Human Resources Committee on Oct. 23rd, 2018

[The Chair, Liberal, Bryan May]

I call the meeting to order.

Good morning, everyone. Welcome to today's meeting on Bill C-81, an act to ensure a barrier-free Canada. The objective of today's meeting is to continue the committee's thorough review of the bill.

Bear with me. I have a bit of a preamble here. I'm sure my colleagues are getting used to this.

I will take a moment to remind those participating in the proceedings, as well as those observing the proceedings of the committee in person and on video, that the committee adopted a motion on September 18 that included instructions for the clerk to explore options to allow for the full participation of all witnesses and members of the public on this study.

As a result, the committee has made arrangements to make all meetings in relation to the study of Bill C-81 as accessible as possible in a variety of ways. This includes providing sign language interpretation and near-real-time closed-captioning in the room. Please note that both American Sign Language and Quebec Sign Language are being offered to those in our audience. The first two rows of benches have been reserved for those who wish to avail themselves of these interpretation services. Screens displaying the near-real-time closed captioning have also been set up. The sign language interpreters in the room are also being videorecorded for the eventual broadcast of the meeting on ParlVu via the committee's website.

If a member of the audience requires assistance at any time, please notify a member of the staff or the committee clerk.

So that you can keep your comments at a steady pace for the interpreters, I will not be very heavy-handed with the stopwatch. If you go over a little, it's not the end of the world.

On our first panel this morning, from the Canadian Bankers Association, we have Marina Mandal, assistant general counsel, and Tasmin Waley, senior legal counsel; from the Canadian Disability Policy Alliance, Mary Ann McColl, a professor at Queen's University; and from the Royal Bank of Canada, Teri Monti, vice-president of employee relations. Welcome to all of you. Thank you for being with us this morning.

We're going to get started with opening remarks from the Canadian Bankers Association. Marina Mandal and Tasmin Waley, the next five minutes are all yours.

[Marina Mandal, Assistant General Counsel, Canadian Bankers Association]

Good morning, and thank you to the committee for inviting the Canadian Bankers Association to provide our comments on Bill C-81, an act to ensure a barrier-free Canada.

The CBA is the voice of more than 60 domestic and foreign banks, and their 280,000 employees, that help drive Canada's economic growth and prosperity.

Canada's banking industry is pleased to support Bill C-81. The CBA was actively involved in the consultation process that led to this legislation, and we look forward to continuing to work with the government on the development of the regulations that will set the standards for accessibility in Canada.

During debate in the House of Commons, Minister Qualtrough stated that this legislation “is good for business and business knows that this is good for business.” We agree. Canada's banks are leaders in providing accessible environments for their employees and customers. Banks are committed to treating all people in a way that allows them to maintain their dignity and independence. Banks believe in providing equitable opportunities through diverse and inclusive environments and are committed to meeting the needs of people with disabilities by preventing and removing barriers to accessibility.

Banks have considerable experience with accessibility as it pertains to the workplace and employees. They offer individual solutions to employees with accommodation needs and have specialized departments to ensure that they continue to foster an accessible work environment. Banks have moved accessibility mandates forward through various approaches, including accessibility committees, policies and strategies, all with a goal to work continuously towards amplifying the voice of employees with disabilities.

Banks are also committed to ensuring accessible customer service. Most banks have groups with a dedicated accessibility mandate within their human resources and IT functions. Putting the needs of their clients first, banks continue to make enhancements so they can offer barrier-free facilities and services in their branches, offices, and bank machines, as well as online and through mobile channels.

Some examples of accessibility options provided by banks include teletype technology for telephone banking; video relay service; sign language interpreters upon request; Braille, large print and audio for various customer materials; enhancements at branches, such as door operators, ramps and washroom upgrades; and accessibility features on computers and mobile devices, such as colour contrast and the ability to increase text size.

We believe any federal accessibility framework should strike the right balance between being principles-based and prescriptive. The framework should also recognize that accessibility and accommodation are often person-specific. In areas where there's frequent technological evolution, such as information technology, overly prescriptive standards could be problematic. In general, we support widely accepted standards that provide flexibility to institutions, customers and employees in order to achieve the intended outcomes, and that provide adequate certainty as to what constitutes compliance. Further, because standards may change frequently, particularly as technology evolves, the framework should provide organizations with the option to comply with the standard mandated in the legislation or an equivalent or higher standard.

Banks recognize that although significant progress has been made in making Canada more inclusive, people with disabilities still encounter barriers. The banks view accessibility as a journey and continually work to improve the inclusive design of their products and services.

We're happy to answer and questions you might have.

[The Chair, Liberal, Bryan May]

Thank you very much.

From the Canadian Disability Policy Alliance, we have with us Mary Ann McColl, a professor at Queen's University. Welcome.

[Professor Mary Ann McColl, Professor, Queen's University, Canadian Disability Policy Alliance]

Good morning, and thank you for this opportunity to appear before this esteemed committee and to share part of the research of the Canadian Disability Policy Alliance that I hope may be of use to you in your deliberations towards the passage of Bill C-81.

I will begin by commending the government on fulfilling its promise to Canadians with disabilities on the timely pursuit of this legislation and on the broad consultation undertaken.

My name is Mary Ann McColl. I'm a professor in the school of rehabilitation science and associate director of the Centre for Health Services and Policy Research at Queen's University.

However, I'm here today in my role as the academic lead of the Canadian Disability Policy Alliance. The alliance is a national collaboration of disability scholars, advocates and policy-makers who are committed to understanding and enhancing disability policy in Canada. The CDPA is also a member of the Federal Accessibility Legislation Alliance, led by Spinal Cord Injury Canada from whom I believe you're hearing tomorrow.

I understand that one of the objectives associated with the passage of Bill C-81 is the adoption of a disability lens, or a process that is reasonable, effective and efficient, for use by everyone in the public service to ensure that all government activities, including legislation, regulation, programs and reports, are considered in light of their implications for people with disabilities.

Such a lens would need to meet a number of criteria. It would need to be easily understood and presume no prior knowledge of disability. It would need to be written in plain language, be brief and efficient to use, comprehensive in terms of all types of disability and all types of policy, compatible with contemporary views and scholarship on disability, and evidence-based. I hope I'm not missing anything in those criteria. It sounds like a tall order, but I'm here today to represent a tool that was developed with exactly those criteria in mind: the CDPA's disability policy lens.

The lens was first developed in 2006, based on an exhaustive review of the literature on disability policy analysis in preparation for a book, Disability and Social Policy in Canada, by myself and Lyn Jongbloed. Since 2006, it has been used by many disability scholars and graduate students in Canada and internationally, and has been cited in numerous publications. In 2017, it was refined and pilot-tested in collaboration with staff from the Office For Disability Issues and the minister's office.

I believe you have the lens in front of you.

The lens takes the reader through a series of seven questions that go to the heart of contemporary disability policy analysis. However, it does not favour any particular ideology or stance. It merely asks the user to be explicit, to state their assumptions and to examine them.

Let's take a closer look at the questions.

The first question asks whether the situation of people with disabilities is explicitly mentioned in the policy. Have their interests and implications been overtly considered, or is it assumed that the implications for people with disabilities are the same as for anyone else, and is that a legitimate assumption?

Second, if disability is mentioned explicitly, how is it defined? Currently, a number of definitions are in force in the federal policy infrastructure—for example, definitions associated with the Canada pension plan, the Canada student loan program, and the disability tax credit. Does the current definition conform with any of those, and does the policy focus on the right group of people? Who was left out, and who determines who is eligible to be considered?

The third question asks what the policy tries to do for people with disability. According to Bickenbach, there are typically three aims of disability policy: access—ensuring the ability to participate; support—providing the necessary goods and services; and equity—ensuring freedom from discrimination. Although admittedly interrelated, there's usually a dominant goal that the policy addresses. If it's equity, what kind of equity is sought: horizontal, vertical or outcome equity?

The fourth question of the disability policy lens looks at the contemporary view of disability.

We no longer look at disability as something that is wrong with a person. That would have been the biomedical definition. Instead, we consider someone with a disability as someone who is prevented from having the life that they seek because of barriers encountered in a society not designed with them in mind.

Question 4 addresses the view of disability espoused by a policy. Are people with disabilities considered a minority group, with special interests or special needs, or are they simply considered citizens entitled to the same rights, privileges and responsibilities as other citizens?

Although it may sound like the answer should always be the latter, in many situations disabled people need to be singled out for special consideration, accommodations, benefits or programs.

