We feel that the act needs to have timelines and deadlines listed for the changes required, as well as for reporting on these changes. Without deadlines, organizations may not do what they need to in order to increase accessibility and remove barriers.
As well, there need to be timelines for putting regulations in place. Without timelines and deadlines in the act, how can we check to see that the act is working? We ask that the bill be changed to include timelines and deadlines for changes and reporting.
People First of Canada strongly believes that all complaints about the act not being followed need to go to the accessibility commissioner. Right now, the act has different ways to make complaints, which are based on what organization is being complained about. It is confusing and will make it harder for people with intellectual disabilities to make complaints when an organization is not following the act.
We also strongly believe that the act needs to be enforced by the accessibility commissioner and not by individual organizations or agencies. We believe that the act must be the same in all areas and that certain organizations should not get to make their own rules. We ask that the bill be changed so that there is one complaint process and that the process be done through the accessibility commissioner.
We're concerned about standards in the new Canadian accessibility standards development organization, CASDO. This new standards organization will develop the standards that will become regulations to be followed.
We feel that this organization must include people with intellectual disabilities on their board and in their work. This organization needs representation from people with lived experience in order to do its job of identifying, removing and preventing barriers through creating accessibility standards. We also believe that people with intellectual disabilities need to be included in the monitoring of the act to make sure government is making changes based on what the United Nations says it must do for people with disabilities.
We think there is too much time before the act is reviewed to see if it's working. We think it should be reviewed much sooner than is stated in the bill, which is five years after the first regulation under the act is made.