LES ANIMAUX DE COMPAGNIE - PROJET-PILOTE

 

 

REPORT RECOMMENDATIONS

 

The Pedestrian and Transit Advisory Committee recommend that the Transit Committee recommend Council:

 

1.         Direct staff to implement a six-month pilot project to allow small, licensed pets in crates/carriers on public transit, during off-peak hours; and

 

2.         Reconsider the OC Transpo policy on issuing animal assistance cards to accommodate persons with disabilities, in need of service animals.

 

RECOMMANDATION DU RAPPORT

 

 

RECOMMANDATIONS DU RAPPORT

 

Le Comité consultatif sur les piétons et le transport en commun recommande au Comité du transport en commun de recommander à son tour au Conseil :

 

1.         De donner instruction au personnel de mettre en place un projet pilote de six mois visant à admettre les petits animaux avec permis transportés dans des cages à bord des véhicules de transport en commun, en dehors des heures de pointe; et

 

2.         De réévaluer la politique d’OC Transpo sur la délivrance de cartes d’assistant aux personnes handicapées ayant besoin d’un animal d’assistance.

 

 

BACKGROUND

 

Following a presentation by the Responsible Dog Owners of Canada at its 17 July 2008 meeting, the Pedestrian and Transit Advisory Committee approved the aforementioned recommendations.

 

This matter was discussed previously at the table of the then-Transit Services Committee in March 1999.  Following a lengthy discussion and several delegations, the following motion was carried on a 5-2 vote:

 

That the Transit Services Committee recommend the Commission make no change in the current by-law which restricts animals on buses to seeing eye and hearing ear dogs.

 

Subsequently, the OC Transpo Commission approved the Transit Committee recommendation  on 28 April 1999.

 

 

DISCUSSION

 

The Responsible Dog Owners of Canada (RDOC)  advised  that several years’ worth of research had been done to establish the need for  a pets on public transit policy in Ottawa.   The RDOC claims that many cities, including Gatineau, already have such a policy and,  with the exception of Calgary and Toronto, which allow larger and uncrated animals, most of the 25 Canadian cities listed allow small, fur-bearing animals or birds in carriers, on-board during off-peak hours.

 

OC Transpo does not permit animals on buses, except for guide dogs and certified assistance animals.  RDOC further stated that OC Transpo is governed under superceeding laws (Canadian Transportation Act, and the City of Ottawa Transit By-Law, No. 2007-268) that in effect exempt it from the Ontario Accessibility for Ontarioans with Disabilities Act (AODA).

 

CONSULTATION

 

Planning, Transit and the Environment – Transit Services

 

There have recently been enquiries about allowing animals on board OC Transpo vehicles, including dogs – and other pets – in pet crates or cages.

 

Recognizing these requests and recommendations put forward by PTAC, it is the position of Transit Services that a well-articulated policy must be developed to balance the various interests of those directly affected, including transit operators and the fast-increasing number of transit users in the City of Ottawa, who make nearly 100 million trips a year on the transit system.

 

In developing a balanced policy, it is important to identify and carefully consider the consequences of allowing pets on transit in the full context of transit service: how it will affect priority seating, the safety of passengers, the safety of operators and their responsibilities, the overall quality of service and customer satisfaction with the City’s transit system.  Furthermore, and as with other significant policy changes, a consultation process with those affected – in this case our customer base and employees – would be important.  Given the varied opinions on this important topic, making a decision without thoughtful debate and research is not recommended.

 

APPLICATION OF THE CURRENT BY-LAW

 

The Transit By-Law 2007-268 states that no person shall bring any animal onto the transit system, not even a service animal, unless the person has an Assistant Card for the animal. On what an Assistant Card may be, the By-Law is alternately very specific and very general. The assistant card may be “a serially numbered card, issued [...] to a person with a disability [and] who requires the assistance of a service animal,” such card identifying both the person and the animal by way of photographs, or “an identification card issued pursuant to […] the Blind Persons’ Rights Act.” On the other hand, “any such other form of identification as authorized by the Director” of Transit Services may also constitute an assistant card, without mention as to the identification of whom (a person with or without a disability?) or of what (a service animal or any animal?).

 

 

The current By-Law goes to some length explicitly defining what a person with a disability is, what a service animal is and how an assistant card may relate to both. In Transit Services’ understanding of the By-Law, the intent of Council was not to delegate authority to the Director such that he could easily issue assistant cards to persons other than persons with disabilities, or allow animals onto the transit system other than service animals (defined as having been trained for the purpose of being service animals by a recognized school or organization).

 

PRACTICAL CONSIDERATIONS

 

This application of the Transit By-Law is guided by a number of practical considerations, which are discussed below.

 

Priority Seating Capacity

The Transit By-Law currently provides for the following categories of transit riders to be entitled to priority seating on a front bench seat: “a person with a disability, an expectant mother, a person with a visible need for priority seating, a person with a child in a carriage or stroller, a person with a Priority Seating Card or a person with an Assistant Card”. Along with the unprecedented levels of transit ridership in the City of Ottawa, there is increasing representation from each of the above categories on board transit vehicles. At present, there is no language in the By-Law about any entitlement having priority over another.

 

Broadening the definition of animals allowed on board and allowing those carried in crates or cages both presume additional pressure on seats in general and on priority seats in particular, as animal-carrying passengers would require access to seats for safety reasons. As a result, the number of occurrences of an entitled person not having a seat would likely increase, both during peak periods and in certain off-peak instances.

 

Safety Risks to Passengers

In spite of on-going efforts to provide a comfortable ride on board buses, the unprecedented levels of transit ridership in the City of Ottawa significantly reduce free space on certain buses, even in certain off-peak instances. This is exacerbated at times by the concurrent presence of combinations of wheelchairs, scooters, walkers, child carriages and strollers of various sizes. Such instances already present safety risks of their own for customers.

 

The presence of animals in crates or cages introduces additional safety risks under crowded conditions. There are risks to transit riders associated with the size of animal-carrying devices, the type of openings and the type of latches they feature, and with the unpredictable behaviour of the animal in a crowd.

 

In the case of Para Transpo operations, the presence of animals in crates or cages also increases the risk of hazards for a vulnerable clientele, in cases of normal operation or evacuation. Animals are not permitted in taxi vehicles, which provide an increasing volume of service for Para Transpo customers.

