Forum: Proposed Public Spaces Accessibility Standard

The Inclusive Design Institute (IDI) hosted on September 18, 2012 a public forum to gather public comment on the Proposed Amendment to the Integrated Accessibility Standards Regulation (Ontario Regulation 191/11) under the Accessibility for Ontarians with Disabilities Act, 2005 – Design of Public Spaces. The goal of the Accessibility Standards for the Built Environment is to remove barriers to access in public spaces and buildings to make it easier for all Ontarians—including people with disabilities, seniors and families—to access the places where they work, travel, shop and play.

We had a roundtable discussion of the amendment by a panel of experts and stakeholders. Comments and discussion by our expert panel were followed by a session for open questions and discussion. An overview of the background to this proposed accessibility standard was provided by David Lepofsky, Chair of the non-partisan Accessibility for Ontarians with Disabilities Act Alliance, the community coalition that has spearheaded the province-wide campaign to make Ontario fully accessible for persons with disabilities; followed by Amy Pothier who is an intern at Quadrangle Architects Limited, interior design, accessibility and building code specialist, combining her expertise on building accessibility code with architectural and interior design. Then, Cheryl Giraudy from OCAD University, a practicing architect, teacher, academic administrator with over 25 years of experience in building design. Over the last decade she has been teaching in the environmental design program including courses for professional practice, spatial planning, and design. She is one of two associate deans in the faculty. Finally, Melanie Moore, a community development worker at the Center for Independent Living in Toronto. She coordinates SPIN, to provide education and awareness and training to parents and perspective parents with disabilities. She is a social worker, and a secretary for Citizens With Disabilities in Ontario.

Our goal is to document and send the conclusions and comments from the roundtable discussion to the Ministry Community and Social Services before the deadline for comments on the amendment, October 1, 2012. For more information about the proposed amendments, visit the Ontario Ministry of Community and Social Services website.

Please add your comments.

Video of the Public Debate on September 18, 2012

https://vimeo.com/50321611

Transcript of the Toronto Forum on Proposed Public Space Accessibility Standard

September 18, 2012

Moderator: Jutta Treviranus. Director of IDI.

Panelists:

David Lepofsky. AODA Alliance

Amy Pothier. Quadrangle Architects Limited

Cheryl Giraudy OCAD U.

Melanie Moore from CILT (Centre for Independent Living, Toronto)

Jutta Treviranus: This is a testament to how important we hold the AODA. What we hope to do is to gather both the comments from the panelists and your questions and responses as well and submit them to the government by the October 1 deadline. We have as I have said, a panel that has a variety of perspectives both from the perspective of the advocates who began the AODA, organizations, users, designers who will choose to implement. We hope to give you a variety of opinions and thoughts on this particular amendment to the integrated standard.

I'm going to start off with David Lepofsky; He is a lawyer, author, lecturer, motivator and a leading advocate for disability issues and rights. He has worked with men and women with disabilities in government - led to the Ontarians with Disability Act. He is also the man to thank for the announcements of stops on the TTC, something that we all depend and take for granted at the moment.

David Lepofsky: Morning everyone. It's an honour to be here. Is fabulous that everyone is taking the time to attend. We are recording this with the hope of taking the audio and making it available on the Internet, and there may also be a video recording as well. I have the privilege of charing The Accessibility for Ontarians with Disability Rights Alliance. United to secure the timely, effective implementation of Accessibility for Ontarians with Disabilities Act. Our predecessor coalition, which I also had the privilege of charing, led the charge from 1984 to 2005, and the campaign that went to the enactment of the Accessibility for Ontarians with Disabilities Act.

Well, my challenge today is to give you in the next seven minutes, an explanation of what the standards are about. We started on this seven years ago, into the 20 years. To get us to full accessibility. We all well behind schedule. How does the AODA get us to that goal? The government is required to develop, enact and enforce a series of accessibility standards. The standards together should require the action to be taken across our economy that will get us to the goal of full accessibility. So far the government has enacted ones in the areas of customer service, employment, transportation, and access to information communication.

The next one they have been working on, a year ago it was promised to be enacted promptly, still not enacted, it will cover barriers in the built environment? What do we need standards? One, the existing law in the area of building code, does not include strong enough requirements to make built environments accessible.

