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Earlier today, AMCTO President Tony Haddad, CMO, on behalf of AMCTO’s Board of Directors, provided the Honourable Madeleine Meilleur, Minister of Community and Social Services with AMCTO’s comments on the Integrated Accessibility Standard policy documents.
Members may recall a September 2nd Express that provided links to these policy documents (click here) and a September 29th Express (click here) that explained the process AMCTO was undertaking to review them.
More than 50 AMCTO members contributed to AMCTO’s submission and the Board and President are grateful for members' engagement on this important subject. They were particularly appreciative of the work of AMCTO’s Municipal Accessibility Project Team and AMCTO’s Legislative Committee that thoughtfully reviewed the government’s proposals and members’ submissions and then offered very constructive feedback that AMCTO could provide the Minister.
Highlights of AMCTO’s submission included advice that the Minister:
- Convert the “policy documents” into a draft regulation and to provide everyone at least 60 days (rather than the usual 45 days) to review these and understand how the proposed Standards would work vis-a-vis other legislation and regulations. Haddad advised the Minister: “Rushed, municipal councils and the municipal sector may simply object whether the regulation is sound or not. This is an unnecessary risk.”
- Provide a three year gap in the time between when the new Standards would be required to be implemented within the Ontario Public Service and when they would be required to be implemented in municipalities (and other Broader Public Sector organizations) with more than 50 employees. (Four years for those with less than 50 employees.) The government had proposed a one year gap (two years for those with less than 50 employees). This will allow time to, as AMCTO said, “to adequately learn from the Ontario Government’s own experience what specific actions are required and then for each municipality to effectively assess the costs of implementing the actions in their context, then budget for them and then make other consequential adjustments to spending and operations in other areas with sufficient warning to these other areas.”
- Create at least an 18 month period between the time the necessary interpretative guides for the Standards are made available to municipalities and the time the Standards need to be implemented.
- Leverage, as other ministries and agencies have, the deep and wide scope of experience and expertise of AMCTO in partnering with ministries and agencies to develop communications materials and training supports on matters affecting municipal operations.
AMCTO made special note that even with the timelines adjusted as recommended, it is anticipated that the proposed Standards will represent a significant challenge to a number of municipalities, especially those that are experiencing high levels of tax arrears and/or a declining revenue base. “While this is a broader issue, it does mean”, the submission states, “that any new provincial requirements are very difficult to accept in these communities.” AMCTO’s Board of Directors will be discussing this broader economic and fiscal issue with a number of senior provincial officials in late November.
These are highlights only. A copy of the full submission, which includes an eight page table of analysis and recommendations, is posted on AMCTO’s website (click here).
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