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UNITED FOR A BARRIER-FREE ONTARIO
November 5, 2012
1. THE NEWS
As a positive step, on October 31, 2012 the McGuinty Government announced a new streamlined process for developing new accessibility standards, and for reviewing existing accessibility standards under the Accessibility for Ontarians with Disabilities Act. It has decided to consolidate all this activity in the hands of one permanent body, the Accessibility Standards Advisory Council (ASAC). ASAC is established under section 31 of the AODA. We set out section 31 of the AODA below.
Before this reform, each proposal for an accessibility standard was developed by a different Standards Development Committee. Each Standards Development Committee was appointed to address only one economic sector or one area of accessibility barriers that impede persons with disabilities. Below we set out the announcement about this new development, that we received by an October 31, 2012 letter from Ellen Waxman, the Assistant Deputy Minister of Community and Social Services responsible for the Accessibility Directorate of Ontario.
2. PLEASE CONSIDER APPLYING TO SERVE ON ASAC
We encourage everyone to consider applying for a position on the new and improved ASAC. You must apply by November 27, 2012, which is fast approaching.
Please widely circulate this announcement. Encourage others to apply for positions on the revised ASAC. We also urge the McGuinty Government to widely publicize this new initiative, and the opportunity to apply for positions on the new and improved ASAC. Apply for a position on ASAC on line.
3. A GOOD STEP FORWARD
We commend the McGuinty Government for taking this step. We consider this as something of a victory for us.
Why is this an improvement? There are several reasons:
* It helps ensure that there is consistency among all proposals for accessibility standards that are developed or reviewed in the future. We learned from disability sector representatives who sat on previous Standards Development Committees that they often did not know what their counterparts on other Standards Development Committees were proposing. This was because the Government did not bring them all together to learn from each other.
* It helps let those working on developing accessibility standards get more experience and expertise as they progress.
* It gives the Accessibility Standards Advisory Council (ASAC) a more significant role under the AODA.
* Under the AODA, when ASAC works on developing accessibility standards, it will have to make its minutes of its meetings public. Therefore, it will be easier for us and the public to monitor. In the past, ASAC was not required to make its meeting minutes public.
4. AN ISSUE WE HAVE BEEN RAISING
Since shortly after the AODA was enacted in 2005, we started to campaign to strengthen and improve the process for developing accessibility standards in Ontario. For example, in the 2007 election, we secured commitments from all three major Ontario political parties to improve that process and to make it fairer for persons with disabilities. You can review the major political parties’ 2007 election commitments to us on the AODA.
In 2009, two years after the 2007 election, we made recommendations to the Charles Beer Independent Review of the AODA. Our proposals called for the reform of the way that accessibility standards are developed under the AODA. In 2010, two years ago the Charles Beer Independent Review of the AODA made good recommendations pointing in the direction we had urged. One of the Charles Beer AODA Independent Review’s major recommendations was that all future accessibility standards should be developed by a single, permanent body that is independent of the Ontario Government.
Since The Charles Beer Independent Review’s Final Report was made public in May, 2010 we have been campaigning for over two years to get the McGuinty Government to implement its Final Report. This new Government announcement is an important and commendable, though long-overdue step in that direction.
5. WHAT THE GOVERNMENT MUST NOW DO TO MAKE THIS NEW REFORM MEANINGFUL
For this new reform to be truly meaningful, the McGuinty Government must now take two additional steps. These are steps that we have been urging for quite some time.
First, the Government should at long last conduct its long-overdue, promised public consultation on which new accessibility standards to develop. Before year’s end, the Government should announce what the next new accessibility standards will be. Unless the McGuinty Government identifies the next new accessibility standards to be developed, all that ASAC will have to do in the next four years in the arena of accessibility standards is to review the existing Customer Service Accessibility Standard. A major reform to the process for developing accessibility standards was not needed for that single task.
The AODA requires Ontario to become fully accessible to all persons with disabilities by 2025. It requires the minister responsible for the AODA (now the Minister of Community and Social Services John Milloy) to set develop, enact and enforce all the accessibility standards that are needed to achieve this goal. Section 7 of the AODA requires this:
“7. The Minister is responsible for establishing and overseeing a process to develop and implement all accessibility standards necessary to achieving the purposes of this Act.”