The building code also does not cover all the built environment, it deals particularly with the inside, and structure. Spaces outside are not covered in spaces inside are also not adequate. It does not require anyone to retrofit an old building even if it's got old barriers unless the building is going to be renovated, and they only have to fix the barriers in the renovation part. You can fix the second floor, but not put in and a letter to reach that newly accessible floor. So the building code is flawed.

The ministry responsible, Ministry of Affairs and Housing has a long track record of keeping the code behind the times. The government decided that this was an area that they had to address. So far what has happened? Some years ago the government, under the AODA appointed the built environment standards committee, with representatives from the disability community, businesses and the private sector.

If you want to track the entire history you will not find it on the government website. They have a tendency to take things down after they have posted comments. We keep them posted forever. If you go to AODAalliance.org you have a link about the built environment. You will see everything we have said about it and all the proposals posted to date. It is the only place to get the full history. What happened was the committee reported a recommendation. Two years ago. The government decided that the first part of the built environment standard would only deal with new construction and major renovation. It would not require retrofit of existing buildings and structures otherwise. We think that is wrong. We got the government to commit on their website back in 2009, but once the built environment standard is enacted dealing with new builds and renovations, they would later deal with the issue of retrofits.

They took that page down. We kept it on ours. The record of their commitment -- if they kept that we cannot find it -- It appears that they took it out. If I am wrong, I will correct that. In any event, what happened? Two years ago the government released the final proposal of the built environment standards. They gave it over to be studied by public officials and the government split it in two. The part that dealt with the building code is over at the ministry of municipal affairs and housing. More on that in a minute. Anything proposed by the built environment standards committee that did not fall in the purview of the building code, for example sidewalks, outdoor spaces and so on, was given over to the Ministry of Community and Social Services’ Accessibility Directorate. They are the ones who have come forward and on August 15, 2012, posted for public comment a draft regulation that would be a partial built environment standard dealing with all expenses only. The government has not given a date for changes in the building code part, and it is that public space that we are here to talk about today.

Let me come back and talk about this building code business. On the one hand it is good that the government plans to amend the building code, to update its out of date accessibility requirements because builders do not know the AODA, The human rights code, but they do know about the building code. We want these requirements in the law they look to. We also call on the government in a letter that we sent this summer on our website, aodaalliance.org, both ministers involved, the Community and Social Services Minister and the municipal housing affairs, the building accessibility must also be passed in the form of a nexus standard under the AODA.

We don't want companies and organizations to face conflicting requirements but we do need it enacted not only in the building code but also on the standard of the AODA. We fought for a number of important protections and we don't want to lose them. We have a guarantee that every five years more or less a standard must be reviewed and must be reviewed by the standards development committee which the government has promised will have 50 percent representation of the facility community, and recommendations and meetings must be made public. Every four years the government has to appoint an independent review to consider how the AODA is working and we want that review to look at changes in the built environment, all changes.

Finally under the AODA an existing standard cannot be amended without being subjected to the standards development committee which by government promise guarantees a 50 percent representation on the table. They have outsourced the built environment right out of the AODA and you cannot get the full accessibility writes by 2025 without fully addressing the AODA. Whatever they come up with later -- the code covered by the standard, we have written the government and they have not answered that request. What about the proposal that you will look at today? Amy will give you a really good summary of what is in it. I will alert you to the concerns that we have. We are here to learn from you and get feedback on what other ideas you may have. Hopefully later this week we will post a draft brief, seek your input and finalize it by October 1. Stay tuned for that. Issues that we would like to address.

We are happy the government is addressing public spaces. We are not happy that they are leaving out retrofits except major renovations and redevelopment. We are happy that they are requiring the standards to be applied to the public sector. We are very unhappy that they have exempted almost in all cases any small, private-sector organization. We know some small, mom-and-pop operations won't be in a position to make some of the changes being discussed. Some small organizations define not by resources but by the number of employees may have the capacity, the resources and the revenue to implement the kind of changes required here. The standard is about barrier prevention. No organization large or small should be creating barriers if we are going to get to full accessibility by 2025. We are concerned about that exemption.

We are happy that in a number of areas the standard tries to set specific technical standards but we welcome your feedback whether those standards are good enough. We are concerned that in a number of areas they use more fluffy language without technical standards which will make it harder to enforce and leave it to organizations to reinvent the wheel. We are concerned about a number of important issues that may not be effectively addressed. While the standard talks about walking service indicators for people with visual loss, it doesn't say what they would have to be. Bumps on the sidewalk, properly structured that tell my feet or my cane about enough coming intersection can be more useful. We need to be more descriptive.

