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January 17, 2024
Accessibility Advisory Committee Agenda January 17, 2024 Hybrid Electronic Meeting – 7:00 pm Main Committee Room For information related to accessibility requirements please contact: Committee Coordinator 905.420.4611 clerks@pickering.ca Members of the public may observe the meeting proceedings by viewing the livestream. Page 1.Review and Approval of Agenda T. Higgins 2.Disclosure of Interest T. Higgins 3.Approval of Minutes T. Higgins 3.1 October 18, 2023 Meeting Minutes 1 4.Presentations/Delegations 5.New Business 5.1 Welcoming new Members T. Higgins, All 7:05 5.2 Equity, Diversity and Inclusion Strategy Jaclyn SanAntonio, Clara Addo-Bekoe 7:10 5.3 Site Plans Review Isabelle Janton 7:20 8 5.4 DRT Service Update Councillor Maurice Brenner 7:50 5.5 Onley & Donovan AODA Review Reports Councillor Maurice Brenner 8:10 21 5.6 Creating an Accessibility Advisory Subcommittee – Re: building an Accessibility Orientation Symposium T. Higgins 8:30 6.Correspondence Accessibility Advisory Committee Agenda January 17, 2024 Hybrid Electronic Meeting – 7:00 pm Main Committee Room For information related to accessibility requirements please contact: Committee Coordinator 905.420.4611 clerks@pickering.ca 7. Other Business 8. AAC Member Roundtable Updates 9. Next Meeting – February 21, 2024 10. Adjournment Page 1 of 7 Minutes/Meeting Summary Accessibility Advisory Committee October 18, 2023 Electronic Meeting 7:00 pm Attendees: D. Currie S.Azhar B. Ferguson P. Milton M. Thorpe Ross C. Rudberg-Chin S. Snyders J. McLellan, Ajax-Pickering Board of Trade Councillor M. Brenner M. Murray, Manager, Community Services Administration I. Janton, Senior Planner – Site Planning T. Higgins, Accessibility Coordinator (Staff Liaison) J. Currie, Legislative Coordinator (Recording Secretary) Absent: A. Khan R. Rizvi Councillor M. Nagy Item/ Ref # Details & Discussion & Conclusion (summary of discussion) Action Items/Status (include deadline as appropriate) 1. Review and Approval of Agenda T. Higgins reviewed the agenda items. Agenda approved. 2. Disclosure of Interest No disclosures of interest were noted. 3. Approval of Minutes Moved by B. Ferguson Seconded by D. Currie That the Minutes of the September 18, 2023, meeting of the Accessibility Advisory Committee be approved. - 1 - Page 2 of 7 Item/ Ref # Details & Discussion & Conclusion (summary of discussion) Action Items/Status (include deadline as appropriate) Carried 4. Presentations/Delegations T. Higgins welcomed all in attendance to introduce themselves. 4.1 Recreation & Parks Master Plan Presentation – Marilou Murray M. Murray provided an overview of the Recreation and Parks Master Plan highlighting Pickering’s changing demographics and how the impact of issues pertaining to the pandemic are being addressed. The Community Engagement Strategy, including a city-wide survey, the dates of five focus group sessions, four Charrette’s, and a youth engagement partnership was shared with the Committee. M. Murray requested Committee Members to complete the online survey, to attend one of the community Charrette’s sessions, and to encourage community members to participate. M. Murray also requested that the Accessibility Advisory Committee select one Member to be its representative and attend one of the five focus group sessions. Discussion with the Committee Members ensued regarding: •the website updates occurring as required, when new information is available; •the Youth Survey and how it mirrors the regular survey, it is amended to exclude questions that may not apply to youth, such as taxes, and includes questions specific to youth activities and programs that would be of particular interest and what may be some barriers faced by youth in participation; •having sent the Catholic School Board invitations to participate in the Youth Focus Groups and that Community Services is waiting for a response; •the Recreation & Parks Master Plan forming its vision as it pertains to accessibility according to the feedback gathered from the planned Community Engagement; •additional engagement events being planned in both the East Shore and West Shore as well as other areas to accommodate a broader outreach and ensuring input from those unable to attend the scheduled focus group sessions and charrette’s; AAC Members to complete online survey and participate in the Community Engagement Strategy. - 2 - Page 3 of 7 Item/ Ref # Details & Discussion & Conclusion (summary of discussion) Action Items/Status (include deadline as appropriate) •the Recreation & Parks Master Plan being a robust, all- encompassing plan and it including 80-120 recommendations; •reaching out to Community Associations as part of the Public Engagement Plan; •Pickle Ball being included in the sport related focus groups; •going beyond minimum accessibility standards to meet the expectations of the City of Pickering, accounting for 1 in 5 individuals living with disabilities, the increasing number of seniors, an increase in mental health associated disabilities, and various invisible disabilities; and, •the benefits of parks and outdoor space in terms of tranquility. 5. New Business 5.1 Review of Site Plans File: 23-009270 – PLAN 40M2625 BLK 291 & PLAN 40M2631 I.Janton provided an overview of the pre-submission proposal for a proposed Catholic Elementary School at the intersection of Sapphire Drive, Hibiscus Drive and Burkholder Drive. Discussion ensued with Committee Members regarding: •the area for portables being a placeholder to accommodate future expansion and that ramps should be considered for accessibility; •whether the number of handicapped parking spaces could exceed the minimum requirement; •whether the proposed theater space was accessible; •the benefit to providing David Lepofski’s video “Accessibility Problems at Ryerson University Student Learning Centre” to developers in Pickering; https://www.youtube.com/watch?v=4oe4xiKknt0 •the presence of accessible areas in the site plan’s theater; •whether the Universal Washrooms are accessible; •whether having only one elevator meets accessibility standards, especially in the event of an emergency; - 3 - Page 4 of 7 Item/ Ref # Details & Discussion & Conclusion (summary of discussion) Action Items/Status (include deadline as appropriate) •an evacuation plan from the second floor for those living with a disability in the event of an emergency; and, •developers accounting for unique needs and demographics of the area they are proposing to build in. File: S 11/23 – 1355 Kingston Road I.Janton provided an overview of the Site Plan for proposed mixed use residential towers at Pickering Town Centre site. There will be three towers at 50-55 story’s, 1877 units, 785 m2 of commercial space, and includes underground parking. The application presented is submitted to address the stormwater management system, the construction of the towers will come at a later date. Discussion ensued with Committee Members regarding: •I. Janton providing cross section images of the stormwater management system; •there being public access to the private owned park area, •the number of units that will be designated as accessible units, •the accessibility needs of larger families and if the two-story units can accommodate them, •the historic lack of accessibility of underground parking in general and if this will be addressed, •inviting CentreCourt to attend a future meeting and inviting them to express in writing their accessibility vision for this property; •offering documents that provide an accessibility lens to CentreCourt, giving them insight to Pickering’s expectations; •the possibility of providing similar documents to all developers, and bringing this concept back to planning to build it into the application process; •providing a symposium or accessibility orientation, sharing the vision of Pickering’s expectations, and asking the developers to mirror this in their plans; •providing Pickering’s expectations prior to the Accessibility Advisory Committee review, allowing for early collaboration, noting that Pickering is asking for more than the legislated minimum Accessibility for Ontarians with Disabilities Act (AODA) and Ontario Building Code standards; •the orientation material being provided by the Accessibility Advisory Committee; T. Higgins to provide I. Janton with documents to provide CentreCourt along with AAC notes to developer. - 4 - Page 5 of 7 Item/ Ref # Details & Discussion & Conclusion (summary of discussion) Action Items/Status (include deadline as appropriate) •a motion to build an accessibility orientation style symposium at the pre-consultation stage of the application process; •developers site plan including a document outlining their vision of accessibility as it pertains to the submission; •the effectiveness of having conversations regarding accessibility earlier in the building application process, and how it is harder to change plans after approval, •adding a step including an accessibility orientation to the pre- consultation phase of site plan applications, Moved by B. Ferguson Seconded by C. Rudberg-Chin That representatives of the Accessibility Advisory Committee meet with the Planning Division of the City Development Department to discuss the methodology around site-planning approval, introducing the idea of a symposium to the pre consultation phase as well as requiring developers to include early documentation of their accessibility lens. Carried Further Discussion ensued with Committee Members regarding: •developers questioning steps that are not mandated; •clarification that should the new requirement be implemented it would only be applied to new developments; •the benefit of providing parameters at an early stage and creating a more collaborative process; •bringing this motion to Council to mandate the mentioned additional steps; and, •bringing the discussion of creating a subcommittee to the next agenda. 5.2 39th Annual Durham Regional Police Service (DRPS) Children’s Games – November 5th, 2023 T. Higgins provided an overview of the Annual Durham Regional Police Service (DRPS) Children’s Games being held November 5th, 2023 at 9am-1pm. Pickering has historically hosted the games at the Recreation Complex and has been a key partner with the Durham Police in helping support children with disabilities. T. Higgins to organize a meeting with AAC Members and Kyle Bentley, Director, City Development & Chief Building Official. - 5 - Page 6 of 7 Item/ Ref # Details & Discussion & Conclusion (summary of discussion) Action Items/Status (include deadline as appropriate) The 39th Annual DRPS Children’s Games will be held at the Durham College Sports Complex this year but will return to the Recreation Complex next year for the 40th Annual DRPS Children’s Games – 2024. The Accessibility Advisory Committee Members are strongly encouraged to attend. T. Higgins to send invitations with the event details to Council through their Executive Assistants. Discussion ensued among Committee Members regarding: •the suitability of the rebuilt Football Dome for the games; and, •the facilities being confirmed for next year’s event. 5.3 LEAD Project - Update T. Higgins provided a brief outline of the work that was done with the Abilities Centre on the LEAD Project. The LEAD Project document was provided, and Members are encouraged to review for discussion at the next committee meeting. AAC Members to review the LEAD Project document for discussion at the November 15, 2023 Committee Meeting. 6. Correspondence There were no items of correspondence. 7. Other Business T. Higgins announced T. Lyle-Gravlev and P. Milton’s resignation from the Accessibility Advisory Committee, thanking them for their work. J. McLellan suggested Stopgap.ca and the December 21, 2023, Business Compliance as items of discussion for the November 15, 2023 Meeting Agenda. T. Higgins to add two items to the November 15, 2023 Agenda. 8. AAC Member Roundtable Updates None 9. Next Meeting – November 15, 2023 10. Adjournment - 6 - Page 7 of 7 Item/ Ref # Details & Discussion & Conclusion (summary of discussion) Action Items/Status (include deadline as appropriate) Moved by C. Rudberg-Chin That the meeting be adjourned. Carried Meeting Adjourned: 9:08 pm - 7 - City Development Department Pickering Civic Complex | One The Esplanade | Pickering, Ontario L1V 6K7 T.905.420.4617 | F. 905.420.7648 | Toll Free 1.866.683.2760 | citydev@pickering.ca | pickering.ca October 30, 2023 Subject: Pre-submission Proposal – File Number S 14/23 Durham District School Board 1100 Azelea Avenue City of Pickering A pre-submission proposal for a future site plan application has been received by the City Development Department for the above-noted property. Proposal The applicant is proposing to develop the subject lands for a 2-storey Public Elementary School in the Lamoreaux Neighbourhood of Seaton with an approximate GFA of 6,300 square metres. The school will also include a Child Care Centre. Response Required By We are presently reviewing this plan in accordance with the City’s pre-submission proposal review process. Please forward your comments to my attention by November 29, 2023. We are only accepting digital copies of the submitted materials. Please find the submitted materials for your review at this link: https://cityofpickering.sharefile.com/d-s75ccab2d97d746a9884c1e9e178d746d If you require any additional materials that have not been provided, please advise. If you wish to discuss this matter, please contact me at 905.420.4660, extension 2091 or by email at ijanton@pickering.ca Regards, Isabelle Janton Senior Planner, Site Planning IJ:ij J:\Documents\Development\D-3900 Site Plans (S Applications)\2020-2029\2023\S14-23 DDSB - Seaton Elementary\Letters\Presub Agency Circulation 1st Sub.doc - 9 -- 8 - Dragonfly Ave n u e B u r k h o l d e r D riv e Azalea A v e n u e Skyridge Bouleva r d C a m e o S t r e e t Belcourt Stre e t Flore ntinePlace Cact u s C r e s c e n t HibiscusDrive S apphire Drive Sepi a S q u a r e T i g e rlily Tr a il Marathon Avenue Cari n a T e r r a c e PelicanTrail Fa l l H a r v e s t C r e s c e n t T a n g re e n T r a il PeterMatthewsDrive Citri n e S t r e e t Enc h a n t e d C r e s c e n t P uru s Path CeriseManor At h e n a P a t h Ap r i c o t L a n e Ki n g p e a k Cres c ent Orenda Street 1:4,000 SCALE:© The Corporation of the City of Pickering Produced (in part) under license from: © King's Printer, Ontario Ministry of Natural Resources. All rights reserved.; © His Majesty the King in Right of Canada, Department of Natural Resources. All rights reserved.; © Teranet Enterprises Inc. and its suppliers. All rights reserved.; © Municipal Property Assessment Corporation and its suppliers. All rights reserved. City DevelopmentDepartment Location MapFile:Applicant:Municipal Address: S 14/23 THIS IS NOT A PLAN OF SURVEY. Date: Oct. 25, 2023 ¯ E Durham District School Board1100 Azalea Ave SubjectLands L:\PLANNING\01-MapFiles\S\2023\S 14-23 Oak Ridges Seaton\S14-23_LocationMap.mxd - 9 - N PYLON SIGNAGE U N L O A D I N G ORDERING STATION/ MENU BOARD BI K E RA C K INTERNALLY LIT ENTRY PORTAL / HEIGHT RESTRICTION BAR EAR T H B I N GAR B A G E / REC Y C L E VEN T P I P E TIRE INFLATOR T H I S P A R K I N G W IL L B E B L O C KE D D U R I N G F U E L D E LI V E R I E S (E M P L O Y E E P A R K I N G ) 8 CH A N N E L CAN O P Y FI R E R O U T E FIRE RO U T E FI R E R O U T E PATIO AREA PEDESTRIAN SAFETY RAILING SEL F SUP P O R T ROO F LAD D E R MOP SINK A&W KITC H E N 103 A ELE C . ROO M 110 MWAT E R F I L T E R HWT COR R I D O R 105 STO R A G E 109 PAY POI N T 102 C/W H O MON I T O R OPE N FAC E COO L E R NOV E L T Y ICE - C R E A M CHE S T ( S ) OFF I C E 108 WOM E N ' S WRM . 107 B SAL E S ARE A 101 WAL K - I N COO L E R MEN ' S WRM . 107 A UNI V E R S A L WRM . 106 T E M P . G L A S S W A L L HUB DRA I N FLO O R REC E S S E D GRE A S E INT E R C E P T O R 18"x 3 6 " 18"x 3 6 " 18"x 3 6 " 18"x 4 8 " 18"x 4 8 " WAL K - I N FRE E Z E R (A& W ) A & W W A S T E S T A T I O N 18"x 3 6 " 18"x 3 6 " 1 8 " x 4 8 " 24"x 3 6 " 24"x 3 6 " 18"x 3 6 " 18"x 3 6 " 2 4 " x 3 6 " 2 4 " x 3 6 " 2 4 " x 3 6 " 1 8 " x 4 8 " 1 8 " x 4 8 " A&W SEA T I N G ARE A 104 (PR O P O S E D 2 2 S E A T S ) A & W C O N D I M E N T S T A T I O N A&W BAC K R O O M 103 B A&W P A N E L A B M L O T T O WAS T E A&W SER V I C E 103 A & W G U E S T F A C E P O P S T A T I O N 6FT O P E N C O O L E R SAN I M A X SAN E C O TAN K BAG I N B O X (A& W ) CO2 (SLU S H ) FUT U R E A & W PRE - C H I L L E R (PH A S E 2 ) B A G I N B O X (S L U S H ) FRAN K E PEDESTRIAN SAFETY RAILING ISSUED CLIENT SEAL DESCRIPTIONNO. DATE ISSUE DESCRIPTION01 MMM DD/YY REVISION REVISION DESCRIPTIONMMM DD/YY1 DRAWING NO. DATE CHECKEDDRAWN SCALE PROJECT NO. DRAWING TITLE PROJECT 2023-07-12 60293 fax (905)337-1986(905)337-9800 2660 Sherwood Heights Dr. Suite 200, Oakville, Ontario, L6J 7Y8 www.kpaularchitect.com T O R O N T O • V A N C O U V E R • O R L A N D O K P A U L A R C H I T E C T I N C. DIMENSIONS AND CONDITIONS TO BE VERIFIED ON THE PREMISES J.NORTON 1:150 A Suncor business PROPOSED SITE LAYOUT NOTES SP1 @ PICKERING PARKWAY 1800 BROCK ROAD - 10 - - 11 - - 12 - - 13 - Qe Qe Qe Qe Qe W W W W W W W W W W W W W W W W W W W W W W W W W W W W W W W W W SELF SUP P O R T ROO F LAD D E R MOP SINK 24"x 3 6 " 24"x3 6 " 24"x 3 6 " 18"x4 8 " 18"x 4 8 " 18"x 3 6 " 18"x 3 6 " 18 " x 3 6 " 18"x 3 6 " 18"x 4 8 " 18 " x 3 6 " A & W W A S T E S T A T I O N A & W G U E S T C O N N E C T S T A T I O N PRO P O S E D TEN A N T HWT ON PLA T F O R M ABO V E 18"x3 6 " 18"x 3 6 " A & W C O N D I M E N T S T A T I O N MWAT E R F I L T E R 18"x 3 6 " 18"x 3 6 " HWT ON PLA T F O R M ABO V E C/W H O MON I T O R U/C SAFE OPE N FAC E COO L E R NOV E L T Y ICE - C R E A M CHE S T ( S ) RBC A B M LOT T O BAG I N B O ; R A C K ALU M I N U M PAC P O L E TO U / S O F C E I L I N G (CO L O U R : B L A C K ) ALU M I N U M PAC P O L E TO U / S O F C E I L I N G (CO L O U R : B L A C K ) N3000 (CO R N E R FACING) WITH DRIV E - T H R U 287.4 sq.m . (3,094 sq.f t . ± ) WAL K - I N COO L E R (PR O P O S E D 3 0 S E A T S ) WAL K - I N FRE E Z E R (A& W ) WAL K - I N COO L E R (A& W ) PAT I O A R E A TEM P . GLAS S WALL 18"x 4 8 " RWL HUB DRA I N FLOO R RECE S S E D GRE A S E INT E R C E P T O R (OP T I O N A L P E R G O L A ) BROCK ROAD PI C K E R I N G P A R K W A Y (10) Rudbeckia hirta (4) Juniperus chinensis 'Blaauw' (40) Rudbeckia hirta (26) Clethra alnifolia 'Hummingbird' (32) Juniperus chinensis 'Blaauw' (39) Carex muskingumensis (23) Carex muskingumensis (3) Rosa rugosa (34) Carex muskingumensis (6) Calamagrostis acutiflora 'Karl Foerster' (1) Quercus robur (3) Amelanchier canadensis (Shrub) (1) Acer X freemanii 'Jeffersred' (1) Acer X freemanii 'Jeffersred' (65) Rudbeckia hirta (45) Calamagrostis acutiflora 'Karl Foerster' (17) Carex muskingumensis (12) Rosa rugosa (1) Celtis occidentalis (29) Juniperus chinensis 'Blaauw' (55) Rudbeckia hirta (4) Amelanchier canadensis (Shrub) (13) Calamagrostis acutiflora 'Karl Foerster' (42) Calamagrostis acutiflora 'Karl Foerster' (1) Quercus robur (13) Juniperus chinensis 'Blaauw' (60) Rudbeckia hirta (20) Hydrangea arborescens 'Annabelle' (1) Quercus robur 1 2 0 0 25 0 0 2 5 0 0 60 0 SOD SOD SOD SOD SOD SOD W W W W W W W W W W W W W W W W W W W W W W W W W W W W W W W W W SELF SUP P O R T ROO F LAD D E R MOP SINK 24"x 3 6 " 24"x3 6 " 24"x 3 6 " 18"x4 8 " 18"x 4 8 " 18"x 3 6 " 18"x 3 6 " 18 " x 3 6 " 18"x 3 6 " 18"x 4 8 " 18 " x 3 6 " A & W W A S T E S T A T I O N A & W G U E S T C O N N E C T S T A T I O N PRO P O S E D TEN A N T HWT ON PLA T F O R M ABO V E 18"x3 6 " 18"x 3 6 " A & W C O N D I M E N T S T A T I O N MWAT E R F I L T E R 18"x 3 6 " 18"x 3 6 " HWT ON PLA T F O R M ABO V E C/W H O MON I T O R U/C SAFE OPE N FAC E COO L E R NOV E L T Y ICE - C R E A M CHE S T ( S ) RBC A B M LOT T O BAG I N B O ; R A C K ALU M I N U M PAC P O L E TO U / S O F C E I L I N G (CO L O U R : B L A C K ) ALU M I N U M PAC P O L E TO U / S O F C E I L I N G (CO L O U R : B L A C K ) N3000 (CO R N E R FACING) WITH DRIV E - T H R U 287.4 sq.m . (3,094 sq.f t . ± ) WAL K - I N COO L E R (PR O P O S E D 3 0 S E A T S ) WAL K - I N FRE E Z E R (A& W ) WAL K - I N COO L E R (A& W ) PAT I O A R E A TEM P . GLAS S WALL 18"x 4 8 " RWL HUB DRA I N FLOO R RECE S S E D GRE A S E INT E R C E P T O R (OP T I O N A L P E R G O L A ) BROCK ROAD PI C K E R I N G P A R K W A Y 12 3 4 5 6 7 8 9 10 111213 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 35 30 31 32 33 34 (37) Clethra alnifolia 'Hummingbird' (58) Calamagrostis acutiflora 'Karl Foerster' (18) Juniperus chinensis 'Blaauw' (2) Quercus robur (7) Calamagrostis acutiflora 'Karl Foerster' (31) Juniperus Sabina DO NOT SCALE DRAWING Landscape Architect's electronic or digital seal or signature is effective only as to that version of this document as originally published by the Landscape Architect. Landscape Architect is not responsible for any subsequent modification, corruption, or unauthorized use of such document. To verify that validity or applicability of the seal or signature, contact Landscape Architect. All drawings are the property of the Landscape Architect and may not be copied, reproduced or altered without written permission from the Landscape Architect. Project Number: Date: Scale: Checked By: Drawn By: ByNo.Date (Y/M/D)Issue / Revision Sheet Title: Client Info: Project Info: Sheet Number: 1653 230719 LANDSCAPE CONCEPT Po p o v i c h 1 0 0 % . c t b We have relied upon the accuracy and completeness of base & background information provided by the following Consultants in preparing this drawing and performing our professional services. We are under no obligation or duty to verify the accuracy and/or completeness of this information and have not done so. We shall not be held responsible for any errors or omissions that may arise or be incorporated as a result of erroneous or incomplete information provided by the Client, Consultants and Contractors. The contractor will check and verify all dimensions and job conditions on the site and report any discrepancies to the Landscape Architect prior to the commencement of construction. SITE DEVELOPMENT 1800 Brock Road, Pickering PETRO CANADA Suncor Energy Group LANDSCAPE PLAN 1653 SX SP as shown L1Mar. 23 DECIDUOUS TREES QUANTITY BOTANICAL NAME COMMON NAME SIZE-CAL ROOT REMARKS 2 Acer X freemanii 'Jeffersred'Autumn Blaze Maple 70mm Cal.W.B.Straight trunk, evenly branched crowns 5 Quercus robur English Oak 70mm Cal.W.B.Straight trunk, evenly branched crowns 1 Celtis occidentalis Common Hackberry 60mm Cal.W.B.Straight trunk, evenly branched crowm CONIFEROUS TREES QUANTITY BOTANICAL NAME COMMON NAME SIZE-CAL ROOT REMARKS 8 Picea pungens Colorado Spruce 200cm ht.W.B.Straight, evenly branched, dense plants DECIDUOUS SHRUBS QUANTITY BOTANICAL NAME COMMON NAME SIZE-CAL ROOT REMARKS 7 Amelanchier canadensis (Shrub)Shadblow Serviceberry Clump 150cm Ht.W.B.Evenly branched, Min. 3 Canes 20 Hydrangea arborescens 'Annabelle' Annabelle Hydrangea 3 GAL. 63 Clethra alnifolia 'Hummingbird'Hummingbird Summersweet 2 GAL.CONT.Full, dense plant CONT.Full, dense plant 15 Rosa rugosa Rugosa Rosa 2 GAL.CONT.Full, dense plant CONIFEROUS SHRUBS QUANTITY BOTANICAL NAME COMMON NAME SIZE-CAL ROOT REMARKS 96 Juniperus chinensis 'Blaauw' Blaauw Juniper 40cm Spr./3 Gallon Cont.Full, dense plant GRASSES QUANTITY BOTANICAL NAME COMMON NAME SIZE-CAL ROOT REMARKS 173 Calamagrostis acutiflora 'Karl Foerster' Karl Foerster Feather Grass 2 Gallon Cont.Full, dense plant 113 Carex muskingumensis Palm Sedge Grass 2 Gallon Cont.Full, dense plant PERENNIALS QUANTITY BOTANICAL NAME COMMON NAME SIZE-CAL ROOT REMARKS 230 Rudbeckia hirta Black Eyed Susan 1 Gallon Cont.Full, dense plant 2 L1 PLANT SCHEDULE 1 L1 LANDSCAPE PLAN 1:200 1 230719 ISSUED FOR SPA SX N.T.S. F O R I S A MA NTO EM A T C S O I OI N O H B E TCST E R I RC A C S D NAL A P E REQUIRED TREE PROTECTION HOARDING TREE PROPOSED FOR REMOVAL PROPOSED SOD LEGEND 31 Juniperus sabina Savin Juniper 50cm Spr./3 Gallon Cont.Full, dense plant - 14 - SUB-GRADE; CULTIVATE TO DEPTH OF 100 mm. REPEAT CULTIVATION FOR AREAS THAT HAVE BEEN COMPACTED BY EQUIPMENT USED FOR HAULING & SPREADING. 150mm TOPSOIL GENERAL NOTES: 1. ALL WORK SHALL BE IN STRICT CONFORMANCE WITH ALL CURRENT APPLICABLE CODES AND REGULATIONS. 3. TOPSOIL MUST BE CAPABLE OF SUSTAINING VIGOROUS PLANT GROWTH AND TO BE FREE FROM SUBSOIL, ROOTS, VEGETATION, DEBRIS, TOXIC MATERIALS AND STONE OVER 50mm DIAMETER. 4. FOR AREAS TO RECEIVE SOD, SET TOPSOIL 15mm BELOW FINISHED GRADE. 5. ENSURE THAT GRADES AND CROSS SLOPE PROVIDE POSITIVE DRAINAGE AND ADHERE TO GRADING PLAN (WHERE APPLICABLE). SOD OR SEED MIX; AS SPECIFIED PRUNE AND REMOVE DAMAGED BRANCHES DO NOT CUT LEADER REMOVE PROTECTIVE WRAPPING AND INSPECT FOR DAMAGE 75mm MULCH BARK PROVIDE 75mm HIGH SOIL SAUCER AROUND PERIMETER OF TREE. SAUCER TO BE SOAKED WITH WATER IMMEDIATELY AFTER INSTALLATION. PROVIDE EDGE AROUND EXTERIOR PERIMETER GENERAL NOTES: 1. LOOSEN SURFACE SOIL OF PLANTING HOLE. 2. HAND DIG ONLY. 3. ALLOW FOR SETTLEMENT WHEN SETTING PLANTS, SET PLANTS 50mm HIGHER THAN ADJACENT FINISHED GRADE. 4. BACKFILL SOIL IN 150mm LIFTS AND HAND TAMP TO PREVENT AIR POCKETS. 