 

Responsibilities of and Risks to Transit Operators

The presence of animal-carrying passengers would put additional pressure on the management of priority seating and space entitlements by transit operators. Operators are trained to give primacy to passengers’ safety, through their own driving skills and by overseeing customer behaviours. Identifying which needs take precedence over which others should not be left to operators’ discretion but should instead be addressed, should it be Council’s direction, through careful consideration in the development of a policy dealing with special needs, including those of animal-carrying passengers.

 

Transit Services would need to work with its employees in advance of developing any new policy dealing with potential issues relating to animals on transit. As some transit employees are known to have severe allergic reactions to animal dander, it is expected that Transit Services will face challenges to accommodate employees on a more frequent basis for them to avoid potential exposure with animals. It is also likely that Transit Services will be required to authorize at-risk employees to deny access to a customer to prevent exposure or run the risk of a work refusal under the Canada Labour Code.

 

Impact on Service Quality

Identifying the best way to address special needs is a challenge being investigated by a number of transit organizations in Canada. One way of doing so is by increasing the number of priority seats on board transit vehicles, however this approach also poses a challenge to maintaining service quality. For instance, an extended priority seating area may require passengers with reduced mobility to walk further down the bus to sit, requiring the operator to wait longer before departing a stop, which ultimately leads to slower travel times. Designing a section of the bus to accommodate mobility devices such as strollers and carriages may improve the flow of traffic through the bus – and passenger safety – but this would need to be accomplished at the expense of total seat availability.

 

Furthermore, following reductions in cleaning standards as a result of productivity measures put in place in 2004, customers have perceived a deterioration in the general hygiene of the transit system, in spite of a significant investment in new buses. The presence of animals as a new source of debris would further impact the overall cleanliness of the transit vehicles given the reduced cleaning frequency currently in effect.

 

Finally, contrary to most urban transit systems, Transit Services do not regulate consumption of food on buses. Consequently, an untrained animal, albeit in a crate or cage, risks being a source of irritant for other customers who may have open food in proximity of the animal.

 

In the absence of a well-articulated policy on special needs, it is left to the transit operator’s discretion to find ways to resolve conflicts that might arise from limited seating capacity or space constraints. This could cause service delays.

 

Impact on Customer Satisfaction

A key objective of the Transit Services Branch is to develop a culture of service excellence for the fast-increasing number of transit users in the City of Ottawa, who together make nearly 100 million trips a year on the transit system.  A key tenet of service excellence is a commitment to listening carefully and openly to citizens and recommending services to Council based on their known and anticipated needs, expectations and degree of satisfaction. 

 

As with any policy change that has a direct impact on individual customers and city staff, it is recommended that the public and staff have the opportunity to fully engage in the development of a well-articulated policy.  Key considerations should be explored and understood in the development of this new policy as they relate to health issues, certain types of zoophobia, culturally based biases, views on certain types of animals, unforeseeable animal disruptions and behaviours, etc. To date, there has been a sizeable influx of comments regarding the above issues to Transit Services Customer Service Centre from the general public, overwhelmingly opposed to allowing animals on board (number and content of comments to be tabled at the Committee meeting).

 

Overall, customer satisfaction and the quality of the customer transit experience must remain as a top priority and an overriding concern when considering a change in policy.

 

THE NEED FOR A WELL-ARTICULATED POLICY

 

The issue of whether or not to allow animals on the transit system should be addressed holistically through the development of a well-articulated policy that balances the various interests of transit employees and all transit users in the City of Ottawa. Given the varied opinions on this important topic, making a decision without thoughtful debate and research is not recommended.

 


Such a policy should address practical questions such as:

·                    Who has seating priority over whom when there is no priority seat left?

·                    Are certain categories of transit users only allowed on board at certain times of day? Only in certain circumstances (volume of passengers already on board, number of entitled passengers already on board, number of mobility devices already on board, number of animals already on board)? How are discriminatory practices to be avoided?

·                    What are the criteria for establishing that a particular situation relating to mobility devices, animal crates or cages, strollers, packages or luggage on board a transit vehicle presents a safety risk and requires for certain entitlements or permissions to be suspended?

·                    What are the alternatives for affected customers?

 

It is Transit Services’ position that any change of policy therefore requires direction from Council for staff to revise the By-Law and propose a comprehensive set of regulations to account for such change.

 

By-Law and Regulatory Services

 

By-law and Regulatory Services Branch supports the concept of permitting appropriately contained and/or controlled pets on public transit, which would be in accordance with its animal care and control mandate and approach in that regard generally.  It is not necessary to include in the report recommendation the reference to "licensed" pets as the City only 'licenses' cats and dogs – it is in fact referred to in the Animal Care and Control By-law 2003-77 as 'registration'.  By-law & Regulatory Services will address any issues of cat/dog registration accordingly, as it is recognized that OC Transpo drivers would not be in a position to do so.  Based on the foregoing, it is suggested that Recommendation 1 be amended to read: 

 

Direct staff to implement a six-month pilot project to allow small pets in crates/carriers on public transit, during off-peak hours, and

 

Further, although it is understood that OC Transpo is regulated federally, it would seem reasonable and appropriate that personal assistance or service animals covered under the Accessibility for Ontarians with Disabilities Act be permitted access to public transit provided that they are appropriately contained and/or controlled which, in By-law and Regulatory Services’ experience, is largely the case.

 

In relation to service animals specifically, perhaps worth noting is that, as part of its consideration of the harmonized Animal Care and Control By-law on October 9, 2002, Council approved the following resolution:  "Whereas service animals should have access to City parks and other City facilities when accompanied by their handlers; Therefore be it resolved that [the proposed by-law] be amended to provide for an exemption for service animals with respect to restrictions in parks; and That service animals be permitted in all City facilities when accompanied by their handler."  Permitting service animals on public transit would perhaps reflect what seems to be the spirit and general intent of that resolution.

 

In addition, we do not believe that there would be a significant number of pets and service animals accessing public transit.

 

Employee Services

 

The Amalgamated Transit Union, Local 279 have expressed that allergens are a health concern for their drivers.