Require a pushbutton on audible signals, finding a beeping button before they can hear, I fear will not be used by people with visual loss, and trigger a lot of money being spent. Those audible pedestrian symbols should operate automatically. They should not require you to push buttons. Eager for your feedback and we have lots to say, that is why we are here and what brings us to this meeting today. Thank you so much.

Jutta Treviranus: Thank you David. We will move on to Amy Pothier who is an intern at Quadrangle Architects Limited, interior design, accessibility and building code specialist, combining her expertise on building accessibility code with architectural and interior design.

Amy has agreed to give us a quick outline, as David mentioned, of what the public consultation has, and what the draft standard has.

Amy Pothier: Today we are talking about the design of public spaces standard in a draft form that was received in August. I don't know how many have had a chance to read that.

I thought I would run through what the standard is actually proposing for specific items, just very briefly, so that we are all on the same page and we know where we are coming from. So, as David mentioned, they have proposed the Ministry of Community and Social Services, to put the public spaces aspect of the built environment in with Integrated Accessibility Standards, for Information, Communication, Employment and Transportation.

This will be included as part of the integrated disability standard. What we are doing here is talking about what they proposed in the 49 pages that we have read.

If you have not read them, primarily they start off with the design of recreational trails and beach access route. As David mentioned, for a large organization and public organizations sectors that have recreational trails and beach access.

The outdoor public use and eating areas, anybody taking a trip along our 400-series highways would know this well. Exterior path of travel, this is a big one. There are not enough pages in the document. But there is a preliminary draft identifying exterior paths of travel. Accessible parking spaces, both on and off street. And service related elements. This is a little bit unclear but I understand is that it pertains to outside service counter spaces and accessible spaces. Is that not true? And inside. It's my opinion that the inside should be with the interior otherwise as a designer, how do you know where to find that information? Also queuing and waiting area spaces. And finally which I am missing in my slide, Maintenance, but it's only two paragraphs. That's basically the standard in a nutshell. I had three main comments about this draft, public spaces standard and are broken down into three topics.

Number one, what is missing? Number two, where could it be found? Number three, how can support be provided to the documents we are using? As we stand now, this draft is something to have, to start conversation in my opinion. Maybe we will see where it goes from here. They are asking for public comment because they have taken parts of the draft accessibility environment standard and incorporated them into here, those items that we know will not be part of the building code. That might work for some people but what is missing is what designers really need.

I don't know how many of your designers. Can I have a raise of hands of those who are designers of public spaces? All the designers that I see and talk to on a regular basis, for the most part, they want to make the space as accessible for everybody. They're not intentionally trying to create barriers to impede people from accessing the spaces. They are designing the spaces to be enjoyed by everybody and that is what we do.

Personally that's what I am always trying to achieve. Everybody to access every building every space, without limitation. If you don't give a designer the criteria that they would need to design that space you are leaving it open to interpretation on what their experience will be. Many people do not know what it is like to have a disability when they are designing these spaces, or have not met anyone or they don't understand and then missing that pertinent information that will change the way they design spaces. Usually it comes from somebody saying that this is beautiful but how are people going to get up the stairs if they cannot use the stairs? You usually see a light on someone's eyes - oh, right!

The standards are broad. Saying that things need to be accessible is not enough. We need to know dimensions. We need to know criteria. If you want to have a service counter - just to specify a counter height of 8. 60mm for some people, maybe 9. 60mm for other people and then 1100, that allows for everyone to be accommodated.

Built structure in the standard is going to confuse designers even more than they are already, and come up with a lot of ambiguous design that does not work for anyone. The other parts of the built environment standard proposed were intended to be part of the building code. There are some things that are missing from the public space entered that could reference the building code. I agree with David. The building code mentality is, I must hurry up and catch you because I am your leader.

Every time something comes up in the code is five years after, that's the way the government works. I won't question that today. That's the way it is. In the meantime there are a lot of aspects of the building code that protect us safety wise but are not addressed in accessibility standards, they're not addressed in the proposed accessibility building code draft and not in the public spaces draft. For example this public spaces draft says that you must have guards to protect trails where there is a steep incline or water adjacent to it.

How do you know how to structurally designed that guard unless you refer back to the building code which gives you load calculations and information on those aspects? Those are important to make sure that our built environment is safe and I cannot stress that enough.

