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Special Education/Student Services
Annual Accessibility Plan

2009-2010
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Prepared by

Bluewater District School Board
Accessibility Working Group

This publication is available in accessible formats upon request


Table of Contents
        

Description of the Bluewater District School Board
3
Purpose of Accessibility for Ontarians with Disabilities Act
3
Definition of Disability
3
Definition of Barrier
4
Executive Summary
4
Historical Perspective
5
Accessibility Working Group Members
5
Communication Plan
5
Accessibility Working Group Contact
5
Prevention and Removal of Physical and Architectural Barriers
6
Prevention and Removal of Information/Communication/Technology Barriers
7
Prevention and Removal of Attitudinal Barriers
8
Prevention and Removal of Policy/Procedure Barriers
9
Appendix A – Ontario Regulation 429/07: Accessibility Standards for Customer Service
10


Description of Bluewater District School Board
Bluewater District School Board provides public education to families in Bruce and Grey Counties in southwestern Ontario.  The two counties of Grey and Bruce cover an area of 8,673 square kilometers.  As of March 31, the District had 11 123.13 FTE students in 42 elementary schools and 7 121 FTE students in 11 secondary schools.  The District is organized into five administrative areas.

Purpose of Accessibility for Ontarians with Disabilities Act, 2005
Recognizing the history of discrimination against persons with disabilities in Ontario, the purpose of the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) is to benefit all Ontarians by,
  • developing, implementing and enforcing accessibility standards in order to achieve accessibility for Ontarians with disabilities with respect to goods, services, facilities, accommodation, employment, buildings, structures and premises on or before January  1, 2025; and
  • providing for the involvement of persons with disabilities, of the Government of Ontario and of representatives of industries and of various sectors of the economy in the development of the accessibility standards
                                        - taken from Accessibility for Ontarians with Disabilities Act, 2005-
Definition of Disability  
The AODA defines a disability as meaning,
  • any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal, or on a wheelchair or other remedial appliance or device;
  • A condition of mental impairment or a developmental disability;
  • A learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;
  • A mental disorder; or
  • An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

Definition of Barrier
The AODA defines a barrier as meaning anything that prevents a person with a disability from fully participating in all aspects of society because of his or her disability including: a physical barrier, an architectural barrier, an informational or communications barrier, an attitudinal barrier, a technological barrier, or a policy or a practice.

To this end, the AODA requires each school Board to prepare an Annual Accessibility Plan, to consult with people with disabilities in the preparation of this plan, and to make the plan public.

Executive Summary
This is the fifth Annual Accessibility Plan (2008-09) prepared by the Accessibility Working Group of the Bluewater District School Board. This Annual Accessibility Plan is in compliance with the Ontarians with Disabilities Act (2001) and is consistent with the belief statements out lined in Foundations for Learning.  It serves as a resource for addressing accessibility issues for the students, staff and members of the community.

Bluewater District School Board is committed to:
  • maintaining an Accessibility Working Group, which will meet regularly to review and update the Accessibility Plan;
  • consulting with people with disabilities, as well as people working  with the disabled in the development and review of its Annual Accessibility Plan;
  • ensuring that the Annual Accessibility Plan is in compliance with the legislation; and,
  • Identifying issues and improving access to facilities, policies, programs, practices and services for staff, students, parents/guardians, volunteers and members of the community.

This plan:
  • describes the measures that the Board has taken this year to identify, remove and prevent barriers for people with disabilities;
  • lists barriers that have been identified;
  • describes the initiatives and interventions the Bluewater District School Board will take in the coming year to identify, remove and prevent barriers for people with disabilities;
  • describes how the Bluewater District School Board will make this Annual Accessibility Plan available to the public.


Historical Perspective

The Bluewater Accessibility Working Group was formally constituted in September 2004.  

In order to identify barriers for staff and students, this group consulted with school administrators, employee groups, the Special Education Advisory Committee, community organizations, individuals with disabilities and those who work with individuals with disabilities.
Additionally, the group reviewed the recommendation made by The Ontario March of Dimes in physical barrier audit that was completed for all of the Board’s schools in 2003.   