 

Ottawa Public Health

 

Ottawa Public Health (OPH) appreciates the opportunity to comment on this proposal. Our comments are restricted to the implications for human health and do not deal with other issues arising from this proposal (e.g. fear of animals, additional maintenance costs, reduced ridership if people avoid transit, legal implications of superceding laws that exempt it from the Ontario Accessibility for Ontarians with Disabilities Act; etc)

 

In assessing this proposal Ottawa Public Health has considered available epidemiological data, as well as the experiences of  other Canadian cities, and is cogniscent of the fact that this proposal is for a pilot study, thereby permiting amendments or cancellation of the direction if significant health issues are identified or related issues remain unresolved at the end of the pilot phase. Further, we note that the proposal is that pets be crated - this would reduce the amount of allergens (dander, pet hair and saliva) in open spaces on the bus, provided that the crate's structural integrity is robust and the animal cannot escape.We have made contact with the Vancouver and Toronto transit and public health authorities and received no negative feedback from these cities.

 

Public Health Concerns: 

 

1.         Rabies and biting incidents are not anticipated to be a significant concern, as pets will be confined in crates/carriers.  All cats and dogs over 3 months of age or older must be vaccinated against the rabies virus in Ontario.  Ottawa Public Health follows up on all animal-biting incidents to ensure that pets have been vaccinated and do not have rabies. 

2.         Pet feces and urine would be confined to crates/carriers and are not likely to pose a public health threat.

3.         Allergens remain a public health concern, ranging from being a relatively minor inconvenience to a life-threatening issue.  It will be important to monitor this problem during a pilot phase, and ensure consultation of the public and interested parties at the end of the pilot. (E.g with groups such as the Environmental Health Association of Ontario - Ottawa Branch). 

 

From a Public Health risk perspective the following questions should be addressed prior to or during any pilot phase of a new policy:

 

1.         Is there a procedure in place for all animal/human-biting incidents to be reported to OPH?

 

2.         Are complaints being made by the ridership regarding serious allergic reactions or allergy-triggered asthma events due to exposure to pets on the transit system? 

 

3.         Is transit staff able to ensure pets not in carriers are restricted from entering the transit system and removed if the owners breach the safety precautions set out to prevent pet escape from their carriers?

 

OPH staff would be available to assist in developing a protocol if requested.  The following points are suggestions we consider important to protocol development:

 

a.         Written information is available for transit staff and the public about the requirements for containment; the size of pets; the hours they would be able to access the transit system; and the discretionary powers of drivers to refuse access to pets and request removal of pets already on the transit system.

b.         The crate/carrier design must ensure pets cannot escape.     

c.         Members of the Environmental Health Association of Ottawa should be involved and requested to provide feedback on the success of the carriers at limiting allergy symptoms among allergy suffers and asthmatics. 

d.         Members of the Responsible Dog Owners of Canada should be involved and requested to provide feedback on their experiences with the community on the buses. 

e.         Animal bites must be reported to OPH.  

 

In summary, Ottawa Public Health has reviewed the relevant public health issues related to the proposed policy to permit small, licensed pets in crates/carriers on public transit, during off-peak hours.  We do not have any objections to a pilot project going ahead on a time limited basis. In 1999, then Medical Officer of Health, Dr. Cushman, expressed concerns that people who have asthma, triggered by allergies to pet dander, could experience a range of adverse health effects.  These concerns remain relevant today, but the proposal currently under consideration has addressed the issues and the provisions proposed (i.e. permit only small, licensed pets in crates/carriers during off-peak hours) can reasonably be expected to result in adequate mitigation of risk of harm to the general public.  The evidence from other municipalities suggests that allergy concerns can be successfully addressed. 

Accessibility Advisory Committee

 

 

FINANCIAL IMPLICATIONS

 

Financial Services Unit

 

A relatively small marketing campaign around this pilot project will be forthcoming, and will be absorbed within existing approved budget funds.

 

 

SUPPORTING DOCUMENTATION

 

Document 1 – Pets on Public Transit, a Pilot Project: Presentation

Document 2 – Other Municipal and Modal Examples

 

DISPOSITION

 

The  Planning, Transit, and the Environment department will carry out the directives of Committee and Council.


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PETS ON PUBLIC TRANSIT

A PILOT PROJECT

 

 

Responsible Dog Owners of Canada

April 2008

 
DOCUMENT 1

PETS ON PUBLIC TRANSIT

A PILOT PROJECT

 

Introduction

In late September 2007, Responsible Dog Owners of Canada (formerly National Capital Coalition for People and Dogs) launched a petition regarding the issue of pets on public transit.  In approximately two months, it collected 2052 signatures in support of a “Pets on Public Transit Policy” for Ottawa.

Numerous Canadian cities, including Toronto, Vancouver, Montréal, Québec City, Gatineau, Victoria, Kelowna, Port Alberni, Prince Rupert, Vernon, Whistler, Comox Valley, Abbotsford, Maple Ridge, Edmonton, Lethbridge, Brandon, Calgary, Winnipeg, Niagara Falls, Hamilton, North Bay, Halifax and St. John's, have an established pets on public transit policy in place and have reported very few problems.  

In researching the need for and feasibility of pets on public transit in Ottawa, some questions raised and answered are as follows: 

 

Who will this policy benefit?

A pets on public transit policy will assist a number people, including persons who require the support of  small service animals that currently cannot be certified because of a lack of standards for such training, people who volunteer with their certified therapy animals to visit the elderly and infirm in hospitals, nursing facilities and retirement homes, seniors, people with disabilities and those on limited incomes, who are most in need of affordable transportation to get their companion animals to veterinary appointments, training classes, etc. 

 

According to the City of Ottawa 2006 Health Status Report, community services and support are in place for the almost 100,000 senior citizens in Ottawa. While many senior citizens in Ottawa are coping well as they age, there are 28.1% of seniors aged 65 and older who live alone and there are as many as 10% of seniors in Ottawa who may be socially isolated with little real connection to the outside world.

According to the 2001 Census, 113,835 people in private households in Ottawa were living in low income situations. This represents 15% of the population living in private households. For people who are 15 years of age and over and who do not live with a family, this increases to 32% or 36,330 people2.