5. CAREFULLY REMOVE ANY LOOSE SOIL FROM TOP OF ROOT BALL. 150 300 75 0 M I N . REMOVE WIRE BASKET, ALL ROPE AND BURLAP FROM TOP 1/3 OF ROOT BALL BEFORE PLACING MULCH (SYNTHETIC BURLAP SHALL NOT BE USED ON ROOT BALL.) UNDISTURBED OR COMPACTED SOIL; MINIMUM SOIL AREA OF 30m² AT PROPER PLANTING DEPTH WITH UNOBSTRUCTED GROWING MEDIUM SCARIFY BOTTOM OF PLANTING BED PLANTING SOIL MIXTURE TO BE TRIPLE MIX TOPSOIL OR APPROVED EQUAL; TOPSOIL LAYER TO BE GREATER THAN 60cm WITH GRADUAL CHANGE OF SOIL QUALITY (TEXTURE/POROSITY) AND ORGANIC MATTER CONTENT THAT VARIES FROM 2% TO 7% U=IN THE TOP 30CM OF SOIL BY DRY WEIGHT AND A pH OF 6.8 TO 8.0. TOPSOIL AND SOD, WHERE APPLICABLE 50x50x6mm STEEL 'T' BARS DRILLED TO RECEIVE #11 GAL. WIRE ENCASED IN 25mm O.D. TWO PLY NEW BLACK RUBBER HOSE. DO NOT DRIVE STAKE THROUGH ROOT BALL. REMOVE BARS ONLY AT THE END OF THE WARRANTY PERIOD. 12 0 0 SET TREE PLUMB PRUNE AND REMOVE DAMAGED BRANCHES DO NOT CUT LEADER REMOVE PROTECTIVE WRAPPING AND INSPECT FOR DAMAGE 75mm MULCH BARK; PROVIDE EDGE AROUND PERIMETER PROVIDE 75mm HIGH SAUCER AROUND PERIMETER OF TREE. SAUCER TO BE SOAKED WITH WATER IMMEDIATELY AFTER INSTALLATION. GENERAL NOTES: 1. LOOSEN SURFACE SOIL OF PLANTING HOLE. 2. HAND DIG ONLY. 3. ALLOW FOR SETTLEMENT WHEN SETTING PLANTS, SET PLANTS 50mm HIGHER THAN ADJACENT FINISHED GRADE. 4. BACKFILL SOIL IN 150mm LIFTS AND HAND TAMP TO PREVENT AIR POCKETS. 5. CAREFULLY REMOVE ANY LOOSE SOIL FROM TOP OF ROOT BALL. 150 300 REMOVE WIRE BASKET, ALL ROPE AND BURLAP FROM TOP 1/3 OF ROOT BALL BEFORE PLACING MULCH (SYNTHETIC BURLAP SHALL NOT BE USED ON ROOT BALL.) UNDISTURBED OR COMPACTED SOIL, MINIMUM SOIL AREA OF 30m² AT PROPER PLANTING DEPTH WITH UNOBSTRUCTED GROWING MEDIUM SCARIFY BOTTOM OF PLANTING BED PLANTING SOIL MIXTURE TO BE TRIPLE MIX TOPSOIL OR APPROVED EQUAL; TOPSOIL LAYER TO BE GREATER THAN 60cm WITH GRADUAL CHANGE OF SOIL QUALITY (TEXTURE/POROSITY) AND ORGANIC MATTER CONTENT THAT VARIES FROM 2-7% IN THE TOP 30cm OF SOIL BY DRY WEIGHT AND A pH OF 6.8-8.0 TOPSOIL AND SOD, WHERE APPLICABLE 50x50x6mm STEEL 'T' BARS DRILLED TO RECEIVE #11 GAL. WIRE ENCASED IN 25mm O.D. TWO PLY NEW BLACK RUBBER HOSE. DO NOT DRIVE STAKE THROUGH ROOT BALL. REMOVE BARS ONLY AT THE END OF THE WARRANTY PERIOD. -DECIDUOUS TREES UP TO 75mm CAL. SHALL BE DOUBLE STAKED -DECIDUOUS TREES OVER 75mm CAL. SHALL BE TRIPLE STAKED 15 0 0 SET TREE PLUMB 75 0 M I N . UNDISTURBED OR COMPACTED SOIL; SCARIFY BOTTOM OF PLANTING BED REST ROOTBALL ON 75-150mm OF PACKED SUBSOIL DESIGN NOTES: 1. ALL WORK SHALL BE IN STRICT CONFORMANCE WITH ALL CURRENT APPLICABLE CODES AND REGULATIONS. 2. ROOT BALL TO BE 300mm UNLESS SPECIFIED OTHERWISE. 3.1 3 OF BURLAP TO BE ROLLED BACK. SPREAD ROOTS OVER COMPACTED SUBSOIL. 4. PLANTING BEDS TO HAVE 75mm SHREDDED BARK MULCH. 5. SAUCER OR BED TO BE SOAKED WITH WATER IMMEDIATELY AFTER PLANTING. PLANTING SOIL MIXTURE c/w BONE MEAL ADDITIVE OR APPROVED EQUAL. SOAK WITH WATER TO REMOVE VOIDS SET TOP OF ROOT BALL 25mm MIN. ABOVE FINISHED GRADE TO ALLOW FOR SETTLEMENT 75mm MULCH BARK; CONTINUOUS AROUND BASE OF SHRUB PROVIDE 75mm HIGH SOIL SAUCER AROUND PERIMETER OF SHRUBS. SAUCER TO BE SOAKED WITH WATER IMMEDIATELY AFTER INSTALLATION. PROVIDE EDGE AROUND EXTERIOR PERIMETER FINISHED GRADE 150 MIN. DO NOT SCALE DRAWING Landscape Architect's electronic or digital seal or signature is effective only as to that version of this document as originally published by the Landscape Architect. Landscape Architect is not responsible for any subsequent modification, corruption, or unauthorized use of such document. To verify that validity or applicability of the seal or signature, contact Landscape Architect. All drawings are the property of the Landscape Architect and may not be copied, reproduced or altered without written permission from the Landscape Architect. Project Number: Date: Scale: Checked By: Drawn By: ByNo.Date (Y/M/D)Issue / Revision Sheet Title: Client Info: Project Info: Sheet Number: 1653 230719 LANDSCAPE CONCEPT Po p o v i c h 1 0 0 % . c t b We have relied upon the accuracy and completeness of base & background information provided by the following Consultants in preparing this drawing and performing our professional services. We are under no obligation or duty to verify the accuracy and/or completeness of this information and have not done so. We shall not be held responsible for any errors or omissions that may arise or be incorporated as a result of erroneous or incomplete information provided by the Client, Consultants and Contractors. The contractor will check and verify all dimensions and job conditions on the site and report any discrepancies to the Landscape Architect prior to the commencement of construction. SITE DEVELOPMENT 1800 Brock Road, Pickering PETRO CANADA Suncor Energy Group DETAILS 1653 SX SP as shown L2Mar. 23 1 L2 DECDUOUS TREE PLANTING DETAIL 1:20 2 L2 CONIFEROUS TREE PLANTING DETAIL 1:20 3 L2 SOD DETAIL 1:20 4 L2 SHRUB PLANTING DETAIL 1:20 SOD & TOPSOIL NOTES: TOPSOIL (SOD AREAS) 1. IMPORTED TOPSOIL: FRIABLE, NEITHER HEAVY CLAY NOR OF VERY LIGHT SANDY NATURE, CONTAINING A MINIMUM OF 4% ORGANIC MATTER FOR CLAY LOAM AND 2% SANDY LOAMS TO A MAXIMUM OF 10% BY VOLUME. FREE FROM SUBSOIL, ROOTS, GRASS, WEEDS, TOXIC MATERIALS, STONES, FOREIGN OBJECTS AND WITH AN ACIDITY RANGE (pH) OF 5.5 TO 7.5 . TOPSOIL CONTAINING CRABGRASS, COUCH GRASS OR NOXIOUS WEEDS IS NOT ACCEPTABLE. 2. TOPSOIL FROM SITE: MATERIAL SUBJECT TO SOIL ANALYSIS FOR SUITABILITY AS A GROWING MEDIUM FOR SEEDING OR SODDING AND APPROVAL BY ARCHITECT/LANDSCAPE ARCHITECT/OWNER PRIOR TO USE. COSTS BORNE BY CONTRACTOR. FINISHED GRADING 1. DO NOT SPREAD TOPSOIL UNTIL CONSULTANT HAS INSPECTED AND APPROVED SUBGRADE. 2. SPREAD TOPSOIL WITH ADEQUATE MOISTURE IN UNIFORM LAYERS DURING DRY WEATHER OVER APPROVED, DRY, UNFROZEN SUBGRADE, WHERE SODDING OR SEEDING. 3. FOR AREAS NOT TO BE SODDED, BRING TOPSOIL UP TO FINISHED GRADE. 4. DISPOSE OF SURPLUS TOPSOIL NOT REQUIRED FOR FINE GRADING AND LANDSCAPING, OFF SITE. SODDING 1. SCHEDULE DELIVERIES IN ORDER TO KEEP STORAGE AT JOB SITE TO A MINIMUM WITHOUT CAUSING DELAYS. 2. DELIVER, UNLOAD, AND STORE ON PALLETS. 3. DURING WET WEATHER, ALLOW SOD TO DRY SUFFICIENTLY TO PREVENT TEARING DURING LIFTING AND HANDLING. 4. DURING DRY WEATHER, PROTECT SOD FROM DRYING AND WATER SOD AS NECESSARY TO ENSURE ITS VITALITY AND PREVENT DROPPING OF SOIL IN HANDLING. DRY SOD WILL BE REJECTED. 5. NURSERY SOD: QUALITY AND SOURCE TO COMPLY WITH STANDARDS OUTLINED IN THE METRIC GUIDE SPECIFICATION FOR NURSERY STOCK, SECTION 17, 1984 EDITION, PUBLISHED BY THE CANADIAN NURSERY TRADES ASSOCIATION. NUMBER ONE KENTUCKY BLUEGRASS SOD: GROWN FROM MINIMUM MIXTURE OF THREE KENTUCKY BLUEGRASS CULTIVARS. 6. OBTAIN APPROVAL OF TOPSOIL, GRADE AND DEPTH PRIOR TO LAYING SOD. 7. LAY SOD DURING GROWING SEASON. SODDING DURING FREEZING TEMPERATURES OR OVER FROZEN SOIL IS NOT ACCEPTABLE. IF LAYING SOD DURING DRY SUMMER PERIOD, ENSURE SURVIVAL WITH IMMEDIATE DAILY WATERING UNTIL TIME OF FINAL INSPECTION. 8. LAY SOD IN ROWS, PERPENDICULAR TO SLOPE, AND WITH JOINTS STAGGERED. BUTT SECTIONS CLOSELY WITHOUT OVER- LAPPING OR LEAVING GAPS BETWEEN SECTIONS. CUT OUT IRREGULAR OR THIN SECTIONS WITH A SHARP KNIFE. 9. STAKE ALL SOD ON SLOPES GREATER THAN 5:1 (20%) 10. PROVIDE CLOSE CONTACT BETWEEN SOD AND SOIL BY MEANS OF LIGHT ROLLING. HEAVY ROLLING TO CORRECT IRREGULARITIES IN GRADE IS NOT PERMITTED. 10. WATER IMMEDIATELY AFTER SOD IS LAID TO OBTAIN MOISTURE PENETRATION THROUGH SOD INTO TOP 100mm (4") OF TOPSOIL. 11. PROVIDE ADEQUATE PROTECTION OF NEW SODDED AREAS AGAINST EROSION, FOOT TRAFFIC, AND MECHANICAL DAMAGE. REMOVE PROTECTION AFTER LAWN AREAS HAVE BEEN ESTABLISHED OR ACCEPTED. 12. CLEAN UP IMMEDIATELY SOIL OR DEBRIS SPILLED ONTO PAVEMENT AND DISPOSE OF DELETERIOUS MATERIALS. 13. SODDED AREAS WILL BE ACCEPTED AT FINAL INSPECTION AND WARRANTY PERIOD BEGINS PROVIDED THAT: 13.1. SODDED AREAS ARE PROPERLY ESTABLISHED 13.2. SOD IS FREE OF BARE AND DEAD SPOTS AND WITHOUT WEEDS 13.3. NO SURFACE SOIL IS VISIBLE WHEN GRASS HAS BEEN CUT TO A HEIGHT OF 40mm (1.5") 13.4. SODDED AREAS HAVE BEEN CUT A MINIMUM OF TWO TIMES 13.5. SOD JOINTS BETWEEN ROLLS ARE NEAT AND TIGHT WITH NO VISIBLE DIRT AREAS 14. IT IS THE CONTRACTOR'S RESPONSIBILITY TO MAINTAIN SOD UNTIL TIME OF FINAL ACCEPTANCE. MAINTENANCE OF SOD DURING WARRANTY PERIOD IS THE RESPONSIBILITY OF THE OWNER. 15. MAINTENANCE TASKS INCLUDE ALL OF THE FOLLOWING: 15.1. WATERING 15.2. FERTILIZING 15.3. WEED CONTROL 15.4. CUTTING AND MOWING 16. SUBMIT SEPARATE MAINTENANCE COST FOR COORDINATION BY OWNER DURING WARRANTY PERIOD ONLY. PLANTING NOTES 1. UNLESS OTHERWISE INDICATED, ALL TREES AND SHRUBS ARE TO BE PLANTED DIRECTLY INTO NATIVE TOPSOIL (SUBJECT TO SOIL ANALYSIS TO DETERMINE SUITABILITY AS A GROWING MEDIUM AND APPROVAL BY OWNER/LANDSCAPE ARCHITECT) OR PLANTING SOIL, 1000-1200mm DEPTH WITH A 1.0m DIAMETER AND 75mm DEPTH MULCH COVER. MULCH TO BE KEPT AWAY FROM TRUNK AND STEMS. REFER TO PLANTING DETAILS. 2. PLANT MATERIALS TO BE SUPPLIED IN SUFFICIENT QUANTITIES TO COMPLETE DESCRIBED SCOPE OF WORK. 3. PLANT MATERIALS TO CONFORM TO THE CANADIAN NURSERY ASSOCIATION METRIC GUIDE SPECIFICATIONS FOR NURSERY STOCK, LATEST EDITION. PLANT MATERIAL NOT CONFORMING SHALL BE REMOVED FROM SITE BY THE CONTRACTOR AT NO ADDITIONAL COST TO THE PROJECT. 4. CONTRACTOR SHALL STAKE OUT ALL LOCATIONS FOR ALL UTILITIES AND SERVICES PRIOR TO STAKING OUT TREE LOCATIONS. 5. ALL SHRUB PLANTINGS SHALL BE IN CONTINUOUS BEDS, UNLESS OTHERWISE INDICATED. 6. PLANT MATERIAL COLLECTED FROM WILD SOURCES WILL NOT BE ACCEPTED. SUPPLIER INVOICES MAY BE REQUIRED BY LANDSCAPE ARCHITECT FOR INSPECTION. 7. LAYOUT OF PLANT MATERIALS TO BE APPROVED BY LANDSCAPE ARCHITECT PRIOR TO INSTALLATION. DRAWING MAY BE SCALED FOR APPROXIMATE LAYOUT OF INDIVIDUAL TREES AND PLANTING BEDS. 8. ANY SUBSTITUTIONS IN PLANT MATERIAL OR CHANGES TO QUANTITIES TO BE AUTHORIZED IN WRITING BY THE LANDSCAPE ARCHITECT. 9. NO PLANTING INSTALLATIONS ARE TO BE EXECUTED DURING PERIODS OF EXTREME HEAT, DROUGHT OR ANY OTHER UNDESIRABLE CONDITION. LANDSCAPE ARCHITECT TO BE CONTACTED FOR AUTHORIZATION AND DIRECTION IN SITUATIONS OF UNCERTAINTY. 10. LANDSCAPE ARCHITECT RESERVES THE RIGHT TO RELOCATE PLANT MATERIAL ON SITE AS NECESSARY TO MAINTAIN DESIGN INTENT AT NO ADDITIONAL COST AGAINST THE PROJECT BY THE CONTRACTOR. 11. SHREDDED BARK MULCH TO BE UNIFORMLY APPLIED UNDER ALL TREES AND IN PLANTING BEDS TO 75mm THICKNESS. SAMPLE TO BE SUBMITTED TO THE LANDSCAPE ARCHITECT FOR APPROVAL. 12. ALL DEAD OR DAMAGED BRANCHES ON TREES OR SHRUBS TO BE PRUNED OUT IN KEEPING WITH GOOD HORTICULTURAL PRACTICES AND AT A TIME APPROPRIATE TO SUBJECT SPECIES. 13. ALL DIMENSIONS AND QUANTITIES TO BE VERIFIED BY CONTRACTOR. ALL DISCREPANCIES TO BE REPORTED TO LANDSCAPE ARCHITECT. 14. ALL MAINTENANCE REQUIREMENTS NECESSARY FOR WARRANTY PURPOSES TO BE IDENTIFIED BY THE CONTRACTOR TO THE OWNER AND LANDSCAPE ARCHITECT. 15. ALL WORKMANSHIP AND MATERIALS TO BE GUARANTEED FOR TWO YEARS FOLLOWING SUBSTANTIAL COMPLETION AS DOCUMENTED BY THE LANDSCAPE ARCHITECT AND/OR MUNICIPALITY. 16. LANDSCAPE ARCHITECT RESERVES THE RIGHT TO EXTEND THE CONTRACTOR'S WARRANTY RESPONSIBILITIES FOR AN ADDITIONAL YEAR IF, AT THE END OF THE INITIAL WARRANTY PERIOD, LEAF DEVELOPMENT AND GROWTH IS NOT SUFFICIENT TO ENSURE FUTURE SURVIVAL AS DETERMINED BY THE LANDSCAPE ARCHITECT. 17. ALL TREE STAKES AND ALL ASSOCIATED RESTRAINTS AND HARDWARE TO BE REMOVED BY THE CONTRACTOR AT THE END OF THE SPECIFIED WARRANTY PERIOD. 18. CONTRACTOR TO PROVIDE UNIT PRICES IN CASE OF ADDITIONS/DELETIONS TO THE CONTRACT. 19. CONTRACTOR IS RESPONSIBLE FOR ANY DAMAGE TO EXISTING LANDSCAPE AREAS AND MUST MAKE ALL NECESSARY RESTORATIONS AND REPAIRS.' 20. ALL PLANT MATERIAL LOCATIONS SHALL CONFORM TO THE HEIGHT AND SETBACK REQUIREMENTS ESTABLISHED BY THE MUNICIPALITY. 1 230719 ISSUED FOR SPA SX N.T.S. F O R I S A MA NTO EM A T C S O I OI N O H B E TCST E R I RC A C S D NAL A P E - 15 - SELF SUP P O R T ROO F LAD D E R MOP SINK 24 " x 3 6 " 24"x 3 6 " 24"x 3 6 " 18"x 4 8 " 18"x4 8 " 18" x 3 6 " 18"x3 6 " 18 " x 3 6 " 18"x 3 6 " 18"x 4 8 " 18 " x 3 6 " A & W W A S T E S T A T I O N A & W G U E S T C O N N E C T S T A T I O N PRO P O S E D TEN A N T HWT ON PLAT F O R M ABO V E 18 " x 3 6 " 18"x3 6 " A & W C O N D I M E N T S T A T I O N MWATE R F I L T E R 18"x3 6 " 18"x 3 6 " HWT ON PLA T F O R M ABO V E C/W H O MON I T O R U/C SAFE OPE N FAC E COO L E R NOV E L T Y ICE - C R E A M CHE S T ( S ) RBC A B M LOT T O BAG I N B O X R A C K ALU M I N U M PAC P O L E TO U / S O F C E I L I N G (CO L O U R : B L A C K ) ALU M I N U M PAC P O L E TO U / S O F C E I L I N G (CO L O U R : B L A C K ) N3000 (CO R N E R FACING) WITH DRIV E - T H R U 287.4 sq.m . (3,094 sq. f t . ± ) WAL K - I N COO L E R (PR O P O S E D 3 0 S E A T S ) WAL K - I N FRE E Z E R (A& W ) WAL K - I N COO L E R (A& W ) PAT I O A R E A TEM P . GLA S S WALL 18"x4 8 " RWL HUB DRA I N FLO O R REC E S S E D GRE A S E INT E R C E P T O R (OP T I O N A L P E R G O L A ) BROCK ROAD PI C K E R I N G P A R K W A Y A Suncor Energy Business J + B ENGINEERING INC. TORONTO 25 CENTURIAN DR. SUITE 201 MARKHAM, ON L3R 5N8 416 229 2636 CALGARY 707-10TH AVE. SW SUITE 150 CALGARY AB T2R 0B3 403 355 2295 - 16 - A1 FLOOR PLAN CL 1:50 A Suncor business fax (905)337-1986(905)337-9800 2660 Sherwood Heights Dr. Suite 200, Oakville, Ontario, L6J 7Y8 www.kpaularchitect.com T O R O N T O • V A N C O U V E R • O R L A N D O K P A U L A R C H I T E C T I N C. 60293 NEIGHBOURS N3000(A&W) 1800 BROCK ROAD @ PICKERING PARKWAY PICKERING, ONTARIO CONSTRUCTION NORTHTRUE NORTH 0 (hrs.)0 (hrs.)0 (hrs.) MEZZANINEROOFFLOOR 0 (hrs.)0 (hrs.)0 (hrs.) MEZZANINEROOFFLOOR SUPPORTING MEMBERS (FRR)HORIZONTAL MEMBERS (FRR) AREA (m )N/AYES( )NO(X)MEZZANINE(S) AREA (X) NO ( ) YES (X) NO ( ) YES (X) NO ( ) YES GARBAGE ENCLOSURE( )ENTIRE BUILDING( )BASEMENT( ) SPRINKLER SYSTEM (X) NO ( ) YES WATER SERVICE / SUPPLY IS ADEQUATE FIRE ALARM REQUIRED STANDPIPE REQUIRED BUILDING CLASSIFICATION 0 (m) 0 (ft.)5.50 (m) 18.04 (ft.) 0 STOREY'S BELOW GRADEABOVE GRADE FACE COMMENTS CONSTRUCTION REQUIRED (FIRE RATED-HR.) (ACTUAL) (ALLOWED) SPATIAL SEPARATION LIMITING DIST H TO L (RATIO) ALLOWED (%)ACTUAL (%) UNPROTECTED OPENINGS AREA OF EXPOSED WALL (SQ. M.) BUILDING HEIGHT CONSTRUCTION TYPE FIRE RESISTANCE RATING (REQ.) NUMBER OF STREETS BUILDING AREA NOTES: COMBINATION( )COMBUSTABLE( )NON-COMBUSTABLE(X) ' E 'GROUP 2 STREET 1 STOREY'S 3169 --- 294.4 --- SQ. FT. SQ. FT. SQ. FT. SQ. M. SQ. M. SQ. M. TOTAL NEW EXISTING 2 MAJOR OCCUPANCY (TABLE 3.1.2.1) OCCUPANT LOAD (SECTION 3.1.17.) 3.2.2.10.(3) WEST EAST NORTH SOUTH C-STORE 3:1/10:1 BUILDING CODE ANALYSIS 100%11 m NECB: SIMPLIFIED TRADE OFF PATH. C-STORE PEOPLE25PUBLIC AREA (90.0 sq.m)3.1.17.1.(1) / TABLE 3.1.17.1 EMPLOYEE (MAX.)4 3.1.17.1 (1) (c) TOTAL OCCUPANT LOAD = 60 PEOPLE PLUMBING REQUIREMENT (SECTION3.7.4. ) REQUIRED PROVIDED 3169294.4 GROSS FLOOR AREA = 182.4 SQ.M.GROSS FLOOR AREA = 112 SQ.M. 42.39± m 3:1/10:120%3 m6.99 m 3:1/10:1100%6 m23.66± m 3:1/10:143%5 m8.23 m N/A 2 HR N/A MAJOR OCCUPANCY ' E 'GROUP (FOR MERCANTILE & RESTAURANT WITH 30 SEATS OR LESS) A&W RESTAURANT A&W RESTAURANT EMPLOYEE (MAX.)5 3.1.17.1 (1) (c) PEOPLE24A&W SEATING - 24 SEATS 3.1.17.1(1)(a) TABLE 3.1.17.12 PEOPLEA&W - ORDER AREA (6.0 sq.m) 2 2 MALE FIXTURES (REQ.) FEMALE FIXTURES (REQ.) 1 1 MALE FIXTURES (PROVIDED) FEMALE FIXTURES (PROVIDED) 1 UNIVERSAL FIXTURES (PROVIDED) 60.54 6.1% (3.72 sq.m) 52.51 70.7% (37.14 sq.m) 55.92 18.2% (10.18 sq.m) 55.09 21.0% (11.59 sq.m) SPATIAL SEPARATION (TABLE 3.2.3.1.C & TABLE 3.2.3.7) 3.2.2.61 GROUP E UP TO 2 STOREYS (2012 ONTARIO BUILDING CODE) NONCOMBUSTIBLE CLADDING 1 HR NONCOMBUSTIBLE CLADDING K-2005KINGSTONC_LAVATORYVITREOUS CHINA Ø17 0 0 K-2005KINGSTONC_LAVATORYVITREOUS CHINA SELF SUPPORT ROOF LADDER 58 0 1200 11 3 7 ± MOP SINK A&W KITCHEN 103A ELEC. ROOM 110 M WATER FILTER HWT CORRIDOR 105 STORAGE 109 PAY POINT 102 C/W HO MONITOR OPEN FACE COOLER NOVELTY ICE-CREAM CHEST (S) OFFICE 108 WOMEN'S WRM. 107B SALES AREA 101 WALK-IN COOLER MEN'S WRM. 107A UNIVERSAL WRM. 106 TE M P . G L A S S W A L L 1000 HUB DRAIN FLOOR RECESSED GREASE INTERCEPTOR 18"x36"18"x36"18"x36"18"x48"18"x48" WALK-IN FREEZER (A&W) A& W W A S T E ST A T I O N 11 0 0 18"x36"18"x36" 18 " x 4 8 " 12 1 8 ± 24"x48"24"x48" 14 1 5 18"x36"18"x36" 24 " x 4 8 " 24 " x 4 8 " 24 " x 4 8 " 18 " x 4 8 " 18 " x 4 8 " 122 5 1508 A&W SEATING AREA 104 (PROPOSED 22 SEATS) A& W C O N D I M E N T ST A T I O N 1381 A&W BACKROOM 103B A&W PANEL 11 5 0 AB M LO T T O WASTE 1031 9 2 9 91 5 A&W SERVICE 103 11 0 0 ± 10 8 0 11 4 8 1339 A& W GU E S T F A C E P O P ST A T I O N 6FT OPEN COOLER 1100 1100 2740 1327 16 9 6 75° 1 5 2 2 RWL SANIMAX SANECO TANK BAG IN BOX (A&W) CO2 (SLUSH) FUTURE A&W PRE-CHILLER (PHASE 2) BA G I N B O X (S L U S H ) 950 4" C H A S E 85 5 m m C O U N T E R D E P T H U 0 8 / 0 5 / 2 0 2 0 4" C H A S E 85 5 m m C O U N T E R D E P T H U 0 8 / 0 5 / 2 0 2 0 FR O N T V E N T I N G 291 1695 9900 NON COMBUSTIBLE ACM PANEL 11873 ARCH BLOCK BASE TO ARCH BLOCK BASE 78 4 6 WO O D G R A I N A L U M I N U M P A N E L 18 0 0 32 0 24 0 0 32 0 29 4 0 32 0 16 4 2 5 AR C H B L O C K B A S E T O A R C H B L O C K B A S E 253 6603 2082 FEATURE STONE WALL 400 ACM PANEL 2050 400 ACM PANEL 4955 884 ACM PANEL 17782 ARCH BLOCK BASE TO ARCH BLOCK BASE 225 3698 ARCH BLOCK BASE TO ARCH BLOCK BASE 2211 ARCH BLOCK BASE TO ARCH BLOCK BASE 52 9 10 3 5 19 2 0 AR C H B L O C K B A S E T O AR C H B L O C K B A S E 51 4 8 NO N C O M B U S T I B L E A C M P A N E L 60 0 0 WO O D G R A I N A L U M I N U M P A N E L 16 4 2 5 AR C H B L O C K B A S E T O A R C H B L O C K B A S E 35 61100 19 2 0 WO O D G R A I N AL U M I N U M P A N E L 1979 WOOD GRAIN ALUMINUM PANEL 3556 WOOD GRAIN ALUMINUM PANEL 2211 WOOD GRAIN ALUMINUM PANEL 32 0 EQ . 37 4 5 EQ . EQ . 26 6 0 10 8 5 EQ . 51 4 8 NO N C O M B U S T I B L E A C M P A N E L 1 1 1 7 BUILDING AREA DATA C-STORE GROSS FLOOR AREA = 182.4 sq.m. (A) PUBLIC AREA = 83.2 sq.m. (B) PRIVATE / STAFF AREA = 72.2 sq.m. (C) WASHROOM AREA = 16.8 sq.m. NET FLOOR AREA = 172.2 sq.m. A&W RESTAURANT GROSS FLOOR AREA = 112.0 sq.m. (D) PRIVATE AREA =69.5 sq.m. (E) SEATING AREA =26.4 sq.m. (F) ORDER AREA =6.7 sq.m. NET FLOOR AREA = 102.6 sq.m. TOTAL NET FLOOR AREA = 274.8 sq.m. TOTAL GROSS FLOOR AREA = 294.4 sq.m. BE F D CB A - 17 - A2.1 EXTERIOR ELEVATIONS RG 1:50 A Suncor business fax (905)337-1986(905)337-9800 2660 Sherwood Heights Dr. Suite 200, Oakville, Ontario, L6J 7Y8 www.kpaularchitect.com T O R O N T O • V A N C O U V E R • O R L A N D O K P A U L A R C H I T E C T I N C. 60293 NEIGHBOURS N3000(A&W) 1800 BROCK ROAD @ PICKERING PARKWAY PICKERING, ONTARIO 1 NORTH ELEVATION SCALE: 1:50 2 WEST ELEVATION SCALE: 1:50 3 EXTERIOR FINISH SCHEDULE SCALE: N.T.S. 1 WINDOW FRAMING ENTRY DOOR FRAMING2 ACM WALL COVER SYSTEM (C-STORE)COLOUR : PCP WHITE3 METAL FLASHING (STONE WALL)PAINT : BENJAMIN MOORE HC-85 FAIRVIEW TAUPE4 INTERNALLY ILLUMINATED SIGN (C-STORE) EXTERIOR LIGHT FIXTURE 6 7 5 METAL FLASHING (PARAPET)COLOUR : VICWEST “CAMBRIDGE” WHITE (OR APPROVAL EQUAL) 8 ILLUMINATED LED RED LEAF BAND 75mm CONTINUOUS ILLUMINATED LED RED BAND PROVIDED BY OTHERS INSTALLED BY G.C. PROVIDED BY SIGN COMPANY 10 METAL CLAD ROOF SCREEN COLOUR TO MATCH: PCP WHITE CULTURED STONE PRO-FIT ALPINE LEDGESTONE COL. PHEASANT 42011711 12 13 14 SECURITY DRAWER 15 16 THERMAL PANE GLASS DOUBLE GLAZED SPANDREL GLASS PANEL PPG EXTRUSION COATINGS: DURANAR COATINGS - UC43352 COLONIAL GRAY (OR APPROVED EQUAL) 18 21 INSULATED PANEL PROVIDED BY A&WILLUMINATED A&W LOGO SIGN22 ROOF SCUPPER 23 COLOUR TO MATCH ADJACENT SURFACE 25 REFER TO SHEET A2.3 FOR LIGHTING SPECIFICATIONS PASS-THRU 360 CAMERA REFER TO SHEET A2.2-1 FOR SPECIFICATION 24 20 COLOUR: SILVER ALUMINUM - REFER TO SHEET A2.2-1 FOR SPEC ILLUMINATED BOOMERANG LIGHT BOX COLOUR : A&W ORANGE PROVIDED & INSTALLED BY A&W A&W POSTER SNAP FRAME WOOD GRAIN ALUMINUM PANEL (HORIZONTAL GRAIN) KNOTWOOD - KED150 COLOUR : ATLANTIC CEDAR (6" DECKING BOARD) FLASHING (A&W BOOMERANG)COLOUR TO MATCH A&W ORANGE ARCHITECTURAL BLOCK SHOULDICE DESIGNER STONE - TEXTURE : TEX-STONE COLOUR: GALAXY SIZE: 390mm x 90mm x 190mm H STACKED APPLICATION ARCHITECTURAL SILL CAP SHOULDICE DESIGNER STONE - 224 SLOPED SILL COLOUR: GALAXY NON-ILLUMINATED A&W LETTER SIGN PROVIDED BY A&W A&W SUSPENDED ILLUMINATED SIGN INTERIOR SUSPENDED PROVIDED BY A&W A&W DRIVE-THRU WINDOW PROVIDED BY A&W 26 28 27 29 30 31 A&W DECAL SIGN COLOUR : BLACK CONCRETED FILL METAL BOLLARD PAINT COLOUR : A&W ORANGE OR APPROVED ALTERNATIVE 17 DOOR OPERATOR BUTTON ACM WALL COVER SYSTEM COLOUR TO MATCH : A&W WHITE COLOUR (ALCOTEX DM 1102 YELLOW WHITE) REMARKSPRODUCTNO.SPECIFICATION & COLOUR COLOUR: CLEAR ANODIZED COLOUR: CLEAR ANODIZED 19 COLOUR : CLEAR ANODIZED COLOUR : CLEAR ANODIZED PROVIDED BY A&W 9 NON-ILLUMINATED RED BAND 75mm CONTINUOUS NON - ILLUMINATED RED BAND NON COMBUSTIBLE ACM WALL COVER SYSTEM COLOUR : PCP WHITE32 PROVIDED BY A&W T/O FIN FLR000 T/O ROOF SCREEN5800 467 T/O PARAPET 4890 T/O FIN FLR 000 3050T/O WINDOWT/O SPANDREL3050 T/O PARAPET 4890 4572 30 5 40 0 0 EQ.2560 EQ. 6 14 TYP. 15 TYP. 14 TYP. 15 TYP. 1 16 32 TYP. 32 TYP. 297 TYP. 135 TYP. 1 18 14 TYP. 15 TYP. 7 TYP. 5 TYP. 10 TYP. 5 TYP. 2 10 TYP. 5 TYP. 9 922 TYP. 23 TYP. 46 7 25 8 3 18 4 0 T/O ARCH. BLOCK BASE T/O ARCH. BLOCK BASE 467 T/O FIN FLR000 T/O FEATURE STONE WALL5000 T/O WINDOW3050 T/O ROOF SCREEN5800 T/O ARCH. BLOCK BASE467 T/O PARAPET 4890 T/O FIN FLR 000 T/O ARCH. BLOCK BASE 467 3050T/O WINDOW T/O PARAPET 4890 46 7 25 8 3 18 4 0 1 16 2 1 16 13 4 711 TYP. 14 TYP. 15 TYP. 14 TYP. 15 TYP. 3 TYP. 7228 35 TYP. 21 27 6 26 225 TYP. 12 10 24 TYP. 23 1 16 19 TYP. 19 TYP.TYP.TYP. 17 10 0 0 CL 91 5 EQ . EQ . 1425 40 7 0 32 0 0 CL CL 29 7 0 2560 EQ.EQ. 30 5 31 0 0 EQ . EQ . - 18 - A2.2 EXTERIOR ELEVATIONS RG 1:50 1 SOUTH ELEVATION SCALE: 1:50 2 EAST ELEVATION SCALE: 1:50 A Suncor business fax (905)337-1986(905)337-9800 2660 Sherwood Heights Dr. Suite 200, Oakville, Ontario, L6J 7Y8 www.kpaularchitect.com T O R O N T O • V A N C O U V E R • O R L A N D O K P A U L A R C H I T E C T I N C. 60293 NEIGHBOURS N3000(A&W) 1800 BROCK ROAD @ PICKERING PARKWAY PICKERING, ONTARIO 3 EXTERIOR FINISH SCHEDULE SCALE: N.T.S. 1 WINDOW FRAMING ENTRY DOOR FRAMING2 ACM WALL COVER SYSTEM (C-STORE)COLOUR : PCP WHITE3 METAL FLASHING (STONE WALL)PAINT : BENJAMIN MOORE HC-85 FAIRVIEW TAUPE4 INTERNALLY ILLUMINATED SIGN (C-STORE) EXTERIOR LIGHT FIXTURE 6 7 5 METAL FLASHING (PARAPET)COLOUR : VICWEST “CAMBRIDGE” WHITE (OR APPROVAL EQUAL) 8 ILLUMINATED LED RED LEAF BAND 75mm CONTINUOUS ILLUMINATED LED RED BAND PROVIDED BY OTHERS INSTALLED BY G.C. PROVIDED BY SIGN COMPANY 10 METAL CLAD ROOF SCREEN COLOUR TO MATCH: PCP WHITE CULTURED STONE PRO-FIT ALPINE LEDGESTONE COL. PHEASANT 42011711 12 13 14 SECURITY DRAWER 15 16 THERMAL PANE GLASS DOUBLE GLAZED SPANDREL GLASS PANEL PPG EXTRUSION COATINGS: DURANAR COATINGS - UC43352 COLONIAL GRAY (OR APPROVED EQUAL) 18 21 INSULATED PANEL PROVIDED BY A&WILLUMINATED A&W LOGO SIGN22 ROOF SCUPPER 23 COLOUR TO MATCH ADJACENT SURFACE 25 REFER TO SHEET A2.3 FOR LIGHTING SPECIFICATIONS PASS-THRU 360 CAMERA REFER TO SHEET A2.2-1 FOR SPECIFICATION 24 20 COLOUR: SILVER ALUMINUM - REFER TO SHEET A2.2-1 FOR SPEC ILLUMINATED BOOMERANG LIGHT BOX COLOUR : A&W ORANGE PROVIDED & INSTALLED BY A&W A&W POSTER SNAP FRAME WOOD GRAIN ALUMINUM PANEL (HORIZONTAL GRAIN) KNOTWOOD - KED150 COLOUR : ATLANTIC CEDAR (6" DECKING BOARD) FLASHING (A&W BOOMERANG)COLOUR TO MATCH A&W ORANGE ARCHITECTURAL BLOCK SHOULDICE DESIGNER STONE - TEXTURE : TEX-STONE COLOUR: GALAXY SIZE: 390mm x 90mm x 190mm H STACKED APPLICATION ARCHITECTURAL SILL CAP SHOULDICE DESIGNER STONE - 224 SLOPED SILL COLOUR: GALAXY NON-ILLUMINATED A&W LETTER SIGN PROVIDED BY A&W A&W SUSPENDED ILLUMINATED SIGN INTERIOR SUSPENDED PROVIDED BY A&W A&W DRIVE-THRU WINDOW PROVIDED BY A&W 26 28 27 29 30 31 COLOUR : BLACK CONCRETED FILL METAL BOLLARD PAINT COLOUR : A&W ORANGE OR APPROVED ALTERNATIVE 17 DOOR OPERATOR BUTTON ACM WALL COVER SYSTEM COLOUR TO MATCH : A&W WHITE COLOUR (ALCOTEX DM 1102 YELLOW WHITE) REMARKSPRODUCTNO.SPECIFICATION & COLOUR COLOUR: CLEAR ANODIZED COLOUR: CLEAR ANODIZED 19 COLOUR : CLEAR ANODIZED COLOUR : CLEAR ANODIZED PROVIDED BY A&W 9 NON-ILLUMINATED RED BAND 75mm CONTINUOUS NON - ILLUMINATED RED BAND NON COMBUSTIBLE ACM WALL COVER SYSTEM COLOUR : PCP WHITE32 A&W BURGER FAMILY DECAL SIGN PROVIDED BY A&W 000 5800 467 4890 2635 T/O FIN FLR T/O SIDE WINDOW T/O PARAPET T/O ROOF SCREEN 7 6 8 T Y P . 170° 76 8 TY P . 610460 14 TYP. 15 TYP. 1 18 13 10 TYP. 26 1919 22 2310 TYP. 5 TYP. 12 TYP. 24 TYP. 22 19 TYP. 31 28 29 1 16 31 10 TYP. 5 TYP. 14 TYP. 15 TYP. 46 7 21 6 8 22 5 5 T/O ARCH. BLOCK BASE 25 72 0 T/O FIN FLR000 T/O ARCH. BLOCK BASE467 T/O ROOF SCREEN5800 T/O FIN FLR 000 T/O ARCH. BLOCK BASE 467 4890T/O PARAPET4890T/O PARAPET 14 TYP. 15 TYP. 14 TYP. 15 TYP. 14 TYP. 15 TYP. 31 5 TYP. 12 24 TYP. 10 TYP.TYP. 30 TYP. 10 TYP. 10 TYP. 7 TYP. 5 TYP. 13932 TYP. 46 7 25 8 3 18 4 0 7 TYP. - 19 - 1 2 12 5 3 5 3 5 3 5 3 7 5 3 7 5 3 7 1 5 3 5 3 7 2 6 1 4 GILBARCO ENCORE S 4+0 (94 OCTANE) 94918987 3 7 6 3 1 7 2 6 1 4 GILBARCO ENCORE S 4+0 (94 OCTANE) 94918987 3 6 3 C1 GAS BAR CANOPY ELEVATIONS RG 1:75 1 NORTH ELEVATION 4 WEST ELEVATION3SOUTH ELEVATION 5 FINISH SCHEDULE SCALE: N.T.S. PRODUCTNO.SPECIFICATION & COLOUR 1 2 3 4 FIBRE REINFORCED PLASTIC 1000mm HALF ROUND FRP WITH INTEGRAL REVEAL GLOSS RED ABOVE REVEAL AND GLOSS WHITE BELOW C/W RED LED LIGHT STRIP IN REVEAL ILLUMINATED SIGNAGE GAS DISPENSER UNIT SUPPLIED BY TRANSWORLD 5 6 COLOUR: MATTE BLACKPIN LETTER / GRAPHIC 7 SNAP FRAME UNITS FIRE EXTINGUISHER 1 PER CHANNEL ALUMINUM COMPOSITE METAL PANEL COLOUR: PCP WHITE A Suncor business fax (905)337-1986(905)337-9800 2660 Sherwood Heights Dr. Suite 200, Oakville, Ontario, L6J 7Y8 www.kpaularchitect.com T O R O N T O • V A N C O U V E R • O R L A N D O K P A U L A R C H I T E C T I N C. 60293 GAS BAR CANOPY 1800 BROCK ROAD @ PICKERING PARKWAY PICKERING, ONTARIO 2 EAST ELEVATION - 20 - 1 Independent 4th Review of the Accessibility for Ontarians with Disabilities Act (AODA) Final Report June 5, 2023 - 21 - 2 Table of Contents Introduction: Declaring a Crisis ........................................................................................................... 