Accessibility Working Group Members 2008-09

Barb Balderston
ETFO Representative
Trudy Baran
SEAC Representative
Brenda Edwards
Human Resources Representative
Glenda Hayes
Autism and Developmental Learners Representative
Fred Johnston
ICT Representative
Suzanne Kennedy
Student Services Representative
Melissa McEwen
Chair of Committee – Student Services Representative
Ron Motz
Health and Safety Representative
Michelle Phillips
OSSTF – Educational Assistants Representative
Sandy Ribey
SEAC Representative
Chris Thomson
OSSTF – Teacher Representative
Donna Torrie    
Specialized Equipment Representative
Peter Wilgress
Plant Department Representative



Communication of the Annual Accessibility Plan  

The Bluewater District School Board’s Annual Accessibility Plan is posted on the Board website at www.bwdsb.on.ca.  It is also available in a variety of accessible formats upon request.   Click here to request an alternate accessible format.


Contact for Accessibility Working Group

Melissa McEwen, Vice-Principal of Student Services
519 363 2014



Prevention and Removal of Physical and Architectural Barriers

Identified Barrier
Action Taken in 2008/09
On-going Intervention
*barrier free accessibility to be provided to all new board  buildings as per the current edition of the Ontario Building Code
The front doors of some schools are very heavy and may be difficult to open for a wheelchair user or someone with limited strength.

As doors have been updated this year, upgrades to address this issue have occurred

As renovations occur in schools, the Plant Department will continue to consider and plan to address this issue.
Doors are adjustable so if issue is brought to the attention of the administrator it could be addressed quickly.
If there is a specific need for a student to have a door opener, this request can be made via the administrator at the school.
Benches in the front lobbies/hallways of buildings obstruct the paths of people who are blind and visually impaired.

Survey was sent to head custodians about this issue.  There were only five issues reported.
This issue will be addressed as part of regularly scheduled Health and Safety inspections on board properties.
Reception counters at some schools are not at eye level for wheelchair users or younger people.
As renovations to office areas are initiated, the Plant Department staff will continue consider and plan to address this issue with a step-down area.
Some washrooms in schools are not easily accessible to individuals with physical disabilities/or persons using a lift
As renovations occur in schools, the Plant Department will continue to consider and plan to address this issue
Visually impaired individuals have difficulty orienting in buildings and using some stairs
When stairs are installed, a non-slip stair of contrasting colour is used.
Fire Alerts for hard of hearing students need to be installed
A majority of fire alarms have been updated to include light and sound  indicators
As any other fire alarms are updated, this issue will be considered
Playground designs need to  consider the needs of physically challenged and visually impaired students
CSA standards will be used when planning and designing playgrounds.  Schools must consult with Health and Safety.
School administration and SCC may need additional training.
Commonly accessed rooms such as the office, library and resource rooms need to be located in accessible areas in schools
When public meetings are scheduled, there should be consideration given to access.
Access to elevator keys needs to be simplified in schools
Issue needs to be addressed at a district level to ensure consistency in all schools.
Elevator size needs to be able to accommodate physically challenged persons
Needs to be considered in future builds.
Signage at school and the board office needs to be standardize to address needs of individuals with disabilities
Signage on the exterior of the building has been standardized  ie parking, fire access, stopping signs
Standards need to be developed for interior signage.
Ramps with railings need to be located at the main entrance of each school
New ramps will be compliant with technical specifications outlined in the Ontario Building Code  

In 2008/09, upgrades and work were completed in schools to address individual needs of students in order to remove physical and architectural barriers.  These needs are identified in on-going meetings that take place between Student Services staff and Plant Department staff. Student Services staff gather this information from students, parents, staff, administration, and a variety of professional individuals and agency staff who provide support in our schools.  A complete list of upgrades is available upon request.  Click here to make a request.

On-Going Initiatives and Future Plans
  • The Accessibility Working Group will serve as the system contact from schools that identify accessibility issues for students, staff and community members.
  • As a prevention mechanism, the plant department staff will continue to incorporate barrier-free modifications in new construction.  
  • Current information pertaining to physical and architectural barriers needs to be gathered on a regular basis.  In the Customer Service Standards as part of the Accessibility for Ontarians with Disabilities Act (2005), a feedback process is being developed by January 2010.