To date, the McGuinty Government has enacted accessibility standards designed to address new barriers in the areas of customer service, transportation, employment, and information and communication. It is long overdue in keeping its August 19, 2011 promise to promptly enact a Built Environment Accessibility Standard that it says will only address new barriers in the built environment. It has yet to develop accessibility standards to comprehensively address removal of existing barriers in any of those areas.
More new accessibility standards are needed to meet the requirement of section 7 of the AODA. The Government has yet to announce any specific plans to develop accessibility standards to address barriers, new or old, in any other sector or area of Ontario’s economy.
We have been urging the McGuinty Government for months and months to announce the next accessibility standards that it will develop. We have been campaigning for it to choose three areas for the next accessibility standards, namely accessibility to health care, to education at all levels, and to residential accommodation (housing). In his August 19, 2011 letter to the AODA Alliance in the 2011 Ontario election, Premier McGuinty promised to consult with us and others on which next accessibility standards to enact. A year and a quarter later, with a spring election quite possible, the McGuinty Government has not taken the simple and obvious step of announcing a public consultation on which next accessibility standards to develop under the AODA, much less has it actually chosen which new accessibility standards it will develop next. Learn more about our campaign to get the McGuinty Government to announce the next accessibility standards it will develop.
Second, to fully live up to the spirit of the Charles Beer recommendations, it is important for the Government to take active steps to ensure that ASAC operates at arms length from the Government and is fully independent of the Government.
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1. MORE BACKGROUND
To get Ontario to achieve full accessibility for persons with disabilities by 2025, the AODA requires the Government to develop, enact and effectively enforce all the accessibility standards needed to cover all the barriers that Ontarians with disabilities face. Under the AODA the Government is required to appoint a “Standards Development Committee” to develop each new accessibility standards that it wants created. For example, after the AODA was first enacted, the Government commendably appointed five Standards Development Committees, one to develop recommendations for accessibility standards in each of five important areas, customer service, the built environment, employment, transportation, and information and communication.
In 2009, with four years of experience under that system, it became clear that there were problems with how it was working. That there were such problems was understandable. Ontario was learning from its front-line experience in this new area.
In 2009, the AODA required the McGuinty Government to appoint an Independent Review of the AODA. This Independent Review was mandated to report on how well the AODA was working after four years, and to make recommendations on how to improve it.
In June 2009, the Government appointed Charles Beer to conduct this Independent Review. Mr. Beer commendably consulted many (including us). Among those with whom he spoke were members of the various Standards Development Committees. From his consultations he learned about problems with how the system was working. He got good ideas on how to fix it.
We submitted a detailed brief to the Charles Beer Independent Review on December 11, 2009. It was full of recommendations for reform. Our brief included, among other things, proposals to improve the process for developing accessibility standards in Ontario.
In our brief we recommended that the Government should create an arms-length body, to advise on all accessibility standards to be developed under the AODA. Our December 11, 2009 brief to the Charles Beer Independent Review of the AODA.
To his credit, Mr. Beer accepted a number of our ideas. He recommended that an independent body should be appointed to develop future accessibility standards, along the lines of the Access Board that is established in the United States under the Americans with Disabilities Act.
We set out below the key passages from the Charles Beer Independent Review’s Final Report. To see the entire 2010 Final Report of the Charles Beer Independent Review of the AODA.
In 2010, we endorsed most of the Charles Beer Independent Review’s report, including this recommendation. However, we urged the Government not to amend the AODA in order to implement it. We did not and now do not want any political party re-opening any provisions of the Accessibility for Ontarians with Disabilities Act at the Legislature. We consider that legislation sacrosanct.
Thus, we have urged the McGuinty Government to do as much as it can to implement this and any other recommendations of the 2010 Final Report of the Charles Beer Independent Review of the AODA by actions that don’t require any amendment to the AODA itself. We commend the McGuinty Government for finding a creative way to do so here. We understand that it plans to cross-appoint any members of ASAC as constituting any and all future Standards Development Committees under the AODA.