The fifth question asks how this policy relates to other policies, first within this jurisdiction and then in other jurisdictions. Is something being given with one hand and taken away with the other? Is the policy objective either duplicated or undermined by policy elsewhere?

Sixth, who are the other stakeholders whose interests need to be considered alongside those of people with disabilities? I don't need to tell you about this. Balancing the competing needs and desires of multiple stakeholders is what you do every day, but I have listed a few examples of other groups whose needs need to be considered, such as other minority groups or businesses in the private sector.

Finally, who are the advocates or proponents of the policy and who are its detractors or opponents? Where might we expect to encounter support or opposition? What might be the fallout of that opposition and how can it be countered?

I hope you will agree that these seven questions that make up the CDPA's disability policy lens represent a process that meets the criteria set out at the outset: brief, evidence-based, versatile, easy to understand and administer, and compatible with contemporary disability studies.

Thank you for your attention and interest in our work. I'll be happy to take questions.

[The Chair, Liberal, Bryan May]

Thank you very much.

Finally, from the Royal Bank of Canada, we have Teri Monti, vice president, employee relations. You have five minutes, please.

[Teri Monti, Vice-President, Employee Relations, Royal Bank of Canada]

Thank you very much, and good morning.

My name is Teri Monti. I'm the vice-president of employee relations at RBC. I have global responsibility for workplace policies and programs, leading a team of expert advisers who help employees and managers deal with workplace issues.

We're a global financial institution with a purpose-driven and principles-led approach to delivering leading performance. Our success comes from our 81,000-plus employees who bring our vision, our values and our strategy to life so we can help our clients thrive and our communities prosper.

In 2017, we had 45,600 employees working in RBC's federally regulated businesses. Of those employees, 7.4% identify as having a long-term or recurring physical, mental, sensory, psychiatric or learning disability. Only 4% consider themselves disadvantaged in employment because of their disability.

Our approach to accessibility has evolved over many years, and our vision has grown beyond the initial steps taken a few years ago. Today, accessibility is embedded in our diversity and inclusion blueprint for 2020, which sets out our vision to be among the most inclusive and successful companies, putting diversity into action to help employees, clients and communities thrive.

At RBC, employee and client accessibility practices are governed by our enterprise accessibility guidelines, which are consistent with the principles of dignity, independence, integration and equal opportunity, and outline our expectations with respect to accessibility practices globally. The guidelines also require employees to comply with the accessibility laws and requirements applicable in the specific jurisdictions where they operate.

Some lines of business and functional groups have also implemented local accessibility policies and best practices. One example would be our technology and operations business, which has its own IT accessibility guidelines. These guidelines are based on international standards for web accessibility and provide guidance in deploying technology solutions that are more accessible to those with blindness, low vision, colour blindness, mobility disabilities, deafness and hearing loss.

We know we have work to do, but we also have some great initiatives to profile, and I'd like to give some examples.

Within the built environment, every new RBC branch we open is wheelchair accessible and built in accordance with applicable building codes. Our physical locations are audited periodically by internal groups and external regulatory agencies to identify and remove barriers. In fact, we were excited to learn that the Rick Hansen Foundation, which we had begun working with to review the accessibility of our premises, will be an assessor working directly with the Minister of Public Services and Procurement and Accessibility.

Within employment, through the “Pursue your Potential” recruitment program, candidates get dedicated support during the job application process, which includes resumé writing and interview coaching, and they are proactively profiled to recruiters and hiring managers.

We're really excited about our partnership with Specialisterne Canada to hire employees with autism, a non-visible disability. Specialisterne remains engaged throughout the entire process, including selection, hiring, onboarding and training.

Within information and communications technologies, today our telephone representatives can assist with a variety of financial solutions, or clients can do their own transactions via interactive voice response, teletypewriter or video relay services.

Our network of over 4,600 banking machines is the largest in Canada. We were the first bank worldwide to provide talking ATMs, now adopted by standards organizations around the world. Today, all RBC branch banking machines are voice guidance-enabled.

Within the procurement of goods and services, we are proud to be the first founding member of the Inclusive Workplace and Supply Council of Canada, which works to ensure that procurement opportunities go to businesses that are owned and operated by veterans or persons with disabilities.

Within delivery of programs and services, in conjunction with the CNIB, we're excited to roll out BlindSquare, the leading navigation app for blind and partially sighted people, which acts as a verbal GPS when navigating the city. We will soon be able to provide verbal wayfinding inside our branches.

In 2017, we received acknowledgements of our work, including being ranked as one of Canada's best diversity employers by Mediacorp and receiving the Spinal Cord Injury Ontario employer of the year award and the employment equity achievement award from the federal government.

We know there are still barriers for people with disabilities that can detract from our collective ability to create truly diverse and inclusive workplaces in communities.

This is very much a journey, and we continue to work hard every day to improve. We support legislation that seeks to make Canada more inclusive and we are committed to respecting the legislation and regulations once adopted.

Thank you very much. I'm pleased to answer any questions.

[The Chair, Liberal, Bryan May]

Thank you very much, all of you.

We're going to get started on the first round with MP Barlow, please, for six minutes.

[John Barlow, Foothills, CPC]

Thanks, Mr. Chair.

Thanks to our witnesses for taking some time out of your busy schedules to be with us today. It's certainly much appreciated to get your perspective on where this legislation is going.

In listening to you, Ms. Monti, about some of the work that RBC is already doing in your branches, which is great news, it certainly sounds like a lot of work has already been done. One of the concerns we have with the legislation is that it doesn't include any standards or timelines to achieve some of those standards. To me, it sounds like there are probably some very good practical examples already in the private sector, as you were outlining.

Maybe you can give me some examples. Is this a concern or something that we should be worried about? Should the legislation have some definitive timelines for when there should be compliance from your members or from RBC, just in terms of some clarity on what your path forward should be?

[Marina Mandal]

As I think you've alluded to—and I hope the remarks that Ms. Monti and I made illustrate it—banks have been doing a lot of this already in the absence of legislation with the introduction of the AODA in Ontario and with Manitoba and Nova Scotia having their own legislation. That has spurred more activity. We're ready to act quickly. From our perspective, this is something that the banking industry was doing prior to Bill C-81, and it will continue to evolve and progress.

Concerns have been expressed about timelines. We're not opposed to timelines, but we recognize that the minister went through a very robust consultation involving so many stakeholders, which we were actively involved in, and we support the notion of a framework legislation that allows standards to evolve over time as best practices evolve and technology evolves.

The other aspect of that, of course, is that CASDO will have persons with disabilities on its board who can inform the process, and a lot of stakeholders have now been engaged in the process who can communicate their lived experience in a way that informs the standards. We support the framework legislation. We look forward to consulting with the government on standards. We really do think that the end product will be much closer to achieving the intended outcomes of the legislation.

[John Barlow]

Ms. Monti, do you want to add anything?

[Teri Monti]

I would agree with what Ms. Mandal has said. This is very big work and it's important to do it right. It's important to consult, and it's important to listen to all of the stakeholders that are involved.

Looking at the policy lens that Ms. McColl referred to, I think you really do need to engage those stakeholders and spend the time to develop something that will work going forward.

[John Barlow]

One of the other issues with the legislation is that there seems to be a two-tiered system, as I read through it. There is a very large number of exemptions for government departments, but federally regulated private sector organizations do not have access to those exemptions. There are fines in place for federally regulated businesses that don't meet the standards—when they are outlined—but there are no fines against government departments.

I would assume that if we want to do this right, as you're saying, Ms. Monti, everybody should be treated the same. The government departments should have to achieve these standards just as a federally regulated private sector group should. I think that if we want to send the right message to Canadians with disabilities, which is that everyone is treated equally, there shouldn't be exemptions and relief for government departments that federally regulated private sector businesses do not have.

I would ask all three groups if you could give me your opinion on that. Should we be looking at that? Should there be an even playing field across all government departments and federally regulated groups?

[Prof. Mary Ann McColl]

You're looking at me, so I'll speak.

[Voices]

Oh, oh!

[John Barlow]

No pressure.

[Prof. Mary Ann McColl]

Obviously, yes, you would expect the same standard to be applied across the board. The mechanism for ensuring that standard is met may be different within government from what it is outside of government. I think the principle you're stating, which is that you would expect the standard to be met across the board, is certainly sensible.

[Marina Mandal]

I'm happy to add on to that; we're pretty much aligned.

