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September 7, 2016

Response to Accessibility Coordination Update


The report submitted by John Traves, QC, Acting Chief Administrative Officer of Halifax Regional Municipality to Mayor Savage and Members of Council entitled Accessibility Coordination Update is poorly researched, derivative, incomplete, offensive, and trivial. It gets an F.


It is written in response to a motion requesting “a staff report on the status of the CAO’s Business unit Strategic Initiative related to Accessibility Coordination.”


“The Strategic Initiative related to accessibility coordination referenced in the above motion was the result of a motion of Regional Council of January 28th, 2014 that directed staff to include a statement “HRM is a leader in building inclusive and accessible community for everyone, including persons with disabilities and seniors” within the Healthy Communities Priority Outcome and develop a Business Plan to support this Outcome for consideration by Council in preparation for the 2015/2016 planning cycle.”


In the the section entitled Work to Date, not a single item of practical use has been accomplished in 922 days. There is shuffling of personnel, mention of a framework (but no  actual plan to do something), a poorly thought out and largely poached review of best practices, unspecified discussions with the Province about upcoming legislation (which people with disabilities have not yet been allowed to see). No ramps have been built, no employee data has been collected, no reports have been shared, and no progress has been made. Discriminatory hiring persists.


The section entitled Framework for Engagement including the Accessibility Advisory Committee is entirely in the future tense.


The section entitled Next Steps is a work of fiction.


There is no section on Community Engagement.


The report lists no Financial Implications because nothing concrete will be done.


The Best Practices Summary in Attachment A is mostly copied verbatim from Ontario Regulation 191/11 made under the Accessibility for Ontarians with Disabilities Act, 2005. In the excerpt below, from Theme area 2 of the the Accessibility Coordination Update, I have highlighted in yellow words taken without change or attribution from the Ontario regulation:


2.1 Notify municipal employees and the public that accommodation, for job applicants with disabilities, is available upon request (recruitment materials and recruitment process).
2.2 Consult with the person making an accommodation request in determining the suitability of an accessible format or communication support.
2.3 Upon request, provide, or arrange for the provision of, information in an accessible format that (a) is needed in order to perform the employee’s job; and (b) is generally available to employees in the workplace. 2.4 Notify municipal employees of policies that support employees with disabilities, including, but not limited to, job accommodation that takes into account an employee’s accessibility needs.
2.5 Provide individualized workplace emergency response information to employees who have a disability, if the disability is such that individualized information is necessary.
2.8 Develop and document in writing a return to work process for employees who have been absent from work due to a disability and require disability-related accommodations in order to return to work.
2.7 Develop and document in writing individual accommodation plans for persons with disabilities.
2.8 Take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when using its performance management process in respect of employees with disabilities.
2.9 Take into account the accessibility needs of employees with disabilities as well as any individual accommodation plans, when redeploying employees with disabilities.
2.10 Take into account the accessibility needs of employees with disabilities as well as any individual accommodation plans, when providing career development and advancement to its employees with disabilities.
2.11 Ensure that all aspects of recruitment and selection of employees are accessible to the needs of persons with disabilities.
2.12 Provide any and all disability related equipment and renovations to facilitate the employment of persons with disabilities on an individual basis.
2.13 Ensure that any cost of accommodation for an employee with disability does not come from the individual budget of the department or business unit that would act as a barrier to employment or career development of an employee.


Item 2.11 makes no sense. There is no explanation of the source of items 2.12 and 2.13, nor any indication why they might be considered best practices.


A best practices review is more than copying from Ontario, which has made many missteps. It should include other jurisdictions:


  • Disability Discrimination Act 1992, Australia
  • Equality Act 2010, UK
  • Americans with Disabilities Act, USA
  • 2005 Disability Act, France
  • And of course the oft cited but seldom observed UN Convention on the Rights of Persons with Disabilities, to which Canada is a signatory


The report mentions none of these.


The report concludes with Attachment B, a list of 27 accomplishments in the area of inclusion.


They range from the ridiculous…
  • Only accessible low floor buses are being purchased (you can’t buy an inaccessible transit bus)


To the offensive, inasmuch as Access-a-Bus is inherently discriminatory and ridiculously expensive...


  • Service hours of Access a Bus the same hours of service as conventional transit.
  • Fare structure for Access a Bus the same as conventional service.


To the obvious and trivial…


  • New Transit Drivers hired have accessibility training
  • Courtesy seating provided for persons with disabilities on conventional transit.
  • Stop request system in place to disembark passengers in safer locations.


To taking credit for simply obeying the law…


  • Service animal policy in place for Transit.
  • Ongoing installation of audible pedestrian signals.
  • More than 150 on-street accessible parking locations in place on HRM streets.
  • More than 30 accessible taxis in service. (And declining)
  • Web site currently being updated to have an accessibility section of information.
  • Two new accessible transit terminals completed.
  • Ferry service has audible terminal announcements.
  • All ferry terminals accessible.
  • Municipal buildings being built to CSA standard in terms of accessibility which is greater than the standards imposed by the Nova Scotia Building Code.


To extremely old news…


  • Pilot project underway testing tactile making on curb cuts to improve accessibility for persons who are blind or visually impaired.  (First proposed in 2004)
  • Regional Council has a sub-committee called the Accessibility Advisory Committee comprised of citizen stakeholders. (Since at least 2002)
  • Call centre has TTY services. (Actually, it’s TDD, invented in 1964 and now largely obsolete)
  • Sign language is provided upon request at Council meetings.
  • CART (Captioning Access Real Time) is provided at Council meetings.
  • Elevator upgraded in City Hall for larger pieces of mobility equipment.


To the ludicrously bureaucratic…


  • Staff member from recreation regularly attends meetings of the meetings of the Accessibility Advisory Committee.
  • Staff member from Corporate Facility Design & Construction regularly attends the meetings of the Accessibility Advisory Committee.
  • Manager of Accessible Services at Transit regularly attends meetings of the Accessibility Advisory Committee.


And finally to the small handful of actual accomplishments…


  • More than a hundred power door operators installed on HRM building as part of program to make HRM properties more accessible.
  • Accessible picnic tables being introduced in parks and open spaces.
  • Additional pool lifts being installed in both indoor and outside pool facilities.

It reflects poorly on the Acting CAO that he is willing to sign off on such a substandard piece of work. It reflects accurately the apathy of those who wrote it. It reflects poorly on Halifax, which aspires to be a leader in accessibility but continuously fails its citizens with disabilities.

Gus Reed

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