Where the building code is lacking in certain places structurally it seems to be working on the Gardiner Expressway. Everything else follows and it is still standing. Everything should be reference back to the building code. That is important - moving forward. Lastly there is so much to be said from guided information.

In the draft accessible built environment standard which I carry with me at all times, there are a number of statements about why they wrote it that way. We reviewed internally the draft at Quadrangle Architects Limited, and I said, I don't get it...

...I am not saying that is the intent behind it. That is our speculation. Providing guiding statement -- You don't ever have one typical situation that works every time. Everything has a reason to be designed the way that it is and you always have complications in your design process. No matter how much you try, something is not going to be square or level. You have to provide designers key information to make educated decisions. That sums up my 8 minutes. And I will pass it on.

Jutta Treviranus: Next we are going to move to a perspective from one of our own, Cheryl Giraudy. She's a practicing architect, teacher, academic administrator with over 25 years of experience in building design. Over the last decade she has been teaching in the environmental design program including courses for professional practice, spatial planning, and design. She is one of two associate deans in the faculty. I will turn it over to Cheryl.

Cheryl Giraudy: I also want to introduce today -- the manager for accessibility at OCAD University -- Cathy Berry. What we can do is provide you with institutional perspective. The guidelines that have come out seeking commentary are like a teaser. We have been waiting for something for some time. It is good to have that. That speaks to our public space as an institution.

We have been taking a scan of where we are with the facilities on campus. As we grow as a university we have been acquiring more spaces, so our students and our faculty are across 13 or so buildings. We are doing this under a mandated accessibility. It is within the equity and diversity office and that reports to not only senior administration but also directly to the president. This is important that where we place disability inclusiveness at OCAD University, something in our strategic landing, administrative procedures.

There are a number of working groups under the directorate. Built environment is one of them along with customer service and other areas that are online with the AODA integrated standards and legislation. And Cathy and I both are sitting on the built environment component and we recently charged a consultant with bringing forth a draft set of accessibility standards; in fact we are looking at that today.

What we want to talk about is the challenges that we face when we have been trying to build our own standards. To take a look at the whole range of standards over the years. CSA, came out in 2012, we have this whole range of standards, the building code. Facilities are meeting 1997 code, not 2006, waiting for the next version of it so we have something that we can look to and incorporate into the development of our own facility standards. It is a huge challenge in and of itself. Maybe Cathy can address some of those issues, trying to create our own standards.

Cathy Berry: Before that, the standards are important. We require those to see where we are at. Equally as important, even within this draft, is to look at -- David you talk about developing ways to engage communities. We have asked people who use our spaces, put their hand to their ear, a cue to speak louder, to develop and enact ways to develop. To ask meaningful questions about what is working and what is not. Standards is one. But we need to find ways to engage in an ongoing way, ways to improve. The recommendation is that we do that in many ways, not just go to the website and respond to us. We need to go out to people.

The accessibility committee has been working groups, students and faculty. Many identify as having a disability, working with us to develop the work on campus. Within our built environment, we are using -- we are trying to find a way to create an OCAD University specific standard. Also important when you think about the integrated standards for 2013, we have to have procurement practices. I think it is important that even in our procurement practices we have standards. Not spending a penny until we have the guidelines. We are at a point where we are thinking, what are we using? Is the building code sufficient? Our consultation with people across campus says no. How do we address that? That is where we are at.

Philosophically as to how to go with this. We are also a research institution. We have a great resource and expertise. The collaborative ways that we can go about developing the standards is looking at research across our communities and other institutions doing research and incorporate that into our status as well. We have a full range of standards, of challenges beyond the physical challenges. There are challenges of cognitive and disability and emotional and environmental, in terms of environmental sensitivities.

We are an argent designed campus. Up until now we have had a need to accommodate many of the community with environmental sensitivity. It is an inclusive approach. I want to reinforce the challenge that we have with the interior building code standards. Or for the generation of the AODA with the built environment. We are stuck. We are looking into the past. What we don't want is a conversation about meeting the minimum. We want to advance that to ensure the best thinking and forward thinking that we can.

One of the other things is we put a call out to many universities across Ontario to see what people were doing. It is interesting. The proposed build environment is coming. Many universities institutions are waiting. People have been waiting long enough. As much as some of us have to push our own institutions as well.

Do we wait or begin the standard? The other piece that Cheryl talked about, we looked at this ability holistically. We looked at non-visible disabilities and people who experience -- Gore Wallace, part of accessibility community and a strong advocate across OCAD University; we want to be as broad as we can. It can impact a lot of people's lives.