I think it's really about focusing on the intended outcome, and the Government of Canada has displayed a lot of commitment to that outcome in introducing this legislation. I think the distinction between the mechanisms and the path versus the outcome that Ms. McColl pointed out is what makes sense to me, so yes, I would say a level playing field, from my outcomes-based perspective, but there might be different ways of getting there.

[Teri Monti]

I don't have anything to add. I agree with both.

[John Barlow]

I appreciate that.

I would agree with your comments, but in my opinion, it would be difficult to reach the same outcome if one group has some legislation that forces them to get to that outcome and another group doesn't. One of them can apply for an exemption and wouldn't have to reach that outcome at all. Your members would have legislation that ensures you meet those standards, whereas government departments would not. There's also an appeal process for government departments that isn't there for federally regulated associations. I think that is something we need to address in this legislation. That's something I wanted to bring to your attention.

I have one quick question.

Mary Ann, you were talking about something with your disability lens. One of the officials from the government said that anybody who self-identifies as someone with a disability would be considered. I want your clarification. What would that entail—someone who self-identifies as someone with a disability? I hadn't heard that term before.

[Prof. Mary Ann McColl]

By definition, someone who self-identifies is basically someone who responds affirmatively to the question “Do you have a disability?” Defining disability is a thorny issue. The government has addressed it in a number of places throughout the federal policy infrastructure.

It would be tempting to think there is one definition that we could apply across the board. In fact, given that different pieces of policy have different intentions and are intended to address different sectors of the population, it's something that needs to be looked at very carefully.

Self-identification is a good start, but there needs to be a bit more thought than someone just coming forward and saying, “I have a disability and so I want to be considered for a particular program or a particular entitlement.”

[The Chair, Liberal, Bryan May]

Thank you very much.

Next up is MP Long, for six minutes.

[Wayne Long, Liberal, Saint John—Rothesay, NB]

Thank you, Mr. Chair.

Thank you to our witnesses this morning. I continue to get an education every time somebody presents.

A lady in a wheelchair a couple of weeks ago said to me, “You're opening up my world with Bill C-81.” I stopped, and we had a great conversation. I walked away from that, and she's right. Bill C-81 is opening up the world for people with disabilities.

It hits home for me. In my riding of Saint John—Rothesay, Key Industries is an organization that deals with a lot of people with disabilities. We recently announced some funding there, EAF funding, so that they could have more accessible washrooms—just small, simple things like that.

Whether it's getting on a plane in Saint John, catching a train, or mailing something, there are absolutely challenges and barriers for people with disabilities. I view transforming our businesses as an investment, not a cost. Sometimes I worry. Not only my Conservative colleagues but also other businesses I talk to say, “I would do that, but there's such a cost.” I look at it more as an investment.

I'll start with you, Professor McColl. Can you speak to that? In your opinion, is taking action to invest in enhancing accessibility more of an investment than a non-recoupable cost? Can you talk to that?

[Prof. Mary Ann McColl]

Yes, and I'll begin my remarks by saying that most people who have actually made the amendments necessary to make their premises accessible or their processes accessible are surprised by how small the costs are. The costs often sit in people's minds as a huge impediment to moving forward with accessibility measures. In fact, our research has shown over and over again that people are surprised by how little the costs are.

[Wayne Long, Liberal, Saint John—Rothesay, NB]

I'll just jump in.

Somebody—and I apologize, because I forget which witness it was—mentioned that it was $500 per person, or something like that. It really wasn't that significant.

[Prof. Mary Ann McColl]

I have not heard a number like that, but that's very interesting. I'd love to know more about that.

The bottom line is that if we plan these things from the outset, if we design processes and structures to accommodate everyone from the outset, the costs are minimal. If we have to retrofit, they are more significant.

What that says to me is that legislation that makes it an expectation and a part of our culture to think about people with disabilities and to ensure their needs are considered in everything we do is the way to go, and it's the way to be cost-efficient with it as well.

[Wayne Long, Liberal, Saint John—Rothesay, NB]

For sure, and somebody like Mark Wafer at Tim Hortons led the way by showing that it was an investment. He came back with higher productivity, lower absenteeism and all of those things.

Thank you.

Ms. Monti, do you have anything to say on investment versus cost?

[Teri Monti]

We would absolutely agree that it's an investment. It's an investment in our people, our clients and the communities we support. It is good for the people and good for the communities, and it is good for business as well.

In terms of the actual cost, I would agree with Professor McColl. On average, it is surprisingly not as expensive as many people would think to accommodate people. That's because a lot of accommodation costs nothing in terms of hard costs. It's a schedule adjustment. It's putting somebody's workstation near a window rather than in the middle of the room. It can be a variety of things that are easily achieved without much cost.

[Wayne Long, Liberal, Saint John—Rothesay, NB]

Can you touch on a couple of investments that Royal Bank has made across the country for people with disabilities?

[Teri Monti]

First of all, as I mentioned in my opening remarks, there are the voice-guided ATMs that are in all of our branches.

[Wayne Long, Liberal, Saint John—Rothesay, NB]

Is that across the country?

[Teri Monti]

They're right across the country in every branch.

[Wayne Long, Liberal, Saint John—Rothesay, NB]

Okay.

[Teri Monti]

All of our ATMs are voice-enabled.

We have at least one wheelchair-accessible ATM in each branch as well. Over the next three years, we plan to have all of our branch ATMs wheelchair accessible and audio-enabled.

[Wayne Long, Liberal, Saint John—Rothesay, NB]

What would happen in the event that a branch simply couldn't adhere to that requirement for wheelchair-accessible ATMs?

[Teri Monti]

We don't anticipate that being an issue. It's part of our plan going forward in terms of ongoing branch renovations and new branch construction.

[Marina Mandal]

I think the only thing I'll add on behalf of the association and its 64 member banks is that there's a lot of competition for talent and for customers. I think we all know this. The banking industry is competing, and this is absolutely a 100% investment, an investment in employees. When you want to attract people, you want to have them stay. You want to promote them through the ranks. You want to accommodate them. It's an investment in our talent pool.

Also, customer service is at the core of what banks do. Why would we not want to accommodate to ensure that more customers can access products and services?

[Wayne Long, Liberal, Saint John—Rothesay, NB]

Have you come up against any resistance at all? What changes have you seen over the last five years?

[Marina Mandal]

In the sense of resistance to the legislation itself?

[Wayne Long, Liberal, Saint John—Rothesay, NB]

Yes.

[Marina Mandal]

We haven't had any resistance to the legislation.

I think the language around accessibility—Ms. Monti referred to this in her opening remarks—is part of the broader discussion and conversation about diversity and inclusion. There isn't resistance to the intended outcomes.

There are always things we think about. As I indicated in my opening remarks, we're thinking about the balance between principles and description. We think about flexibility. Especially for our large cross-border members, we think about how other jurisdictions in the world evolve, particularly on information communication technology, let's say, and how we can create standards that do not compel the Canadian bank to be completely at odds with what RBC's U.K. subsidiary is required to do.

Those are the kinds of things we think about, but there there has been no resistance to the desired outcomes.

[The Chair, Liberal, Bryan May]

Thank you very much.

Go ahead, MP Hardcastle, please, for six minutes.

[Cheryl Hardcastle, NDP, Windsor—Tecumseh, ON]

Thank you, Mr. Chair.

Good morning. I'm hoping that we can get some more feedback from you with regard to how we can make Bill C-81 effective in using that disability lens. Other jurisdictions, other countries, have done this. This bill should be our first attempt at complying with the UN convention.

There are a lot of definitions out there. There are best practices being used, and it is evolving all the time.

A lot of the work that has been done focuses on seeing disability as one of the variables of the population, so that this act is ensuring more coverage, more access. We're just broadening that cookie cutter, if you will, in saying that this is a part of the population who we have to start fitting in.

One of my colleagues mentioned in his question a fact that was provided to us about the Public Service Alliance of Canada. They've done a lot of groundwork because of the Employment Equity Act. I'm not sure how many of you are familiar with that in your roles right now, having to roll out the Employment Equity Act, but there's a lot of synergy. There is a lot of opportunity here for us to leverage that. I would like to hear you expand on that if you could.

My time is brief. With that preamble, I'll let you share your thoughts on how we can be leveraging existing legislation such as the Employment Equity Act.

[Marina Mandal]

I'm happy to start.