This new announcement of the reforms to ASAC was foreshadowed earlier this year. In her May 24, 2012 speech at a conference in Toronto on accessible information technology hosted by the Ontario College of Art and Design University, Ellen Waxman, Assistant Deputy Minister responsible for implementation of the AODA, announced in general terms that the Government was expected to implement a new regime for developing accessibility standards under the AODA. Ms. Waxman’s remarks included:
“• From a public policy perspective, the process was considered leading edge and innovative as it brought all interests to the table through a consensus-building approach to develop the standards
• However there were many challenges in this process. In fact, the first independent review of the AODA in 2010, recommended the current process be replaced with one committee or board that would oversee the development of any future standards and the reviews of existing ones
• We are hoping to implement a new structure in the near future before any new standards are developed or reviews conducted of existing ones.”
Later, under the heading “What’s Next,” her remarks included:
“Establishment of new process for developing Accessibility Standards”
And still later:
“• We will be establishing new processes and structures for developing accessibility standards in the future.”
2. EXCERPT FROM THE OCTOBER 31, 2012 LETTER TO THE AODA ALLIANCE AND OTHER STAKEHOLDERS, FROM ELLEN WAXMAN, ASSISTANT DEPUTY MINISTER OF COMMUNITY AND SOCIAL SERVICES RESPONSIBLE FOR THE ACCESSIBILITY DIRECTORATE OF ONTARIO
“In response to recommendations made by Mr. Charles Beer in the first independent review of the AODA, the government is streamlining and strengthening the standards development process. To do this, the role of the ASAC (i.e. Accessibility Standards Advisory Council) will be expanded to include the work of an SDC (i.e. Standards Development Committee). This one body will be responsible for advising the Minister on issues related to accessibility and for developing proposed accessibility standards and as well as reviewing existing ones.
ASAC will be made up of a Chair, seven members from the disability community and six members from obligated sectors. This will allow ASAC to provide the government with diverse and meaningful advice on how accessibility impacts the lives of all Ontarians, our businesses and economic prosperity.
Under the AODA, a mandated review of each accessibility standard is required within five years of enactment. The Customer Service Standard was enacted in 2008 and will be the first accessibility standard required to be reviewed by 2013 by an SDC.
A vacancy advertisement for ASAC has been posted on the Public Appointments Secretariat (PAS). The Ontario Government is looking for private sector representatives and disability representatives who want to play a leadership role in improving accessibility for people with disabilities and help organizations meet the requirements of the AODA and accessibility standards. I encourage you to apply or send this to others who may be interested. Interested applicants should apply for membership on the ASAC through the Public Appointments Secretariat website http://www.pas.gov.on.ca/scripts/en/upcomingVac.asp no later than November 27, 2012.
Improving our standards development and review process will help us get better value for money and improve our efficiency, transparency, accountability and civic engagement.
For more information about the AODA visit www.ontario.ca/AccessON<http://www.ontario.ca/AccessON or to apply to the Council, visit the Public Appointments Secretariat website http://www.pas.gov.on.ca/scripts/en/upcomingVac.asp .
If you require further assistance, please contact ASAC-SDC@ontario.ca<mailto:ASAC-SDC@ontario.ca> or call the ServiceOntario Contact Centre at 1-866-515-2025 (TTY Toll-Free: 1-800-268-7095).”
3. SECTION 31 OF THE AODA
“Accessibility Standards Advisory Council
31. (1) The Minister shall establish a council to be known in English as the Accessibility Standards Advisory Council and in French as Conseil consultatif des normes d’accessibilité. 2005, c. 11, s. 31 (1).
(2) A majority of the members of the Council shall be persons with disabilities. 2005, c. 11, s. 31 (2).
Remuneration and expenses
(3) The Minister may pay the members of the Council the remuneration and the reimbursement for expenses that the Lieutenant Governor in Council determines. 2005, c. 11, s. 31 (3).
(4) At the direction of the Minister, the Council shall advise the Minister on,
(a) the process for the development of accessibility standards and the progress made by standards development committees in the development of proposed accessibility standards and in achieving the purposes of this Act;
(b) accessibility reports prepared under this Act;
(c) programs of public information related to this Act; and
(d) all other matters related to the subject-matter of this Act that the Minister directs. 2005, c. 11, s. 31 (4).
(5) At the direction of the Minister, the Council shall hold public consultations in relation to the matters referred to in subsection (4). 2005, c. 11, s. 31 (5).
(6) The Council shall give the Minister such reports as the Minister may request. 2005, c. 11, s. 31 (6).”