3 Summary of Recommendations .......................................................................................................... 5 Disability in Ontario ................................................................................................................................. 7 Process of the 4th Review of the AODA ............................................................................................ 8 Summary of Interim Report: The State of Accessibility in Ontario ......................................... 9 What We’ve Heard Since ..................................................................................................................... 11 Full Recommendations of the 4th Reviewer .................................................................................. 12 Crisis Recommendations ................................................................................................................. 13 Strategic Recommendations .......................................................................................................... 20 Tactical Recommendations............................................................................................................. 24 Conclusion ................................................................................................................................................. 48 Appendix 1: List of Organizations Consulted by the 4th Reviewer........................................ 49 Appendix 2: Organizations who Submitted Feedback to the 4th Reviewer ....................... 51 - 22 - 3 Introduction: Declaring a Crisis Frequently in my career I spend time with Ontario Government stakeholders in upper- floor offices, taking the elevator up some dozens of levels to rooms with commanding views of the cityscapes they govern. Years ago, while visiting one of these stakeholders there was a routine fire drill. Most employees orderly made their way to the stairs for the long descent. Others – those using wheelchairs and managing vision issues – instead made their way to what was, in essence, a closet. This was not to spare these people the hassle of using stairs for a fire drill. This was what they were told to do in a fire. Sit. Wait. Hope someone comes for you. In the six years since that fire drill these remain typical emergency procedures. The Ontario government is aware of this problem – I have raised it personally in formal letters to two Ministers. For these reasons: the direct and tangible threat to the lives and well-being of a quarter of Ontario’s population, combined with 17 years of missed opportunities under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA), I, the Fourth Reviewer of the AODA, have no choice but to declare a crisis. This crisis extends beyond immediate emergency response. More than 75% of surveyed Ontario residents in 2021 with a disability reported negative experiences.1 2.9 million people in Ontario currently have a disability.2 Despite this, there has been minimal change in accessibility. This in turn means Ontario is forgoing a material, and growing, economic opportunity. This crisis declaration is not intended as an assessment of accessibility in Ontario. This ground has already been well covered in past reviews of the AODA, as well as the Interim Report by the Fourth Reviewer.3 Instead, this crisis declaration is intended to be a necessary catalyst to get Ontario back on track for accessibility. It is a near certainty that the goal of an accessible Ontario by 2025 will pass. That does not mean the next years of accessibility regulation, action, and enforcement are not critical. This crisis state, intended to last six months, will allow Ontario to accelerate key overdue processes to get accessibility right in the coming years. With this groundwork, 1 IPSOS Awareness & Attitudes Towards Accessibility 2021. 2 Disability estimates based on disability rates by age and gender categories as found on the 2017 Canadian Study on Disability (see Stuart Morris, Gail Fawcett, Laurent Brisebois, and Jeffrey Hughes, A demographic, employment, and income profile of Canadians with disabilities aged 15 years and over, 2017. Statistics Canada: 2018. These estimates are applied to reference growth projections for 2021 and 2040, as found in the Ontario Data Catalogue. The Ontario Data Catalogue can be accessed here 3 The Interim Report of the Fourth Reviewer can be downloaded here - 23 - 4 Ontario will see major improvements in accessibility. Not just blue buttons at doors (that work), but major changes that allow the province to maximize the contributions of the 2.9 million Ontarians with a disability. These people are not statistics. They work. They pay taxes. They purchase goods and services. They vote. After 17 years and three reviews, this Fourth Review recommends a profound shift in how accessibility is regulated and enforced in Ontario. In brief, the Fourth Reviewer strongly recommends shifting accessibility regulation of the private sector from provincial jurisdiction to federal, while leaving the provincial government accountable for ensuring the services, buildings and careers of the broader public sector in Ontario are accessible to all Ontarians. The reasons for this are outlined in the following sections. This final report should not be read as an admonishment of the provincial government. This ground has been covered, and doing so, in itself, does not improve the experiences of the 2.9 million Ontarians living with disabilities. A key reason for releasing an interim report was to ensure that this final report can instead focus on concrete action the Ontario government can take to get its own house in order, fulfill its promises, and unlock the potential of millions of Ontarians. - 24 - 5 Summary of Recommendations This report outlines 3 categories of recommendations: immediate crisis recommendations, strategic recommendations intended to shift accessibility to new partners, and tactical recommendations that can make meaningful strides to improve accessibility while also retaining the ability to be integrated into strategic changes later. Crisis recommendations are intended to solve immediate safety threats and to lay the necessary foundation for all other recommendations. Within 30 days of the tabling of this report, the province must form a Crisis Committee chaired by the Premier and co- chaired by the Secretary of Cabinet. This committee will be tasked with implementing 5 recommendation themes: 1. Emergency response 2. Service delivery and employee experience within the broader public sector 3. Creating a new Accessibility Agency to be elevated above the legislature 4. Creation of a preliminary action plan with corresponding success metrics 5. Develop initial actions for accessible government procurement These crisis recommendations, or a detailed plan for their implementation, must be completed within 180 days of the formation of the Crisis Committee. These recommendations form the basis of the strategic and tactical recommendations that follow, and include key emergency procedures intended to save lives. Strategic recommendations are those intended to shift the bulk of private sector accessibility regulation and enforcement to the Federal Government. The key reasons for this are twofold. First, the Accessible Canada Act (ACA), which pertains to federally regulated entities, creates a duplication of accessibility regimes in Ontario. Second, the province has often lacked resources to properly enforce the AODA, even for large organizations. This problem is compounded by the fact that there are 412,000 entities in Ontario subject to the AODA, 370,000 of which are small businesses. Ontario does not have the infrastructure to properly regulate this many entities for accessibility, and building such infrastructure is costly. However, federal agencies such as the Canada Revenue Agency (CRA) regularly collect information from, and audit, such small and medium enterprises (SMEs). With tweaks to budget and training, the CRA has the potential to audit and enforce accessibility in a far more cost-effective way than the provincial government. Tactical recommendations are immediate actions the province can take following the conclusion of crisis recommendations. They can be pursued concurrently to the strategic - 25 - 6 recommendations of federal integration. The majority of these recommendations would fall under the purview of a new Accessibility Agency, and thus ownership of activities would be more easily transferable once strategic recommendations are complete. This report includes 23 tactical recommendations centered around the following four themes: 1. Research 2. Tools and Mechanisms for Behavioural Change 3. Mobilizing Government Actions 4. Built Environment The vast majority of recommendations are designed to be completed within the next three years. The reason for the short timeframe is simple: the recommendations provided by the 4th Review are not centered on standards, but on process. While standards may be one viable tool to attain the goal of an accessible Ontario, they cannot be the only tool. Only by creating repeatable and measurable processes – centered on understanding, measuring and improving experiences of People with Disabilities (PWD) – can Ontario (or any jurisdiction) reach its accessibility goals. - 26 - 7 Disability in Ontario People with Disabilities (PWD) are one of the largest population categories in Ontario. Approximately 2.9 million Ontarians aged 15+ currently have one or more disabilities. By 2040 this number will increase by another one million.4 The majority of these functional disabilities are also not visible. The sheer size of the population with disabilities means that PWD are everywhere: as consumers, employees, friends, and family. It is likely that every person in Ontario knows a PWD. Probably more. Despite this, PWD regularly face discrimination. This takes two main forms: attitudes of individuals; and conscious design decisions that exclude PWD from activities, services, and structures. These activities include career progression, education, and health care. To address the discrimination faced by PWD, in 2005 the Ontario government passed the Accessibility for Ontarians with Disabilities Act (AODA). Its purpose is to develop, implement, and enforce accessibility standards to achieve accessibility for Ontarians with disabilities with respect to goods, services, facilities, accommodation, employment, buildings, structures and premises. The target for completion of these goals is January 1, 2025. Despite these goals, the progress of the AODA has been, to borrow the words of the Third Reviewer, the late David Onley, glacial. Each review of the AODA has commented on its lack of progress. As at June 2023, the goal of an accessible Ontario for 2025 is difficult to achieve. Over the course of 15 months, the Reviewer consistently heard stories of frustration, both from PWD and AODA stakeholders.5 These experiences underscore the motivation for the 4th Review of the AODA: The current experience for many people with disabilities in Ontario is poor. This stems from design flaws in services, products, technology, buildings, infrastructure, careers, processes, and human imagination. 4 Disability estimates based on disability rates by age and gender categories as found on the 2017 Canadian Study on Disability (see Stuart Morris, Gail Fawcett, Laurent Brisebois, and Jeffrey Hughes, A demographic, employment, and income profile of Canadians with disabilities aged 15 years and over, 2017. Statistics Canada: 2018. These estimates are applied to reference growth projections for 2021 and 2040, as found in the Ontario Data Catalogue. The Ontario Data Catalogue can be accessed here 5 For a longer discussion of the current state of accessibility in Ontario, please refer to the Interim Report - 27 - 8 Process of the 4th Review of the AODA The key focus of this 4th Review of the AODA has been data and outcomes. Both are rooted in experiences and demands. Not just the experiences of PWD, but also the experiences of AODA stakeholders that must follow and/or enforce the legislation. This experiential focus differs from previous reviews, which have focused on defining disability, creating or expanding accessibility standards, and complying with/enforcing these standards. There were three reasons for this decision: 1. PWD do not demand standards or definitions, they demand positive experiences similar to that of the rest of the population. 2. Grounding assessments in experience prevents viewing accessibility as “checking a box” tied to standards 3. Definitions tied to identities like disability are fluid. An experiential focus elevates assessment and action above attempts to expand or narrow categories. This is consistent with the goal of an accessible Ontario for all. This shift from a sole reliance on standards, and towards data-driven experience, differs from past AODA Reviews. This is intentional. To advance a stalled agenda, it is necessary to adopt new principles centered in emerging best practices. The six principles embedded in the Fourth Review of the AODA are: 1. Focus on execution: ensuring that final recommendations address actionable ways to drive immediate change. 2. Not tethered to past Reviews: use a comprehensive approach that reflects recent innovative thinking. 3. More than compliance: a focus on what will work to create a barrier-free environment, not just checking a box. 4. Grounded in lived experience: continuously seeking and embedding real world PWD experiences to prioritize change and evaluate success 5. Considering multi-year implications: develop recommendations focused on both 2025 deadline and continuous improvement objectives. 6. Evidence-based data-centric approach: apply credible data to form an evidence- based approach for assessments and recommendations Consistent with this evidence-centric approach, the Reviewer conducted interviews with over 100 AODA stakeholders and disability experts, convened 4 virtual public town halls with over 300 participants, and conducted two surveys of 250 business leaders and 400 PWD. These, combined with the Reviewer’s 15 years of experience working in the disability market, have formed the basis of the recommendations of this final report. - 28 - 9 This Review process has not been adequate to address the complexity of making Ontario accessible. The Reviewer notes that adjusting for accessibility in one large organization is a series of difficult tasks requiring all manners of economics, organizational change, risk management, process development and sourcing adequate funding. Any attempt to adjust the behaviours of Ontario’s broader public sector and its 412,000 businesses must be viewed as a challenge beyond taking humans to Mars. Complex. Multi-faceted. A worthy, yet gargantuan lift requiring deep knowledge of the factors affecting policies and their resulting processes. Perhaps a microcosm of the AODA itself, the 4th Review has a team of 3 people and a budget of less than $500,000. To get to Mars. The AODA has a 17-year history of under resourcing and failing to put the best minds of our generation to tackle an epic societal challenge: full participation of people with disabilities in our economy and society. Society has decided to tackle this problem. Let us, finally, do it properly. Summary of Interim Report: The State of Accessibility in Ontario It is the assessment of the 4th Reviewer that at present the AODA can only be described as a failure. After 17 years, the Reviewer has heard stories of missed opportunities and stalled progress – from both PWD and those AODA stakeholders responsible for implementing or complying with the regulation. The Reviewer has identified 5 key themes from consultation feedback during this review as to why the AODA is currently a missed opportunity. These themes are: 1. Outcomes are poor: There is a near unanimous consensus that the AODA is currently failing People with Disabilities. Experience design does not consider the functional needs of PWD and thus PWD receive poorer experiences than their peers – including in health care and education. Senior business and government leaders told the Reviewer that changing behaviours to incorporate disability is not a priority. 2. Enforcement does not exist: There is no meaningful enforcement of the AODA. There are significant logistical constraints to enforcement. The entire Compliance and Enforcement Branch of the AODA has approximately 25 staff. This staff is responsible for the management, policy, administration, and enforcement of legislation that pertains to 412,000 private sector organizations. 3. Data/research does not exist: AODA stakeholders consistently indicated a lack of data was a significant problem in improving the experiences of PWD. Concerns - 29 - 10 were raised that the Ministry for Seniors and Accessibility were not experts on disability by an individual with significant insight on these issues. The Reviewer considers the lack of data to be the single biggest missed opportunity over the 17 years of the AODA. 4. Basic leadership does not exist: Stakeholders observed there was a lack of urgency on getting accessibility right within the Ontario government. Leadership has been further hampered by legislative and senior staff turnover. 5. Nobody owns outcomes/no accountability: Tied closely to leadership and enforcement, consultation participants indicated there was a lack of accountability for implementing the AODA within both the private and public sector. This lack of accountability is compounded by lack of public knowledge, which makes it difficult to hold organizations to account. From these consultation themes, the Reviewer provided five categories of assessments. These assessments are summarized below. A full explanation can be found in the Interim Report of the 4th Reviewer. 1. Outcomes: Outcomes under the AODA have been poor. The underlying causes are a lack of data that has led to an overreliance on standards; and a lack of enforcement or incentives to comply with regulation. Too often, standards ignore the lived experiences of PWD and fail to identify cost-effective solutions to maximize impact. A lack of incentives – penalties for non-compliance or financial incentives for getting accessibility right – means accessibility is frequently ignored in planning decisions. This lack of positive incentives too is a symptom of a lack of data. 2. Government and Governance: There are two governance issues that prevent the AODA from operating as intended. First is a lack of a “north star” or positive role model for organizations to emulate. This role can and should be played by the Ontario government. Second is a lack of harmonization across accessibility regimes that leads to inefficient and confusing processes. One critical area of harmonization is with the Accessible Canada Act. 3. Leadership: Leadership has been absent on this file for 17 years. The reason for this is a lack of incentive for political leaders to prioritize it. This responsibility rests with a combination of the Ontario government, who is obligated to serve the needs of the 22% of Ontarians with a disability; but also the media and political opposition, whose role is to hold the government to account. 4. Accountability: Leadership requires accountability. Yet at present there is no accountability on this file. A key driver of this issue is lack of data, which prevents - 30 - 11 transparency and accurate tracking of progress. One needs only to compare data on disability over the course of the AODA with provincial tracking of Covid-19 via public dashboards to appreciate the lack of public accountability mechanisms. It should be noted the Federal Government has started its own journey of data collection about disability in Canada. 5. Built Environment: It is the assessment of the 4th Reviewer that accessibility as it pertains to built environments should be treated separately from other accessibility priorities. Costs associated with changes to built environments have been a reason not to advance accessibility in general. These costs are real, and failure to address them is a significant risk. The Accessible Canada Act, requires federally regulated entities to remove barriers in their operations, including built environments. Soon entities such as banks will be required to have accessible real estate – and no later than 2040. They hold or lease thousands of retail locations across the province, and will be forced to abandon these should remediations not occur. Addressing this issue will take additional resources and strategies beyond that of other AODA areas. What We’ve Heard Since Since the publication of the Interim Report, the 4th Reviewer has continued to hold consultations with AODA stakeholders, especially those within the Ontario Government. The Reviewer has noted that Assistant Deputy Ministers (ADMs) have been more active in their engagements with the Reviewer since the release of the Interim Report. This reflects the importance of the file. This is a positive development. The Reviewer would also like to highlight that the Ontario Government is currently spending approximately $160 million on the remediation of Ontario Government buildings. This is a positive and necessary step. However, the Reviewer is obliged to report that this spending is likely insufficient to cover the full remediation needs of the province. The Reviewer addresses these concerns with a series of Built Environment Recommendations. While a theme in the Interim Report, it is also increasingly clear that there is little to no research on disability as a market segment in Ontario. Instead, information is derived from a series of often ad hoc advisory committees of PWD, both to elicit feedback in general, and to inform the development of new disability standards. It is also clear that this approach, while almost always involving PWD, rarely centers on everyday lived experiences. The reason for this is relatively simple: advisory committees are rarely composed of “typical” PWD users of a given service or experience. Because of this, the - 31 - 12 advice of advisory committees does not center the way in which a “typical” PWD user navigates an environment. This is not a rebuke of those on advisory committees. It is an observation that advocates view problems differently than the average user. An additional theme that was touched on in the Interim Report, and is increasingly obvious, is that official government opposition – that in the Legislature – has yet to attempt to hold the government to account on accessibility. Given that disability represents approximately 22% of the voting age population, this is a clear failure. It should also be noted this failure is consistent across opposition parties for 17 years. The Reviewer extended multiple invitations to Members of Provincial Parliament representing both opposition parties to discuss accessibility. The Reviewer has yet to receive a response to these requests. The Reviewer considers this lack of response insulting to 2.9 million Ontarians with disabilities. It appears that Queen’s Park harbours many politicians who are willfully oblivious to a quarter of their constituents. As part of the Reviewer’s role, he interacts with members of the media upon request for transparency and as public education. In the course of these media requests, one national broadcast media outlet requested the Reviewer be interviewed regarding the interim report. After a preliminary interview, the producer informed the Reviewer that their supervisor had concerns about the Reviewer’s voice, suggesting they reduce the interview to a 5-minute pre-recorded session from a 45-minute live show (the Reviewer has a unique accent caused by his disability). After pointing out the irony of the request and politely suggesting the producer’s supervisor remove their head from their body cavity, the Reviewer declined the invitation. While the supervisor changed their mind after conferring with colleagues, this anecdote illustrates the outright discrimination that people with disabilities face every day. Even those that are tasked with reviewing accessibility regulations. The media plays a key role in holding government accountable in a democratic society. The media is failing people with disabilities by excluding voices (literally and figuratively) and tending to cover disability as “inspirational” public interest content or as The Honourable David Onley once described as “water-skiing squirrel” stories. The media must do better for 25%+ of its audience. Full Recommendations of the 4th Reviewer This section