There is obviously a certain element of duplication there on the employment front. From a first principles perspective, the accessibility Bill C-81 is much more foundational legislation that covers a lot more. The Employment Equity Act, as you know, focuses just on the employment side.

That said, I think a lot of what has been done by federal employers under the EEA can be leveraged—and I'll look to Ms. Monti to expand on that—to meet some of the requirements that we will see in the employment standards under Bill C-81.

[Teri Monti]

To add to that a bit, inclusion is the real goal. Inclusion is one of our core values, and that's the goal we're working towards.

The Employment Equity Act processes and reporting procedures help us get to that goal. This accessibility legislation will help us as well. They're both channels, ways forward, that help us take that really holistic view of accessibility within RBC. It has multiple dimensions and takes that holistic view and helps us go forward with this work.

[Prof. Mary Ann McColl]

I think one of the strengths of this legislation is that it is structural in its approach rather than individualistic.

I referred before to the three objectives of policy, equity, access and support. Whereas the Employment Equity Act is about equity, about ensuring freedom from discrimination, this one is more about ensuring access and looking at the responsibilities of individuals and organizations toward people with disabilities. It's ensuring an equitable and inclusive environment rather than affording people with disabilities redress against discrimination.

It's a different way of approaching the same issue. Of course, the two ideas of equity and access are related, but I was delighted to see that this legislation was taking an access approach rather than simply adding another layer of anti-discrimination protections, which we're well furnished with in Canada.

[Cheryl Hardcastle, NDP, Windsor—Tecumseh, ON]

Mr. Chair, do I have another minute?

[The Chair, Liberal, Bryan May]

You have 30 seconds.

[Cheryl Hardcastle, NDP, Windsor—Tecumseh, ON]

Okay.

What do you think of us having this new standards organization, especially as we've discussed here? What do you think of having that comprised with a majority, which sometimes could be one more than half? We were hearing testimony to the effect that 70% of the board should be people living with different abilities.

I would like to hear about your experience and how you gather your input, if you have some ideas for us about where you think that approach should go.

[Marina Mandal]

We're aware that other witnesses have talked about specific numbers. I would say a couple of things. I think having this unique entity that has, just at the beginning, the requirement of 50% plus has been really great. We don't have a specific number in mind. The provision, as you know, also requires the CASDO board to reflect the diversity of Canada overall. I'm optimistic that once it's put into place and we see how the dynamic works between individuals on the board, it might evolve to a higher number.

I would say that it's a very positive development in the first instance to have the CASDO board, unlike other boards that have a role in this, such as CHRC, be informed by persons with disabilities.

[The Chair, Liberal, Bryan May]

Thank you very much.

MP Ruimy, you have six minutes.

[Dan Ruimy, Liberal, Pitt Meadows—Maple Ridge, BC]

Thank you very much, everybody, for being here today. As my colleague Mr. Long said, every day is a new day of education. We keep learning more and more.

I want to stick with timelines. We're hearing a lot about timelines. When I think of timelines, I think of “by this date, this has to be done”, but I keep hearing, in all the testimony, about evolution. We haven't told you to do things, but the banks and the airplane transportation agency are all saying the same thing: It's an evolution to get to where we need to go, because there are so many different pieces.

When I look at the disability policy lens, I can see that; I can see why. There's not one thing that says, “We're there now. We've done it. Yay! We've done our job.” It doesn't work that way.

At the end of this, we have to come up with potential recommendations for amendments and so on and so forth. I know that this one will play prominently, so I'd like to get more feedback on your thoughts around why we should or should not, as we're proposing, have hard-core timelines on there, and why.

Let's start with you, Ms. Mandal.

[Marina Mandal]

I touched on this earlier, but I'll go into it in a bit more depth.

For us, it really is a very complex piece already in terms of what the framework legislation sets out. You have the infrastructure. You have to create CASDO, appoint the commissioner, appoint the officer. You have the standards development, which we heard about from many other witnesses, including us today. You heard that it needs to be finely tuned. It needs to be informed by experiences in other jurisdictions. It needs to be informed by stakeholders.

On the stakeholder point, the minister, I believe Minister Qualtrough, said that just in the last two years she has received feedback from 6,000 individuals and organizations. As we get into the details of the standards, we would expect to see more of that and other views being at the table. One of the points that we and other stakeholders have made to the government is about the desire to see harmonization within Canada—that is, with the provinces that already have legislation. As I indicated earlier, for our cross-border banks there is a desire to see at least ICT harmonization.

All of that takes a lot of time. There's no end point where Canada is 100% barrier-free—that's a dream—but as best practices and technology evolve, I think it will keep moving in that direction.

Ms. Waley, do want to add something on the progressive realization piece?

[Tasmin Waley, Senior Legal Counsel, Canadian Bankers Association]

Sure.

One thing that's mentioned throughout the act is this idea of “progressive realization”, the idea that accessibility is dynamic and constantly evolving. There will never be a date by which we're finished with accessibility. That's the view our banks take. This is an evolving process. We always want to be aware of best practices and always be innovating in terms of providing accessible options.

[Dan Ruimy, Liberal, Pitt Meadows—Maple Ridge, BC]

Does anybody else want to add to that?

[Teri Monti]

I would echo Ms. Mandal's comments about the need for harmonization. Making sure that the Canadian public, our employees and our clients have a consistent experience no matter which RBC door they come through, whether it's a provincially regulated subsidiary or the federally regulated bank, is very important to us. It's important to take the time as we go through this to make sure that the experience remains consistent.

This is very much a journey, as both Ms. Waley and Ms. Mandal have mentioned. The world evolves and things change. The goal you're working toward today might shift a little bit with some new, innovative technology that makes more things possible. It's important to have the flexibility to move forward in a way that takes that harmonized approach and also takes advantage of innovation as it happens.

[Dan Ruimy, Liberal, Pitt Meadows—Maple Ridge, BC]

Do you want to add something?

[Prof. Mary Ann McColl]

I'd like to roll into my response a response to the questions about both the composition of the standards development body and the timelines.

A lot of stakeholders are involved here. There's an opportunity to do this quickly or to do this well or something in the middle. We're obviously balancing those two things. It's complicated by the number of different stakeholders.

I refer you back to question number 6 on the policy lens. It says to be sure to give everybody who needs to have a voice a voice if they are going to play a part in implementation. As we know, if people don't have their say at the outset, they dig their heels in and create opposition.

I know the number is important to some disability groups, but to me the issue is more about letting the right people have a voice so they don't end up just being opponents to whatever happens. They have to buy into the process at some point.

[Dan Ruimy, Liberal, Pitt Meadows—Maple Ridge, BC]

Thank you. I have just about 30 seconds left.

Would you say that actually putting in timelines, legislating timelines, would be a downfall? Would it limit people to thinking “Oh, we only have to do this, so we're not going to do anymore, because that's what the law says"? Would you agree that would actually be detrimental to this process?

[Marina Mandal]

I think it could be, absolutely, conceptually.

There is low-hanging fruit, and perhaps more so for the industry I represent and some of the other industries you've heard from. I'm cognizant, you know, that the minister did talk about the mom-and-pop trucking companies.

I think the answer is that it depends on the timeline. I think there could be a negative impact insofar as people saying they have x amount of time to do this and then they are done.

[Dan Ruimy, Liberal, Pitt Meadows—Maple Ridge, BC]

Thank you.

[The Chair, Liberal, Bryan May]

Thank you very much.

MP Hogg, go ahead for six minutes, please.

[Gordie Hogg, South Surrey—White Rock, Lib.]

Thank you.

I think this is our fourth session. We've heard from maybe 12 or 15 witnesses, and not surprisingly, everybody who comes before us sees this is as a positive venture. The bill has a lot of positive notions to it, so they respect the values and the principles inherent in it. There are misgivings just about some of the details, but obviously the people who are coming are those people who are in favour of it.

I'm an adherent of John Stuart Mill's notion of being able to understand the other side in order to make an informed decision. The other side has not come before us, yet people keep making references to it.

I wonder if each of you could take a couple of minutes and tell me what the other side would say, the people who are saying this is wrong, because no doubt we're going to have to face some of those. Some of them are out there.

Professor McColl, what are the questions or the other side of this or the edges of this that we would hear from those people who are not in favour?

[Prof. Mary Ann McColl]

I think that one of the other sides may be people with disabilities who think that it's not enough, who want the legislation to go further and faster and be more far-reaching. I think that's perhaps one of the most delicate sources of opposition to be addressed. I suspect you've already heard from some of them.