In 2001, the population of disabled people in Ottawa was 36,675 citizens and an additional 6585 disabled people can be added to that number by 2001.  More than half of Ottawa’s disabled citizens live on less than $15,000 a year, below the poverty line and about 21% live on less than $9,600 a year.3

Evidence illustrates that pets are invaluable to the health and wellbeing of humans and that many seniors, disabled people and other socially isolated people rely on pets for companionship, security and a sense of purpose. For people with physical and/or psychological challenges, assistance animals, certified or uncertified, provide both physical and psychological assistance and support, see The Healthy Pleasure of Their Company: Companion Animals and Human Health; The Role of Pets in the Social Networks of Children, Adolescents and Elderly People; Pets make hospital rounds, bring 'therapeutic touch' to patients, Seattle Post Intelligencer and Reasonable accommodation or nuisance? Service animals for the disabled, Elizabeth Brandon, attached.

 

What would the policy consist of?

Responsible Dog Owners of Canada recommends policy based on other successful models that would allow small pets in crates or carriers, which can easily rest on the owners lap or fit under the seat, to travel on Ottawa’s OC Transpo buses during off peak hours and Para Transpo vehicles at all times.

 

 

What about allergies?

According to our research, the transfer of pet dander from pets in crates/carriers is minimal and that more pet dander is transferred from pet owners’ clothes using the transit system daily than what would be transferred from a pet in a carrier. A comprehensive report is attached. 

 

What about diseases (Zoonoses)?

 

The chances of contracting a zoonotic disease from a pet are slim.  With the majority of zoonoses indigenous to this area, human infection would require very close contact with animals or their excretions.

Some of the common (but rarely transmitted between species) zoonoses include:   

Salmonellosis:  A bacteria that generally makes its way into human bodies through contaminated food but can be passed through contact with animal feces.

Roundworms:  Roundworm eggs and microscopic adult worms are usually excreted in the feces of dogs and cats infected by the worms.  Direct contact with the faecal matter is the mode of infection.

Cat Scratch Fever:  This bacteria is normally transmitted from cats to humans through scratches.

Strep Throat:  Studies indicate that pets are probably not the culprit in spreading and that it is more likely that humans infect pets.  However, the possibility of animal/human transmission does exist with direct contact, e.g. kissing, licking or exchanging food by mouth with pets.

Ringworm:  A fungal infection of the skin, hair or nails, humans can be infected through use of contaminated objects like hair brushes, towels or clothing or by direct contact with infected animals like cats, dogs, mice, rats and guinea pigs.

Scabies:  Also called sarcoptic mange, scabies is a skin disease caused by itch mites which burrow under the skin. Scabies cause intense itching and scratching that can result in severe eczema. Humans can be infected through direct contact with infected animals.

Giardia:  A parasite that infects the intestines of humans and animals, it is usually a water-borne disease transmitted by drinking surface water from sources such as streams, rivers, lakes or shallow wells that are contaminated by human or animal feces, swallowing contaminated water while swimming in lakes, ponds, streams, rivers, swimming pools and hot tubs or eating contaminated food..

Leptospirosis:  A bacteria that affects humans and animals, it is spread through the urine of infected animals, which can get into water or soil and can survive there for weeks to months. Humans and animals can become infected through contact with this contaminated urine (or other body fluids, except saliva), water, or soil. The bacteria can enter the body through skin or mucous membranes (eyes, nose, or mouth), especially if the skin is broken from a cut or scratch. Drinking contaminated water can also cause infection.

Rabies:  A viral infection that is spread through the saliva of an infected animal.  Transfer of the virus most often occurs through a bite from an infected animal.  In 2000 and 2003, two people in Canada died of rabies infection, one in Quebec (2000) and one in British Columbia (2003). These were the first cases of human rabies in Canada since 1985. The most likely sources of infection for both of these people were unrecognized bat exposures. Since 1924, there have been a total of 6 deaths from rabies in the Province of Ontario.

Zoophobia:Zoophobia is defined in medical terms as an abnormal and persistent fear of animals.  Zoophobia may have one of two closely-related meanings: a generic term for the class of specific phobias to particular animals, an irrational fear or even simply dislike of any non-human animals.

Zoophobia should not be confused with sensible fear of dangerous or threatening animals such as the fear of venomous snakes, etc. And, while it is recognized that some people have a valid reason to fear an animal like a dog, cat or other domesticated animal perhaps because of an unfortunate experience, small pets in crates are securely contained and should not pose any threat or discomfort.

 

Will the presence of crated animals provoke disruptive reactions from guide dogs and other certified assistance animals?

 

Guide dogs and assistance animals are especially trained to provide aid to humans who are blind or who have specific disabilities such as hearing loss, mobility deficiencies, epilepsy or psychiatric conditions, etc.  Guide dogs and assistance dogs must be intelligent, alert, and willing to serve and must be able to remain undistracted by other animals such as squirrels, cats or other dogs.  Dogs that do not meet these standards are rejected as unsuitable as a working dog.  Therefore, while not impossible, it is highly unlikely that a guide dog or other certified assistance animal will react in a disruptive manner to the presence of a small, crated animal that in most instances would go unnoticed by other transit riders, both human and animal.

Although it is more likely that a pet would react to the presence of another animal, the fact that in accordance with the policy proposed pets are crated and secure, a disruptive reaction is improbable.  

 

Would the policy result in an animal invasion of the transit system or inconvenience other passengers?

 

As mentioned previously, this policy will benefit a limited number of people who do not have access to a vehicle and who have small animals. A small pet carrier on an owner’s lap will not take up any additional space. Nor would there be any concerns about bites, disease or pet waste. Therefore, this policy would not constitute an invasion of the transit system or create an inconvenience for other passengers.

 

Implementation of pets on public transit

 

The Responsible Dog Owners of Canada recommends that a "pets on public transit policy", allowing small pets in crates/carriers on public transit during off peak hours, be introduced as a six-month pilot project.  It also recommends that eligible animals be licensed in accordance with the City of Ottawa Licensing By-law and that bus drivers be given the discretion to refuse boarding to anyone with a crate that is exceeds size restrictions, e.g. larger than can be carried and stored easily or a crate or carrier that appears insecure.

There are a number of practical models across Canada that would be viable in Ottawa and Responsible Dog Owners of Canada would be pleased to offer its assistance in drafting a policy for Ottawa residents.

