You are here:

Ontario's 10-Year Infrastructure Plan: Promoting Access or Perpetuating Exclusion?

Wednesday, September 1, 2010

A Brief Submitted to Ontario's 10-Year Infrastructure Plan Consultation Process


The Alliance for Equality of Blind Canadians / L'Alliance pour l'égalité des personnes aveugles du Canada (AEBC) is pleased to submit the following comments and recommendations on the development of Ontario's 10 Year Infrastructure Plan. This submission is based on an oral presentation at the Sutton Place Hotel, Toronto, on Thursday, August 12, 2010.


The AEBC is a national organization of rights holders who are blind, deaf-blind and partially sighted. The bulk of our work focuses on public awareness to improve public attitudes and offer input on public policy issues of direct concern to our community.

The AEBC is active in Ontario. Two of AEBC's seven member national Board of Directors live in Ontario, and 4 of our 15 chapters are located in this province. For background and further information on our organization and work, please visit our fully accessible website,


Over the next ten years, the power of the public purse must be used in strategic and proactive ways to move Ontario towards achieving its mandated goal of "full accessibility" by 2025.


Will the Ontario Government develop new leadership and use infrastructure, capital and procurement initiatives to make real progress towards accessibility and inclusion for Ontarians with various disabilities - or will it continue down its traditional road, allowing the broader public and private sectors to perpetuate barriers that impede or prevent our full participation in all aspects of life in the Province of Ontario? In short, will this new Infrastructure Plan be part of the solution, or part of the continuing barriers and exclusion that persons with disabilities, including Ontarians who are blind continue to face?

It's that basic and straight forward a question, and the AEBC demands clear answers!


At a meeting on June 11, 2009, we learned that the Ontario Government has no consistent, government-wide requirements to include accessibility in its infrastructure, capital or procurement initiatives.

We also learned at that meeting that the Ministry of Energy and Infrastructure mainly leaves it to the front-line ministries that give out infrastructure capital grants to address disability accessibility.

Leaving these decisions to the ad hoc discretion of each ministry (e.g. the Ministry of Health, the Ministry of Transportation, the Ministry of Education or the Ministry of Training, Colleges and Universities), with no centralized, consistent approach, makes it impossible to assess if the Government is using its spending power effectively as an incentive to promote accessibility.

In addition, Section 9 of the Ontarians with Disabilities Act 2001 (which is still in force) already authorizes the Government to make disability accessibility a criterion in allocating capital grants. It provides:

Government-funded capital programs
9. (1) If a project relates to an existing or proposed building, structure or premises for which the Building Code Act, 1992 and the regulations made under it establish a level of accessibility for persons with disabilities, the project shall meet or exceed that level in order to be eligible to receive funding under a government-funded capital program.

Same, other projects
(2) If a project is not a project described in subsection (1) or if the projects in a class of projects are not projects described in that subsection, the Government of Ontario may include requirements to provide accessibility for persons with disabilities as part of the eligibility criteria for the project or the class of projects, as the case may be, to receive funding under a government-funded capital program. S.O. 2001, c. 32, s. 9, in force September 30, 2002 (O. Gaz. 2002, p. 898- 899).

Clearly, a more comprehensive and consistent approach is desperately required.


There are clear and compelling demographic, economic, business, legal, and ethical reasons for expecting the Ontario Government's new 10 Year Infrastructure Plan to be part of the solution and not part of the problem - to help remove existing barriers and to prevent the introduction of new ones. And believe it or not, even in the year 2010, new barriers to the

participation of persons with disabilities continue to appear.

A) The Demographics Imperative

The number of persons with disabilities in the population (PwD) is large and growing. While in 2001, 13.5 percent of Ontarians identified themselves as having a disability, by 2006, the rate had risen to 15.4 percent.

Disability rates increase with age. In Ontario, in 2006, the disability rate for 15 to 24 year olds was 5.3 percent, 8.7 percent for 25 to 44 year olds, 20.6 percent for 45 to 64 year olds and 47.2 percent for 65 years and above.

B) The Economic Imperative

The Report, "Releasing Constraints: Projecting the Economic Impacts of Improved Accessibility in Ontario," by the Martin Prosperity Institute, Rotman School of Management University of Toronto states:

Enabling increased workforce participation among persons with disabilities (PwD) will not only increase their individual and family income, but it could also increase the GDP per capita in Ontario by up to $600 per annum.

Statistics Canada reports that in Ontario, PwD have lower participation rates in the labour force than those without. In 2006, 54 percent of PwD were in the labour force whereas 80 percent of Pw/oD were in the labour force.

At present, an unacceptable number of persons with disabilities live in chronic poverty, subsisting on social assistance. Recent statistics indicate the Ontario Disability Support Program (ODSP) has 273,611 cases, supporting 379,817 beneficiaries. Increasing access to the education system, workplaces and the community, should make it possible for more Ontarians to go to work, thereby lessening reliance on social assistance, improving income levels, and increasing the spending power of this segment of the population.

C) The Business Imperative

We all live in a globalized world. If Ontario businesses become leaders in developing and manufacturing products that are fully accessible and usable, Ontario will become a world leader, and will be in a prime position to increase exports. This would be good for business and for persons with disabilities alike.

