Quebec Accessible recently attended Parliamentary hearings on Bill C-81, the proposed federal accessibility law. Although Bill C-81 is a step in the right direction, it contains some important gaps. These gaps must be addressed before the bill is adopted.
Quebec Accessible has signed on to a letter asking Minister Carla Qualtrough to strengthen Bill C-81. Over fifty disability organizations have signed on to this letter. We hope the federal government will respond to our concerns by amending the bill.
We also hope the Quebec government will take this opportunity to strengthen its own accessibility law. Let’s build on this momentum and create a country that’s accessible to all people with disabilities!
Here is the text of the letter sent to Minister Qualtrough:
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.