If the pilot project indicates that pets on public transit are not problematic, we recommend that a policy be implemented on a permanent basis.

 

Bibliography

 

1)        City of Ottawa 2006 Health Status Report: Health Detriments, www.ottawa.ca/residents/health/publications/hsr/health_determinants_en.html#P43_6209 ;

2)      City of Ottawa 2006 Health Status Report:  Health Detriments, Income, www.ottawa.ca/residents/health/publications/hsr/health_determinants_en.html#P5_708 ;

3)     Para Transpo In Ottawa, Canada:  Why the Disabled Community in the Capital Need Better Transport, Mona Harb, humanrights.suite101.com/article.cfm/a_closer_look_at_para_transpo .

Enclosures:

i)        The Healthy Pleasure of Their Company: Companion Animals and Human Health, Karen Allen, School of Medicine, State University of New York Source, Delta Society;

ii)       The Role of Pets in the Social Networks of Children, Adolescents and Elderly People, June McNicholas, Department of Psychology, University of Warwick, UK, Delta Society;

iii)     Pets make hospital rounds, bring 'therapeutic touch' to patients, Susan Phinney, Seattle Post Intelligencer;

iv)     Reasonable accommodation or nuisance? Service animals for the disabled, Elizabeth Brandon, Florida Bar Journal

 

Allergies and Pets on Public Transit:

A Non-Issue

 

People with allergies and pets on public transportation raise valid a concern of possible incompatibility. However, the incidence of a person with pet dander allergies crossing paths with a pet on an OC Transpo bus would be low. Furthermore, if certain steps are taken to alleviate or eliminate the cause for concern, it is possible for a pet and a person with a dander allergy to temporarily co-exist aboard public transit. As over 18 other major city centres in Canada including Toronto and Vancouver continue to demonstrate, serving a population of people with allergies and people who wish to travel with pets on public transportation is quite compatible.

 

Low Incidence

It is important to note that due to a minority allergic population and a minority of people who would use public transit to transport their pets, the incidence of people with allergies and a pet on public transit would be low.

Of the general population, 15% is allergic specifically to dogs or cats1. While 20-25% of the Canadian population suffers from allergic rhinitis, according to the Allergy/Asthma Information Association in Canada2, not everyone in that category is allergic to pets.

30% of Ottawa residents ride OC Transpo on typical weekday: 346,800 people3 (out of Ottawa’s 1,148,800 residents). There are no confirmed statistics as to how many people would take their pets on OC Transpo. However, approximately 54% of all households own at least one pet. Therefore, although approximately half of the OC Transpo ridership might potentially take their pet aboard OC Transpo, it is obviously highly unlikely. Most pet owners have a vehicle in which to transport their furry companion. The people who would most benefit from a ‘pets on public transit policy’ would include those who are unable to own or drive their own vehicle, including the disabled and elderly.

 

 

Allergic Rhinitis

Allergic rhinitis is when a person’s immune system overreacts to particles (called allergens) in the air that they breathe and cause them to have an allergic reaction. Allergic reactions include sneezing and a runny nose, water and itchy eyes, nose and throat4. Types of allergens that cause allergic rhinitis include pollens, mould, dust mites, animal dander, and cockroaches.

A more severe allergic reaction is anaphylaxis. However, this type of reaction occurs in people with food allergies, allergies to medications or reactions to vaccines, and bee stings. If a person has a severe allergy to a certain substance that causes the blood vessels to leak fluid into the area around them, a sudden drop in blood pressure will result in restricted blood flow and less oxygen to the brain. The body goes into shock and may respond to the allergen by releasing histamines, which cause swelling of the skin, a red rash, and severe itching. They may also experience trouble breathing, including wheezing, trouble swallowing, tightness in the throat, or chest, swelling of the lips, tongue, throat or another part of the body, and red, watery eyes. 

According the Health Canada:

 

Severe allergic reactions (e.g. anaphylactic shock) occur when the body's immune system reacts to a particular allergen or irritant. These reactions can be triggered by certain foods or food ingredients, insect stings and medications.

The most common food products that cause reactions are peanuts, tree nuts, sesame, soy, fish, wheat, eggs, milk and seafood. Foods account for most of the cases in children, while drugs and antibiotics like penicillin are more likely to cause a reaction in adults. Stings from yellow jackets, hornets, wasps and bees are the most common cause of insect reactions. Some individuals also experience severe allergic reactions to natural latex rubber5.

Health Canada does not mention pet dander as a potential allergen that triggers anaphylaxis.

It must be noted that while pet dander may cause an allergic reaction in the people with allergies to pets, the reactions, while annoying and uncomfortable, are not life-threatening.

Additionally, and importantly, there are steps that can be taken to ensure that on the chance a pet and a person with an allergy to pet dander happen to be riding the same bus at the same time, the person with allergies will experience zero to minimal symptoms.

 

Guidelines to alleviate or eliminate allergy symptoms if a pet and a person with allergies were to ride the same bus

A person with allergic rhinitis who is allergic to pets is not allergic to the pet hair or fur. It is actually the pet’s saliva, urine, or dander that will trigger an allergic reaction. While saliva and urine are somewhat avoidable, dander is invisible to the naked eye and clings to the pets’ fur, and to carpeting and furniture.

If a pet were allowed to ride on OC Transpo, there have been assertions that the animal would drool over other riders, urinate or defecate en route, and leave hair and dander on the seats and in the air. While pet owners know that a trained dog is highly unlikely to have an accident while traveling on the bus, this is not the place to carry on such an argument. Nor can one argue that a dog or cat freely riding the bus would not release pet dander into the air.

If the pet were contained within a crate, drooling and accidents would become a non-issue. If they happened, it would be contained within the crate and would not inconvenience any fellow passengers. Furthermore, pet dander being released into the air would be significantly reduced.  

If the pet were contained in a fully covered pet carrier, the incidence of pet dander being released into the air would be nearly non-existent. The fully covered pet carrier would contain the pet and its pet dander. People who suffer from allergies should not even be able to detect the fact they are traveling a bus with a pet.

Should these responsible guidelines be implemented simultaneously with the implementation of a ‘Pets on Public Transit’ policy, there would remain no reason to have concern over pets on public transportation and riders with pet allergies.