The "Releasing Constraints" Report goes on to say:

Ontario’s businesses can benefit from these standards in three ways. First, increased access to retail and tourism opportunities would result in accelerated growth in these sectors. Second, a number of Ontario regions have the capacity to support significant clusters of accessibility-focused businesses able to serve global markets. Third, our universities, colleges and other institutions can help educate the next generation of workers and develop new intellectual property that can prepare businesses to compete in the growing number of markets defined by accessibility requirements.

D) The Legal Imperative

The Ontario Human Rights Code (R.S.O. 1990, c. H.19) has long provided that "Every person has a right to equal treatment with respect to services, goods and facilities, without discrimination because of.…disability," and the Accessibility for Ontarians with Disabilities Act 2005 requires Ontario to become fully accessible for persons with disabilities by 2025.

Persons with disabilities have been covered under the provisions of the Ontario Human Rights Code since 1982. Yet representatives from the obligated sectors seem to think the AODA imposes new requirements.

If these organizations have failed to fulfil their long standing obligations, it's not our fault. Stop whining and whinging; stop blaming the victims. It's their fault for ignoring us, not ours. And we are not prepared to bear the brunt of their inaction!

E) The Moral Imperative

Politicians of all political persuasions agree that increasing accessibility is simply the right thing to do. It is time to put this unanimous view to the test and walk this talk. We all know talk is cheap; what we need is concrete action.


Every year, the Ontario Government spends billions of dollars on infrastructure initiatives, other capital programs, and the procurement of goods and services for use by the Ontario Government and the public. We want to change how public funds are actually used. They must be used in a conscious way to promote accessibility and prevent the introduction of new barriers.

  1. The Government of Ontario should no longer purchase any goods or services that are not fully accessible and usable by all. To achieve this goal, the Ontario Government must take new concrete steps to ensure that capital grants and loans to the private sector or broader public sector, or the spending of public money to procure goods and services for use by the Ontario Public Service or the public will be used to expand disability accessibility, and that no public money is used to create new barriers against persons with disabilities.
  2. The Government of Ontario must include in all future Requests for Proposal a question about how the project, if approved, will assist the Province to remove existing barriers and prevent the introduction of new ones. It is not sufficient for an applicant for capital funding, or for an organization bidding on a procurement opportunity, to merely note in their application that they will comply with existing legislation on accessibility. This kind of talk has failed us in the past. Positive concrete steps must be taken to be effective. This proposal does not assume an increase in spending on infrastructure or procurement initiatives; it does expect the Ontario Government to do business in a different way.
  3. The Government of Ontario must implement the use of a Disability Lens that will be used in determining the allocation of all future projects.
  4. When an organization from the broader public sector or the private sector applies to the Government for a capital grant or loan, such as for an infrastructure project, their application must clearly demonstrate how the funds will be used to improve accessibility for persons with disabilities and ensure that no public funds are used to create any new barriers against persons with disabilities, or to perpetuate existing ones. Similarly, when suppliers bid to provide goods and services to the Ontario Government, the suppliers must show that these goods and services will be fully accessible to and usable by persons with disabilities. In deciding between competing applications or bids, a preference should be given to those applications which best promote accessibility, and least perpetuate inaccessibility.
  5. To promote accountability on the part of recipients of capital funding, applicants for such grants and loans should be required to post on their public website their intended steps on accessibility, and their planned use for the infrastructure funds. This would enable members of the public, including Ontarians with disabilities, to monitor these expenditures and offer the Government feedback on whether the goal of accessibility is being effectively advanced.

Note #1: We recognize that some infrastructure projects, e.g. road or highway repair, are very important, and may not significantly contribute to accessibility.

Note #2: Our proposal requires no major new Government spending. It addresses how the Government will choose which projects to support and fund.


In his Report, "Charting a Path Forward: Report of the Independent Review of the Accessibility for Ontarians with Disabilities Act, 2005," February 2010, Charles Beer wrote:

Accessibility turns legal rights into practical, everyday realities. The goal behind the AODA is to create an inclusive society where everyone can participate to their full potential.
Ontario as a whole will benefit from providing full accessibility for persons with disabilities. As accessibility increases, Ontarians with disabilities will bring their talents to bear more effectively in the workplace and in all other aspects of Ontario life. Youth with disabilities will have more opportunity for educational achievement and seniors will live more fulfilling lives. Consumer spending by persons with disabilities will rise. And our quality of life will be enriched by the fuller inclusion of Ontarians with disabilities in our social relationships and community activities.

Most important, the realization of accessibility will demonstrate our shared commitment to each other — and reinforce the values of decency, fairness and respect for individual dignity that bind Ontarians together.

In her 1931 song, Florence Reece asked, "Which Side Are You On?" Today we are asking you that same question.

We ask, will the Ontario Government's new 10 year Infrastructure Plan contribute to making Ontario truly accessible and inclusive and a model for all of Canada, or will it allow the perpetuation of barriers? Will it contribute to bringing Ontarians with various disabilities into the mainstream of all aspects of life, or will it contribute to relegating the next generation of Ontarians with disabilities to the scrap heap of history?

As rights holders, we in the AEBC demand answers, and we are equally anxious and available to collaborate and play a positive role in making Ontario a better place in which to live.

John Rae, First Vice-President, AEBC
Toronto, September, 2010

ZZ - Disregard this link; it is used to trick spammers.