In the current way that the bill is written, the complaints can come forward in many different ways. I know that the government has so far been pushing for a “no wrong door” approach, but we're concerned that individuals will have a complaint and not know who they should go to, or go through the wrong door, and possibly it could take two or three years to resolve an issue.
What we would like to see is that CASDO be responsible for developing the regulations and that the reporting of any complaints go through one organization. Whether that organization has individuals underneath—for example, the Canadian Human Rights Commission, and then potentially several individuals underneath who would manage complaints—people would know where they go when they have a complaint about federal accessibility. It wouldn't be that you might go to the CRTC for this complaint, and you might have to call Service Canada for that complaint, or you might have to call a specific airline for another complaint: there would be one place for people to call and have their complaints directed, one organization to develop the regulations and to provide a disability lens in the writing of those regulations. I don't mean any disability lens; I mean a human rights disability lens.
I would also like to see work on the intersectionality that I know government has attempted to do through the gender-based analysis plus, which has not been very successful for the disability community, which is why we strongly feel that having one organization responsible for the complaints and for the management of regulations is critical: it's so that across the board we have equal access and a clear understanding of barriers and what accessibility looks like.
Thank you.