 

A Sample of Cities with Successful ‘Pets on Public Transit’ Policies

 

Many major cities in Canada continue to demonstrate that serving a population of people with allergies and people who wish to travel with pets on public transportation can actually be quite compatible. Cities that currently have a successful ‘Pets on Public Transit’ policy in place include: Hull/Gatineau, Toronto, Vancouver, Victoria, Whistler, Abbotsford, Nanaimo, Prince Rupert, Sunshine Coast, Kelowna, Calgary, Edmonton, Lethbridge, Regina, Winnipeg, Montreal, Halifax and St. John’s.

Toronto (population of 2,481,500)

In Toronto, you may travel on subway, bus and streetcar with your large or small dog either leashed or in a traveling crate. Peak travel periods are off limits, but other than that your dog is welcome aboard. Toronto Transit has had this by-law, last re-written in 1990, in place for quite some time now. According to Toronto Transit Systems Security, there have never been any major problems and neither have too many dogs infiltrated Toronto’s transit system.

 “…although we have received complaints in regards to (pets on public transit), they represent only a minority of the complaints received by the Toronto Transit Commission in relation to animal acceptance onboard our vehicles or station”

 

Dan Micner, Senior Customer Service representative, TTC*

Mr. Micner also stated in a phone conversation that when he receives complaints with regard to pets and transit, they are commonly questions of why pet wasn’t allowed on the transit system at a certain time of day. No pets are allowed the TTC between the hours of 6:30-9:30 a.m. and 3:30-6:30 p.m.. These rules are strictly enforced on the subway but bus and streetcar drivers have been known to be lenient with these time constraints if their bus or streetcar is not a busy one. The driver always reserves the right to refuse to allow a pet to board the bus if it is felt the animal is not under control or a threat to other riders.

The fact that Toronto welcomes both large and small dogs aboard their buses merits recognition here. This is the largest city in Canada and yet its by-laws have allowed any dog, as long it is under control of its owner, to travel on Toronto’s subways, buses, and streetcars. Judy Shulga, System Security Coordinator for the TTC, also noted that in her 28 years of experience she has never heard of any major problems. As far as she is concerned, Toronto’s ‘Pets on Public Transit’ policy works well.

Vancouver (population of 600,000 within a region of more than 2,000,000 people)

In Vancouver, small pets, including dogs, may be permitted on transit vehicles provided they are in handheld cages. After a probation period in 2001, the TransLink Board of Directors approved the motion to permanently allow small pets in carriers onto Vancouver’s public transportation. There have been no problems with dogs riding Vancouver busses.

“(Pets on Public Transit) programs have very specific guidelines, have been in place for a few years and run smoothly.”

Steve New, Senior Vice President, Municipal Systems Program, BC Transit*

“…we have not had any difficulties. Coast Mountain (subsidiary of BC Transit) did ask the advice of allergy specialists and dermatologists and their suggestions were implemented and we have not had a problem.”

Customer Relations, Coast Mountain Bus Company*

Winnipeg (population of 633,451)

“Winnipeg Transit currently has a policy that to have an animal on the bus it is mandatory that it is in an enclosed carrier, with the exception of working dogs. To date we have not received any complaints regarding the transport of animals on the bus while in an enclosed carrier.”

Dierdre Schultz, Customer Service Representative, Winnipeg Transit*

Calgary (population of 988,193)

Calgary welcomes both large and small dogs on its buses for an extra fee of $2.25, while cats in kennels are free of charge.

 


“We have not had any reports of such types of dogs causing problems on our system… Occasionally we come across passengers who bring a dog on the train and did not know that the dog was required to pay fare. That is the extent of the concerns raised.”

 Tina Mercier, A/Ops. Supervisor, Protective Services Section, Calgary Transit VP166

Other cities to note include Edmonton, which allows small to medium pets on their transit system as long as they are fully enclosed in a secure cage. Regina’s by-laws stipulate that small pets are only allowed on if they are in a cage that is fully covered so no one can see inside. Montreal, Halifax and St. John’s all require that pets be in some sort of carrier in order to be welcomed aboard.

1)      Pet Education.com (http://www.peteducation.com/article.cfm?cls=0&cat=1278&articleid=145), accessed October 4, 2007.

2)      Allergy/Asthma Information Association. Dust, Pet and Mold Allergies: (http://aaia.ca/en/dust_brochure_en.pdf), accessed October 2, 2007.

3)      OC Transpo website and Ottawa Kiosk: (http://www.octranspo.com/about_index.asp?lang=E&page=AABOUT_MAIN; http://www.ottawakiosk.com/people.html), accessed October 4, 2007.

4)      BC Health Guide. Allergic Rhinitis (http://www.bchealthguide.org/kbase/topic/special/hw33436/sec1.htm), accessed October 2, 2007. 

5)      Health Canada. Severe Allergic Reactions (http://www.hc-sc.gc.ca/iyh-vsv/med/allerg_e.html), accessed October 4, 2007.

6)      http://www.cuhumane.org/topics/allergy.html

 

 

 

 

 


Document 2

Other Municipal and Modal Examples

Agency/City

Animals

Policy

Air Canada

Service animals

* Must be certified, professionally-trained service animals

Pets

* Not allowed

WestJet

Service animals

* Required to travel at guest’s feet; service animal support documentation must be carried

Pets

* Allowed in cabin, in an enclosed kennel

Via Rail

Service animals

* Professionally trained seeing-eye dogs with U-harness

Pets

* Cats, dogs and small rodents allowed in baggage cars

* Must be carried in rigid, padlocked cage large enough for them to stand in

* Some trains do not have proper ventilation in the baggage car

Windsor

Service animals

* Working dog must be wearing dog halter and vest with sign indicating it is a working service dog

Pets

* Small pets must be secured in a proper pet carrier for duration of the ride

STO (Gatineau)

Service animals

Seeing-eye dogs

Pets

Small pets in enclosed container on person’s lap; person responsible for the animal not to soil or create any inconvenience to other passengers

Winnipeg

Service animals

* Working dogs must be registered seeing-eye or hearing-ear dogs

Pets

* Must be in an enclosed carrier that can be safely stored while onboard

Calgary

Service animals

* Service dogs

Pets

* Pets that can be transported in small cages or on one’s person and that are not a threat to the safety of other passengers are free of charge