Prevention and Removal of Information, Communication, and Technology Barriers


Identified Barrier
Action Taken in 2008/09
On-going Intervention
Forms, records and information are only available in print


All board forms, policies and procedures are available electronically on the board website.

Forms, policies and procedures will be continually updated electronically to ensure there is access to current information.
Board website information is  not compatible with screen readers
A majority of screen readers now work with the board website.  If there are challenges, the board website can be easily converted to text only and used with any screen reader.
Student information and brochures are sometimes difficult to procure in alternative formats
The Bluewater Board is committed to ensuring that information is accessible to all individuals.
Alternative formats are available on request.
Information about accessibility is not easy to find on the board website
The accessibility plan is linked on the board website via Student Services.
A working committee will be reviewing the placement of information on accessibility on the board website as part of the implementation of the Customer Service Standards in 2009/10.
Need a consistent procedure to communicate identified barriers
A working committee will be looking at communication procedures as part of the implementation of the Customer Service Standards in 2009/10.

Need for large print format of board and school websites
Information on board and school websites can be manipulated using the text only function.  Individuals can then adjust the size of the text to meet their needs.

Suggested future initiatives
  • develop supports for navigating the board website
Prevention and Removal of Attitudinal  Barriers


Identified Barrier
Action Taken in 2008/09
On-going Intervention
Teaching and Non-Teacher Staff are sometimes unaware/lack knowledge of methods of accommodating people with disabilities

Upon request, the student services department provided information on persons with disabilities
As part of the implementation of the Customer Service Standard in 2009/10, all staff will be provided with training on persons with disabilities.

On-Going Initiatives
  • Professional development addressing programming needs for student’s with special needs.
  • Adherence to Human Rights Policy (BP 7520)
  • Adherence to Anti-Bullying Policy (BP 6821)
  • The following is a sample of initiatives and resources available for individuals or  individual schools:
  • Human diversity workshops
  • Peace workshops
  • Peer mentoring programs
  • Values, Influence, and Peers (VIP)
  • Lion’s Quest
  • Virtues Program
  • Choices into Action
  • The Employee Assistance Program (EAP)
  • Implementation of Accommodation in the Workplace and Safe Return to Work Program (BP 7360).
  • Ensure awareness of students, staff and community to understand the purpose and value of public/school barrier free parking spaces.
  • The Board partners with agencies such as the Children’s Aid Society, Community Living, Keystone Family and Youth Services, and Regional Support Services to provide ongoing training for staff and support for students through shared initiatives to increase awareness of attitudinal barriers affecting people with disabilities.
Prevention and Removal of Policy/Procedure  Barriers


Identified Barrier
Action Taken in 2008/09
On-going Intervention
No central procedure of identifying and addressing accessibility issues

Review of policy and procedures developed for Customer Service Standard.
As part of the Customer Service Standard implementation,  related policy and procedures must be developed by January 2010.


On-going Initiatives
  • as policies and procedures are reviewed by the board, the issue of accessibility should always be considered


Plans for 2009-10
Bluewater District School Board is working on ensuring compliance with the Customer Service Standards outlined in the Accessibility for Ontarians with Disabilities Act, 2005 (AODA).  The customer service standards must be implemented by January 2010 (Appendix A).

Additional information about the AODA and all of the compliance standards can be found at www.accessON.ca


Appendix  A
ONTARIO REGULATION 429/07
made under the
ACCESSIBILITY FOR ONTARIANS WITH DISABILITIES ACT, 2005
Made: July 25, 2007
Filed: July 27, 2007
Published on e-Laws: July 31, 2007
Printed in The Ontario Gazette: August 11, 2007
ACCESSIBILITY STANDARDS FOR CUSTOMER SERVICE
CONTENTS