4. EXCERPTS FROM THE 2010 FINAL REPORT OF THE CHARLES BEER INDEPENDENT REVIEW OF THE FIRST FOUR YEARS OF THE IMPLEMENTATION OF THE ACCESSIBILITY FOR ONTARIANS WITH DISABILITIES ACT
The Charles Beer Independent Review’s Final Report included the following excerpts:
1. “As part of my consultations, I met with senior officials of the United States Access Board in Washington, DC. The Access Board was established in 1973 to support the Architectural Barriers Act enacted in 1968. The board’s mandate evolved over time including significant changes introduced with the enactment of the Americans with Disabilities Act (ADA) in 1990.
Although there are many differences between the accessibility legislative framework in the U.S. and the AODA, there are general principles and best practices that can be applied to Ontario’s approach to standards development and review. For example:
• an inclusive process that incorporates extensive involvement of the disability community and the obligated sectors on an ongoing basis
• a transparent process
• a recognized role and process for establishing technical and sectoral committees, and
• a permanent accessibility board.
For more than 30 years, the U.S. model has been successful in cultivating a group of individuals who have built a significant and perhaps unique level of knowledge and expertise. Over the decades, the board’s responsibilities and mandate has changed. Today, an important part of the board’s role is to monitor developments nationally and internationally with respect to accessibility as well as the body of knowledge that is constantly evolving.
The board has been effective in bringing together key players from the disability community, government, the broader public sector and private industry. Its structure and process ensures broad public policy input from all sectors, coupled with knowledgeable technical and sectoral expertise. The board plays an important role in enhancing public awareness about the need for increased accessibility in the United States.”
2. “Findings and Recommendations: Establish the Ontario Accessibility Standards Board It is clear that changes to the standards development process are needed. This is the opportune time to reflect on the strengths and challenges of the process that was undertaken to develop the standards and determine what is necessary to achieve the goals of the legislation going forward.
Strengths of the Standards Development Process
The task of the Independent Reviewer is to impress upon the government of Ontario the value of the work that has been done, but at the same time to propose ways in which the value of that work can be enhanced, both in itself and in the eyes of those who behold it from all sides.
Written Brief, Community Living Association of Ontario
The cornerstone of the AODA legislation is the development of accessibility standards through an inclusive stakeholder process. It is widely appreciated that the AODA process of creating standards through committees involving the disability community, the obligated sectors and representatives of government was innovative and groundbreaking. Countless hours and untold effort were expended by the many individuals involved in developing standards. They worked to the best of their abilities to fulfil the promise of the legislation. An inclusive process is a unique and positive feature that has been endorsed as important and necessary by most stakeholders.
The process, as implemented, was well intended but proved to be challenging as a result of a number of factors. Specifically:
• The complexity of much of the subject matter in terms of its technical nature.
A lack of sufficient access to technical expertise and the lack of knowledge of best practices led some to believe that the proposed standards were ill-defined. Many of those involved in the process believe that the make-up of the committees did not adequately reflect the knowledge and expertise required to develop workable standards.
Good public policy has taken a back seat to timetables. We recommend that no other standards be passed into regulations until the issues identified are addressed and reconciled. The absence of a good and thorough policy approach to the standard development process will undermine everyone’s efforts to achieving accessibility.
Written Brief, Association of Municipalities of Ontario
• The absence of central coordination, direction and an underlying public policy framework supporting the standards initiative.
There was no overarching coordination across the standards committees and no centralized clearinghouse to vet standards, align timelines and harmonize the provisions. The parallel processes resulted in a disconnect between each set of requirements and made it difficult to determine gaps, overlaps, discrepancies, priorities, costs and training requirements.
• Disagreement about the timelines for developing the proposed standards.
The length of time it took to complete the standards was the source of significant friction among committee members. Some believed that the process did not move quickly enough and that the standards took too long to develop. Others felt that the timelines were too aggressive and that more time was needed to consult with the obligated sectors to clarify the costs and impacts of various options.
• Disagreement about the timeframes for achieving accessibility contained in the proposed standards.
Another cause of friction was the push by some disability representatives for many of the proposed requirements to take effect over a much shorter period than the 20 year timeline in the legislation. The tighter deadlines led to increased worries about costs.
