Inclusion BC Brief: 16 recommendations

British Columbia Framework for Accessibility Legislation

November 27, 2019

Inclusion BC has submitted a written brief with 16 recommendations in response to the request by Minister of Social Development and Poverty Reduction, Shane Simpson, to help the ministry prepare new accessibility legislation for the Province of British Columbia.

You can review our formal submission, “Inclusion BC Brief, British Columbia Framework for Accessibility Legislation”, which we are sharing publically as a PDF.

Accessibility: Our Guiding Principles


Thank you for the opportunity to submit a written brief to support this historical shift in BC with the introduction of provincial accessibility legislation.

Inclusion BC is a non-profit provincial organization that advocates for the rights and opportunities of people with intellectual disabilities and their families. We are a federation of members that include people with disabilities, their families, and agencies that serve them.

Inclusion BC appreciated the opportunity to participate in the Accessibility Legislation Consultation Advisory and would like to reinforce the following guiding principles that are important for our federation in the development of the legislation:

  • Human Rights: Accessibility is a human right and should apply to all areas of daily life for all citizens.
  • Full Citizenship: New legislation should recognize full citizenship and support the government of BC to achieve its obligations under the UN Convention on the Rights of Persons with Disabilities (UNCRPD).
  • Culture of Inclusion: All levels of government must work together to improve accessibility in all areas and to establish a culture of inclusion.

Key Recommendations

Our recommendations focus on ensuring that accessibility legislation is rights-based, in alignment with the UNCRPD, and that people with intellectual disabilities participate in the development of accessibility standards. We are also recommending the creation of a provincial Disability Action Plan to coincide with the development of this legislation, and the establishment of a Provincial Office for Disability Issues with a broad mandate to educate the public, enforce the standards, and manage accountability to support the development of a culture of inclusion in our province.

In response to the questions set out in the British Columbia Framework for Accessibility Legislation we are making the following sixteen (16) recommendations:

  1. The accessibility legislation must be rights-based in alignment with the UN Convention on the Rights of Persons with Disabilities (UNCRPD), enhanced by meaningful investment, robust infrastructure for delivery, and include built-in accountability and measurement tools.
  2. The accessibility legislation should embrace a cultural model of disability to change the prevailing understanding and reframe disability as a valuable way of being in the world.
  3. Create a Disability Action Plan during the development phase of the legislation to put a disability lens on all government policies, procedures, and decisions.
  4. The accessibility legislation should clearly define and acknowledge Ableism as a major barrier to inclusion and incorporate the fundamentals of universal and inclusive design as guiding principles.
  5. Accountability must be a guiding principle for the implementation of the accessibility legislation, and the Standards Development Board must include people with intellectual disabilities.
  6. The accessibility legislation will address real-world barriers in British Columbia with rights-based regulations compliant with the UNCRPD, in particular:• Article 7 – Children with disabilities• Article 9 – Accessibility• Article 21 – Freedom of expression and opinion, and access to information

    • Article 19 – Living independently and being included in the community

    • Article 24 – Education

    • Article 25 – Health

    • Article 27 – Work and employment.

  7. Timelines should allow for consultation and ensure alignment of standards with the UNCRPD, and once developed, the requirement for compliance on new services should be immediate while allowing two to four years for existing services.
  8. The accessibility legislation and implementation mechanisms should acknowledge the diversity within the disability community and ensure that their unique needs and voices are recognized and addressed.
  9. The governance of the accessibility legislation should be managed by an Accessibility Directorate, a Standards Development Board, and an Accessibility Commissioner, each of which is nestled within the Provincial Office for Disability Issues.
  10. The establishment of a Provincial Office for Disability Issues with a broad mandate to educate the public, investigate and enforce the standards, and manage accountability to support the development of a culture of inclusion.
  11. The accessibility legislation should require built-in action plans, reporting mechanisms, and accessible complaint processes.
  12. A Provincial Office for Disability Issues should act as the entity to monitor compliance with the accessibility legislation and have the authority needed to adjust incentives and apply enforcement measures.
  13. Legislative reviews should be conducted as a tool for accountability and to ensure that legislation continues to reflect current best practices.
  14. Legislative Reviews of crucial target areas should occur at three years and five years with a complete reanalysis of the legislation after eight years.
  15. Expand and strengthen existing initiatives with provincial and national partners to create a broad coalition and promote the culture of accessibility.
  16. Launch a Public Awareness Campaign to support the new accessibility legislation and Disability Action Plan and foster a culture of inclusion which recognizes the value and different abilities of every person.

To further inform the process, we are including in our formal submission quotes and examples of lived experiences brought to our attention to ensure their perspectives and voices are included in the consultation.

In the development of this submission, Inclusion BC made consultations with members of our Board of Directors, Self-Advocates Advisory Committee, Family Advisory Committee, members of our Federation, our Community Inclusion Advocacy Program, and the Canadian Institute for Inclusion and Citizenship. Inclusion BC has also drawn from the wisdom and experience of our national federation to support our submission.

Download our complete submission: Inclusion BC Brief: British Columbia Framework for Accessibility Legislation

Inclusion BC
227 6th Street,
New Westminster, BC V3L 3A5
T: 604-777-9100

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