Cheryl Giraudy: We are planning for a barrier buster. I don't know if you want to mention that.

Cathy Berry: There are lots of designs. We are thinking it can be an evolving thing, but we would like the idea of a shift. One of the things we are doing is incorporated accessibility feedback. Certainly the barrier buster will have a piece of - what is the feedback around campus for all people here? Even in public. And take that feedback, and give it to ourselves and those who work in admin and across campus to be accountable and to do something. That is to come. The accessibility and students across campus to be part of the initiative. Thank you very much.

Jutta Treviranus: Thank you Cheryl and Cathy. I think we have identified quite a number of people on the building committee here at OCAD University and also a number of the graduate programs working on inclusive design. They will contribute to the conversation afterwards.

Our last speaker is Melanie Moore, and Melanie is a community development worker at the Center for Independent Living in Toronto. She coordinates SPIN, to provide education and awareness and training to parents and perspective parents with disabilities. She is a social worker, and a secretary for Citizens With Disabilities in Ontario. She got up at 5:30 a.m. to speak to CBC Metro on our behalf. She did an amazing job. And I'm going to turn over to Melanie to continue this amazing job.

Melanie Moore: Thank you, good afternoon. I feel that working at the Independent living Center, this piece will put everything into a whole perspective. I'm going to be speaking about examples of when accessibility isn't happening, and what that looks like. I will also speak about different experiences of people with disabilities from many different perspectives.

As a person that is blind, visually impaired, I live in Hamilton and work in Toronto because I was able to find employment in Toronto. There is one example when businesses are not welcoming or are accessible to people with disabilities. The things you have to do. I want to mention that there were comments about what can we do to make things better and so on? What I want to say is, if you want to follow or not follow the -- system, not accessible. For example people in wheelchairs.

The tickets machines when you go to Union I swear to God are in arbitrary locations. You have to go in Union, and it's loud and challenging. On top of this, Presto came to the center for Independent living. We gave them significant feedback and suggestions. I don't know what happened to the suggestions. The beeps that you hear when you use your Presto card, because it is so loud, you cannot understand what they mean, whether it's working or not. In this day and age, when there are bank machine to talk to you, I don't understand why they cannot be put in place.

The other comment that I am going to make is that in terms of people with disabilities, we all want to live in our own chosen community. We want to live an independent life. We want to live with dignity, which means if I want to go down the street, and walk to a specific park, I want to be able to get in and not have to figure out how the heck to get there. It means to me, walking down the street to a corner, it's square. It has a specific tactile, or if you're using a dog, for with a ramp so people in wheelchairs can get in. it is square. You know how to get in. It is dignity for all.

The solutions affect everyone whether an aging population, seniors, people with intellectual disabilities, development of disabilities, mental health, it doesn't matter what the disabilities. All the standards successfully can help everyone. The idea of "it's too expensive", let's keep doing consultations and amendments.

You can't tell me that that does not cost money, because it does. We as people with disabilities need to be involved with the planning process from beginning to end. We need to be involved when making the policies. We need to be involved in making suggestions, not just consultations once the projects are put in place. We need to be involved from the get go. Are there people with disabilities that are lawyers? Absolutely. Use the skills.

The other thing I wanted to mention, there are a couple of different things I mentioned again. When you are consulting people with disabilities don't give us 45 days to read a document, because it will take me more time to understand it from A to B.

When you're writing documents, if you're not able to make it in plain language, have some sort of a guide or a contact person that can walk people with intellectual disabilities through it. Even myself, even though I do not have an intellectual disability, that document needs to be in plain language for me. I am not afraid to say so.

Jutta Treviranus: Thank you all our panelists. Now it is your turn. We would love to hear your questions, comments, suggestions. Can we have the first question? There will be someone walking through.

Participant 1: I am a professional engineer. Instead of providing a development standard, the system has requirements submitted to an individual, and subjected to whether he or she likes them. Accessibility. People work hard to develop a standard, presented to one person who decides, I like this -- I don't want this.

Participant 2: I want to make a quick comment. I am the chief diversity officer. Language is important. As we try to change our frame of reference. I would like to see us stop using the term "best practices" that connotes a final end. David, you mentioned that the standards probably should be reviewed every three to five years, a very good idea. In my office we now use "good practices." We should assume that everything we do can be improved. And I want to reinforce the comment about the narrow definition of mobility aid, one of our concerns as well. That it should be much broader than using a wheelchair or something like that.