• Lack of information about compliance and enforcement mechanisms.
The government has not announced the compliance and enforcement framework for the AODA. Many felt that this contributed to an atmosphere of confusion and uncertainty during the standards development process.
• The lack of credible and comprehensive cost/benefit analyses to assess the separate and cumulative impact of the standards.
Uncertainty with respect to costs, feasibility and the cumulative impact of the standards was a major concern raised by a number of stakeholders.
The challenges noted above were intensified by the changes that were introduced to the standards development process in late 2007, specifically:
• A change in the composition of the standards development committees with 50 per cent of members to be persons with disabilities or representatives of the disability community
• A change in the role of government waiving the right of ministries’ representatives on the committees to vote.
These measures created a number of unintended results. They led to confusion about committee processes (including voting and decision-making practices), contributed to delays and increased the size of the committees (in some cases close to 50 members). With the loss of a voting role, the government members became little more than observers. The timing of the changes worsened the problems as some committees were well into their work when the structure and membership were altered. For example, the changes came after one committee had already released its proposed standard for public review.
Collectively, the changes caused much frustration and stirred up emotions among some participants. This significantly altered the dynamics of the process, moving it from an atmosphere of consensus-building to one of negotiation, creating, in some cases, an “us versus them” dynamic.
While it is important to acknowledge these shortcomings, I believe that we are now at a point when the discussion needs to shift and move forward.
Virtually everyone consulted about the standards development committee process identified areas for improvement. Although there was not agreement on every issue, there was overall consensus that the process would have benefited from:
• A clearer governance and accountability framework articulated at the outset – including unambiguous terms of reference, transparent voting procedures and well-defined roles for the different players (e.g., chair, consultants, ADO, ministry representatives)
• Clarity on the role of government and the public interest in the decision-making model
• Explicit provincial public policy and principles to guide the standards development committee process
• More careful consideration of the composition of the committees to support a balance of perspectives reflecting the governance model, terms of reference and expertise required
• Credible background documents to support the process drawing on research about evidence-based and best practices in Ontario and other jurisdictions
• Engagement of appropriate technical and sectoral expertise (i.e., technical resource and sector subcommittees) to support the committees in their deliberations
• More transparent timelines for the development of the standards and ongoing assessment of the feasibility of timelines, and
• Establishment of a formal orientation and training program for committee members.
At the outset let me reiterate that the process under the AODA was new, innovative and groundbreaking. It was to be expected that there would be challenges. However, in my opinion tinkering with the current process will not be enough. Nor do I believe we can return to the traditional government regulation-making process, which may or may not involve consultations. A number of fundamental changes are needed, including replacing the standards development committees. However, any new approach to standards development must continue to respect the spirit and intent of the AODA.
I have reached the conclusion that an arm’s-length advisory body with ongoing responsibilities is required to bring greater focus, experience and expertise to the standards development process. What is needed going forward is focused, continuing attention by a dedicated group that can build the expertise required to review and develop credible accessibility standards.
Amendments to the AODA will be required as I do not believe these changes can be accomplished under the current framework in the legislation.
Determining the governance model for the Ontario Accessibility Standards Board has been a particular challenge. In fact, many of the issues raised in the consultations on the standards development committee process related to governance questions. I have strived to respect the principle of inclusiveness in the AODA, while addressing the key issues that were raised about the current process.
I began with a review of the language in section 1, the purpose clause, of the AODA.
Recognizing the history of discrimination against persons with disabilities in Ontario, the clause:
• sets the goal for an accessible Ontario by 2025 through the development and implementation of accessibility standards, and
• requires the involvement of persons with disabilities, the government of Ontario and of representatives of industries and of various sectors of the economy in the development of those standards.
I have concluded that for the standards development process to be effective going forward, the best approach is to ensure the inclusion of all the key players (the disability community, the provincial government and the other obligated sectors) from the beginning.
The board members should be experienced individuals, able to bring the views of their sectors to the table but also practised in consensus-building. I see the board process first and foremost as a collaborative one. The chair should be a high-profile individual with standing and credibility in the province who is highly skilled in facilitation and has experience working with boards in complex environments.