[Gordie Hogg]

Are there others?

[Teri Monti]

I think one thing you might hear from opponents is about the cost. I think we've talked a little bit about that versus making an investment. That might be a concern for smaller organizations that aren't quite as far down the path as we are. You might hear a little bit about that.

[Marina Mandal]

I don't think I have anything to add. Those would have been the two I would have pinpointed.

[Gordie Hogg]

Certainly we've heard from a lot of large organizations, national organizations, large businesses. Some references have been made. In fact a witness yesterday from YVR, the Vancouver airport, was saying he had concerns about some of the smaller organizations and their ability to finance some of the changes that were associated with it. That's certainly been an issue, as have the timing and the standards, which MP Ruimy just made reference to.

I think contextually those are some of the things we have to look at, manage and deal with. There's been a lot of discussion as well in terms of the policy development and ensuring that we have people with their own disabilities to inform the development of the policy. My experience in terms of policy is that that's obviously a positive thing to do, but sometimes it seems to me that after the policy or legislation is developed and then goes to a bureaucracy, a government, to implement, that some things get lost between the policy development and the implementation stages.

Could you talk a little bit about how we might be able to ensure that is contained within the implementation process so that we have access to those people who have informed the policy to ensure that there's not a disconnect between the policy and its actual implementation? I've seen that happen a number of times.

Are there some safeguards, some experiences you have, that would be helpful in terms of informing that?

[Prof. Mary Ann McColl]

I think the standards development organization is a good safeguard against the intention getting lost and also a very direct way of implementing the policy. Of course, what happens in the public service is opaque to many of us. Probably you're more familiar with it than we are. I must admit that I felt that the standards development organization was a good assurance that the intent of the legislation would be upheld.

[Marina Mandal]

I would add that for the accessibility plans, the feedback and the progress report, as you know, Bill C-81 sets out the duty to consult with persons with disabilities. I think it's another safeguard that ensures the people most impacted by the legislation stay involved on an ongoing basis as it's implemented by the private sector.

[Gordie Hogg]

Can you talk about other jurisdictions that we might learn more from? How does Canada, where it sits today, compare with other jurisdictions? Where are the very best practices? What are the pieces that we might learn from in terms of those jurisdictions that are doing this perhaps more effectively than we are in certain areas?

[Prof. Mary Ann McColl]

Our natural comparators are the U.K., the U.S., Australia, New Zealand and those kinds of countries, and they've all gone the anti-discrimination route, of course, with their federal legislation. I'm very pleased that Canada didn't go that route, but rather took an access-and-inclusion route. Ontario is the one jurisdiction that stands out as having tackled the problem of society-wide standards. I think there are lessons to be learned from Ontario's experience.

[Marina Mandal]

Ms. Waley and I are not all that familiar with experiences outside of Canada, although I take the point that Ms. McColl has just made. I would say that in Ontario, one of the things that has been great and has been translated into the Bill C-81 context is that notion of framework legislation with standards to follow, with separate consultations on each standard. I think Ontario is a good role model to look at.

[Teri Monti]

I would also agree that Canada has been a leader in this area. I manage a global team. I have a team in the U.S. that does accommodations and a team in Canada that does accommodations. There's a huge difference between the legal requirements and what is actually done. From that perspective, the individual perspective, I think we have gone considerably further than our colleagues in other parts of the world. I would say again that the AODA is probably a good example of existing legislation and process.

[Gordie Hogg]

Are you saying—

[The Chair, Liberal, Bryan May]

I'm sorry, Gordie. I have to cut you off there. We have to get one more question in from MP Diotte.

[Kerry Diotte, Edmonton Griesbach, CPC]

To the banking representatives, thanks for outlining some of the good stuff you've done. It looks like there's been significant progress.

I'm lucky enough to be an able-bodied person, yet I frequently have accessibility problems when trying to get through to a local branch or to a live person and in trying to navigate overly complicated websites to find features. How much more difficult is that for people with disabilities?

[Marina Mandal]

I'll start.

As we said in our opening remarks, we do see this as a journey, right? Also, I think that other stakeholders, not just the banking community or the private sector, see it as a journey.

There is a huge amount of innovation in the banking space, as there is in many other industries. It can often mean that we're not communicating, that the communication out to customers and clients might not always come perfectly in sync with the evolution of the products and services, but going back to my point a little earlier, I can tell you that customer service is the core of our business. The banks don't exist without customers, period. To the extent that persons with disabilities or persons who are able-bodied are challenged in finding information at a branch or on a website, I'd say that banks are there to help.

[Teri Monti]

We do train people in customer service. We do try to make our websites and all of our information as accessible as possible to everybody. We are on a journey. We have said that. This is very much a journey.

We are looking for opportunities to improve, absolutely, and this legislation will give us a more harmonized view and the opportunity to get feedback to help us get there as we go through this process.

[Kerry Diotte]

One of the things that helped me recently with a problem with Shaw, I think it was, was the feature of live chat. You get frustrated. You can't reach anybody. You're on hold. Are banks going that route? Do they have that now? Is it accessible for people with disabilities as well?

[Teri Monti]

We do. We have a number of channels that people can use to reach out to us, including live chat on our websites. These are accessible through multiple formats.

[Kerry Diotte]

Do any of you have any ideas regarding amendments that could be used for this bill?

[Marina Mandal]

We don't have amendments in mind for Bill C-81. Some of the considerations that we put forward to the government as we engaged over the last two years actually would end up relating more, I think, to the standards, whether it's a balance between a principles-based approach and a prescriptive approach, or harmonization with the provincial jurisdictions that have accessibility legislation. Our concerns or considerations have been more in that direction, but not with regard to the text of the bill itself.

[Kerry Diotte]

I think both banking representatives talked about how a lot of progress has been made, but how there are still barriers for people with disabilities. Can either of you give me some examples of the barriers that still exist?

[Marina Mandal]

I think one we can point out—and again, it's a point about how innovation happens and how there might be a bit of a gap or a lag time—is touch screens. A lot of people are banking on mobile now, and those touch screens might not be accessible to everybody, although there's a lot that the banks and our vendor partners have done to bring the technology forward and make it more accessible. That's an example I would use.

[Kerry Diotte]

Ms. Monti, do you have any examples?

[Teri Monti]

There are individual situations, because each individual, obviously, presents different capabilities and different disabilities. We do find, occasionally, individual issues with the location, parking and things like this that can act as barriers.

[Kerry Diotte]

I'll stay on that note. Obviously banks are going to a model of taking away the neighbourhood locations and going to farther satellite locations, merging three or four branches into one. How does that impact somebody with a disability?

[Marina Mandal]

With regard to branch closures, they're always happening in consultation with the community. It's definitely not an easy decision. Part of that consultation in determining whether to have a physical location involves consultation with all of the impacted customers. There are alternative ways to deliver products and services, whether it's online, mobile, or having mobile financial planners or mortgage advisers who can be made available to customers.

Again, I keep going back to the first principle: that banks don't want to lose customers. They're waging a war for customers, so these decisions are made with a lot of thought and consideration. Obviously part of that is how to retain customers and ensure that they continue to be serviced, regardless of the manner in which they're serviced.

[Kerry Diotte]

Do you think that you'll be going more and more to a model of bankers coming to us, to able-bodied and disabled people? I know that in larger business deals and so forth, they'll do that. Is that something that's on the horizon?

[The Chair, Liberal, Bryan May]

Give a very quick response, please.

[Teri Monti]

We are certainly looking to expand our network of mobile advisers.

[Kerry Diotte]

Excellent.

[The Chair, Liberal, Bryan May]

Thank you very much.

That takes us to the end of this panel.

I want to thank all of you for joining us and contributing to our study on Bill C-81.

We're now going to suspend very briefly to bring in the next panel.

[The Chair, Liberal, Bryan May]

I'd like us to come to order. Please take your seats. Thank you.

Welcome back, everybody. Welcome to our second panel for today. I'm not going to go through the whole preamble from earlier with regard to the accommodations being made. I will just remind everybody that both French and English sign language is going on. As a result, and as a request from them, please keep your comments at a metered pace. If you are going too fast, I will interrupt you, so I apologize in advance. We just want to make sure that everyone is heard appropriately through the different accessible means.

Joining us here on our second panel from Accessible Media Incorporated is David Errington, president and chief executive officer.

From ARCH Disability Law Centre, we have Robert Lattanzio, executive director; and Kerri Joffe, staff lawyer.