outlines the full recommendations of the 4th Reviewer. These recommendations are organized into three categories: crisis, strategic, and tactical. Crisis recommendations must be resolved within 180 days, and are intended to address immediate threats to public safety, and to lay the necessary groundwork for a successful accessibility regime that has been absent for 17 years. These recommendations are to - 32 - 13 be overseen by a special Crisis Committee. Strategic recommendations are those pertaining to shifting accessibility regulation of the private sector to the Federal Government. Tactical recommendations are intended to build on the foundations laid by the Crisis Committee, make immediate tangible improvements to accessibility regimes in Ontario, and ensuring these improvements are sustainable while strategic recommendations are being acted upon. Crisis Recommendations As noted in the opening of this report, the 4th Reviewer declares the current state of accessibility to be a crisis. Within 30 days of the tabling of this report, the province of Ontario must form a Crisis Committee chaired by the Premier and co-chaired by the Secretary of Cabinet. Within 30 days of the formation of the Crisis Committee, said committee must communicate its ability to take action on the crisis recommendations. All crisis recommendations are intended to be actioned within 180 days of the formation of the Crisis Committee. If any actions will take longer than 180 days, the Crisis Committee must provide publicly explicit reasons as to why this is the case within this 180 day window. All crisis recommendations are to be owned by the Crisis Committee until implementation, and accountability will rest with the Premier and Secretary of Cabinet. Crisis Recommendation 1: Implement Emergency Response Protocols Context: At present, emergency procedures for People with Disabilities that manage limited vision or mobility often consist of sheltering in place. Given the lack of accessibility of many buildings and the shutting down of lifts during emergencies, there is often no way for some PWD to safely evacuate a building. In addition, communication during emergencies fails to account for the life-critical needs of those that manage hearing and/or cognitive/neurodiverse issues. This represents an immediate and acute risk to a significant number of Ontarians that has remained unaddressed. Moreover, it is clear that there is no standard for the safety of PWD that can be easily emulated, leading to a system in which there is a general unawareness of best practices, uneven access to lifesaving process and equipment, and lack of knowledge for how to improve this situation. Actions: i. The Crisis Committee must establish clear, consistent emergency response protocols for all provincial government buildings that include the immediate, safe evacuation of all individuals within the building regardless of their mobility, vision, or any other functional difference that individual may have. This will alleviate the immediate risk to wellbeing in all provincially operated buildings. - 33 - 14 ii. The Ontario government, via the Crisis Committee, must publicly publish its emergency procedure plans integrating PWD. This will provide an example of best practices for other organizations to follow, and provide a potential catalyst for change. At present there is a lack of knowledge of accessible emergency procedures. There is material opportunity for leadership on this issue. iii. The Ontario government, via the Crisis Committee, must table legislation that all places of employment develop an emergency response plan that includes PWD within 180 days of implementation. While requirements for such procedures are embedded into accessibility standards, lack of enforcement has meant these standards are rarely followed. Organizations, especially small and medium enterprises, also often lack knowledge on how to do this properly. Combined with the publication of provincial emergency plans, this will alleviate a significant public safety concern. iv. Alongside legislation, the Crisis Committee must develop a plan for oversight of emergency response plans in the broader public sector and the private sector to ensure compliance. Compliance has been difficult to achieve via AODA. It is essential for emergency procedures. Timeline and Success Metrics: i. Publish government evacuation plans publicly within 180 days of Crisis Committee formation. ii. Alongside emergency procedure plans, publish a supporting document outlining the process of ensuring successful execution of emergency procedures, as well as known gaps in the process that were identified in the creation of emergency procedure plans for public buildings iii. All Ontario employers develop an emergency response plan within 180 days of the passing of related legislation. Crisis Recommendation 2: Focus Deputy Ministers (DMs) on service delivery and employee experience Context: As per the Interim Report, an overreliance on standards derived from input from advisory committees has created a situation in which the lived experiences of everyday PWD are ignored, both in accessing government services and as employed government workers. Given that PWD represent roughly a quarter of Ontario’s population, a standards-based approach is not sufficient, nor is one predicated on raising awareness. - 34 - 15 Virtually everyone in Ontario knows at least one PWD. It should be noted for service delivery, the highest touch areas are likely health care and education. Ergo, these areas deserve enhanced attention for both the number of individuals they serve, and the critical nature of their services. Action: i. The Crisis Committee must issue a directive to all Deputy Ministers to identify barriers in customer (public) and employee experiences within their respective Ministry and its services. To identify such barriers, DMs must engage in material consultations with PWD, both as customers and employees. For clarity's sake, “material” is intended to refer to a statistically relevant sample size of the population served by a given business unit. ii. The Crisis Committee must issue a directive to all Deputy Ministers that they must publish the barriers identified during consultations, as well as a plan to remove these barriers. This plan will have a three-year timeframe, after which a new plan must be developed. It should be noted that both actions within this recommendation mirror the requirements of federally regulated entities under the Accessible Canada Act (ACA), and as such, there is a repository of best practices on which to draw upon. Like ACA plans, each should include a mechanism to anonymously provide feedback. Timeline and Success Metrics: i. Written directives are to be received by all DMs within 180 days of Crisis Committee forming ii. Within 180 days of receiving said directives, each DM must submit their plan to uncover barriers iii. Within one year of receiving directives, each DM must provide a report of key barriers faced by both customers and employees within their respective Ministry and its services, as well as the steps that will be taken to remove these barriers. These plans must be made public, in a variety of formats, to maximize transparency Crisis Recommendation 3: Create a new agency to elevate AODA delivery above legislature Context: At present there is no body that has demonstrated success in enforcing accessibility standards and regulation on to the provincial government itself. Due to this lack of - 35 - 16 accountability, disability has rarely been a priority within the Ontario government. This has downstream effects: unless government can lead on this file, it is unreasonable to expect others to do so. Moreover, there is a lack of centralized resources to tackle accessibility challenges within government. These resources are not just financial: the largest current resource gap is reliable information. The Reviewer found that Ministries often work in “silos” in developing their own accessibility initiatives, meaning there is no repository of best practices or opportunity for inter-organizational learning. An agency dedicated to accessibility can alleviate these coordination problems. Action: i. Develop a framework for the creation of a new Accessibility Agency. This agency would be tasked with leading and coordinating provincial and municipal accessibility activities, many of which are outlined in the tactical recommendations. The agency would also be responsible for the oversight of AODA recommendations; maintain control of processes; conduct research; create, analyze and distribute data; provide consultation to relevant stakeholders; and broader public sector enforcement. Many of these correspond with other recommendations in this report. To underscore its importance, it is recommended this agency report into either the Ministry of Economic Development, Job Creation, and Trade or the Ministry of Public and Business Service Delivery. Both capture missed opportunities in private sector growth and government services, respectively. The creation of such an agency allows for more independent, flexible, direct action and follows other key government priorities such as infrastructure. This will improve accountability. ii. Develop list of funding sources for the new Accessibility Agency Timeline and Success Metrics: i. Plan for the creation of new agency published within 180 days of the formation of the Crisis Committee ii. Creation of fully funded Accessibility Agency within one year of announced plan iii. All AODA and major accessibility initiatives moved under purview of new agency within 180 days of its inception - 36 - 17 Crisis Recommendation 4: Develop Success Metrics and New Action Plan Context: There are currently no clear metrics as to what success looks like in accessibility, apart from adherence to an ever-shifting landscape of standards and definitions. This lack of metrics has made accountability difficult to achieve, not only for the Ontario government, but also for Ontario’s private sector who are seeking a clear “north star” to emulate. This lack of clear success is striking given the stated goal of an accessible Ontario by 2025. Without a clear action plan 2030, much less 2025, is unattainable. Action: i. Assign the Secretary of Cabinet as the owner accountable for Ontario’s accessibility action plan over the next 5 years. This owner should have a close working relationship with the head of the new Accessibility Agency. ii. Define and publicly communicate clear success metrics embedded within a multiyear accessibility plan for which progress is tracked and publicly communicated. This will likely be an aggregated form of the individual Ministry accessibility plans, combined with goals for the private sector and municipalities. Success metrics must be tied to economic and PWD experience goals, not simply the meeting of standards, to provide positive incentives for private sector entities to comply with the AODA and preferably exceed it. This is especially important for small businesses for whom the AODA is largely viewed as a pure compliance cost. iii. Provide a budget for each accessibility plan action item that does not fall within the budgetary purview of individual Ministries. Timelines and Success Metrics i. Owner for new accessibility action plan identified and put in place within 30 days of Crisis Committee formation ii. Working with their team, owner of accessibility plan must publish preliminary success criteria within 180 days of being assigned to their position iii. First provincial action plan must be published within one year of publication of preliminary success criteria, coinciding with plans of individual Ministries - 37 - 18 Crisis Recommendation 5: Accessible Procurement Context: Accessibility gaps frequently occur when organizations source products and services from third party vendors that fall short of their own stated accessibility standards. This problem is especially acute for smaller organizations, who lack the purchasing power to leverage vendors to include built in accessibility features at a feasible price point. Large organizations such as governments have the purchasing power to shift incentive for third party vendors to ensure product accessibility, creating downstream benefits for all. It should be noted the Federal Government leverages its purchasing power in this way, creating the potential for collaboration to improve accessibility in frequently sourced third-party systems such as digital hardware and software. Action i. Assign owner to audit provincial procurement processes. This auditor must have the resources to coordinate their activities across Ministries. For this reason, the auditor should be based in the new Accessibility Agency ii. Develop a plan to audit accessibility in systems procured by the Ontario government, prioritizing those used by the largest number of people. This process should also prioritize systems frequently used in the private sector, especially by small and medium enterprises who lack the purchasing power to leverage accessible procurement at favourable price points iii. Through the accessibility audit, identify and remove accessibility gaps within the procurement process itself, coordinating with Ministries on their individual accessibility plans. Combined with the procurement of accessible goods, this will create a fully accessible public procurement process end-to-end. Published alongside Ministry plans, this will provide a series of best practices for private sector emulation, which will combine with leveraged procurement from the provincial and/or Federal Government (see below) to increase accessibility in Ontario iv. Open discussions with the Federal Government to combine purchasing power in procurement agreements. This will provide further purchasing leverage on commonly sourced systems to ensure they are fully accessible. By allowing the government to procure accessible systems, these systems will become available at better price points for smaller enterprises throughout Ontario - 38 - 19 v. Issue a mandate that Supply Chain Ontario must only procure accessible products and services after January 1, 2025. Any exception must be approved by the Premier and published for public consumption. Timeline and Success Metrics i. Audit ownership to be assigned within 180 days of the creation of the new Accessibility Agency ii. A full audit of the five most procured systems, measured in terms of number of users, should be completed within the first year of audit following assignment of ownership iii. Talks of coordinating procurement should commence within 30 days of the formation of the Crisis Committee iv. Mandate to Supply Chain Ontario published within 180 days of the formation of the Crisis Committee v. The province should set a goal of coordinated procurement with the Federal Government within two years vi. Within three years of tabling this report accessibility is fully integrated into all Ontario government procurement practices - 39 - 20 Strategic Recommendations After 17 years of inaction, a different approach to accessibility is required. This is true not just within Ontario, but across Canada. The Federal Government has begun to act more decisively in the disability market with the passing of the Accessible Canada Act. This requires that all crown corporations, Federal Government entities, and federally regulated organizations publish public accessibility plans outlining key barriers and how they will be removed, in consultation with People with Disabilities, every three years. They must also produce annual progress reports. Readers of these recommendations will note that these criteria and timelines align with those required of the individual Ministry plans as per Crisis Recommendations. This is intentional. The surest path to an accessible Ontario is to harmonize provincial efforts with federal ones, leveraging the financial, logistical, and knowledge advantages of the Federal Government in this space. It is this insight that drives the 4th Reviewer’s two strategic recommendations which aim to federalize accessibility in the private sector while enabling the Ontario Government to set its own specific internal priorities for the broader public sector. The Reviewer also notes the opportunity for the provision of access to federal funding to provinces for accessibility, provided the provinces meet to be considered pre- established quality standards. These recommendations are detailed below. Given the scope of strategic recommendations, these must be owned by a combination of the Premier’s Office and Cabinet. The new Accessibility Agency can play a supporting role in this process. Strategic Recommendation 1: Shift private sector regulation to Federal Government. Ontario to retain regulation of, and focus on, broader public sector. Context There is currently a duplication of accessibility regimes in Ontario that affect some of the province’s largest private sector employers with operations in multiple provinces such as large retailers, large manufacturers, financial institutions and telecommunications providers. These two accessibility regimes are the Accessible Canada Act and the melange of provincial accessibility regimes. Of the two, the ACA has far more robust reporting requirements and enforcement mechanisms, making it a more useful regulatory platform to drive results. Enforcement is non-existent under the AODA, due to a combination of lack of resources and the size of the private sector that falls under the jurisdiction of this legislation. There are 370,000 small businesses in Ontario, which creates a logistical enforcement issue unless an agency is already collecting data on each of these enterprises. - 40 - 21 As of December 2021, there were 1.21 million employer businesses in Canada. Of these, 1.19 million (97.9%) were small businesses, 22,700 (1.9%) were medium-sized businesses, and 2,868 (0.2%) were large businesses.6 Ontario hosts 32% of Canada’s small businesses. This represents the largest regulatory burden, by province, in the country. The Federal Government has tools that can be utilized to solve the logistical hurdle of regulating Ontario’s 380,000 small businesses. The Canada Revenue Agency (CRA) routinely collects information from, and audits small and medium businesses across Ontario, making it an ideal partner to enforce the accessibility legislation currently under the AODA. While such a transition would require additional training and resources within the CRA, it is a more efficient means of enforcing accessibility than what currently occurs in Ontario, and while outside the scope of the Reviewer’s mandate, opens an avenue to extend such accessibility legislation across the country. An additional advantage of shifting private sector regulation to the Federal Government is that it is farther along in building the regulatory structure and data gathering process in disability than the Ontario Government. Alongside the ACA, the Federal Government has launched funding for numerous disability research projects that can be leveraged to provide more informed auditing and advice to both the private and public sectors. It is a more efficient use of resources to leverage these data collection processes than to develop them independently of and redundantly to the Federal government. Finally, the financial resource advantage of the Federal Government makes it a natural candidate to be responsible for accessibility regulation. Not only can it commit additional resources to fund research and audit results, but its greater borrowing power also means it is in a better position to retain risk for capital intensive actions such as systemic remediation of assets for accessibility (see also Crisis Recommendation 5). Action i. Initiate a conversation with Federal Government partners as to the feasibility and potential timelines of transferring private sector accessibility regulation and its enforcement from the provincial to federal level ii. Following agreement with the Federal Government, Ontario is to transfer the regulation, enforcement and legislative authority surrounding private sector accessibility to the Federal Government 6 Government of Canada 2022. Key Small Business Statistics 2022. Note that these numbers follow the Statistics Canada definition of small and medium-sized businesses, rather than that of the AODA, which defines a large business as any with 50 or more employees. - 41 - 22 iii. Following the transfer of authority, the current AODA enforcement and research body – the new Accessibility Agency – becomes a provincial resource to assist in implementing and enforcing broader public sector accessibility changes iv. Public sector regulation, enforcement and legislation remains under provincial control, with tied federal funding to ensure completion and maintain quality standards Timelines and Success Metrics i. Ontario government initiates discussions with Federal Government within 180 days of the tabling of this report ii. Within one year of tabling of this report, create priority areas in which to transfer jurisdiction to the Federal Government iii. The Ontario government is to transfer the enforcement and legislative authority of the private sector to the Federal Government within three years of the creation of priority areas iv. Within three years of the transfer of enforcement and legislative authority, the Canada Revenue Agency becomes responsible for auditing Ontario SMEs for accessibility Strategic Recommendation 2: While Federal Government is to own laws, standards, and regulations, Ontario maintains control over accessibility regulation of Ontario’s broader public sector, under the AODA. The Federal and Ontario governments to coordinate on quality standards tied to funding. Context As per above, the current regulatory environment surrounding accessibility in Ontario is inefficient and ineffective. Governments outside Canada that have implemented accessibility legislation rely on a more centralized model. The Reviewer contends that one unified centralized approach is more effective and efficient for all parties implementing regulations. Action i. Alongside federal partners, develop a set of quality standards that all broader public sector entities must meet to be compliant with accessibility regulation ii. Develop a funding model with federal partners to attain and maintain accessibility in the Ontario broader public sector, in accordance with previously established quality standards. Funding is to be tied to adherence with these standards. It is the recommendation of the 4th Reviewer that the - 42 - 23 Federal Government provide 50% of costs of remediating public sector buildings and digital holdings if quality standards are met. For clarity, quality standards may exceed building codes and accessibility standards. Quality standards should be directly linked to an intended experience for people with disabilities. Timelines and Success Metrics i. Development of set of quality standards within one year of accepted transfer of authority to Federal Government. These standards must be grounded in data and experience (see Tactical Recommendations) ii. Funding model established within one year of agreement of quality standards iii. Long term: Ontario becomes “north star” of provincial accessibility that other provinces seek to emulate within a national accessibility regulatory framework - 43 - 24 Tactical Recommendations Tactical recommendations are intended to build on the foundation created by the Crisis Recommendations to create a sustainable accessibility regime in Ontario. To create such sustainable change, these tactical recommendations emphasize data collection, data analysis, information dissemination, behavioural change mechanisms, and government action. The 4th Reviewer also includes a section specific to the built environment, following the assessment that this area should be treated separately from other accessibility initiatives given its future risk and high financial cost. It should be noted that while these recommendations build on the Crisis Recommendations, they may operate independently of the Strategic Recommendations. All data and change mechanisms recommended in this section, the majority of which would be owned by the new Accessibility Agency, can be shared with federal partners depending on the progress of the Strategic Recommendations. These recommendations will significantly improve the bedrock on which accessibility regulation and enforcement is based in Ontario irrespective of the progress made on the Strategic Recommendations. Tactical Recommendation Area 1: Data, Analytics, and Research As has been noted in this report, and extensively in the Interim Report, data on disability and accessibility in Ontario is poor. This is not unique to Ontario. The Federal Government is only beginning its foray into actionable accessibility data. These recommendations are intended to create a robust quantitative and qualitative data collection, data analysis and information dissemination regime for Ontario. Research Recommendation 1: Build team to collect, analyze, and publish disability research as a public asset Context: At present disability data is largely limited to the Federal Government, using blunt tools such as census data. There has been little effort to