Purpose and application
Effective dates
Establishment of policies, practices and procedures
Use of service animals and support persons
Notice of temporary disruptions
Training for staff, etc.
Feedback process for providers of goods or services
Notice of availability of documents
Format of documents
Commencement
Boards, Commissions, Authorities and Agencies
Broader Public Sector
Purpose and application
1.~~(1)~~This Regulation establishes accessibility standards for customer service and it applies to every designated public sector organization and to every other person or organization that provides goods or services to members of the public or other third parties and that has at least one employee in Ontario.
(2)~~In this Regulation,
“designated public sector organization means the Legislative Assembly and the offices of persons appointed on the address of the Assembly, every ministry of the Government of Ontario, every municipality and every person or organization listed in Schedule 1 or described in Schedule 2 to this Regulation; (organisation désignée du secteur public)
“provider of goods or services means a person or organization to whom this Regulation applies. (fournisseur de biens ou de services)
Effective dates
2.~~The accessibility standards for customer service apply to the designated public sector organizations on and after January 1, 2010 and to other providers of goods or services on and after January 1, 2012.
Establishment of policies, practices and procedures
3.~~(1)~~Every provider of goods or services shall establish policies, practices and procedures governing the provision of its goods or services to persons with disabilities.
(2)~~The provider shall use reasonable efforts to ensure that its policies, practices and procedures are consistent with the following principles:
1. The goods or services must be provided in a manner that respects the dignity and independence of persons with disabilities.
2. The provision of goods or services to persons with disabilities and others must be integrated unless an alternate measure is necessary, whether temporarily or on a permanent basis, to enable a person with a disability to obtain, use or benefit from the goods or services.
3. Persons with disabilities must be given an opportunity equal to that given to others to obtain, use and benefit from the goods or services.
(3)~~Without limiting subsections (1) and (2), the policies must deal with the use of assistive devices by persons with disabilities to obtain, use or benefit from the provider’s goods or services or the availability, if any, of other measures which enable them to do so.
(4)~~When communicating with a person with a disability, a provider shall do so in a manner that takes into account the persons disability.
(5)~~Every designated public sector organization and every other provider of goods or services that has at least 20 employees in Ontario shall prepare one or more documents describing its policies, practices and procedures and, upon request, shall give a copy of a document to any person.
Use of service animals and support persons
4.~~(1)~~This section applies if goods or services are provided to members of the public or other third parties at premises owned or operated by the provider of the goods or services and if the public or third parties have access to the premises.
(2)~~If a person with a disability is accompanied by a guide dog or other service animal, the provider of goods or services shall ensure that the person is permitted to enter the premises with the animal and to keep the animal with him or her unless the animal is otherwise excluded by law from the premises.
(3)~~If a service animal is excluded by law from the premises, the provider of goods or services shall ensure that other measures are available to enable the person with a disability to obtain, use or benefit from the providers goods or services.
(4)~~If a person with a disability is accompanied by a support person, the provider of goods or services shall ensure that both persons are permitted to enter the premises together and that the person with a disability is not prevented from having access to the support person while on the premises.
(5)~~The provider of goods or services may require a person with a disability to be accompanied by a support person when on the premises, but only if a support person is necessary to protect the health or safety of the person with a disability or the health or safety of others on the premises.
(6)~~If an amount is payable by a person for admission to the premises or in connection with a persons presence at the premises, the provider of goods or services shall ensure that notice is given in advance about the amount, if any, payable in respect of the support person.
(7)~~Every designated public sector organization and every other provider of goods or services that has at least 20 employees in Ontario shall prepare one or more documents describing its policies, practices and procedures with respect to the matters governed by this section and, upon request, shall give a copy of a document to any person.
(8)~~In this section,
“guide dog means a guide dog as defined in section 1 of the Blind Persons Rights Act; (chien-guide)
“service animal means an animal described in subsection (9); (animal dassistance)