Vancouver

Service animals

* No restrictions

Pets

* Small pets must be in handheld cages

* “Suggest” traveling with pets during off-peak times

* Operators may refuse an animal to board if there is a concern for safety or comfort of passengers

Montreal (STM)

Service animals

Seeing-eye or service dogs

Pets

Must be carried at all times in a cage or container designed for travel purposes

Toronto (TTC)

Service animals

* Seeing-eye and hearing dogs

Pets

* Dogs must be on a leash

* Small animals must be carried without danger or offense to passengers

* Prohibited weekdays from 0630 to 0930, and from 1530 to 1830

* Drivers may refuse an animal to board if it is felt that the animal is not under control or is a threat to the riders



            PETS ON PUBLIC TRANSIT - A PILOT PROJECT

LE TRANSPORT EN COMMUN ET LES ANIMAUX DE COMPAGNIE - PROJET-PILOTE

ACS2008-CCV-PTA-0002                                             CITY WIDE / À L'ÉCHELLE DE LA VILLE

 

Angela Connidis, Vice Chair, Pedestrian and Transit Advisory Committee (PTAC) introduced the report and briefly mentioned when the issue was debated by the Committee and the concerns raised by the delegations at that meeting.

 

When asked whether OC Transpo was present during that meeting, Ms. Connidis indicated they were not.  Alain Mercier, Director of Transit Services added that this is a very complex issue; he mentioned the comments in the report, the issues of priority seating space and the conflicting demands for seating on buses.  When asked whether the PTAC had followed up with staff to ask their views, the delegation advised that they had not because the committee would not convene again until following this meeting.

 

Councillor Leadman made note of the fact that the City of Toronto has implemented a similar pilot and suggested that if it could work there, why could it not work here.  Mr. Mercier explained that that is the question that before the Committee.  He went on to state that staff have highlighted the fact that they have approached Ottawa’s system in a different manner than other systems.  He recognized that each transit system over time have permitted different policies (for different reasons) and the current situation in Ottawa is that OC Transpo is dealing with complaints about congestion, priority seating, cleanliness of buses, et cetera.

 

John McLuckie, ATU, Local 279 asked that the Committee reject the report recommendations for the following reasons:

·        bringing animals on buses will negatively affect the work place of employees ATU represents and the level of service to the passengers

·        priority seats are close to the driver and he wondered how a driver can be expected to safely and effectively perform their job while in the middle of an allergic reaction as a result of an animal on their bus

·        similarly, how do they address the concerns of the public who have similar allergic reactions

·        operators will carry home allergens from their work environment that could negatively affect family members

·        the Canada Labour Code will allow operators to decline work environments if bus operators feel it will put them in a difficult situation;

·        Will drivers be responsible for policing the policy?

·        Once the public discover they can bring pets on board, some will ignore the regulations and bring other animals on board, including mice, rabbits and snakes.

 

Chair Cullen made note of the fact that for those transit services in other cities that allow pets on transit, there have been no recorded complaints received.

 

Councillor Leadman asked how drivers respond to serious allergies when service animals are allowed on the bus.  Mr. McLuckie offered that there is a very low per centage of service animals on buses and cats, which are not service animals, but would be permitted under this proposal, are a significant trigger for people to suffer an allergic reaction.  The councillor inquired of any instances where a driver has refused to work because of a service animal and the delegation advised that he was not aware of any, but reiterated the fact that they have that right to do so.  He believed that the quantity of animals on buses would increase dramatically, causing more reactions to allergies for drivers.  This in turn could create a conflict between passengers and the driver.

 

Michele Parsons, bus driver was concerned about bringing home pheromones, which cats and ferrets give off and to which her children are allergic.  She was also concerned that people would not use the recommended carrier or crate and that they would be bringing animals (including birds) in boxes too.  And, since the crates are vented, she believed they would have to have cleaners on the bus to deal with the scent of the animal in the crate.  She was particularly concerned about passengers who may have an animal/bird phobia and while she is a good driver, admitted she would react to anyone who jumps up and starts shrieking.  This would affect her ability to do her job and she did not believe it was fair to ask her to choose between her passengers - those with pets and those with phobias.  She was also concerned about the arguments this might generate and what kind of role she would have to take with respect to providing ‘mediation’ between conflicting passengers.  She suggested people can use pet taxis or ask their vet to make a house call, rather than using public transit to take them to see the vet.  On a closing note, she commented that despite the allergies people have with certain foods, eating is still permitted on OC Transpo buses.

 

Responding to a question posed by Councillor Wilkinson, Mr. Mercier explained that a segment of the population who want to travel with their pets are seniors and they would be entitled to use priority seating, which is close to the driver.

 

Councillor Leadman was concerned about the safety of the driver if they have to deal with arguments between passengers.  When she asked what procedure is currently in place that operators must adhere to in such situations, Ms. Parsons explained that she has to stop the bus and open the door and call her supervisor or security to advise her.  She noted that the waiting time can be long.

 

Candice O'Connell, Chairperson, Responsible Dog Owners of Canada referred to their paper which was contained in the PTAC report and commented on the issue of pet dander as being negligible in a crate or on a person on the bus.  She reminded the Committee that the proposal is for a six-month trial pilot for small animals only and suggested that the amount of people who would take advantage of this, i.e., seniors and the disabled, is so low, it would not constitute an invasion of their constitution.  She offered examples of carriers people could purchase to bring their small animals on the bus.

 

Councillor Leadman believed a person would have to take their pet to a vet once or maybe twice a year and did not believe people would purchase an expensive carrier ($30-$100) to transport them on a bus.  Ms. O’Connell suggested there were all kinds of reasons for people to be travelling with their pets, not just to take them to the vet.

 

Bruce Roney, Executive Director, Ottawa Humane Society spoke in support of the proposal, noting the positive integration of companion animals to the community.  He was concerned that a lack of transportation may result in animals being left loose rather than being brought in to the shelter and, if they could transport them on public transit, perhaps more people would come to the shelter to claim a pet.  Animal ownership should not be predicated by car ownership.  He was concerned that animals might not be seeing their vets regularly because of the lack of affordable transportation for those without their own vehicles and even injured animals might not be seen when they should be.  He referred to the therapeutic program using dogs and cats and indicated that not having private transportation is a barrier to people taking advantage of this program.  He believe the City should support responsible animal ownership and encourage using public transportation.