From the Canadian Radio-television and Telecommunications Commission, we have Scott Shortliffe, chief consumer officer and executive director. Joining him we have Marie-Louise Hayward, manager, social and consumer policy; and Adam Balkovec, legal counsel. Welcome, everyone.

We'll start this morning with opening remarks. Please keep the remarks to about five minutes. Again, keep a steady pace and don't worry too much about going a little over your time.

First, from Accessible Media Incorporated, we have David Errington, president and chief executive officer.

The next five minutes are all yours, sir.

[David Errington, President and Chief Executive Officer, Accessible Media Inc.]

Good morning, Mr. Chair and members of the committee. My name is David Errington, and I'm the president and CEO of Accessible Media Inc., or AMI. Thank you for inviting me to appear before you today.

AMI commends the government on tabling Canada's first federal legislation aimed at improving accessibility for people with disabilities. The objective of the proposed accessible Canada act, namely to enhance the full and equal participation of persons with disabilities in society, is very much in keeping with AMI's mandate.

AMI is a media company that entertains, informs and empowers Canadians who are blind and partially sighted. AMI's mandate is to establish and support a voice for Canadians with disabilities, representing their interests, concerns and values through accessible media, reflection and portrayal.

AMI is currently licensed by the CRTC to operate three television services: AMI-audio, AMI-tv and AMI-télé. All three services have been deemed by the CRTC to be of exceptional importance to obtaining the objective in paragraph 3(1)(p) of the Broadcasting Act, which provides the following:

programming accessible by disabled persons should be provided within the Canadian broadcasting system as resources become available for the purpose;

As a result, all three services have been granted mandatory carriage status as part of the basic television service by the CRTC.

AMI-audio is Canada's only English-language television audio reading service. It offers a variety of compelling stories and engaging original content to Canadians who are blind, partially sighted or otherwise print-restricted. AMI-audio's mandate is to deliver a steady and timely flow of information that is essential to the decision-making needs of our audience.

AMI-tv and its French language counterpart, AMI-télé, are television services that provide blind, partially sighted, deaf and hard-of-hearing Canadians with access to open-format described video and closed-captioned versions of popular programming, as well as original first-run content, in a manner that is inclusive for all.

For those unfamiliar with the term “described video”, or DV, it's a narrated description of a program's main visual elements, such as settings, costumes and body language. Descriptions are added during pauses in dialogue, and enable blind and partially sighted individuals to form a mental picture of what's happening in the program. While DV typically uses a separate audio track, AMI has pioneered the use of integrated described video, or IDV, whereby the identification of the key individual elements is incorporated into the pre-production, production and post-production phases of the original programs.

In addition, all the programming on AMI-tv and AMI-télé is provided in open-format described video with closed captioning. No special equipment or extra steps are required to access any of our television services, making them truly accessible 24 hours a day, seven days a week.

All three of our television services are the first of their kind in the world. These three services, along with our companion websites, mobile app, online media player, YouTube channel, and social media presence, provide blind, partially sighted, deaf and hard-of-hearing Canadians with access to entertainment, news and information programming that they would not otherwise be able to enjoy on platforms of their choice.

However, AMI is more than just a broadcaster. In order to address the evolving needs and expectations of blind and partially sighted Canadians and the changes within the audiovisual environment, AMI is involved in a multi-faceted company that creates, advocates, collaborates and innovates in order to enable accessibility to all media.

With regarding to creating, our television services focus on creating commissioned, original first-run Canadian programs that directly address issues of importance to blind, partially sighted and disabled communities. Without AMI's provision of this type of programming, these stories would not otherwise be told. These programs all provide positive on-air portrayal of blind and partially sighted individuals as hosts or subjects of the programs, and feature themes and material of particular relevance to blind and partially sighted individuals.

As a result, AMI has become a springboard for talent in the blind and partially sighted community, with approximately 78% of our on-air personalities being persons with a disability.

Regarding advocacy, AMI has become a leader in advocating on behalf of the blind and partially sighted community to domestic and foreign regulatory bodies, such as the CRTC and the disability advisory committee of the Federal Communications Commission, or FCC.

In addition, we provide opportunities for blind, partially sighted and disabled individuals to participate more fully in social, political and cultural life. For example, we hosted an accessible federal election town hall for the 2015 federal election, which encouraged blind and partially sighted individuals to cast their ballots and participate in a key aspect of our democracy.

On collaboration, we collaborate with numerous organizations, including the Canadian Association of Broadcasters, the Federal Communications Commission and, most recently, the World Wide Web Consortium to ensure that Canada's accessibility agenda is advanced both domestically and internationally.

We partner with other broadcasters in local colleges to teach integrated described video techniques, in the hopes that future generations of producers will regard accessibility as a fundamental component of production rather than a post-production afterthought.

We innovate. Through our innovation, we try to ensure that scientific and technological advances in accessibility are extended to blind and partially sighted communities. Our innovative and pioneering use of integrated described video has resulted in multiple awards. Together with the Canadian Association of Broadcasters and other organizations, we have created an award-winning online described video TV guide. We launched our first successful online media player for broadcasts in North America, and starting with our breakthrough live description of Toronto Blue Jays baseball games, we have described live events that were previously thought to be unsuitable for described video, opening a whole new world of possibility and enjoyment for our viewers.

We're also actively involved in developing and approving DV awareness and standards both within the Canadian broadcasting system and on the international scale. Together with the Canadian Association of Broadcasters and other organizations, we have created best-practice guides for DV and IDV production in both official languages.

In 2017 we were awarded the FCC Chairman's Award for advancement in accessibility for the integrated described video best practice guide. AMI was one of only four winners of this award, two others of which were Facebook and Amazon.

These innovations enable AMI and other broadcasters to improve the quality of their described video productions and to make them readily available to blind and partially sighted viewers. As evidenced from these examples, AMI's mandate is not just about accessibility but also about representation, reflection and positive portrayal of blind and partially sighted Canadians.

However, there is still more work to be done. The needs and expectations of the blind and partially sighted community with respect to media accessibility are undergoing the same profound shift as experienced in broader Canadian broadcasting systems. Like everyone else, these viewers are in search of high-quality content that speaks directly to their needs and interests and that is readily available on a variety of platforms.

According to the CNIB, approximately half a million Canadians are estimated to be living with significant vision loss that impacts their quality of life, and every year more than 50,000 Canadians will lose their sight. Moreover, CNIB predicts that the prevalence of vision loss in Canada is expected to increase nearly 30% in the next decade. This is due to the demographic shift caused by the aging population, with the population of Canadians aged 65 and older expected to double in the next 25 years.

In addition, there is a growing incidence of key underlying causes of vision loss, such as obesity and diabetes. The CNIB warns that without action, the number of people with sight problems in Canada is likely to increase dramatically.

[The Chair, Liberal, Bryan May]

Excuse me, Mr. Errington; you're running at about seven and a half minutes.

[David Errington]

Okay.

[The Chair, Liberal, Bryan May]

I'm wondering if you can just conclude quickly, and then maybe we can deal with some things in questions. Thank you.

[David Errington]

Sure. No problem. I'll just do the final part.

We are pleased that the CRTC has prioritized certain of these accessibility measures in their recent policy decisions. The CRTC has implemented a tiered approach to ramp up the amount of DV programming being provided by television broadcasters based on the size and resources of broadcasters. The CRTC has required certain television distributors to include in their annual returns certain information relating to the availability of set-top boxes, the penetration of set-top boxes, and the number of accessibility-related queries they receive. These measures are consistent with and perhaps even overlap some of the reporting requirements contained in Bill C-81.

Given the limited financial means of many blind and partially sighted individuals and the lifeline that television and media provide to these individuals, we believe the Government of Canada should ensure that accessible set-top boxes and remote controls are available for free or at a substantially discounted rate to blind and partially sighted individuals. Until accessible set-top boxes and remote controls become ubiquitous, there will continue to be a barrier to television programs for blind and partially sighted Canadians.

I appreciate the opportunity to present AMI's views on this important matter, and I will be pleased to respond to any questions you may have. Sorry for being long.

[The Chair, Liberal, Bryan May]

Thank you.

Up next, from ARCH Disability Law Centre, we have Robert Lattanzio, executive director; and Kerri Joffe, a staff lawyer.

Welcome to both of you. Go ahead for five minutes, please.

[Robert Lattanzio, Executive Director, ARCH Disability Law Centre]

Thank you, Mr. Chair.

