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April 14, 2013


On March 25, 2013, the AODA Alliance submitted a brief to the Ontario Ministry of Municipal Affairs and Housing (MMH) on the Ontario Government’s fall 2012 proposed accessibility reforms to the Ontario Building Code. Below we set out the summary of our 19-page brief that is included in the brief’s introduction.

Download in MS Word format the text of the AODA Alliance’s March 25, 2013 brief on the Ontario Building Code, as well as the text of the five briefs by other organizations that we have endorsed.

Please let the Ontario Government know if you endorse our brief. You can email your support to this address:

Read the Ontario Government’s fall 2012 proposals for reforming the Ontario Building code’s accessibility provisions.

If you want more background, you can learn about the AODA alliance’s multi-year campaign to get the Ontario Government to enact a strong and effective Built Environment Accessibility Standard under the Accessibility for Ontarians with Disabilities Act.

The battle to get the perennially-deficient Ontario Building Code to effectively address accessibility needs of people with disabilities in the built environment goes has gone on for many years. See what our predecessor coalition, the Ontarians with Disabilities Act Committee was saying about this fully eleven years ago.

The same Ministry of Municipal Affairs and Housing was in substance asking the public about the same accessibility barriers in the built environment over a decade ago. That the Ontario Government is still so far behind on this issue is a matter of deep and abiding concern. That its 2012 proposals for reform fall so far short, and come only after so many years of inexcusable delays, is even more troubling.

On August 19, 2013, over one and a half years ago, during the 2011 Ontario election, Premier Dalton McGuinty promised that the Built Environment Accessibility Standard would be enacted “promptly.” On December 3, 2012, Kathleen Wynne promised the AODA Alliance that if she became Ontario’s premier, she would honour all of Premier McGuinty’s accessibility pledges, and would ensure that Ontario is on schedule for full accessibility by 2025, as the AODA requires.

The Liberal Government’s 2011 disability accessibility election pledges are set out in former Premier McGuinty’s August 19, 2011 letter to us.

Read Kathleen Wynne’s December 3, 2012 letter to the AODA Alliance.

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2. Summary of the AODA Alliance’s Submission

We commend the Ministry for consulting with the public on its proposed accessibility reforms to the Building Code. There is a pressing need for action to make the Building Code effective as a means to promote the accessibility of the built environment in Ontario.

For many years, the Ministry of Municipal Affairs and Housing (MMH) has had responsibility for ensuring that the Building Code’s accessibility provisions are strong, effective and up-to-date for decades. Despite this, the Building Code has been chronically inadequate and behind-the-times on the accessibility front.

In this brief we provide general feedback. We conclude that while several of the Government’s new proposals can be helpful as far as they go, they are woefully inadequate. They will not bring the Building Code up to date. They will clearly not ensure full accessibility of the built environment by 2025, even in the limited range of buildings that these proposed amendments address i.e. new buildings and the parts of existing buildings that undergo extensive renovations.

These proposals are far too limited in scope. They contain exemptions that are far too broad. These proposals do not accord with basic human rights principles. They leave organizations wide open to litigation under the Human Rights Code.

MMH has evidently not tried to achieve the requirements of the Accessibility for Ontarians with Disabilities Act i.e. achieving full accessibility by 2025. Instead, it has only tried to meet or exceed the requirements of other laws in other jurisdictions. That far more limited goal is inadequate to meet the legitimate accessibility needs of Ontarians with disabilities. It in effect abandons the Government’s commitment of full accessibility by 2025.

In this brief, we support the analysis and recommendations from certain organizations that advocate for equality. We also supplement those thoughtful submissions. Our failure to comment on any specific proposal should not be taken as an endorsement or approval of that proposal.

We also make recommendations that we summarize as follows:

1. All Building Code accessibility reforms should also be enacted as a built environment accessibility standard under the AODA.
2. Building Code reforms should effectively address removal of barriers in existing buildings that are not undergoing extensive renovations.
3. Building Code accessibility requirements should be made applicable to a wider range of renovations.
4. All accessibility requirements should be mandatory, not voluntary.
5. Building Code accessibility amendments should be expanded to cover all barriers in the final recommendations of the Built Environment Standards Development Committee.
6. Government should not set its built environment accessibility goals so low.
7. Excessively broad exemptions from accessibility requirements should be narrowed.
8. Far more accessible units should be required in new and redeveloped rental and condominium buildings.
9. Substantial added accessibility requirements should be set for all major high-traffic buildings.
10. Specific accessibility requirements should be strengthened.

In addition to the specific analysis in this brief, we here adopt and re-submit our October 4, 2012 brief on the Government’s proposed Public Spaces Accessibility Standard. That brief’s discussion and recommendations regarding the Government’s fall 2012 proposes for addressing barriers in public spaces outside the reach of the Building Code apply with full force to any comparable proposals that MMH is now considering to implement in the Building Code. AODA Alliance’s October 4, 2012 brief on the Government’s Proposed Public Spaces Accessibility Standard.

3. Endorsing Submissions by Other Equality-Seeking Organizations

Except where we call for stronger measures, we support the submissions to MMH on the proposed accessibility reforms to the Building Code by the Ms Society, Citizens with Disabilities Ontario (CWDO), the Canadian Hearing Society, Spinal Cord Injury Ontario, and the Ontario Human Rights Commission. In a number of areas, we would particularly go further than the Human Rights Commission. We similarly endorse concerns that the Quadrangle Architects organization has communicated to MMH, to the effect that certain of the Government’s proposed accessibility reforms to the Building Code are unclearly worded or otherwise insufficient.

By not here listing submissions by any other disability community organizations, we are not implying that we support or oppose any other submissions. We are simply identifying those submissions that we have received and have had an opportunity to review.