systematically collect information to understand the experiences of PWD. In these conditions, reliable data is poor, as no Agency or Ministry routinely seeks to collect, analyze and understand this data nor has a disability data and information strategy been developed. Action: i. Identify and hire a data, analytics and research team lead. This individual will be a key member of the leadership team of the new Accessibility Agency. ii. Empower team lead to hire team of qualitative and quantitative data experts to collect and analyze experiences of PWD. This team should have mixed methods expertise and operate within the new Accessibility Agency. To be - 44 - 25 clear, the team should be research and experience (UX) experts first, and can learn disability through their research. iii. Reallocate and increase funding from current accessibility awareness campaigns to the research team. This research team serves a similar role of disseminating information, yet produces greater results by also conducting original research that can then be utilized by media and/or other interested parties. Timelines and Success Metrics: i. Research lead appointed within 180 days of creation of the new Accessibility Agency ii. Budget for research team and initial six years of research sourced within 180 days of creation of the new Accessibility Agency iii. Initial research team hired within 180 days of hiring research lead iv. Publication of first research project within one year of hiring of full team. Publication of new public research quarterly, and continuously, including updates to past research Issue owner: i. Head of the new Accessibility Agency to be responsible for hiring of research team lead ii. Crisis Committee to establish operating budget for the new Accessibility Agency, including research funding, for initial six years. Budget cycle must be longer than election cycle iii. Research lead within the new Accessibility Agency to be responsible for hiring research team and conducting and disseminating research findings Research Recommendation 2: Build equitable representation and analysis of the disability population in publicly collected datasets to be used for decision- making and evaluation Context: Simply collecting disability data is insufficient to ensure an accessible Ontario. There is a need to ensure this data is not only an accurate representation of disability (i.e.: proportionately capturing disability “types” across social groups) but is also integrated into analysis across social issues. For example, disability data must be integrated into the analysis of housing, educational outcomes, and health care outcomes. This capacity for data capture and analysis must be in-house and not outsourced. Once collected, this data must form a basis for public policy decision making and evaluation, and should be - 45 - 26 used to inform the activities of broader public sector organizations. This information should be a public asset to be used to inform the activities of private sector organizations. This research will also allow for the benchmarking of PWD experience. Action: i. As part of research activities, the research team within the new Accessibility Agency must be tasked with building public datasets. These datasets should reflect known frequency of disability within the population, across age and disability type. It must include economic data such as income, employment and added cost to individuals driven by disability. ii. Data and analysis must be widely marketed to the public, the broader public sector and private sector shareholders for use in decision making iii. Data must be actively disseminated to the public in channels and formats that allow for easy consumption (see Research Recommendation 4). iv. Data is to be used for audits and public policy decisions by relevant policy stakeholders Timelines and Success Metrics: i. Creation of first working dataset within two years of securing the new Accessibility Agency research funding ii. Publication of public dataset within three years of the new Accessibility Agency research funding iii. Recurring updates to dataset(s) every 90 days to reflect ongoing research iv. Mandated use of accessibility datasets within one year of publication for public policy decisions in all issue areas at provincial and municipal levels of government, as well as audits of public policy – starting with health, education, housing and transportation Issue owner: i. The creation, curation, and analysis of datasets is the responsibility of the research lead within the new Accessibility Agency ii. The new Accessibility Agency is responsible for demonstrating relevance of public data for public policy making, and in specific issue areas, within one year of its publication iii. Individual stakeholders in the broader public sector are responsible for using this data in their design, evaluation, and auditing of public policy and service delivery, with the new Accessibility Agency research team providing a supporting role upon request - 46 - 27 Research Recommendation 3: Direct coroner reports to record disability in order to measure relative mortality Context: One critical area of missing data pertains to life expectancy for PWD. Because disability is not captured in mortality demographics, this is a critical black box of information. Yet, it is likely that there are significant differences in life expectancy for PWD compared to the general population. First, disability is not well considered in emergency procedures, making accidental death more likely. Second, disability is more likely to coincide with co-morbidities for illnesses such as Covid-19. Finally, disability is more prevalent in other conditions likely to lead to higher mortality rates such as age and lifestyle. Action: i. Ontario must direct coroner reports to include disability, including disability type, regardless if disability is related to cause of death ii. Coroner data must be shared with the new Accessibility Agency research team for integration into public datasets, with required consideration of the privacy of health care data Timelines and Success Metrics: i. Ontario must direct coroners to record disability within one year of the tabling of this report ii. Disability should be integrated into mortality reporting within 180 days of provincial directive Issue owner: i. The Ministry of the Solicitor General is responsible for directing coroners and ensuring disability is integrated into mortality reporting ii. The Ministry of Solicitor General must ensure this data is shared with the new Accessibility Agency research team iii. The new Accessibility Agency research team is responsible for integrating this data into public datasets Research Recommendation 4: Develop a province-wide public disability dashboard Context: Accountability for progress under the AODA is low. A key reason for this is the lack of data and knowledge about the state of accessibility in Ontario. From a public education perspective, this has also led to disjointed and ad-hoc activities that rarely capture the - 47 - 28 scale of disability in Ontario and the experience of PWD in any way, thus leading to wasted resources on educational opportunities. To create accountability, media, opposition parties, and the public must be able to clearly track accessibility and accessibility progress in Ontario. This is the case for other states in the disability space, such as New Zealand, which has created a public disability dashboard that is easily consumed by all. It should be noted that this public dashboard approach was recently adopted in Ontario for tracking Covid-19 data. At that time, this allowed for greater public debate and accountability. It was also an invaluable resource for the Ontario private sector for charting their course in an otherwise information poor environment. Action: i. As part of the Data, Analytics and Research Team, identify lead specialized data and visualization analyst within the new Accessibility Agency research team to own public data presentation ii. Create a public dashboard with all quantitative accessibility data iii. Continued updating of dashboard to reflect new research and findings iv. Provide links on dashboard to further qualitative studies and reading Timelines and Success Metrics: i. Hiring of data analyst responsible for public dashboard within 180 days of hiring research team lead ii. Launch of dashboard including first database results within 90 days of first dataset completion iii. Creation of qualitative research library within one year of dashboard launch Issue owner: i. The public dashboard is to be owned by the new Accessibility Agency Research Recommendation 5: Establish a panel with PWD to consult on priority issues impacting accessibility Context: A key principle in accessibility is “nothing for us without us.” In other words, that People with Disabilities must be consulted through the entirety of a product, service, or policy design cycle. This emphasis on experience is a major theme of the 4th Review of the AODA. - 48 - 29 Too often, the principle of “nothing for us without us” has led to an emphasis on consulting advocacy organizations and/or “experts” rather than the main PWD users of a product, service, or experience. This has in turn led to an emphasis on standards rather than the processes PWD most frequently use when engaging with a given environment. It has also led to costly accessibility initiatives on systems that PWD almost never use. Done properly, consulting with those with lived experience reduces the cost of targeted program delivery. An example is the UK Fulfilling Lives Programme, which funded local partnerships across 12 areas in England to address complex needs such as homelessness, mental illness, and substance abuse. This program saved more than £700 per person, per year in government services. Essential to this program was that its intended beneficiaries were engaged as users to co-produce program reports. This led to the abandonment of programs that actual users knew would be ineffective, saving significant resources. Given the number of PWD in Ontario, building a significant panel of users to consult is not a difficult undertaking. Having these individuals available will provide a simple and direct source of consultations for government stakeholders, both for creating their own accessibility plans, and for the creation and evaluation of policy. Action: i. Assemble panel of 100 PWD for initial consultation work. This panel should reflect the disability population in terms of disability type. These users should not be employed as activists or be members of advocacy organizations to ensure consultations capture ordinary users (advocates may be consulted at other stages of projects) ii. Make panel available across government stakeholders for consultations on accessibility plans, experience design and public policy iii. Continue to expand panel over time, with a goal of exceeding 1,000 users, with rotating membership iv. The new Accessibility Agency may wish to consult with advocacy groups and “experts” periodically as a confirmation and/or fact-finding exercise. This must not act as a replacement for robust user research Timelines and Success Metrics: i. Assembly of initial panel of 100 users within one year of appointment of the new Accessibility Agency research team lead ii. Addition of 100 panelists/quarter, with a target of 1,000 PWD as “steady state” after two years - 49 - 30 iii. Consultation with PWD users for every service design, accessibility plan, legislative design or review, as needed, within 180 days of assembly of first panel iv. Creation of specific panels for health, education, and Ontario Public Service within two years v. Build and maintain specific panels for municipalities and/or groups of municipalities, within three years Issue owner: i. The creation and maintenance of user panels is to be owned by the new Accessibility Agency ii. Public sector stakeholders are responsible for engaging these panels in consultation with the new Accessibility Agency Research Recommendation 6: Define and update measurable outcomes for accessibility success, reflecting diverse stakeholder needs Context: A common theme that emerged when consulting private and public sector AODA stakeholders is that there is no clear idea as to what success looks like. This has led to either following the advice of advocacy organizations, or relying on externally generated standards, both of which materially ignore the experiences of core PWD users. A key task of the Crisis Committee is to establish a set of preliminary outcomes to inform the first year of accessibility planning (see Crisis Recommendations 2 and 4). These outcomes must continue to evolve as new data is collected. These outcomes must be multifaceted, targeting specific policy areas such as, but not limited to, employment experience within the broader public sector, health, and education. For reference, see Phase 2 of the Review of the Information and Communications Standards – 2020 Final Recommendations Report. For clarity’s sake, it is plausible that “audited adherence to Standard X” could be a measurable outcome. This assumes, of course, that adherence to Standard X reflects the actual intended experiences of users with disabilities. Action: i. Develop clear metrics establishing the current state of accessibility in the public sector, emphasising health, education, and the Ontario Public Service ii. Establish clear target benchmarks that can be measured and tracked over time to ensure progress and accountability - 50 - 31 Timelines and Success Metrics: i. Establishment of key metrics to be used to define current state of accessibility within one year of hiring research team in the new Accessibility Agency ii. Publication of “where we are” metrics across health, education, and Ontario Public Service within one year of definition of key metrics. This publication should include integration into the public dashboard (see Research Recommendation 4) iii. Continuous updating of metrics as new information becomes available, including new research and annual progress reports Issue owner: i. The new Accessibility Agency is responsible for the creation of success metrics, in consultation with relevant public sector stakeholders ii. Broader public sector Ministries, departments and agencies are responsible for collecting and sharing internal data on their current state, using the new Accessibility Agency success metrics iii. The new Accessibility Agency is responsible for aggregating and disseminating current state of accessibility and track/publish progress over time Research Recommendation 7: Develop public accessibility action plan and publicly share and track progress against previously identified milestones Context: Publicly available data and clear success metrics promote accountability. Accessibility action plans can only be successful if owners are held to account. A key element of improving accessibility is thus ensuring that plans, success metrics, and progress are made publicly available. It should be noted that it is already mandatory for many organizations to create public multiyear accessibility plans – the key needed differences are that these plans have annual public progress reports tied to milestones to ensure accountability, and critically, that the plans must extend beyond legalistic/boilerplate commitments to meet the experience needs of the public and of public sector employees. While provincial public sector entities must already meet these requirements, they must be made more robust in light of stalled progress on this file. Action: i. The Ontario Government, municipalities and their respective Ministries, departments and Agencies must each publish an accessibility plan every three years, with progress reports every year (see Crisis Recommendation 2). These - 51 - 32 plans must be based on consultations with PWD, identify current barriers for both the public and employees in their interaction with the Ministry/Agency, and how the Ministry/Agency intends to remove those barriers over the life cycle of the plan. Note that this follows the structure of the Accessible Canada Act. ii. A new plan must be published for each Ministry, department and Agency every three years Timelines and Success Metrics: i. Publication of an accessibility plan for each Ministry, department and Agency within two years of the tabling of these recommendations (see Crisis Recommendation 2). ii. Publication of success metrics, as defined by the new Accessibility Agency within one year of the public release of accessibility plans to be integrated into subsequent plan cycles iii. Publication and tracking of all broader public sector accessibility plans as part of the provincial accessibility dashboard within 180 days of integrating success metrics Issue owner: i. Each government Ministry, department and Agency is responsible for their respective accessibility plan and progress report ii. The new Accessibility Agency is to play a support role, upon request, in the creation of accessibility plans iii. The new Accessibility Agency is responsible for aggregating Ontario accessibility plans and integrating into public dashboard Research Recommendation 8: Develop public feedback mechanisms for accessibility across the broader public sector Context: The collection of data is not limited to specific studies conducted by the new Accessibility Agency. Particularly in the context of identifying accessibility barriers and obstacles to maximizing public and/or employee experiences with a Ministry, department or Agency, it is necessary to collect continuous stakeholder feedback. For this reason, it is essential that all Ministries/Departments/Agencies allow for the submission of anonymous feedback through a variety of channels. Moreover, given the lack of knowledge of government agencies, it is necessary that feedback be shared from where it is submitted to the correct stakeholder to allow proper aggregation and response (No Wrong Door). - 52 - 33 Action: i. Each Ministry, department and Agency must provide multiple means of providing feedback related to accessibility in their area of operations, including employment. Feedback should be able to be provided via phone, email, or mail, at minimum. Feedback information should be easily available on the website of the Ministry, department or Agency, and also be within the 3-year Accessibility Plan (see Research Recommendation 7) ii. Each Ministry, Department or Agency must forward feedback that does not pertain to their organization but instead to an alternative Ministry, Department or Agency to the new Accessibility Agency iii. The new Accessibility Agency must organize feedback sent to the wrong Ministry or Agency and provide it to the relevant stakeholder iv. Feedback should inform Ministry and Agency progress reports and subsequent Accessibility Plans. They are not sufficient on their own to constitute consultations Timelines and Success Metrics: i. Feedback mechanisms must be published alongside Accessibility Plans (see Research Recommendation 7) ii. The new Accessibility Agency must have a team in place to reallocate feedback prior to the publication deadline of provincial Accessibility Plans Issue owner: i. Each Ministry, department and Agency is responsible for providing feedback mechanisms ii. The new Accessibility Agency is responsible for reallocating feedback as required and ensuring compliance with feedback obligations by Ministries, Departments and Agencies Tactical Recommendation Area 2: Behavioural Change Tools and Mechanisms For 17 years the AODA has created and nominally enforced standards as a way of changing behaviour in both the private and public sectors. The sole use of standards has failed. Alongside lack of consistent and meaningful enforcement, there have been few positive incentive-based mechanisms of change. This in turn has made organizations reluctant to increase accessibility for a misguided fear of high costs and low returns. Both the costs and returns must be addressed to create sustained behavioural change. - 53 - 34 Behavioural Change Recommendation 1: Pilot accessibility funding initiatives including social impact bonds and customer fees Context: A crucial barrier in addressing accessibility concerns is cost, especially for small- and medium-sized enterprises, and for capital-intensive remediations such as those to built environments. This has led to inaction across accessibility. Without intervention, smaller organizations will be unable to meet their accessibility requirements, and large, federally regulated organizations may consider divesting certain assets if they must unilaterally bear the cost of meeting their accessibility requirements in built environments. This will in turn put downward pressure on some of the highest value corporate real estate in Ontario, thus creating a significant economic risk. Action: i. Identify and vet investors that aspire to provide social impact bonds tied to accessibility ii. Create social impact bond pilot project that prioritizes high cost remediations such as those to built environments. Results of pilot project are to be aggregated by the new Accessibility Agency and publicly published iii. Conduct research on public response to small accessibility surcharges on identified government services. The model for this program would be airport improvement fees that can only be applied to remediations and improvements of current airport infrastructure. Timelines and Success Metrics i. Plan for social impact bond developed, including process of vetting of potential investors, within one year of the new Accessibility Agency receiving full funding ii. Opening of application process for social impact bond pilot process within 180 days of plan development iii. Full evaluation report of pilot study within two years of launch, with subsequent publication iv. New Accessibility Agency to complete study of reaction to surcharges within two years of hiring internal research team Issue Owner i. Social impact bond program to be developed and operated by the Ontario Financing Authority, in consultation with the new Accessibility Agency ii. Study of surcharges to be completed by the new Accessibility Agency - 54 - 35 Behavioural Change Recommendation 2: Apply social influence tools to shift public conversations and underlying social norms about disability and accessibility Context: People with disabilities consistently indicate the most frequent barriers they encounter are attitudinal. Shifting attitudinal barriers is difficult to do through regulation. Instead, the Ontario Government should be seeking to shift norms underlying discussions of disability. Normative shifts require persuasion, especially on key potential first-movers that will push smaller players to follow. This will require a multifaceted approach including use of social platforms, understanding current norms, and identifying key messages and potential first-movers. Action: i. Identify current norms and conversational trends surrounding issues of disability and accessibility in Ontario, emphasizing social platforms and mainstream media to maximize reach. The focus needs to be outside of advocacy groups ii. Identify potential first-movers that could be engaged to shift conversations on disability in Ontario iii. Craft potential messages to emphasize for first-movers, centering lived experiences and the messages themselves avoiding stereotypes iv. Create process to measure changes in conversations on disability on social platforms over time v. The Reviewer highly recommends engaging high-quality outside message consultants to assist in messaging. To date, Provincial communications teams have struggled to deliver compelling messages involving disability Timelines and Success Metrics i. Audit of accessibility norms and conversations in Ontario context within one year of the new Accessibility Agency receiving full funding ii. Identification of key influencers within one year of the new Accessibility Agency receiving full funding iii. Crafting of targeted message points within 180 days of identification of key influencers iv. Launch of influence campaign leveraging and potentially funding influencers to spread identified messaging within two years of the new Accessibility Agency receiving full funding v. Quarterly analysis of influence campaign impact - 55 - 36 Issue Owner i. The social influence campaign will be designed and operated by the new Accessibility Agency Behavioural Change Recommendation 3: Partner with Ontario’s tech leaders to explore low-cost technology solutions to identify leaders in space and build accountability Context: Given current regulatory challenges, it has been difficult to generate accountability within the private sector. Indeed, PWD have consistently indicated few improvements in accessibility in Ontario. Alongside this lack of accountability, there are no clear examples of who is doing this well. To mitigate this, there is the potential to use crowd-sourced review software to provide real time feedback for accessibility, thus identifying leaders and laggards in this space. Action: i. Explore partners that can configure interfaces that enable required user inputs for relevant accessibility information ii. Partner with companies to add features that promote accessibility within