Thank you to this committee for this opportunity to speak with you this morning.

ARCH Disability Law Centre is a specialty legal clinic focused solely on disability rights. We work on the ground with communities of persons with disabilities, with disability organizations, and within all levels of courts and tribunals in test case litigation. We commend the government and the minister for introducing Bill C-81, an important and positive step towards advancing full inclusion for persons with disabilities. We believe that amendments are needed for this bill to achieve its stated purpose.

Today we highlight four recommendations.

First, we would like to address exemptions. This committee has heard from government that exemptions are needed to ensure innovation and flexibility for small organizations and those who exceed accessibility standards. We do not agree that the broad exemption powers currently in the bill are necessary to achieve these policy objectives. The bill must send a strong message that accessibility is everyone's responsibility. Therefore, as a general matter, regulated entities must not be exempt from complying with accessibility requirements. If exemption provisions do remain in the bill, we recommend safeguards, including these next three: one, exemptions should be granted only in the narrowest of circumstances; two, reasons for the exemption should be made public and the public should be afforded opportunities to provide feedback; three, any exemptions should be subject to periodic review and should be removed if and when they are no longer necessary.

The second recommendation today, as the committee is aware, relates to the fact that the bill lacks timelines. ARCH shares the concerns of disability communities. Timelines are essential for ensuring that the bill will advance accessibility in Canada and for measuring progress towards this goal. We support recommendations that clause 5 include a timeline for achieving a Canada without barriers. We support recommendations that the bill include timelines by which accessibility standards are developed and enacted into law.

With regard to timelines, progressive realization is an important international law concept that can provide a framework for ongoing implementation and monitoring of accessibility requirements. ARCH recommends that the minister and regulated entities establish benchmarks for progressively realizing a Canada without barriers in all the designated areas, establish specific and progressive timelines for meeting these benchmarks, and monitor progress towards meeting these benchmarks.

We also recommend that independent reviews of the act be held to coincide with Canada's reporting obligations under the UN Convention on the Rights of Persons with Disabilities. We recommend that the first independent review of the act be held in 2025, to coincide with Canada's third report to the UN CRPD committee, and every four years thereafter.

Third, we need amendments to ensure that accessibility requirements do not diminish existing legal rights of persons with disabilities. The Canadian Human Rights Act and the charter provide vitally important protections from discrimination for people with disabilities. Disability communities fought hard for these protections. We are concerned that regulated entities may believe that compliance with accessibility requirements is the same as fulfilling their obligation to accommodate and not discriminate. This would be a troubling, unintended consequence of Bill C-81. The bill must work together with the Canadian Human Rights Act and the charter. Therefore, we recommend that the preamble and the purpose clause of Bill C-81 clarify that nothing in the act lessens existing human rights obligations of federally regulated entities under the Canadian Human Rights Act, and that where a conflict arises between the proposed accessible Canada act and another law, the law that provides the greatest accessibility for persons with disabilities will apply.

Fourth, Bill C-81 does not designate one central agency to oversee compliance of accessibility requirements and to adjudicate complaints. Rather, it creates an overly complex system of multiple agencies. This will create confusion and additional unnecessary barriers to access to justice for persons with disabilities. We heard this concern consistently throughout the consultations that we conducted. Multiple bodies adjudicating accessibility complaints will likely result in uneven or unfair enforcement, delay and inefficiency.

Following a legal analysis of CTA decisions, and from our experience, we are concerned that the CTA may be more likely to treat human rights and accessibility as secondary to technical concerns, resulting in weak enforcement of accessibility requirements in transportation. We heard similar concerns from the community about the CRTC.

To avoid these problems, the accessibility commissioner should receive all complaints about violations of accessibility standards. The no-wrong-door policy is inadequate to address our concerns.

Our materials include recommendations in relation to the rights of indigenous persons with disabilities, intersectionality and recognition of sign languages, among other important issues.

Thank you. We would be happy to take any questions.

[The Chair, Liberal, Bryan May]

Thank you very much.

Up next, from the Canadian Radio-television and Telecommunications Commission, is Scott Shortliffe, chief consumer officer and executive director, as well as Marie-Louise Hayward, manager, social and consumer policy, and Adam Balkovec, legal counsel.

Thank you to all three of you. You have five minutes, please.

[Scott Shortliffe, Chief Consumer Officer and Executive Director, Canadian Radio-television and Telecommunications Commission]

Thank you, Mr. Chair, for this opportunity to participate in the committee’s review of Bill C-81, an act to ensure a barrier-free Canada.

I’d like to begin today by saying two things. First, I'd like to acknowledge that we meet today on traditional Algonquin territory. Second, if you'll permit me:

[Witness speaks in sign language]

The CRTC's approach to accessibility is based upon the fundamental belief that a person's ability to access broadcast and telecommunications services dictates their ability to participate meaningfully in society. Our accessibility policy is grounded in the principle that equality is a core Canadian value and is central to public interest.

During the last three decades, the CRTC has adopted a series of regulatory policies to enhance the ability of Canadians with disabilities to access communications networks. We have updated these policies as new technologies and resources have become available.

The CRTC has continually championed accessibility and has required service providers to deploy appropriate technologies to improve access for all Canadians, regardless of their level of ability.

In the mid-1980s, for example, the CRTC began to mandate teletypewriter, or TTY, relay services for Canadians who have a hearing or speech disability. In 2009, the requirement was expanded to include the provision of IP relay services, and, five years later, the provision of video relay service.

Accessibility requirements for broadcasters have followed a similar evolution. Initially, broadcasters were required to closed-caption only a percentage of programming. Today, all pre-recorded English and French programming must be closed-captioned.

In 2009, the CRTC began to require that broadcasters provide described video services four hours per week. Beginning next year, all large integrated broadcasters must provide the services throughout prime time.

The CRTC's work in the domain of accessibility also includes regulatory measures designed to facilitate access to the devices Canadians use to access communications services, whether it is accessible set-top boxes, remote controls or wireless mobile handsets.

The CRTC also recognizes the importance of facilitating interactions with service providers. This is why we established mandatory industry codes of conduct: the Wireless Code and the Television Service Provider Code. These codes ensure that persons with disabilities can receive contracts and bills in accessible formats, and can access extended trial periods to ensure that equipment and services will meet their individual needs.

To develop regulatory policies, the CRTC consults with Canadians—including those with disabilities—along with service providers and other stakeholders by holding open, public proceedings. The input of Canadians with disabilities is crucial to developing effective and impactful accessibility policies. It's also why the CRTC website presents key content, such as a guide to our Rules of Procedure, in ASL—American Sign Language—and LSQ—Quebec's Langue des signes québécoises.

To achieve the larger goal of barrier-free access, the CRTC recognizes that it must engage with other administrative tribunals. To this end, the CRTC participates in working groups alongside the Canadian Human Rights Commission and other administrative tribunals in order to leverage accessibility expertise and increase efficiency.

As a federal regulatory tribunal, the CRTC must pursue the policy goals set by the Broadcasting Act and the Telecommunications Act and also act fairly, abiding by the Canadian Charter of Rights and Freedoms. This requires the CRTC to balance competing objectives in rendering decisions that ultimately serve the public interest.

As communications technologies evolve, Canada's regulatory framework must be flexible and rigorous enough to make the most of new opportunities and to eliminate and prevent systemic barriers related to accessibility. Advances in communications technologies have opened the door to an unprecedented wealth of content and interactivity. The CRTC's position is that it is the right of all Canadians to be able to access this wealth regardless of their ability, and it is committed to working to ensure that all Canadians can benefit from it.

As I mentioned, the CRTC's approach is informed by Canadian human rights principles, and these principles will continue to guide our regulatory work.

I'd like to remind this committee that the CRTC is an independent regulator. I note that this panel includes a party regulated by the CRTC. As such, and to preserve the commission's independence as a regulator, I may be unable to comment on certain issues raised or to fully answer certain questions. That said, I will do my best to answer any questions this committee may have.

Thank you very much.

[The Chair, Liberal, Bryan May]

Thank you, sir.

Up first is MP Falk for six minutes, please.

[Rosemarie Falk, Conservative, Battlefords—Lloydminster, SK]

I'd like to thank you all for taking time out of your day to be here today. The committee really appreciates it, because we are hearing different things.

Earlier today, colleagues across the way mentioned that they'll be pushing for no timelines, or they alluded to that. On that, I have a question for ARCH, for Mr. Lattanzio and Ms. Joffe.