 

Responding to some of his concerns, Councillor Leadman asked if he had proof that less animals would be found or picked up if public transportation was not available to transport them on.  Mr. Roney explained that many people complain about being able to access the shelter without public transportation and he maintained that if it was available for small animals, the better it would be for all.

 

Carole Eldridge, Chair, Ottawa Therapy Dogs explained that they bring trained dogs to people who do not have animal companionship, for therapeutic reasons.  It is a volunteer-based program and she believed they would have more volunteers if they did not have to use their own vehicles.  This program helps those that would normally be isolated in the community and she believed people would use public transit to take their pets to visit friends and loved ones.

 

Frank Fata explained that while he is a bus driver, he was speaking as a husband and father.  He explained that when they learned that this program may be offered, they purchased a car for their son who attends Carleton University because he has allergies and cannot take public transit if animals are going to be allowed on the bus.  He has to change as soon as he gets home and wash his clothes because of his family’s allergies, but if pets were allowed on the bus, he would have to bring a change of clothes and change even before he leaves to go home, to avoid bringing any allergens into his car and into his home.  Mr. Fata suggested there was also a slim possibility of liquids spilling out of a cage containing a pet, especially as the person enters the bus and turns to go down the aisle.  He was also concerned about diseases that may be transmitted between animals and humans.  His mother also has a phobia of animals and would be unable to take public transit.

 

Jan Lam was not in support of this proposal to bring small pets on public transit and even suggested the definition of what a small animal is could cause disputes between the driver and the passenger.  Even if the recommendation is for off-peak hours, he indicated that Route 95 is crowded all the time and adding animals would not help that situation.  He wondered what happens if the animal urinates or defecates in their crate, or if it were to get loose while on the bus.  He believed there are other more important issues the City needs to deal with.

 

Catherine Gardner indicated her support for this program, but did have some concerns.  She made note of the fact that food is allowed on public transit and yet the City does not seem to be concerned about problems that may cause for people with food allergies.  She made note of the fact that the barrier she has is taking her pet to the vet because she cannot do that on Para Transpo or in a regular taxi.  She also pointed that some places where passengers would transfer to another bus, would not permit them to travel with their pet if the transfer point takes them through a shopping centre, for example, so if this proposal is approved, that would be something the City would have to consider.  Ms. Gardner believed that allowing people to travel on public transit with their pets would allow them to get out and socialize more.

 

Councillor Doucet introduced a Motion he asked the Committee to consider, the effect of which would be to direct staff to create a policy and come back to the Committee.  He explained that when this first came forward, he was inclined to support the pilot, but in light of the informative comments provided by some of the delegations today, was prepared to go a different route to ensure a policy is created first.

 

Councillor Bloess believed the City is already facing a myriad of issues with public transit without adding to that mix.  He explained that he has had difficulties getting buses into new areas in his ward and preferred that staff not be bogged down with having to create a policy.

 

Councillor Wilkinson wondered how this Motion would fit into the existing workplan for OC Transpo and whether or not this is an appropriate time to be working on such a policy.  Mr. Mercier responded by stating that should the Committee choose to move forward, the next four months are a very busy time for them and would give them enough time to work through all the issues they would have to look at and how to deal with all the issues raised today.  He assured the Committee that to proceed in the absence of a comprehensive policy would be problematic.  The councillor suggested a more likely timeframe for reporting back would be February and Councillor Doucet agreed to amend his Motion accordingly.

 

The Chair expressed the view that his ward is made up of a majority of seniors and the reason for implementing this pilot would be to make life more convenient for people in the community to use a public service so they can do things with their pets.  He was aware of the issues with respect to allergies, but felt there was more mis-information than good information being shared.  He did not people many people would take advantage of this program, but he was concerned about the large number of people in his ward that do have pets and that cannot afford to take taxis.  He reminded Committee that pets on public transit is a program offered in many other cities and suggested that if they can make it work, so can Ottawa.  He encouraged members to support the Doucet Motion.

 

Moved by C. Doucet

 

WHEREAS several Canadian municipalities allow caged or crated animals aboard their transit systems;

 

AND WHEREAS the transit system should be an accessible system that provides those who wish to transport their pets in a safe fashion, the opportunity the opportunity to do so;

 

THEREFORE BE IT RESOLVED THAT staff be directed to develop a Pets on Public Transit policy, including an amendment to the Transit By-law, to permit the accommodation of pets on the transit system provided that they are:

§         crated

§         in the lap of the transit rider

§         travelling in off-peak transit hours;

 

AND BE IT FURTHER RESOLVED THAT this policy include the consideration of the following:

§         the safety of the operator and bus riders

§         the liability of Transit Services for the safety of the pet

§         the discomfort of those with allergies or zoophobia

 

AND BE IT FURTHER RESOLVED THAT this policy be brought forward by February 2009 and include a communications plan.

 

                                                            LOST

 

YEAS (4):                    C. Leadman, C. Doucet, M. Wilkinson, A. Cullen

NAYS (4):                   R. Bloess, G. Bédard, M. McRae, D. Thompson

 

The Committee then considered Recommendation 1 of the Advisory Committee’s report:

 

The Pedestrian and Transit Advisory Committee recommends that the Transit Committee recommend Council:

 

1.         Direct staff to implement a six-month pilot project to allow small, licensed pets in crates/carriers on public transit, during off-peak hours.

 

                                                                                                            LOST

 

YEAS (2):                    C. Doucet, A. Cullen

NAYS (6):                   R. Bloess, G. Bédard, C. Leadman, M. McRae, D. Thompson, M. Wilkinson

 

            Recommendation 2 (below) was considered as part of another item that the Committee considered on the same day, dealing specifically with service animals on buses.  The discussion on that particular item appears at Item 1A of Minutes 22 of the Transit Committee, 20 August 2008.

 

2.         Reconsider the OC Transpo policy on issuing animal assistance cards to accommodate persons with disabilities, in need of service animals.

 

                                                                                                            REFERRED TO ITEM 1A FOR DISCUSSION