businesses by providing a public score that users can contribute to Timelines and Success Metrics i. Explore partners that can configure necessary interface within one year of launch of the new Accessibility Agency ii. Bid out and award contract to develop program within 180 days of partner exploration iii. Create a fully functional pilot program within one year of awarding of this contract; overall target is three years since the reading of this report Issue Owner i. The interface program is to be owned by the new Accessibility Agency Behavioural Change Recommendation 4: Identify organizational benefits in increasing accessibility and build appeal into communications with private sector stakeholders Context: The market size of PWD should create incentives for private sector entities to increase accessibility in order to maximize profitability. However, at present few organizations are - 56 - 37 aware of the size of the disability marketplace. Moreover, inaccurate preconceptions of PWD poverty have precluded organizations from meaningful action in this space. From a practical standpoint, creating change is easier and more sustainable through the realization of positive incentives than solely from the threat of regulatory penalty. Not only does it incentivize organizations going above and beyond minimum standards, it also reduces the cost of regularly auditing over 412,000 organizations. Action: i. Identify priority messages to communicate to private and public sector stakeholders, emphasizing economic return ii. Communicate these messages amongst stakeholders, prioritizing larger organizations that are likely to be emulated by smaller ones iii. Reinforce messaging during audit cycles, especially in instances of non- compliance, to promote change Timelines and Success Metrics i. Identification of key messages within 180 days of the new Accessibility Agency receiving funding ii. Targeted messaging disseminated to large public sector stakeholders within 90 days of message identification, to large private sector stakeholders within 180 days of identification, and to medium-sized stakeholders within one year. Mass communication to small enterprises within two years of key message identification or during audit processes, whichever is sooner Issue Owner i. The new Accessibility Agency is responsible for collecting and disseminating key messages of the benefits of accessibility Behavioural Change Recommendation 5: Deliver nudge-based programs and tools to incentivize more prompt and effective organizational compliance Context: Regulation and “strong” incentives, such as those that provide additional funding, are costly. Given the scale of change that must occur in Ontario, reducing these costs is a public expenditure priority providing accessibility targets can be met. One way of reducing costs is by using information sharing and the desire to emulate more successful practices on the part of public and private organizations to “nudge” compliance. This approach has been used most successfully in the U.K. whose government has invested significantly in this approach. - 57 - 38 Action: i. As part of accessibility auditing and data collection processes, identify key barriers to compliance in different sized organizations and in different public/private sectors ii. Identify leading and/or innovative practices that organizations have used to overcome these barriers while maintaining proprietary information iii. Communicate best practices in comparable organizations to those struggling to overcome key barriers to compliance to encourage emulation and build their internal processes and capacity iv. Research must be global, beyond Ontario’s borders, to maximize impact. Timelines and Success Metrics i. Identification of key barriers within one year of full Accessibility Agency funding ii. Identification of leading organizations that have overcome key barriers within 180 days of barrier identification iii. Communication of key insights from leading organization to lagging organizations within one year of identification of leading practices, to be repeated during audit periods Issue Owner i. Nudge practices are to be owned by the new Accessibility Agency Behavioural Change Recommendation 6: Tie public sector results and execution of accessibility plans to compensation packages at Deputy Minister level Context: Within an organization, two of the most significant barriers to acting on accessibility commitments are a lack of governance and a corresponding lack of accountability. Establishing governance and accountability starts at the top of an organization. This is true of both the private and public sectors. Unlike the private sector, the Ontario Government can shape governance within public sector organizations. While recognizing the need for organizational autonomy, leaders of Ministries – Deputy Ministers – must be held accountable for accessibility within their Ministries to avoid a repeat of 17 years of inaction. - 58 - 39 Action: i. Tie action – the publication of accessibility plans and the meeting of their goals – to compensation for Deputy Ministers. This will establish individual responsibility for instituting proper internal governance and accountability models. To be clear, the Reviewer is recommending that Deputy Ministers be required to sign accessibility plans and that their pay be cut by at least 5% if they do not meet the objectives on accessibility in their plans Timelines and Success Metrics i. Progress, measured in annual progress reports of accessibility plans, to be tied to Deputy Minister signing and pay within three years Issue Owner i. Responsibility for ensuring signing of accessibility plans and pay incentives are executed will rest with the Treasury Board Secretariat, supported by the new Accessibility Agency. Behavioural Change Recommendation 7: Formally recognize disability as core platform of Environmental, Social, and Corporate Governance (ESG) Context: At present, ESG is a key pillar shaping business decisions, and one of the core concepts encouraging and incentivizing businesses and public sector organizations to conduct their business and service delivery in ways that capture emerging demand. Explicitly including disability under the “social” component of ESG will accelerate action within organizations by providing easier socialization and harmonizing accessibility initiatives with other areas of corporate governance. Tying accessibility to ESG is also a no-cost way of the Ontario Government signalling the importance of this issue. It also presents an opportunity for the Ontario Government to demonstrate leadership on this file. Action: i. Identify leading large private organizations willing to be first movers in integrating accessibility into ESG ii. Alongside potential first movers, collaborate on relevant accessibility standards and definitions to be incorporated into ESG umbrella – for example, The Global Reporting Initiative7 iii. Provide public support to first movers, including announcements from senior government leadership and funding mechanisms 7 Information on The Global Reporting Initiative can be found here - 59 - 40 Timelines and Success Metrics i. Identify first movers within 1 year, consistent with timelines for nudge tactics ii. Working with first movers, create definitions within 180 days of identification of first movers iii. Relevant public sector leaders to support announcements from first movers at discretion of first movers Issue Owner i. The new Accessibility Agency will be responsible for identifying potential first movers ii. The Ontario Financing Authority will be responsible for working with first movers to establish definitions and to publicly support announcements Behavioural Change Recommendation 8: Explore and pilot technology and digital solutions to bypass built environment barriers Context: Remediations to built environment, while necessary, are both costly and time consuming. To ensure inclusion of PWD in the workplace and as consumers, it is essential to develop rapid solutions that can bypass barriers in the built environment while barriers are remediated. Technology can be leveraged to temporarily overcome these barriers. In particular, insights from the Covid-19 Pandemic can be leveraged to understand how to maximize participation even when built environments remain inaccessible. This includes working from home, digital shopping, and increases in services offered online. Providing a stop-gap to built environment barriers will increase Ontario’s workforce and consumer base. Moreover, it should be noted that in the survey commissioned by the 4th Reviewer, PWD consistently indicated they faced few, if any, digital barriers when compared to built environments. Action: i. Identify industries that provide greatest impact from implementing digital technologies that emphasize working from home ii. Create and fund pilot project to implement/incentivize digital solutions in select, high value sectors. Timelines and Success Metrics i. Begin return on investment (ROI) analysis for digital solutions within one year of launch of the new Accessibility Agency ii. Completion of ROI analysis within 180 days iii. Launch of first pilot program within 180 days of completion of ROI analysis iv. Public report on preliminary project results after 180 days of program - 60 - 41 Issue Owner i. The new Accessibility Agency will be responsible for conducting research and this pilot project(s) Tactical Recommendation Area 3: Mobilizing Government Actions Notwithstanding the Reviewer’s Strategic Recommendations, there is need to further mobilize government action in two key areas: cooperation between levels of government and the enforcement of accessibility legislation in both the public sector (auditing themselves) and the private sector. Mobilizing Government Recommendation 1: Develop a cooperation framework between levels of government that clarifies their roles in improving accessibility Context: Once the Strategic Recommendations are completed it will be necessary to develop clear role expectations for three levels of government: federal, provincial, and municipal. Even prior to the completion of the Strategic Recommendations there is a key need to harmonize provincial and municipal service delivery, as municipalities are often on the front line of service delivery, with the provincial government providing funding. Action: i. Assess level of need to initiate reforms based on specific levels of government. This should be done in consultation with key stakeholders, including a range of municipalities across the province that vary along key demographic factors such as age, population, and population density. ii. Assign a federal liaison to coordinate with the new Accessibility Agency to ensure cooperation between three levels of government. Given existing overlap with the ACA, it is imperative that this liaison work with all three levels of government even before completion of Strategic Recommendations Timelines and Success Metrics i. Assessment of potential reforms across levels of government completed within one year of the publication of the provincial accessibility plans ii. Appointment of federal liaison within one year of the publication of provincial accessibility plans Issue Owner i. The federal liaison will be tied to the Ministry of Intergovernmental Affairs. - 61 - 42 ii. The assessment of potential reforms will be done by the new Accessibility Agency, in collaboration with stakeholders across levels of government Mobilizing Government Recommendation 2: Strengthen enforcement measures Context: Independent reviews of the AODA have consistently found that enforcement is non- existent. This is in large part due to lack of resources made available given the number of organizations subject to the AODA. While the Reviewer views positive incentives – “carrots” – as preferable to sanctions, sanctions must be available as a viable policy lever. Enforcement should fall under the purview of the new Accessibility Agency to ensure the power to sanction is combined with the knowledge necessary to utilize complementary tactics such as nudging. Action: i. Provide resources to Accessibility Agency to increase number of audits and site inspections – the level of which should be similar in scale to Ontario Securities regulations and CRA audit/enforcement metrics ii. Leveraging data collection and organizations identified as leaders in the accessibility space, provide necessary support to small and medium enterprises to comply with regulations (see also Behavioural Change Recommendation 5) iii. Provide greater authority to relevant enforcement officials, including the ability to publicize and prosecute instances of non-compliance iv. KEY SHIFT: Establish complaint procedures for centralized resolutions of public sector barriers Timelines and Success Metrics i. Develop and implement public complaint procedures within 1 year of the tabling of this document ii. Provide greater authority to enforcement officials within 1 year of the tabling of this document iii. Allocate additional resources for hiring within provincial jurisdiction of AODA enforcement (keeping in mind strategic recommendations), within 3 years of the tabling of this document iv. Create a package of support tools for small and medium enterprises – including explicit funding – to comply with the AODA, leveraging insights from Research and Behavioural Change Recommendations, within two years of the tabling of this document - 62 - 43 Issue Owner i. Enforcement and complaint mechanisms should be owned by the new Accessibility Agency Mobilizing Government Recommendation 3: Create the permanent position of Assistant Auditor General, Commissioner of Accessibility within the Office of the Auditor General of Ontario Context: The role of Reviewer has proven to be a dull tool to hold the government of the day to account on accessibility. Four consecutive reviews have found fundamental gaps in implementing the AODA. Clearly, this approach has not been effective. Furthermore, it is unclear whether the AODA allows for continued reviews after 2025. In creating the new role of Assistant Auditor General, Commissioner of Accessibility within the Office of the Auditor General of Ontario, a more consistent approach to oversight is created. This action also elevates accessibility to a prominent place within the formal oversight regime of the province. Given the scale and scope of disability and 17 years of inaction from two duly elected governments, the Reviewer sees this as an appropriate impetus for oversight and public accountability. Action: i. Establish the role of Assistant Auditor General, Commissioner of Accessibility within the Office of the Auditor General of Ontario ii. Assistant Auditor General, Commissioner of Accessibility, along with the Auditor General is to report to the Ontario Legislature on the State of Accessibility in Ontario no less than annually. iii. These reports must include the following: a. An independent assessment regarding progress made on the Crisis Recommendations made in this report. This shall continue until the Auditor General deems the crisis over b. A financial accounting of program spending for accessibility within Ontario’s broader public sector c. An assessment of the level of accessibility in Ontario d. Ongoing recommendations to achieve full accessibility in Ontario’s broader public sector Timelines and Success Metrics i. Hire the role Assistant Auditor General, Commissioner of Accessibility under the Office of the Auditor General of Ontario within 180 days of tabling this report - 63 - 44 ii. Publish an audit of action on the Crisis Recommendations contained in this report within 270 days of the tabling of this report. Until the crisis is deemed over by the Auditor General, subsequent gap analyses shall be published every 90 days iii. Publish a Report to the Ontario Legislature annually iv. Liaise closely with the new Accessibility Agency and Ministries to educate, provoke best practise and audit activity Issue Owner i. The process managed by the Commissioner of Accessibility is to be owned by the Office of the Auditor General. Tactical Recommendation Area 4: Built Environments It is the assessment of the 4th Reviewer that built environments must be considered separate from other accessibility initiatives and projects. The reason for this is twofold. First, the cost of remediating built environments far exceeds the capacities of most small or medium enterprises to do so. Even for large organizations, the amount of property owned can make the cost of full remediation difficult if not impossible. Second, built environment concerns pose a material risk to the Ontario economy. The Accessible Canada Act mandates that all federally regulated entities must remove barriers in their built environment. These entities – including all financial institutions and telecommunications providers – are major leaseholders in some of the most lucrative real estate markets in the province. Unless these buildings can be remediated, these organizations will have little choice but to abandon such leases. This will put significant downward pressure on corporate real estate valuations, leading to reduced revenue for the province and larger municipalities. Built Environment Recommendation 1: Provide financial and non-financial support for existing and new built environment projects as they pertain to accessibility Context: The cost of built environment remediations exceeds the ability of organizations to unilaterally bear. Without government intervention, this will create high levels of risk as leases to federally regulated entities expire. These types of interventions represent a perfect risk mitigation role for governments in a market economy. - 64 - 45 Action: i. Explore social impact bonds for high-cost infrastructure projects (see also Behavioural Change Recommendation 1) ii. Issue negative interest rate loans for built environment improvements. These loans should incur negative interest providing accessibility goals are being met, thus incentivizing built environment improvements. Priority should be given to spaces leased by federally regulated entities to mitigate future economic risk Timelines and Success Metrics i. For timelines on social bonds see Behavioural Change Recommendation 1 ii. Assess requirements and feasibility of negative interest rate loans within one year of tabling this report iii. Providing loans are feasible, open first round of applications and assessments within 180 days of completing assessment of feasibility, prioritizing those space leased to federally regulated entities and those with greatest financial risk iv. Expansion of program to other entities within five years of launch, prioritizing based on highest cost and number of persons impacted by potential barriers Issue Owner ii. The loan program is to be owned by the Ministry of Economic Development, Job Creation and Trade Built Environment Recommendation 2: Audit accessibility of public sector built environments Context: It is probable that large amounts of public sector real estate fall short of accessibility requirements. This is in large part due to the large number of older buildings in use across the province. However, to be a leading organization that the private sector can emulate, the Ontario Government must prioritize its own accessibility. The first step to doing this is identifying current gaps, while also making these gaps public to ensure accountability. Action: i. Conduct full accessibility audit of all provincial building, prioritizing education and healthcare ii. Publication of audit results on accessibility dashboard - 65 - 46 Timelines and Success Metrics i. Commencement of audit process within 180 days of tabling of this report Issue Owner i. Each Ministry to be responsible for the auditing of its built environments, in consultation with the new Accessibility Agency Built Environment Recommendation 3: Ministry of Infrastructure to become Center of Excellence for accessibility in built environments Context: As both a high-cost area and one in which the province will be making continued investments to both its property holdings and those in the private sector, it is essential to develop centralized built environment expertise. Consistent with the principle of separating the built environment from the remainder of accessibility initiatives, this expertise should reside within the Ministry of Infrastructure. Action: i. Identify best practices in built environment remediations by identifying leading players and practices in this space ii. Create repeatable processes and benchmarks for remediations in different built environments that can be provided to public and private stakeholders iii. Create an action team within the Ministry of Infrastructure that can provide expertise and advice to private and public stakeholders for all new projects and remediations Timelines and Success Metrics i. Identification of best practices and leading actors in this space within two years of tabling of this document. ii. Creation and publication of sharable documents within 180 days of identifying best practices iii. Action team within the Ministry of Infrastructure to be created within two years of the tabling of this document Issue Owner i. New Accessibility Agency to be responsible for initial identification of best practices and leading actors ii. Ministry of Infrastructure responsible for creating sharable documents and building internal expertise in consultation with the new Accessibility Agency iii. New Accessibility Agency to provide oversight of program - 66 - 47 Built Environment Recommendation 4: All provincial buildings to be accessible by 2030 Context: Given the current state of accessibility progress in Ontario, the goal of provincial government real estate being accessible by 2025 is unrealistic. A 2030 timeline is plausible with material investment. These investments must be made. The Ontario Government must demonstrate leadership in the built environment – the most costly aspect of accessibility – so others will follow. Action: i. Full remediation of all provincial buildings, making them accessible Timelines and Success Metrics i. All provincial buildings pass accessibility audit by 2030 ii. Highest traffic buildings: schools, hospitals, Service Ontario, and large provincial employers to be remediated prior to 2030 deadline iii. Publication of audit results in 2027 and 2030, including explanations for remaining non-compliant environments Issue Owner i. Each Ministry responsible for its own remediations ii. Budgetary support to be provided by the Treasury Board Secretariat iii. Audit of built environments to be conducted by the new Accessibility Agency iv. New Accessibility Agency to publish audit results every three years thereafter to maintain and improve experience for PWD - 67 - 48 Conclusion This report is not intended to be an indictment of the Ontario Government. While the identification of gaps is necessary, the emphasis of the Recommendations Report is how to move forward. It is the conclusion of the 4th Reviewer that accessibility in Ontario currently constitutes a crisis, and that bold and decisive action is needed. Declaring a crisis allows this action to occur. Within one year of the tabling of this document, the Ontario Government must implement all Crisis Recommendations to reduce immediate risks to life and to lay the necessary groundwork for future success in accessibility. A second bold – and in the eyes of the Reviewer necessary – action is transitioning the regulation of accessibility in the private sector from the Ontario Government to the Federal Government. At present there is a wasteful duplication of regimes for some of the largest organizations operating in the province, as well as a lack of provincial resources to properly audit and enforce the number of small and medium enterprises in the province. These tools are available to the Federal Government. They must be utilized. Finally, while the Reviewer provides 23 tactical recommendations, emphasis must be placed on lived experience, aggregated as proper data and analysis. The single greatest missed opportunity of the past 17 years of the AODA has been data collection. Without data, there can be no informed decision-making, no accurate measure of improvement, no accountability, and thus no impetus for change. More importantly, data presents the positive case for accessibility. The case for accessibility is clear for those with experience in disability economics. At least 2.9 million Ontarians currently live with a disability. This number is growing. These Ontarians represent at least 22% of the consumer base and the workforce. Due to barriers, Ontarians with disabilities are too often falling short of their full potential. This is a massive cost to the Province of Ontario, limiting economic efficiency and consumption. They are also voters. The conclusion of the Interim Report opened and concluded with the question “Do you care?” The implications of getting accessibility right – and the continually rising costs of failing to do so – are why the Ontario Government must care. Must prioritize. And must act. Any further delays are an unacceptable risk to the province. - 68 - 49 Appendix 1: List of Organizations Consulted by the 4th Reviewer8 • Organizations Consulted • Accessibility Standards Advisory Council • Accessibility Standards Canada • AODA Alliance • Association of Municipalities Ontario • BC Accessibility Directorate • Cabinet Office • Carleton University • Centre for Addiction and Mental Health • City of Toronto • Canadian National Institute for the Blind (CNIB) • Colleges Ontario • Conference Board of Canada • Design of Public Spaces Standards Development Committee • Employment and Social Development Canada • Inclusive Research Design Centre • Ministry of Intergovernmental Affairs • Inter-University AODA Coordinators • K-12 Education Standards Development Committee • March of Dimes Canada • Metrolinx • Ministry of Public and Business Service Delivery • Ministry of Infrastructure • Ministry of Municipal Affairs and Housing • Ministry for Seniors and Accessibility • Ministry of Transportation • Ontario Human Rights Commission • Ontario Hospital Association • Ontario Restaurant Hotel & Motel Association • Ontario Catholic School Trustees' Association 8 Note that the Reviewer spoke to multiple individuals at many organizations, as well as with a series of individuals whose organizational affiliation would reveal their identity if listed here. Moreover, consultations were with individuals within these organizations, and as such, the Reviewer did not meet with the entirety of a given organization. - 69 - 50 • Ontario Network of Accessibility Professionals • Post-secondary Education Standards Development Committee • Retail Council of Canada • Supply Ontario • Spinal Cord Injury Ontario • Transportation Standards Development Committee • Treasury Board Secretariat • University of Guelph • University of Ottawa • University of Toronto • Winnipeg Transit • YMCA • United Way of Greater Toronto Area - 70 - 51 Appendix 2: Organizations who Submitted Written Feedback to the 4th Reviewer9 Organizations • Accessible Housing Network • Advancement of Women Halton • AODA Alliance • ARCH Disability Law Centre • Association of Municipalities of Ontario • Citizens with Disabilities Ontario • City of Ottawa • Colleges of Ontario • March of Dimes Canada • Ontario Human Rights Commission • Ontario Public School Boards’ Association • Ontario Society of Occupational Therapists • The City of Cambridge • The City of Pickering 9 Note the Reviewer also received written submissions from individuals. To ensure anonymity, these individuals are not listed here. - 71 - Copyright © 2023 Deloitte Inc. All rights reserved. Public Compendium for the 4th Review of the Accessibility for Ontarians with Disabilities Act (AODA) MAY 31, 2023 Copyright © 2023 Deloitte Inc. All rights reserved. Table of Contents Public Compendium for the 4th Review of the Accessibility for Ontarians with Disabilities Act (AODA) ............................................................................................................................ 