Membership on the board would consist of 15 members, including the chair, who would be non-voting. Persons with disabilities or their representatives would have seven members (50 per cent representation) on the board, consistent with the government’s commitments made in 2007 for the standards development committees. The obligated sectors (broader public, private and not-for-profit) would be represented by six senior and experienced individuals knowledgeable about their own sectors and versed in government structures and processes. The provincial government would be represented on the board by a senior public servant. Various ministries would be involved through sectoral and technical committees.
I appreciate that the proposed membership may at times introduce tension in the board’s decision-making process. I believe, however, that with an experienced chair and the commitment of board members to the goals of the AODA, this model can work.
The following outlines the purpose, mandate, and roles and responsibilities of the new board.
Purpose: To review and develop accessibility standards under the AODA and provide recommendations to the Minister Responsible for Accessibility.
Mandate: To build expertise on accessibility standards development; conduct research and monitor national and international accessibility developments; conduct five-year reviews of accessibility standards as mandated by the AODA; advise the Minister Responsible for Accessibility on the need for new standards; and, on the direction of the minister, develop and harmonize proposed new standards and integrate them with other relevant legislation and government policy.
Roles and Responsibilities: Similar to those outlined for the standards development committees in Part III (Accessibility Standards) of the AODA, with necessary modifications.
Details on the roles and responsibilities of the new board would be articulated in proposed amendments to the AODA and in a memorandum of understanding between the board and the Minister Responsible for Accessibility and the ADO. These would include:
• Review and revise accessibility standards in accordance with the AODA through an inclusive process, and submit proposed standards to the government for consideration as regulations
• Advise the minister on the need to develop new standards
• At the direction of the minister, develop new standards through an inclusive process, and submit proposed standards to the government for consideration as regulations
• Support the ADO in the preparation of guidelines and other reference materials and in promoting partnerships to share knowledge and best practices, to further the implementation of the standards
• Develop a transparent and inclusive public consultation process, involving persons with disabilities, to support the review of both existing and proposed new standards
• Establish appropriate technical and sectoral committees for the review and development of standards through a process of subcommittees reporting to the board, and establish procedures to guide the subcommittees
• Ensure harmonization of the standards
• Build expertise on the development and review of accessibility standards.
Structure of Board
The composition of the board would consist of:
• the chair (non-voting)
• seven representatives from among persons with disabilities or their representatives
• six representatives from the obligated sectors, and
• one provincial government representative (a senior public servant).
Selection and Appointment of Members
The chair and members would be appointed by the government through Order-in-Council. The government should develop selection criteria and recruitment strategies in consultation with stakeholders.
The board would be supported by an executive director and a small, dedicated staff.
Consideration should be given to transferring employees from the ADO to ensure continuity. At the direction of the board, the executive director would be responsible for operational activities, budget allocations, stakeholder engagement and liaising with the ADO. Part of the role of the secretariat would be to ensure that the board members from the disability community receive appropriate support.
The board would be required to establish technical and sectoral committees to support the review of existing standards and development of new standards. I see the role of these committees as critical in advising the board on the content and form of the standards. The work of the committees must be transparent and accessible to the public and include input from the board’s consultation process.
The board would need to establish a process for the committees including mandates, criteria for membership and the term of appointments.
Accountability and Reporting
The board would be accountable to the minister and report to the minister on a regular basis. The board would be required to submit an annual report to the minister.
Timeframe for Creating Board
The first standard on customer service came into force on January 1, 2010 for the provincial government and the broader public sector. The government is now completing its review of three of the remaining four standards (information and communication, employment, and transportation) and I expect it to be preparing regulations for each. The built environment standard is still in the committee stage. As I have recommended above, it is imperative for the government to ensure that all five standards are fully harmonized. Once the five accessibility standards have become law and the AODA moves to the next phase of implementation, the new Ontario Accessibility Standards Board should commence its work.
I, therefore, recommend that:
The AODA be amended to establish an arm’s-length advisory body — the Ontario Accessibility Standards Board — to review and develop accessibility standards — replacing the standards development committee process.
Interim Recommendations to Begin Transition
Because the recommendation for a new board would require amendments to the AODA, it may take some time for the changes to take effect and the board to be established. I am therefore recommending the appointment of a director under the existing legislative framework to achieve some necessary interim steps. The director could be provided with sufficient authority to enable him or her to start the process of establishing the new board, until the proposed amendments to the AODA are considered by the legislature.”