“support person means, in relation to a person with a disability, another person who accompanies him or her in order to help with communication, mobility, personal care or medical needs or with access to goods or services. (personne de soutien)
(9)~~For the purposes of this section, an animal is a service animal for a person with a disability,
(a) if it is readily apparent that the animal is used by the person for reasons relating to his or her disability; or
(b) if the person provides a letter from a physician or nurse confirming that the person requires the animal for reasons relating to the disability.
Notice of temporary disruptions
5.~~(1)~~If, in order to obtain, use or benefit from a provider’s goods or services, persons with disabilities usually use particular facilities or services of the provider and if there is a temporary disruption in those facilities or services in whole or in part, the provider shall give notice of the disruption to the public.
(2)~~Notice of the disruption must include information about the reason for the disruption, its anticipated duration and a description of alternative facilities or services, if any, that are available.
(3)~~Notice may be given by posting the information at a conspicuous place on premises owned or operated by the provider of goods or services, by posting it on the provider’s website, if any, or by such other method as is reasonable in the circumstances.
(4)~~Every designated public sector organization and every other provider of goods or services that has at least 20 employees in Ontario shall prepare a document that sets out the steps to be taken in connection with a temporary disruption and, upon request, shall give a copy of the document to any person.
Training for staff, etc.
6.~~(1)~~Every provider of goods or services shall ensure that the following persons receive training about the provision of its goods or services to persons with disabilities:
1. Every person who deals with members of the public or other third parties on behalf of the provider, whether the person does so as an employee, agent, volunteer or otherwise.
2. Every person who participates in developing the provider’s policies, practices and procedures governing the provision of goods or services to members of the public or other third parties.
(2)~~The training must include a review of the purposes of the Act and the requirements of this Regulation and instruction about the following matters:
1. How to interact and communicate with persons with various types of disability.
2. How to interact with persons with disabilities who use an assistive device or require the assistance of a guide dog or other service animal or the assistance of a support person.
3. How to use equipment or devices available on the provider’s premises or otherwise provided by the provider that may help with the provision of goods or services to a person with a disability.
4. What to do if a person with a particular type of disability is having difficulty accessing the provider’s goods or services.
(3)~~The training must be provided to each person as soon as practicable after he or she is assigned the applicable duties.
(4)~~Training must also be provided on an ongoing basis in connection with changes to the policies, practices and procedures governing the provision of goods or services to persons with disabilities.
(5)~~Every designated public sector organization and every other provider of goods or services that has at least 20 employees in Ontario shall prepare a document describing its training policy, and the document must include a summary of the contents of the training and details of when the training is to be provided.
(6)~~Every designated public sector organization and every other provider of goods or services that has at least 20 employees in Ontario shall keep records of the training provided under this section, including the dates on which the training is provided and the number of individuals to whom it is provided.
Feedback process for providers of goods or services
7.~~(1)~~Every provider of goods or services shall establish a process for receiving and responding to feedback about the manner in which it provides goods or services to persons with disabilities and shall make information about the process readily available to the public.
(2)~~The feedback process must permit persons to provide their feedback in person, by telephone, in writing, or by delivering an electronic text by email or on diskette or otherwise.
(3)~~The feedback process must specify the actions that the provider of goods or services is required to take if a complaint is received.
(4)~~Every designated public sector organization and every other provider of goods or services that has at least 20 employees in Ontario shall prepare a document describing its feedback process and, upon request, shall give a copy of the document to any person.
Notice of availability of documents
8.~~(1)~~Every designated public sector organization and every other provider of goods or services that has at least 20 employees in Ontario shall notify persons to whom it provides goods or services that the documents required by this Regulation are available upon request.
(2)~~The notice may be given by posting the information at a conspicuous place on premises owned or operated by the provider, by posting it on the provider’s website, if any, or by such other method as is reasonable in the circumstances.
Format of documents
