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In a powerful Open Letter sent to the Federal Government, An Extraordinary Lineup of Thirty-four Disability Organizations Unite to Press for Key Amendments to Bill C-81, the Proposed Accessible Canada Act

Accessibility for Ontarians with Disabilities Act Alliance Update United for a Barrier-Free Society for All People with Disabilities Twitter: @aodaalliance

October 31, 2018


A major effort has just been unveiled by Canada’s disability community to get the Federal Government to amend Bill C-81, the Federal Government’s proposed Accessible Canada Act, to transform it into a strong and effective bill. Thirty-four disability organizations in Canada have united to jointly send the Federal Government an open letter, set out below. This letter, delivered to the Federal Government by the Council of Canadians with Disabilities (CCD), identifies nine “significant concerns” with the bill, where the bill must be strengthened through amendments. The letter states:

“These amendments are indispensable to ensure that the Bill achieves its purpose and potential.”

The timing of this open letter is pivotal. The crunch comes next week for Bill C-81. Public hearings on the bill ended last week. The political parties must file their proposed amendments to the bill this Friday. The House of Commons’ Standing Committee on Human Resources, Skills and Social Development and the Status of Persons with Disabilities will start to vote on proposed amendments to the bill on November 8, 2018.

If people with disabilities are to have a real voice in these amendments, it will be when votes are taken on the amendments. The federal Liberals have a majority in Parliament, so they control which amendments will pass. If we are to have an impact, it must be right now. After amendments are tabled and voted on, the House of Commons will have made its decisions on the bill for practical purposes.

The Federal Government has said that this bill is designed to reflect the principle: “Nothing about us without us!” The amendments that will be made to this bill are where the Federal Government can put that pledge into action.

So many from Canada’s disability community, both organizations and individuals, have told the Federal Government what is needed to strengthen this law. There is real harmony among the many ideas that have been brought forward, including among those who presented at the Standing Committee’s public hearings. As is only natural, there are different ideas on the table, but they converge around important themes.

This open letter is an attempt to build on those themes, and to focus on especially critical problems with the bill. The signatories to this letter are not in any way suggesting that these are the only changes that are needed, nor is this meant to take away from any of the other important issues that individuals and community organizations have also raised. Rather, this is meant to be a helpful response, developed in an incredible hurry due to the Federal Government’s tight legislative time lines.

In our thriving democracy, the disability community, like our society in general, has a rich diversity of views. There is little on which everyone will agree. However, the impressive spectrum of community organizations that have signed this open letter shows a powerful shared voice that all political parties should heed.

We expect that more community organizations will wish to join this open letter. Some came forward even as this open letter was about to be emailed to the Federal Government. The list of signatories will be expanded after this, as they come forward. If a community organization wishes to add its name as a signatory to this open letter, please send an email to Robert Lattanzio, executive director of the ARCH Disability Law Centre, at

For our part, the Accessibility for Ontarians with Disabilities Act Alliance is proud to be one of the many respected organizations that are signatories to this open letter. On October 25, 2018, speaking for the AODA Alliance, its chair David Lepofsky told the Standing Committee of the House of Commons that Bill C-81 is great on intentions but weak on implementation and enforcement. In joining in today’s effort, the AODA Alliance draws on its years of experience campaigning to get strong accessibility legislation passed, and then campaigning to get it effectively implemented. We’ve been around this block before. We believe this open letter at this time is a very important way for our voices to be heard, and to work with all parties in Parliament in our ongoing spirit of constructive, cooperative non-partisanship


Open Letter Regarding the Need to Strengthen Bill C-81 Accessible Canada Act October 30, 2018