David Lepofsky: All of this feedback is fabulous, two quick points.

If you have ideas after today, and you want to share them with us about specific problems of the proposed public spaces standards, let us know by e-mail aodafeedback@gmail.com. We tried to -- we cannot include everybody, but we can include as many diverse points as we can.

Let me give you, because people talk about bulleted devices, what Amy said and a number of you said in the number of contexts it is good the standard is trying to set new built environment requirements for service areas where you go to a public area to get service. They talk about having requirements for how a counter is set up. We are eager for your feedback on that. They talk about how to set up the queuing lines so when you are zigzag back and forth, you know where you are. And also accessible seating in the waiting area. It only requires three percent accessible seating. They don't mean the furniture. It means a space where you can put a mobility device, whether a wheelchair, or scooter or whatever. Then the exempt -- they keep that is a requirement.

If we are talking about accommodating not by having furniture but having space all you have to do is make sure the furniture you are using can be moved. Then you can have a lot more room. It does not cost anything. Since most furniture is welded to the floor.

The other thing that occurred to me, and I welcome your feedback on the three percent; it would seem to me that it is okay to have percentages when you talk about parking spots. We welcome your feedback on the percentages they came up with. There is a problem when you come up with a flat three percent for all kinds of organizations. It would seem that a hospital should have more. I bet a neurologist or an orthopedic surgeon has more people with mobility problems than the average. Three percent might just be too low. It seems that it needs to be a little bit more sensitive to that kind of diversity.

Finally I welcome particular feedback and ideas on a problem that we had presented, legitimate problem. How many accessible parking spots should be in a parking lot and they set caps which seemed low. The argument is to raise it, otherwise you have empty spots in front of busy shopping mall and people who don't have a disability, who are angry that there is not a spot available they end up cheating. We want to make sure that there are enough for us but not using more space then we need. I am thinking out loud. Maybe two tiers of mandatory accessible spots. Should be left open if there are no available alternatives. 4% of mandatory spots, and second tier that tells people to try to avoid them, but if the place is full use them. We want to find a way to crack that nut.

Participant 3: I am a young person with a disability. It is absolutely critical that we pressure the government that the standard should not only apply to buildings. We cannot let them off the hook in that regard. I had an opportunity to study in England last year. I visited London, England, which you would think would be harder to make accessible because it is older, bigger and has more people. I was shocked. It was the most accessible city I've been in. I asked people why. They said because it is the law. We cannot let our government of the hook in this province. We need to make every building as accessible as possible by 2025 or earlier.

Participant 4: A couple of things. I want to touch on the whole issue of designated spaces for a moment as one of the points I have. While the standards require a certain percentage be dedicated and so on, a need for requirement or specifications with regards to where those places are, and I refer to public spaces or areas such as open theaters, art, where you are often going to fund the space but either they are in the back, or the back door. They will be there. If you participate in activities or concerts, we are segregated from the rest of the public. There has to be more specificity in that area and more care in integration. The second point, when we talk about lack of organization at a national level, I referred to a bank, a federally regulated organization that sits in a provincially regulated building. How do those two affect organizations like ours? When I am walking down Yonge or Queen St., or whatever, I don't know if the building is regulated. Thanks.

Participant 5: I would like to ask about enforcement. When I complain about vendors on sidewalks that make a sidewalk narrower, the city says they lack personnel to enforce that. Is there anything in the standard that says how this can be enforced? If not complied with, what happens? That is another component that we need to consider.

Participant 6: Hi my name is Michelle, a social worker and a woman with a disability. Three points come to mind. One, I am not sure how much snow comes into this, with regards to the built environment. Curb cuts are part of the built environment. They are available for half the year in Toronto. The rest of the year there, several inches of snow is dumped on top. I am not sure how this will be built into the standard if at all. Two, I was thinking about stores recently. It seems to be a habit of those stores to place their objects on sale in the middle of isles. It is more of a habit. I wonder where that fits in. Last, I have been thinking for a long time about accessible parking spaces in public, be it malls or whatever. I wonder where the accessible spots are at the front. I understand people have mobility challenges with regards to the distance. I would love to have a place to park my van where I can open my ramp. It is not a problem about getting into the store. It's a problem about opening the ramp. And lastly, when you open the ramp, it is not an open invitation for someone to double park. I had to literally climb over the ramp into my chair to move the vehicle. I wonder if signs can be made available to indicate that these are singular parking spaces. Thank you.