9.~~(1)~~If a provider of goods or services is required by this Regulation to give a copy of a document to a person with a disability, the provider shall give the person the document, or the information contained in the document, in a format that takes into account the person’s disability.
(2)~~The provider of goods or services and the person with a disability may agree upon the format to be used for the document or information.
Commencement
10.~~This Regulation comes into force on January 1, 2008.
SCHEDULE 1
BOARDS, COMMISSIONS, AUTHORITIES AND AGENCIES
1. Agriculture, Food and Rural Affairs Appeal Tribunal.
2. Agricorp.
3. Alcohol and Gaming Commission of Ontario.
4. Algonquin Forestry Authority.
5. Assessment Review Board.
6. Board of negotiation continued under subsection 27 (1) of the Expropriations Act.
7. Cancer Care Ontario.
8. The Centennial Centre of Science and Technology.
9. Child and Family Services Review Board.
10. College Compensation and Appointments Council.
11. Each community care access corporation as defined in section 1 of the Community Care Access Corporations Act, 2001.
12. Consent and Capacity Board.
13. Conservation Review Board.
14. Criminal Injuries Compensation Board.
15. Crown Employees Grievance Settlement Board.
16. Custody Review Board.
17. Deposit Insurance Corporation of Ontario.
18. Echo: Improving Women’s Health in Ontario.
19. Education Quality and Accountability Office.
20. Environmental Review Tribunal.
21. Financial Services Commission of Ontario.
22. Financial Services Tribunal.
23. Fire Marshal's Public Fire Safety Council.
24. Fire Safety Commission.
25. Greater Toronto Transit Authority.
26. Greater Toronto Transportation Authority.
27. Health Professions Appeal and Review Board.
28. Health Professions Regulatory Advisory Council.
29. Health Services Appeal and Review Board.
30. Human Rights Tribunal of Ontario.
31. Landlord and Tenant Board.
32. Legal Aid Ontario.
33. Licence Appeal Tribunal.
34. Liquor Control Board of Ontario.
35. Each local health integration network as defined under section 2 of the Local Health System Integration Act, 2006.
36. McMichael Canadian Art Collection.
37. Metropolitan Toronto Convention Centre Corporation.
38. Niagara Escarpment Commission.
39. Niagara Parks Commission.
40. Normal Farm Practices Protection Board.
41. Office of the Employer Adviser.
42. Office of the Worker Adviser.
43. Ontario Civilian Commission on Police Services.
44. Ontario Clean Water Agency.
45. Ontario Educational Communications Authority.
46. Ontario Electricity Financial Corporation.
47. Ontario Energy Board.
48. Ontario Farm Products Marketing Commission.
49. Ontario Film Review Board.
50. Ontario Financing Authority.
51. Ontario Food Terminal Board.
52. Ontario French-language Educational Communications Authority.
53. Ontario Health Quality Council.
54. Ontario Heritage Trust.
55. Ontario Highway Transportation Board.
56. Ontario Human Rights Commission.
57. Ontario Infrastructure Project Corporation.
58. Ontario Labour Relations Board.
59. Ontario Lottery and Gaming Corporation.
60. Ontario Media Development Corporation.
61. Ontario Mental Health Foundation.
62. Ontario Municipal Board.
63. Ontario Northland Transportation Commission.
64. Ontario Parole and Earned Release Board.
65. Ontario Pension Board.
66. Ontario Place Corporation.
67. Ontario Police Arbitration Commission.
68. Ontario Racing Commission.
69. Ontario Realty Corporation.
70. Ontario Review Board.
71. Ontario Securities Commission.
72. Ontario Special Education Tribunal (English).
73. Ontario Special Education Tribunal (French).
74. Ontario Tourism Marketing Partnership Corporation.
75. Ontario Trillium Foundation.
76. Ottawa Congress Centre.
77. Owen Sound Transportation Company.
78. Pay Equity Hearings Tribunal.
79. Pay Equity Office.
80. Province of Ontario Council for the Arts.
81. Public Service Grievance Board.
82. Royal Ontario Museum.
83. St. Lawrence Parks Commission.
84. Science North.
85. Smart Systems for Health Agency.
86. Social Assistance Review Board.
87. Social Benefits Tribunal.
88. Soldiers’ Aid Commission.
89. Trillium Gift of Life Network.
90. Walkerton Clean Water Centre.
91. Workplace Safety and Insurance Appeals Tribunal.
92. Workplace Safety and Insurance Board.
SCHEDULE 2
BROADER PUBLIC SECTOR
1. Every district school board as defined in section 1 of the Education Act.
2. Every hospital as defined in section 1 of the Public Hospitals Act.
3. Every college of applied arts and technology established under the Ontario Colleges of Applied Arts and Technology Act, 2002.
4. Every university in Ontario, including its affiliated and federated colleges, that receives operating grants from the Government of Ontario.
5. Every public transportation organization in Ontario, including any municipally operated transportation services for persons with disabilities, that provides services for which a fare is charged for transporting the public by vehicles that are operated,
i. by, for or on behalf of the Government of Ontario, a municipality, a local board of a municipality or a transit or transportation commission or authority,
ii. under an agreement between the Government of Ontario and a person, firm, corporation, or transit or transportation commission or authority, or
iii. under an agreement between a municipality and a person, firm, corporation or transit or transportation commission or authority.



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