Dear Minister Qualtrough and HUMA Committee Members:
We the undersigned commend the Federal Government for committing to enact national accessibility legislation. As provincial and national disability rights organizations, we write to express significant concerns regarding Bill C-81. The following highlights our key concerns and reflects the concerns raised by our communities before the HUMA Committee. Amendments are essential to effectively remedy these concerns.
1. Bill C-81 requires timelines. Timelines are essential to ensure that key accessibility measures are taken. Timelines are also required so that progress on accessibility can be measured. In particular, we support recommendations for the Bill to include a timeline for achieving a Canada without barriers, and timelines by which accessibility standards are developed and enacted into law. Timelines are also needed for establishing the infrastructure necessary to implement the Bill.
2. Bill C-81 imposes no duty on Government to use the powers available in the Bill. We support recommendations to change the word may to shall to ensure that the Government implements key steps for achieving accessibility.
3. Bill C-81 requires federally-regulated organizations to establish accessibility plans. However, the Bill does not require these to be good plans. It does not require an organization to implement its accessibility plan.
4. Bill C-81 wrongly splinters the power to make accessibility standards (regulations) and the power to enforce the Bill across numerous Federal agencies. This splintering will make the Bill’s implementation and enforcement less effective, more confusing, more complicated, more costly, and will increase delay.
5. Bill C-81 wrongly gives the Federal Government and various federal agencies the sweeping, unjustified and unaccountable power to exempt organizations from a number of important accessibility obligations. The Government can even exempt itself.
6. The Bill does not require the Federal Government to use its readily-available power to ensure that federal money is never used by any recipient to create or perpetuate barriers. The Bill must be amended to leverage the federal spending power, in order to promote accessibility.
7. The Federal Government is the largest organization that will have to obey this legislation. Therefore, the key federal agencies that will develop accessibility standards, oversee and enforce this legislation must be independent of the Federal Government. Under the Bill, they are not. They all report to the Federal Government. We support recommendations for amendments to ensure that CASDO, the Accessibility Commissioner and other key agencies are sufficiently independent.
8. Bill C-81 does not sufficiently address barriers created by poverty and intersectional discrimination. Nor does it address the unique barriers experienced by Indigenous and First Nations persons with disabilities.
9. Bill C-81 does not recognize ASL/lsq as the official languages of people who are Deaf.
We believe that if these priority changes are made, among the amendments to Bill C-81, this Bill has the potential to truly advance accessibility and inclusion of persons with disabilities in Canada. We ask that the Bill be amended to address the concerns and objectives outlined above. These amendments are indispensable to ensure that the Bill achieves its purpose and potential.

In Solidarity,
Council of Canadians with Disabilities (CCD)
Communication Disabilities Access Canada (CDAC)
In addition to the concerns outlined in this open letter, CDAC recommends that Bill C-81 address communication as a domain across all federal jurisdictions and includes the needs of people with speech and language disabilities.ARCH, CCD and other disability organizations support CDACs recommendations. DAWN-RAFH Canada
Canadian Association for Community Living (CACL)
National Network for Mental Health (NNMH)
Independent Living Canada (ILC)
March of Dimes Canada
Canadian National Institute for the Blind (CNIB)
Barrier Free Canada Canada sans Barrières
Alliance for Equality of Blind Canadians (AEBC)
People First of Canada
AODA Alliance
ARCH Disability Law Centre
Québec Accessible
Views for the Visually Impaired
Physicians of Ontario Neurodevelopmental Advocacy (PONDA)
Unitarian Commons Co-Housing Corporation
Citizens with Disabilities Ontario (CWDO)
Community Living Ontario (CLO)
Barrier-Free Manitoba
Regroupement des associations de personnes Handicapées de lOutaouais (RAPHO) Barrier Free Saskatchewan
DeafBlind Ontario Services
Community Living Toronto (CLT)
Ontario Autism Coalition
Confédération desorganismes depersonneshandicapées du Québec (COPHAN) Canadian Multicultural Disability Centre, Inc. (CMDCI)
Community Legal Assistance Society (CLAS)
Northwest Territories Council for Disability
Voice of Albertans with Disabilities
North Saskatchewan Independent Living Centre Inc.
Older Women’s Network
Centre for Independent Living in Toronto
Ontario Disability Coalition