1 Context and Overall Approach .............................................................................................................. 3 Adjacent Policy Spaces ............................................................................................................................. 3 Alternate Governance Models ............................................................................................................... 7 Conclusion .................................................................................................................................................... 9 End Notes ................................................................................................................................................... 11 Copyright © 2023 Deloitte Inc. All rights reserved. Context and Overall Approach Deloitte was contracted to provide support to the Independent Reviewer in conducting the 4th Legislative Review of the Accessibility for Ontarians with Disabilities Act. The scope of work included developing high-level strategies, conducting research and analysis, creating an assessment tool, and synthesizing findings. The objective of this compendium was to present a summary of the main findings derived from this analysis, which served as input for the Independent Reviewer in formulating the recommendations. At the onset, our team worked with the Independent Reviewer, Rich Donovan and his team to co-create an assessment framework (aspirations and scope, areas of impact, enablement success mechanisms) and key strategic choices, drawing inspiration from early stakeholder feedback and conducting preliminary secondary research on the current state of accessibility and disability. Our work was iterative, collaborating closely with the Independent Reviewer, incorporating insights from stakeholder engagement, supplementing with targeted research, and jointly refining potential recommendations. In alignment with the six guiding principles outlined in the review, the analysis conducted by Deloitte, guided by the Independent Reviewer, focused on researching two areas: 1. Adjacent Policy Spaces: For the strategic themes identified, research was conducted to explore industry practices, successes and lessons learned from policy spaces, countries, and organizations, outside of accessibility. 2. Alternative Governance Models: Tested and evaluated how greater federal involvement in accessibility regulation could create meaningful improvements for persons with disabilities (PWD) by researching 1) the level of federal regulation involvement in Canada across other policy spaces 2) how disability is regulated across other countries 3) the most appropriate type of governance model to initiate action. Adjacent Policy Spaces Overview Using the co-developed assessment framework, our analysis honed in on 9 thematic strategic choices to consider regarding the future of the AODA. These were: accessibility data, lived experiences, built environment, defining success, accountability, incentives and compliance, action planning, funding model, and resource allocation. Copyright © 2023 Deloitte Inc. All rights reserved. For the scope of research, we focused on governmental, non-profit, and private organizations both within and outside of accessibility. Geographically, we focused on Canada, Australia, New Zealand, the United Kingdom, and the United States. We explored a total of 32 case studies across 8 countries following the 9 thematic choices. Greater emphasis was placed on key areas of lived experience, building accountability, and incentives and compliance with lighter analysis conducted on the other areas. Below we have summarized the key successes and lessons learned. Key Findings Lived Experience: How could we facilitate an environment to reliably obtain, test, scale and voice lived experiences from PWD? Collecting experiences from providers and recipients, shapes policy design. For example, in domains like product features, medical testing, and technology solutions, data bias is prevalent in default user designs. Therefore, incorporating lived experiences becomes crucial to identify and rectify biases.1 Successful outcomes arise when individuals facing limitations actively engage as experts, challenging assumptions and co-producing initiatives as seen in the UK Fulfilling Lives Programme.2 Furthermore, focused collections of lived experiences provide compelling evidence of impact, benefiting the wider population and generating economic opportunities.3 Building Accountability: How could we engage stakeholders as a customer to increase accountability and make it easy to comply (e.g., education, training, government support, address unique needs)? By leveraging the 5-step potential framework called SHIFT, which encompasses social influence, habit, individual self, feelings/cognition, and tangibility, stakeholders can effectively engage in behavior change.4,5 Moreover, using a crowdsourcing review software could provide a cost-effective and scalable way to hold businesses accountable. Partnering with review companies in the private sector to rate and promote accessibility within businesses could initiate action within the private sector and improve the experience for PWD.6 Lastly, achieving broad-scale accountability in social issues necessitates a dedicated and sustained campaign, marked by transparent public and social media engagement, with the potential for a single organization to spearhead this transformative endeavor.7,8 Incentives and Compliance: What incentive mechanisms could we create to drive compliance and behavioral evolution for stakeholders (outside of PWD)? Copyright © 2023 Deloitte Inc. All rights reserved. To drive behavioral evolution, regulatory clarity provides the necessary incentive to encourage consumer adoption, addressing barriers in product affordability and access.9 Additionally, leveraging tools such as social engineering, psychology, and marketing enables effective decision-making influence and policy compliance support. By defining outcomes, understanding context, building interventions, and conducting randomized control trials, the process of forming a nudge becomes achievable.10,11 Lastly, exploring cost-effective digital-based solutions, like crowd-sourced technology, incentivizes greater compliance with public measures for citizen well-being.12 Accessibility Data: How could we consistently gather and share data (qualitative and quantitative) on the overall gaps and progress for accessibility? In situations where issues span across international borders, such as the case of COVID- 19, the sharing of data, both anonymous and otherwise, presents an opportunity to drive open discourse and informed decision-making. Utilizing a public-facing dashboard, like the CDC COVID Tracker, to aggregate and visualize national-level data proves effective in communicating progress on social issues and enhancing public understanding.13 Lastly, taking inspiration from New Zealand, allocating resources to create an interactive Tableau dashboard for publicly sharing and visualizing accessibility data showcases a commitment to transparency and facilitates meaningful discussions.14 Built Environment: How could we address concerns on existing built environments and plan for new developments? Setting up technology infrastructure is an effective approach to address barriers faced by populations with limitations, particularly those in rural areas.15 This approach minimizes the need for costly and time-consuming adaptations to existing built environments. Additionally, to promote accessibility in new developments and existing buildings, government support in terms of design and technical assistance for designers and contractors prior to construction is crucial.16 This support enables the optimization of capital usage and enhances the overall experience for PWD. Define Success: How can we better define what “good” for accessibility means for stakeholders and the urgency for change? Defining and refreshing measurable outcomes is critical in recognizing and collaborating on social challenges. For example, the healthcare Quintuple Aim exemplifies how defining metrics as the North Star clarifies misconceptions, facilitates industry buy-in, and fosters mutual understanding for advancing healthcare improvement.17,18 However, when determining eligibility for social assistance, it is easy to anchor on a single statistic Copyright © 2023 Deloitte Inc. All rights reserved. like the poverty line income. Yet, individuals and families have diverse needs spanning health, education, living standards, and social factors, necessitating a comprehensive approach.19 Given the influence of physical, economic, and cultural factors on complex social issues, aligning all impacted parties on a single definition is often infeasible. Thus, flexibility should be embedded to account for other relevant indicators and address the complexity effectively.17 Action Plan: How can the Ontario government better build, centralize, and communicate a sustainable action plan for accessibility? To achieve sustained systems change, collaboration among public and private organizations is crucial. This requires a multi-year progressive build, incorporating essential tools such as taxation, compliance, and marketing. A four-pronged approach can guide the development of a systems change plan, encompassing defining the system, mapping its intricacies, conducting insightful analysis, and implementing tangible actions.20,21 In addition, transparent and visual communication of progress by the government is effective for policy implementation, allowing for tracking progress and upholding accountability is encouraged.22,23 This ensures that stakeholders are informed and engaged, fostering a sense of shared responsibility throughout the process.24,25 Funding Model: How could we develop a funding model to support stakeholders that realistically accounts for economic costs and risk (e.g., for the built environment)? Social impact bonds, a financing mechanism for delivering social programs, foster multi- sector partnerships among governments, corporations, private investors, service providers, and social enterprises. Social programs such as the Social Finance Fund could be further explored to address systemic biases and inequities historically present in financial systems and investment decisions regarding PWD.26 This collaborative approach incentivizes performance management and emphasizes outcomes.27 In some models, consumers bear fees to offset costs incurred by service providers, as exemplified by the new Ontario credit card surcharge.28 Similarly, the airline industry has successfully implemented consumer fees to fund airport infrastructure upkeep and maintenance. These examples demonstrate how incorporating fees within consumer transactions can be an effective strategy for sustaining social programs and infrastructure maintenance without significant adverse effects on demand.29 Resource Allocation: How could we more effectively guide government leaders to invest resources in solving the problems with the biggest impact? Copyright © 2023 Deloitte Inc. All rights reserved. New Zealand's COVID-19 response provides valuable learnings with strong public health and economic outcomes as core principles in leadership and partnerships, collective action, political consensus, and infrastructure reform were emphasized.30 Similarly, Canada's national Critical Infrastructure strategy promotes coherent and complementary actions across government levels and industry through cooperation.31 Lastly, gathering ample data points from individuals experiencing social issues, as seen in Australia's approach to gender equality, aids governments in prioritizing resource allocation.32 These experiences underscore the importance of leadership, partnerships, data-driven decision-making, and effective governance in achieving positive social outcomes. Alternate Governance Models Overview We have explored the considerations of greater federal involvement in accessibility regulation for PWD by researching: 1. Canadian Federal Government Involvement Across Adjacent Policy Spaces: Assessed case studies across various policy spaces (outside of disability) where regulation spans different levels of federal and provincial responsibility. 2. The Regulation of Disability Across Other Countries: Assessed case studies in different countries to identify what elements of disability falls under each jurisdiction. The jurisdiction selection process consisted of ensuring the country had a) similar demographics b) similar system of government. 3. An Applicable Governance Model that can Initiate Action: Assessed three different types of models the ministry can implement to enable authority and ownership of recommendations. Key Findings 1. Canadian Federal Government Involvement Across Adjacent Policy Spaces The current regulatory structure for disability in Ontario consists of federal oversight for organizations that are governed by ACA (Accessible Canada Act) and provincial oversight for all other organizations not governed by ACA, subject to AODA standards (provincially regulated private sector and the Ontario Public Service). To envision a potential future state, we identified several case studies across various policy spaces that had different levels of federal and provincial regulation, including food safety, HST, food and drug regulations, cannabis legalization, and employment insurance. Copyright © 2023 Deloitte Inc. All rights reserved. Each case study had unique reasons for seeking greater federal involvement. The most common reasons included the streamlining of administrative processes, the implementation of more consistent regulations to alleviate the burden on small businesses, and the enhancement of enforcement and compliance measures. For instance, in the case of employment insurance, there was a shift from primarily provincial to federal regulation to establish a uniform system nationwide. The previous system, which relied on provincial programs, had varying eligibility criteria, benefit levels, and administrative practices. The national employment insurance program was viewed as more efficient and cost-effective than having multiple provincial programs. It also ensured that all workers across the country had access to similar levels of income support and benefits.33 2. The Regulation of Disability Across Other Countries No single country has emerged as a leader in designing a future where barriers to accessibility are prevented and eliminated, thus enabling individuals with disabilities to lead unrestricted lives in social, economic, and institutional domains. As a result, there is no conclusive evidence that adopting governance structures from other jurisdictions would yield better outcomes for people with disabilities. However, despite this limitation, valuable insights were attained from exploring how other countries allocate responsibilities within their respective levels of government. The analysis focused on four countries: Australia, New Zealand, Denmark, and Finland. These countries exhibited varying degrees of collaboration between federal and provincial governments. Across these jurisdictions, three key components were found to be the responsibility of different levels of government: 1) Experience standards, 2) Funding, and 3) Enforcement and Compliance. For instance, in Australia, disability regulation is led by the federal government, with support from the state/territory level. The Disability Discrimination Act 1992 (DDA) is the main piece of legislation at the federal level that regulates employment, education, accommodation, and access to goods and services. Many states/territories have their own standards focused on employment and support services. The federal government takes the lead in both funding and enforcement, with support from the state/territory level.34 In contrast, the New Zealand government structure is unitary, meaning the national government is responsible for setting the legislation and standards, funding, and enforcement and compliance. Local municipalities are responsible for assisting with the implementation of these standards across their jurisdictional oversight, in alignment with the corresponding national policies and regulations.35,36 Copyright © 2023 Deloitte Inc. All rights reserved. Alongside various other governance structures, this research served as an inspirational resource for identifying ways in which different levels of government could collaborate to enhance the experiences of PWD. 3. An Applicable Governance Model that can Initiate Action To initiate action, there are various governance models the ministry can implement to enable authority & ownership of recommendations including a) Decentralization, where there is a distributed execution of services across the enterprise, within business and functional groups that own their own strategy, budget and execution b) Federated, where there is a dedicated body owning strategy, advisory & governance of employee accessibility enterprise-wide. Note: This is not full centralization which can impede the coordination of actions c) Centralized, where there is a dedicated central body with the authority and responsibility to own the employee accessibility strategy, budget and execution across the entire enterprise. Through discussions with the Independent Reviewer our research suggests that the best approach is to pursue a federated model based on the landscape within which the AODA operates. This will help create a) one central owner dividing responsibility, making delivery more consistent b) flexibility, autonomy and empowerment of functions to own employee accessibility c) productivity and efficiency by ensuring the appropriate amount of work is assigned to the respective function at the appropriate time. Conclusion In alignment with the Independent Reviewer, our objective was to identify potential strategies to fill in the current gaps that exist for PWD. By sharing our independent perspective, our hope is to create an impact that matters and help design a future in which barriers to accessibility are prevented and removed, enabling PWD to lead unconstrained lives – socially, economically, and institutionally. Copyright © 2023 Deloitte Inc. All rights reserved. Deloitte, one of Canada's leading professional services firms, provides audit, tax, consulting, and financial advisory services. Deloitte LLP, an Ontario limited liability partnership, is the Canadian member firm of Deloitte Touche Tohmatsu Limited. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee, and its network of member firms, each of which is a legally separate and independent entity. Please see www.deloitte.com/about for a detailed description of the legal structure of Deloitte Touche Tohmatsu Limited and its member firms. This publication contains general information only and Deloitte is not, by means of this publication, rendering accounting, business, financial, investment, legal, tax, or other professional advice or services. This publication is not a substitute for such professional advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified professional advisor. Deloitte shall not be responsible for any loss sustained by any person who relies on this publication. © Deloitte Inc. and affiliated entities. Copyright © 2023 Deloitte Inc. All rights reserved. End Notes 1 "Everyday Gender Bias Makes Women '53% More Likely' to Develop Mental Health Problems." Mirror, March, 2019, Women Gender Bias 2 “Evidence from the Fulfilling Lives programme: Supporting people experiencing multiple disadvantage” CFE Research and The Systems Change Action Network, May, 2022, Fulfilling Lives UK how to design public policy and levers through cocreation lived experience committees 3 "Committee on Economic Inclusion and Equitable Growth. 'Closing Racial Inequality Gaps.' Citi. November 2020, Closing the Racial Inequality Gaps 4 "Shifting consumer behavior to address climate change." ScienceDirect, May 2021, Science Direct 5 "What Consumer Psychology Tells Us About Social Change Movements." UWM News, March, 2021, Psychology Climate Change 6 "Yelp Makes It Easy to Find and Support Eco-Friendly Businesses with New Business Attributes." Yelp Blog, April, 2022, Yelp Sustainable Business Review 7 "Cargill and A&W Canada Partner with ALUS to Scale Climate Change Mitigation Efforts." Beef Up Sustainability, August, 2021, A&W Canada Sustainability Campaign 8 "The Tipping Points for Clean Energy and Electric Cars." Bloomberg, Clean Energy – Cars 9 "Major Step Forward on Site Solar in Ontario." Canadian Renewable Energy Association, April, 2022, Ontario Solar Power Case Study 10 "Behavioural Insights Team." Wikipedia, Behavioral Insights Team or Nudge Unit 11 "Ontario long-term care home ordered to find new management after failing to comply with inspection notices." CTV News Toronto, August, 2022, Long-term care inspections 12 "Cycling UK. 'Fill That Hole Campaign.' Cycling UK. Fill That Hole. 13 Centers for Disease Control and Prevention. COVID Data Tracker. 14 'Inequality in Accessibility for Disabled People.' ODI Tableau Public. ODI Tableau Disability Dashboard 15 Tech helps poor rural women navigate India’s COVID-19 crisis. Lifeline Tech – Reuters. 16 New Zealand Public Buildings Action Plan. Designer and Contractor Support 17 "On the Quintuple Aim: Why Expand Beyond the Triple Aim." Institute for Healthcare Improvement, February, 2022, Healthcare Quintuple Aim Copyright © 2023 Deloitte Inc. All rights reserved. 18 The Quintuple Aim for Health Care Improvement: A New Imperative to Advance Health Equity." JAMA (Journal of the American Medical Association), January, 2022, Healthcare Quintuple Aim 2 19 "Global Poverty Facts." World Vision, April 2023, Multidimensional Poverty 20 "Building Momentum: Our Construction Plan for Future Homes." Kāinga Ora - Homes and Communities, 2022, New Zealand Systems Change 21 "The Role of Lived Experience in Creating Systems Change." Brighton Housing Trust, March, 2021, UK The role of lived experience in creating systems change – Evaluation of Fulfilling Lives 22 "Canada's Tobacco Strategy." Health Canada, Canada’s Tobacco Strategy 23 "History of Tobacco Control." Canadian Cancer Society, Smoking – Canadian Cancer Society 24 “New Zealand Disability Strategy and Action Plan.” Office for Disability Issues, New Zealand Disability Strategy 25 "The National Disability Strategy 2021: Content and Reaction." House of Commons Library, January, 2023, UK Accessibility Success 26 Government of Canada. 