Participant 7: I want to mention that -- my name is Melissa Graham, the first point I want to mention, I agree with David. I have a disability. Bigger spaces in hospitals and institutions, [will be required]. My other concern was also with the snow. I live in London, Ontario. I live in an accessible building across from the police station. During the winter, the police station will have its sidewalk cleared after a snow. Third and final point, consistency in rural areas. I grew up in a small town where there are not a lot of trails. They cannot make those kinds of accommodations. Thank you.

Participant 8: My name is Mohammed -- A specific example. People with limited vision. Starting with the TTC, if I want to board a train, I cannot tell if it is Southbound or Northbound. I have to ask somebody. If I want to get into a bus, I have to ask somebody. Walking on the street, I see electricity poles - maybe. I realize that when I make contact with them. There should be indications, that there is something in front and I need to be careful. If they can be an indication in the amended regulations to make sure we have full accessibility in the area. Thank you very much.

Participant 9: My name is Elizabeth. I would like to make a comment in two areas. One is more the goals; I'm having a hard time understanding why the regulations would polarize society. We should find a solution, all governments, all levels, the seal of us as humans and to create -- I don't know if this will be possible in my life -- an environment totally inclusive for everybody, as we are today, maybe younger but we all have different needs. The more technical -- in public spaces we should see everywhere charging batteries places.Fully accessible.

Participant 10: It would be great if we could [indiscernible] to present all regulations for disability because disability also represents many invisible parts of our human bodies. Emotional, important to everybody. Toronto, a city with all cultures without enough spaces for people to shake hands and talk. Amy, she was right about writing designer dimensions.Terrific. Definitely, what designers need. They need to think immediately while they are having their dimensions, me to think about maintenance and specs for materials.The need to choose the right materials with low emissions, because this is about accessibility and caring about human health.

Participant 11: Dick Forester. I lived through those regulations. I notice that there are minimum standards, not enough to let two wheelchairs pass in opposite directions and yet they are talking about accessibility. The other thing it would like to know is, will there be anything in the act that gives the accessibility committees anything more than just paying lip service that they can ignore at their leisure? Most builders build to the minimums. I see drawings. They only show the outside of the building, no elevations, and no dimensions except the overall dimensions of the multiunit buildings.

Participant 12: I want to address one of the amendments. We have been talking about the design of public spaces. Section 18 of the information and communication standard, libraries and institutions... Restricted to students with disabilities. I would like to note the earlier comment, I am guessing that the assumption is that the access needs of employees' institutions would be covered under employment standards but what I don't like about this is that it further restricts accommodations. How can people understand what accessibility is all about? Explain that accommodation and accessibility are not the same approach. Accommodation is not a bad thing. Individual accommodation is what is required. You make things accessible in the first place, you then may not need individual accommodation, more accessibility, less accommodation. In the standards there is too much. As requested, if things are made accessible, we need less accommodation. The amendment restricts that accessibility.

David Lepofsky: I want to respond to that comment, about the libraries and educational institutions. What was posted for comment is largely a new standard on making public spaces accessible, that's good. Tacked on in the front of it are a couple of pages of changes to the regulation passed last year, integrated accessibility regulation to address transportation and employment and access to information communication. We raised the concern with the government that those added amendments don't belong in this draft at all. They don't belong there for a couple of reasons.

First, under the AODA, once a standard is made it is our position that it cannot be revised or amended without first being reviewed by the standards development committee. Last year, a standard was made that guarantees certain things In access to libraries and educational institutions. The government cannot change that by posting for 45 days for comment. That has to be a consultation process. They can do it if they do it right. They cannot do it unilaterally as proposed. We asked last year that all three parties would not cut back on anything we gained on accessibility. In a letter to the AODA alliance -- wrote say they would not cut back on anything related to accessibility.

A year later the post-regulation that would cut back on something we gain in legislation last year. As of last year educational institutions were required to make library materials accessible to people with disabilities, not just students. It would include professors, teachers, visiting scholars, members of the public who would use the public. Now they're proposing to cut that back and saying that only students with disabilities should be able to read them accessibly. That is a violation of the promise from last year.

Finally the government up until this has been good about putting up a plain language explanation. This time they put a plain language exclamation that tells you nothing. Give us your input, but we won't tell you what it is about in a meaningful way. We said that is wrong. They should submit these changes to the standards development committee. If they want to make changes because the transit sector asks for them, we should have the opportunity to make changes we want to make and put our comprehensive list on the table.

A couple of people have asked how this needs to be enforced. 14 years ago, -- promise that he would pass the disabilities act. We are non-partisan; we give praise where it is due. But the Liberals blasted the Harris conservative government because their 2001 accessibly act had no enforcement. The AODA does have enforcement tools, but they have to be used. They have not been effectively employed. We do not see effective enforcement going on. We see steps taken but not enough. You will be hearing more from the AODA Alliance about that issue in the next coming weeks. Stay tuned. Sign up.

Participant 13: I want to applaud you for trying to get standards set and try to get the government to accept it. First thing, what do you do with the existing groups that are supposed to help people with disabilities? I applied several times over five years to the technology program. I kept getting turned down because I lived in the house. I lived selling the house that I lived in for 48 years and live in a condo so I could qualify for a scooter. My house was too small for the scooter to be used to ride around. Also for the AODA standards, I don't know if you realize what we are becoming -- more like Americans all the time. We are becoming larger and larger. Myself, I gained a lot of weight. I gained 330 pounds in one year.

When I moved into a condo and got my scooter, they gave me a heavy-duty scooter, much larger than the standard scooter than the wheelchairs around today. When they came to deliver it, two men came, had to lift it up and put it in the elevator, brought it to my condo door, parked it and asked me to sign. What good does it do me? They said we were just asked to deliver. This is the company that deals with this sort of thing, the technology that helps you gain your freedom. I spend the last two months with this thing sitting in the hallway, staring at it. Until I came up with this system to adapt the technology so that I can use it. Now I have this 235 pound scooter that can push in one hand, spin in a circle and slide into the elevator. You have to do it yourself you cannot rely on the government.

Participant 14: My name is Kayla. People have been talking about parking spaces. It got me thinking about language, and how it relates to a built environment and customer service standard. In the hospitality industry, Language is maybe "DB". Accessible rooms are coded with "HC", handicap rooms. As a result, the way they consider spaces, if that is occupied, utilize language out of date. The built environment, where is it catching up with those standards? When you are using language like that you are not shifting the way people think. The other point was the alternative... I wonder what the burden of proof is. Does the student have to prove their disability to get online? If I have depression, will I be disabled enough to access an online text? It also applies to built environment.

You have to move your body around, your stomach or chest... may hit these metal bars to rotate them. They also have accessible entrances marked with the stroller or accessible symbol, but you have to get someone to unlock those. How do I gain access to that? I have gone to the courthouse at -- Someone to enter at the rear of the building with the big blue sign. The officer tried to stop me. That is a -- entrance. My response was, oh, I was under the impression that was an accessible entrance. He asked me what my accessibility was. I tried to explain that question was not appropriate. Do I have to prove that I am not disabled enough to go through what is supposed to be an accessible space? Where is the officer's responsibility to shut his mouth? Do people have to be specifically disabled to utilize these built environment facility features?

Participant 15: I will make a quick comment. Cheryl talked about the subcommittee... and how we are collectively working on the standard to be inclusive of all disabilities, including those with non-visible disabilities. Amy talked in her presentation about what is missing, accessibility for everyone... built environment space. I leave for the question of what work is being done to include standards for those with non-visible disabilities? Including mental, psychological, environmental, and visual and so forth. Briefly address what work is being done for that inclusion.

Jutta Treviranus: Unfortunately we have run out of time. I noticed that there were quite a number of additional hands. What we will be doing is we will -- everyone that RSVPd, will be sent the mechanism for your additional comments and create a wiki space that will summarize what has been contributed, and you can add to it, comment, suggest edits. For those that have not RSVPd, there someone at a desk in back. You can grab a card. It will have a link at the wiki page, on the card at the back. Although you have not had an opportunity to say your piece, we will try to provide that mechanism online.

If you're feeling uncomfortable about either e-mailing us for using the online system, we’ll also provide any information that we send a way to phone us. In addition to the input that we provide to the AODA, feel free to share the comments with the AODA Alliance. There are brochures in the back as well and a sign-up sheet. We will echo the comments. Whatever you submit will be sent twice from two different sources. Thank you for coming in with your thoughtful comments. Thank you for helping us give meaningful and community input to this particular public consultation on a very, very important standard.