2023. Employment and Social Development Canada. Social Finance Fund 27 "Are Impact Bonds Delivering Outcomes and Paying Out Returns?" Brookings Institution, September, 2020, Social Impact Bonds 28 "Credit Card Surcharge Battle Heats Up as Retailers Push to Make Shoppers Pay Fee." CBC News, October, 2022, Ontario Credit Card Surcharge 29 "List of Airport Fees for Each Airport in Canada." Flytrippers, December, 2019, Canada Airport Fees 30 "New Zealand's Covid strategy was one of the world's most successful – what can it learn from it?" The Guardian, April, 2022, New Zealand Pandemic Response 31 "Strengthening the Resilience of Canada's Critical Infrastructure." Public Safety Canada, July, 2022, National Strategy for Critical Infrastructure 32 "Case Study: Gender Equality Maps Darebin and Melton." Victoria State Government, October, 2020, Gender Equality Map in Australia 33 Government of Canada. (2021, September 2). Employment Insurance (EI) program. Canada.ca. 34 Disability Discrimination Act 1992 (Cth). Legislative Documentation 35 New Zealand Government. How government is structured. System of Government 36 Office of Disability Issues. Ministry of Social Development. Our Role and Responsibilities 1/8/24, 4:24 PM Ford Government Belatedly Makes Public Blistering Independent Review’s Final Report on Failed Government Implementation of O… https://www.aodaalliance.org/whats-new/ford-government-belatedly-makes-public-blistering-independent-reviews-final-report-on-failed-government-i…1/13 AODA Alliance Accessibility for Ontarians with Disabilities Act Alliance Ford Government Belatedly Makes Public Blistering Independent Review’s Final Report on Failed Government Implementation of Ontario’s Disabilities Act – Report Declares Disability Inaccessibility a “Crisis” Needing Urgent Action, Will Premier Ford Take Action? ACCESSIBILITY FOR ONTARIANS WITH DISABILITIES ACT ALLIANCE NEWS RELEASE – FOR IMMEDIATE RELEASE Ford Government Belatedly Makes Public Blistering Independent Review’s Final Report on Failed Government Implementation of Ontario’s Disabilities Act – Report Declares Disability Inaccessibility a “Crisis” Needing Urgent Action, Will Premier Ford Take Action? - 123 - 1/8/24, 4:24 PM Ford Government Belatedly Makes Public Blistering Independent Review’s Final Report on Failed Government Implementation of O… https://www.aodaalliance.org/whats-new/ford-government-belatedly-makes-public-blistering-independent-reviews-final-report-on-failed-government-i…2/13 December 18, 2023 Toronto: After improperly keeping it secret for over six months, last Thursday, the Ford Government quietly made public the blistering Final Report of the Independent Review of Ontario’s Disabilities Act, which it hand-picked Mr. Rich Donovan to conduct. Ontario is getting very close to 2025, the mandatory deadline for the Ontario Government to lead this province to become accessible to Ontarians with disabilities. Yet the report found that Ontario is far behind schedule and has no e ect- ive action plan to lead this province to become accessible by 2025 or by any time in the future. Download the Report at https://www.ontario.ca/page/2023-legislative-review-ac- cessibility-ontarians-disabilities-act-2005 The Ford Government received this report back on June 6, 2023. The Disabilities Act re- quired the Government to make it public. Last Thursday, the Government issued no an- nouncement that it made this report public. The NDP, and not the Government, told the AODA Alliance that the report had been released to the public. In its most important recommendation, Donovan’s report declares that the many barri- ers that impede 2.9 million Ontarians with disabilities is a crisis, endangering the safety of this large vulnerable population. It recommends several urgent actions to immedi- ately tackle this crisis which the AODA Alliance applauds, such as: Establishing a Crisis Committee chaired by the Premier and co-chaired by the Secretary of Cabinet, to oversee urgent crisis reforms. Directing all Ontario Government Deputy Ministers to identify disability barriers in their areas of responsibility and to design and implement action plans to remove these barriers, with their pay tied to their performance on this issue. Requiring the Ontario Government to implement an audited strategy to ensure that it only procures goods and services that are accessible to people with disabilities. Prioritizing the removal of the many barriers people with disabilities face in Ontario’s health care system and education system. Directing Ontario’s Auditor General to monitor and publicly report on provincial ac- tions on tearing down disability barriers. Strengthening the paltry enforcement of the Disabilities Act. - 124 - 1/8/24, 4:24 PM Ford Government Belatedly Makes Public Blistering Independent Review’s Final Report on Failed Government Implementation of O… https://www.aodaalliance.org/whats-new/ford-government-belatedly-makes-public-blistering-independent-reviews-final-report-on-failed-government-i…3/13 “Rich Donovan’s Final Report calls on Premier Ford to immediately establish a Crisis Committee, chaired by Ford, to oversee urgent reforms over six months,” said David Lepofsky, who chairs the non-partisan grass roots AODA Alliance that campaigns to tear down accessibility barriers. “But instead of using the past six months to follow this wise recommendation, Premier Ford squandered those months by keeping Donovan’s report secret.” “Donovan’s Final Report also included several recommendations that we disagree with and urge the Ford Government to reject,” said Lepofsky. “For example, the Report said Ontario should o oad its legislative authority over regulating accessibility in the private sector to the Federal Government. Yet this would require an undesirable amendment to Canada’s Constitution that we’d oppose. It would unfairly force vulner- able Ontarians with disabilities to have to lobby federal MPs from coast to coast just to get new private sector reforms enacted. The Federal Government would likely not agree to take this on. Moreover, Donovan proposes that the Canada Revenue Agency should enforce accessibility in Ontario’s private sector, even though the overloaded CRA has no expertise in this area.” Below is a summary of Donovan’s recommendations we agree with, those we object to, and those added measures which Ontario needs but which the Report did not address. Contact: AODA Alliance Chair David Lepofsky, aodafeedback@gmail.com Twitter: @aodaalliance For background, read: - 125 - 1/8/24, 4:24 PM Ford Government Belatedly Makes Public Blistering Independent Review’s Final Report on Failed Government Implementation of O… https://www.aodaalliance.org/whats-new/ford-government-belatedly-makes-public-blistering-independent-reviews-final-report-on-failed-government-i…4/13 The March 1, 2023 Interim Report of the Rich Donovan 4 AODA Independent Review The January 31, 2019 Final Report of the David Onley 3 AODA Independent Review The AODA Alliance’s May 31, 2023 brief to the Rich Donovan AODA Independent Review on the recommendations for reform that he should make The AODA Alliance’s February 6, 2023 brief to the Rich Donovan AODA Independent Review on the ndings that he should make. The March 20, 2023 Toronto Star editorial echoing the March 1, 2023 Initial Report by the Rich Donovan AODA Independent Review AODA Alliance’s Initial Response to the Final Report of the Rich Donovan Independent Review of the Accessibility for Ontarians with Disabilities Act Recommendations We Support 1. We strongly support the report’s most important nding, declaring “the current state of accessibility to be a crisis.“ It requires a crisis response. We endorse this report’s most important recommendation: “Within 30 days of the tabling of this report, the province of Ontario must form a Crisis Committee chaired by the Premier and co-chaired by the Secretary of Cabinet. Within 30 days of the formation of the Crisis Committee, said committee must communicate its ability to take action on the crisis recommendations. All crisis recommendations are in- tended to be actioned within 180 days of the formation of the Crisis Committee. If any actions will take longer than 180 days, the Crisis Committee must provide publicly ex- plicit reasons as to why this is the case within this 180-day window. All crisis recom- mendations are to be owned by the Crisis Committee until implementation, and ac- countability will rest with the Premier and Secretary of Cabinet.” th rd - 126 - 1/8/24, 4:24 PM Ford Government Belatedly Makes Public Blistering Independent Review’s Final Report on Failed Government Implementation of O… https://www.aodaalliance.org/whats-new/ford-government-belatedly-makes-public-blistering-independent-reviews-final-report-on-failed-government-i…5/13 2. We agree with three of the Report’s recommendations aimed at deputy ministers across the Ontario Government: 1. “The Crisis Committee must issue a directive to all Deputy Ministers to identify barri- ers in customer (public) and employee experiences within their respective Ministry and its services. To identify such barriers, DMs must engage in material consulta- tions with PWD, both as customers and employees.” 1. “that Deputy Ministers be required to sign accessibility plans and that their pay be cut by at least 5% if they do not meet the objectives on accessibility in their plans”. 1. “The Crisis Committee must issue a directive to all Deputy Ministers that they must publish the barriers identi ed during consultations, as well as a plan to remove these barriers. This plan will have a three-year timeframe, after which a new plan must be developed.” 3. We agree with the Final Report’s recommendation that Ontario should mandate spe- ci c protocols for people with disabilities in the public and private sectors in an emergency. Our experience with the Ontario Government’s failed treatment of people with disabilities during the COVID-19 pandemic shows this to be more im- portant than ever. 4. We endorse the report’s recommendation that Ontario should create an action plan for achieving accessibility and that the Secretary of Cabinet should be assigned with lead responsibility for this. - 127 - 1/8/24, 4:24 PM Ford Government Belatedly Makes Public Blistering Independent Review’s Final Report on Failed Government Implementation of O… https://www.aodaalliance.org/whats-new/ford-government-belatedly-makes-public-blistering-independent-reviews-final-report-on-failed-government-i…6/13 5. We strongly support the report’s recommendations requiring that the Ontario Government: “Issue a mandate that Supply Chain Ontario must only procure accessible products and services after January 1, 2025. Any exception must be approved by the Premier and published for public consumption.” We also support the report’s recommendations that a process be put in place to audit procurement to ensure that this requirement is obeyed. The AODA Alliance has pressed for this for 15 years. See the AODA Alliance website’s public money page. 6. We endorse the report’s recommendation that there is a pressing need for action on barriers facing people with disabilities in the health care system and the education system. The AODA Alliance has campaigned for accessibility standards in these areas since 2009. See the AODA Alliance website’s health care page and education page. 7. We agree with the report that a new provincial agency should be created, which is above the Legislature and which will have lead responsibility for AODA implementa- tion and enforcement. We recommended something similar to the Federal Government when it was designing the Accessible Canada Act. A limited version of this was also recommended by the 1 AODA Independent Review conducted by Charles Beer. We support this reform only if there will be no amendments to the AODA. We never want the Legislature to open up the AODA for any amendments. We also caution that the report risks piling too much responsibility on to this agency, creating unrealistic expectations. st - 128 - 1/8/24, 4:24 PM Ford Government Belatedly Makes Public Blistering Independent Review’s Final Report on Failed Government Implementation of O… https://www.aodaalliance.org/whats-new/ford-government-belatedly-makes-public-blistering-independent-reviews-final-report-on-failed-government-i…7/13 8. We support the report’s recommendation that AODA enforcement should be as- signed to an arms-length provincial agency and that this be properly funded. Earlier AODA Independent Reviews have made similar recommendations, as has the AODA Alliance. We emphasize that this should be done within the existing terms of the AODA. See the AODA Alliance website’s enforcement page. 9. We endorse the report’s recommendation that Ontario should create a package of support tools for small and medium enterprises. Contrary to the report, however, we do not believe that the province should provide those organizations with funding to obey the AODA. This is a cost of doing business that the taxpayer should not be ex- pected to subsidize. 10. We agree with the report’s recommendation that a position should be established at the o ce of the Auditor General, an Assistant Auditor General, Commissioner of Accessibility, to report to the Legislature on the State of Accessibility in Ontario no less than annually. The report was uncertain whether the AODA requires further AODA Independent Reviews after 2025. In fact, the entire AODA remains in full force after 2025. 11. We endorse the report’s recommendation that disability should be formally recog- nized as a core platform of Environmental, Social, and Corporate Governance (ESG). 12. We see value in the report’s encouragement of leveraging digital technology as a short-term solution to exclusion of people with disabilities due to barriers in the built environment. However, the report incorrectly suggests, based on its survey, that people with disabilities face “few, if any, digital barriers when compared to built en- vironments.” In fact, huge barriers to digital accessibility impede some people with disabilities, such as those with vision loss. - 129 - 1/8/24, 4:24 PM Ford Government Belatedly Makes Public Blistering Independent Review’s Final Report on Failed Government Implementation of O… https://www.aodaalliance.org/whats-new/ford-government-belatedly-makes-public-blistering-independent-reviews-final-report-on-failed-government-i…8/13 Recommendations with Which we Disagree in Whole or in Part 1. We strongly oppose the report’s proposal that Ontario should transfer to the Federal Government its legislative jurisdiction over the regulation of accessibility in private sector organizations. It would require a constitutional amendment, which is ex- tremely unlikely to happen. We also doubt the Federal Government would accept this provincial responsibility. This change would seriously hurt Ontarians with disabilities. It would make it even harder to win enactment of long-overdue much-needed e ective accessibility standards for the private sector. We’d have to convince a majority of MPs from right across Canada, most of whom don’t come from Ontario. Moreover, the Federal Government has a very poor track record in implementing the Accessible Canada Act, passed in 2019. The report’s proposal would harmfully splinter legislative authority. The same Ontario private organizations would have their accessibility regulated under the provincial Ontario Human Rights Code and some new federal legislative regime. 2. We disagree with the Final Report’s recommendation that the Canada Revenue Agency be assigned to enforce the AODA for private organizations in Ontario. The CRA has no expertise in disability accessibility. It is not accountable to Ontario voters for its actions enforcing Ontario legislation. We doubt the Federal Government would agree to the CRA taking on this work. It is overloaded collecting taxes. 3. We do not support the report’s unwieldy and impractical proposal that a group of at least 100 people with disabilities, who are separate from disability organizations, should be assembled to consult government on policy issues. - 130 - 1/8/24, 4:24 PM Ford Government Belatedly Makes Public Blistering Independent Review’s Final Report on Failed Government Implementation of O… https://www.aodaalliance.org/whats-new/ford-government-belatedly-makes-public-blistering-independent-reviews-final-report-on-failed-government-i…9/13 4. The report substantially overemphasizes a need for data collection. It fundamentally misses the mark when it concluded: “The single greatest missed opportunity of the past 17 years of the AODA has been data collection.” Those recommendations would distract from and delay the reforms that Ontarians with disabilities need now. People with disabilities don’t need a massive provincial data collection to know what barriers we face in housing, transportation, education, health care, employment, information and communication and access to goods and services. We need action to x this, not more research to study it. 5. We reject the report’s recommendations that the government impose accessibility surcharges on identi ed government services. This would unfairly create hostility or backlash against people with disabilities and their needs. It disregards the fact that organizations already have a decades-old legal duty to allocate funds to removing and preventing disability barriers. It is not some new unfunded legal mandate. 6. We resoundingly reject the report’s implicit questioning of the e ectiveness of man- datory accessibility standards as if they had been treated as the sole tool for leading Ontario to become accessible to people with disabilities. The Report concedes that standards “may be one viable tool to attain the goal of an accessible Ontario…” We have always recognized that accessibility standards must be deployed in combina- tion with other strategies. In this regard, we disagree with the Final Report as well as the Donovan Independent Review’s Interim Report that there has been an overreliance on accessibility standards. Instead, there has in fact been a serious failure to develop the full range of e ective AODA accessibility standards that people with disabilities and obligated organizations - 131 - 1/8/24, 4:24 PM Ford Government Belatedly Makes Public Blistering Independent Review’s Final Report on Failed Government Implementation of O… https://www.aodaalliance.org/whats-new/ford-government-belatedly-makes-public-blistering-independent-reviews-final-report-on-failed-government-…10/13 need and a failure to e ectively enforce those limited accessibility standards that have been enacted. The Report relies on a harmful and inaccurate false dilemma. It stated that people with disabilities “…do not demand standards or de nitions, they demand positive experi- ences similar to that of the rest of the population.” It is not a matter, as the Report would have it, of people with disabilities either wanting e ective accessibility standards or wanting positive experiences similar to people without disabilities. They want and need both. The former is an indispensable means to achieve the latter. The non-partisan grass roots organized disability movement spend an exhausting, grueling decade from 1994 to 2005, campaigning in community after community across Ontario to get the AODA passed. They did this so that we would be entitled to the enact- ment and enforcement of strong accessibility standards. It has similarly campaigned hard for the past 17 years to get that legislative commitment honoured. In other contexts, the Report points to New Zealand for guidance. Yet earlier this year, the New Zealand disability community resoundingly rejected a proposed weak access- ibility law, in large part because that bill did not include the twin requirements to cre- ate accessibility standards and e ectively enforce them. 7. We disagree with the Report when it suggests that compliance with the AODA would only be mere checking of boxes. Compliance, done right, would ensure that disability barriers are removed and no new barriers are created. We regret that the Ontario Government’s failed approach to compliance has largely not achieved this. - 132 - 1/8/24, 4:24 PM Ford Government Belatedly Makes Public Blistering Independent Review’s Final Report on Failed Government Implementation of O… https://www.aodaalliance.org/whats-new/ford-government-belatedly-makes-public-blistering-independent-reviews-final-report-on-failed-government-i…11/13 8. We do not support the report’s emphasis on trying to solve the accessibility barriers that people with disabilities face by changing attitudes towards disability through yet more public education. Been there. Done that. Minister after minister has already announced public education campaigns, targeted at the public and at busi- ness leaders like those the report recommends. Decades of experience shows that this does not materially reduce the problem. The solution is to raise action, not merely raise awareness. 9. We disagree with the report’s denigrating advocacy organizations in this context and its urging government to engage “high-quality outside message consultants to assist in messaging.” Such a waste of public money would only enrich expensive consultants. More generally, we disagree with the report’s unfounded and incorrect claim that dis- ability advocacy organizations are divorced from and disregard the experiences of indi- viduals with disabilities. Rich Donovan never raised this concern with the AODA Alliance or sought our feedback on it. 10. We agree with the report’s conclusion that a dedicated strategy is needed to address the barriers that people with disabilities face in the built environment. We however do not agree with most of the report’s recommendations on what that strategy should be or the reasons for the current problem. They rest on an inaccurate under- standing of what the Accessible Canada Act requires and what that federal law’s im- pact will be on the Ontario economy. They implicitly fail to recognize the legal oblig- ations that Ontario organizations have had in this area for the past four decades un- der the Ontario Human Rights Code and, where applicable, the Canadian Charter of Rights. In this context, we support the report’s proposed goal of ensuring that public sector buildings become accessible by 2030. We agree with the Report’s proposal that public - 133 - 1/8/24, 4:24 PM Ford Government Belatedly Makes Public Blistering Independent Review’s Final Report on Failed Government Implementation of O… https://www.aodaalliance.org/whats-new/ford-government-belatedly-makes-public-blistering-independent-reviews-final-report-on-failed-government-…12/13 sector buildings should be audited for accessibility. Although the report did not address this, we would strenuously oppose the Government using the controversial and inad- equate Rick Hansen Foundation’s private accessibility certi cation program for that purpose. 11. We agree that it would be great if the Ontario Ministry of Infrastructure could be- come a centre of excellence regarding built environment accessibility. However, that would require a massive re-engineering of that Ministry. Its long track record of fail- ures cannot be o set in the short run by hiring a new team of specialists. 12. We disagree with some parts of the report’s assessment of why there has been poor enforcement of the AODA. The truth is that no Ontario Government has been pre- pared to take seriously the AODA’s e ective enforcement. 13. We do not place any hope or emphasis on the report’s priority on trying to coordin- ate e orts by the federal, provincial and municipal levels of government. It is ex- tremely unlikely that decision-makers from the three levels of government will ever get together with su cient authority to commit to anything meaningful. Even if they did, there is a real and serious risk that their e orts will dilute e orts to the lowest common denominator. That would hurt people with disabilities. Vital Recommendations Absent from the Rich Donovan Final Report The following important measures, desperately needed to strengthen the AODA’s imple- mentation, are not in Rich Donovan’s Final Report: - 134 - 1/8/24, 4:24 PM Ford Government Belatedly Makes Public Blistering Independent Review’s Final Report on Failed Government Implementation of O… https://www.aodaalliance.org/whats-new/ford-government-belatedly-makes-public-blistering-independent-reviews-final-report-on-failed-government-…13/13 Proudly powered by WordPress Strengthening the inadequate existing AODA accessibility standards that address customer service, information and communication, transportation, and employ- ment, and enacting new accessibility standards to comprehensively cover the built environment, including residential housing. Measures to e ectively ensure that Ontario legislation and regulations do not create or permit the creation of disability accessibility barriers. A comprehensive strategy to substantially reduce the disproportionately high unem- ployment rate facing Ontarians with disabilities. E ective measures to ensure accessibility of elections for voters and candidates with disabilities. - 135 -