You mentioned in your opening remarks the importance of timelines and benchmarks. Do you have suggestions of what those timelines or benchmarks should be?

[Robert Lattanzio]

We have some examples, but I would just like to start, if I may, by talking a little bit more about what flowed from the earlier session in terms of “progressive realization”. We understand it to be much more rigorous than what was discussed at that previous session. When we think about examples of timelines, we're really thinking about how we break down the various pieces. As complex as this piece of legislation is, we're really thinking about creating a structure whereby we can start parcelling off and achieving certain benchmarks.

Some examples would be just around the standards development process—having some timelines, some measurements, and some benchmarks for regulated entities to develop and implement their accessibility plans. Those are just a few examples, but we can really break that down and identify various other things.

[Rosemarie Falk, Conservative, Battlefords—Lloydminster, SK]

Even with regard to having the accessibility commissioner and CASDO established, and the timelines with that, with the way the legislation sits right now, once this receives royal assent, what happens?

[Kerri Joffe, Staff Lawyer, ARCH Disability Law Centre]

As my colleague stated, we certainly support the calls from the other disability organizations that have appeared before the committee that of course there should be timelines attached to part 5 of the bill for bringing in the regulations and standards, for CASDO being set up, and for the standards development process.

I think what we've been trying to emphasize as well, in addition to those standards, which are crucial for ensuring that we can monitor progress towards meeting accessibility requirements, is that we also need to insert benchmarks and some kind of timeline process within the development of the standards process in order to ensure that we do reach markers for progressive realization of the standards and the ongoing work toward improving meeting the standards.

[Rosemarie Falk, Conservative, Battlefords—Lloydminster, SK]

Do you think that having some type of timelines or benchmarks while doing this piece by piece, step by step, would achieve the balance? The trend I'm seeing or hearing from people within the disability community is that they expect timelines to be in this. A lot of the organizations I've met with said that this should have been dealt with yesterday, not today, just as a whole.

I understand that we're moving forward. Things are evolving. Things change over time. I understand that. I'm just concerned that if this legislation has no timelines, no benchmarks, what type of message would that send to people in the disability community?

[Robert Lattanzio]

I would be concerned about that message. I think overall the concern, as you mentioned, is that as of day one, when this bill receives royal assent, there isn't anything else required.

In addressing the concern about the progression of technology, for example, or how we understand disability and how it evolves, our response would be that standards would have to be updated as we go, and that these updates would fit within whatever timeline is set out. There are ways of dealing with that kind of progression and change.

[Rosemarie Falk, Conservative, Battlefords—Lloydminster, SK]

Perfect. Thank you.

I have one other question regarding complaints. We know—and I believe you touched on this—that we have four administrative bodies that would be responsible for dealing with accessibility-related complaints. These would include the accessibility commissioner, the CRTC, the Canadian Transportation Agency, and the Federal Public Sector Labour Relations and Employment Board. I'm wondering what would happen, theoretically and hypothetically, if an individual were to bring a complaint to the wrong administrative body. What would happen if, for example, somebody brought a complaint to the accessibility commissioner when it should have instead been filed with the Canadian Transportation Agency?

[Kerri Joffe]

That's an excellent question. I don't think that we know right now what would happen in the absence of regulations and without sufficient experience in how the process would roll out within the various agencies.

What I will say is that in doing our analysis of the bill and in coming up with recommendations, we consulted with our members, with disability communities and with a number of the other groupings of disability organizations that have appeared before the committee and will appear before the committee later this week. We heard consistently across all those consultations that there is great concern within the community about having these various agencies deal with complaints and about the additional access-to-justice barriers that this would create, especially when disabled people already experience a number of barriers to accessing justice and accessing extremely complicated service delivery systems and programming systems. People are very concerned about that.

From a legal point of view, we are concerned about the ability of the other bodies charged with addressing these complaints to apply a robust human rights analysis in conjunction with a full understanding of disability accessibility and human rights. We've made a number of recommendations in our other materials for ensuring that either complaints all go to the accessibility commissioner, a body that we would anticipate would have a deep understanding of human rights and can do justice to those kinds of complaints, or, if the complaints are going to continue across multiple agencies, that those agencies have obligations in the legislation to apply a much more robust human rights analysis than they currently do.

[Rosemarie Falk, Conservative, Battlefords—Lloydminster, SK]

Thank you.

[The Chair, Liberal, Bryan May]

Thank you very much.

MP Morrissey is next, please.

[Bobby Morrissey, Liberal, Egmont, PE]

Thank you, Chair.

My question is to ARCH. An earlier witness made the statement that at no time will Canada be barrier-free, which then leads to a question we've heard from a number of stakeholders, namely, that there is no deadline to make Canada fully accessible. Should the goal be to always strive to achieve a more accessible Canada, or should the goal be to achieve a static standard of accessibility? I'd be interested in your observation.

[Robert Lattanzio]

I don't think that having timelines means we are taking the position that we are accepting a static accessibility goal. We think about timelines just as a way to move us forward into whatever evolution.

I think we also need to remember that this bill is not going to do it all. This isn't the one law that will make inclusion real for people with disabilities. This isn't the law that will make full citizenship real. This is one important piece—one piece—and we need to understand that we have a lot of different layers. We have an incredibly aspirational convention that we've ratified. We have the charter, of course, and we have the Canadian Human Rights Act. I think this committee has heard a lot about how the Canadian Human Rights Act, like those types of laws, is a piece of legislation that is reactive, and that this bill is proactive.

I want to challenge that a bit, because I think that in order to really understand where this bill fits into the larger landscape, we need to acknowledge that the human rights legislation is actually not just reactive. There are a lot of things from a rights perspective that really strive to encourage government and the private sector to push for accessibility through a non-discrimination lens. When you think about that with the charter, and then you add this piece, you start to really understand the importance of some of the recommendations we're making around ensuring that one piece of law doesn't impact the other, but rather complements the other.

I hope that answers your question.

[Bobby Morrissey, Liberal, Egmont, PE]

It spoke to the global issue, but it didn't get back to what the target should be: to achieve a more accessible Canada or to achieve a static accessibility goal.

I have another question for ARCH. This legislation, as was referenced a number of times, takes on an access approach versus an anti-discriminatory route. Could you comment?

[Robert Lattanzio]

Sure. I guess this—

[Bobby Morrissey, Liberal, Egmont, PE]

Other jurisdictions have used an anti-discriminatory route rather than the focus on access.

[Robert Lattanzio]

Again, if we think about how these different laws operate, we see that we have a more individually driven system through an anti-discrimination approach, whereby you have a complainant identifying an issue of discrimination and bringing it forward through a process. It's somewhat piecemeal. It's embedded within the facts of that scenario, within the facts of that complaint. The attempt here is that we are thinking about it more globally. We are thinking about a level of minimum standards.

Again, I don't want to treat them as different. I think they need to really work together for this to really work. Think about how we work through human rights complaints. Obviously we deal with the facts before us, but we think about the systemic implementation of some of the remedies. We think about the impact. Sometimes we deal with issues that this act may very well deal with. There are a lot of those commonalities.

Again, I fear to draw clear distinctions between the two. There is overlap, and there is a real need to make sure they work together.

[Bobby Morrissey, Liberal, Egmont, PE]

Did your group participate in the consultation process?

[Robert Lattanzio]

Yes, we did.

[Bobby Morrissey, Liberal, Egmont, PE]

In that consultation process, did you comment on or question the situation that I just posed to you?

[Kerri Joffe]

We did. During the consultation process, we made comments and provided information around trying to think about this legislation as not only focused on accessibility but really focused on rights for persons with disabilities, in terms of thinking about persons with disabilities as rights holders and about the CRPD implementation kind of legislation.

We wrote a couple of papers in the pre-bill consultation period that tried to think about and put forth some recommendations around how this legislation could implement a number of rights that are in the Convention on the Rights of Persons with Disabilities and implement those much more fully into Canadian domestic law. We can provide those to you if that would be of interest after today.

Yes, when Bill C-81 was getting going, I think we definitely were thinking of this legislation much more as rights-conferring legislation, rather than focusing only on accessibility.

[The Chair, Liberal, Bryan May]

Thank you very much.

MP Hardcastle is next, please.

[Cheryl Hardcastle, NDP, Windsor—Tecumseh, ON]

Thank you, Mr. Chair.

Thank you very much for the testimony and for pointing out the importance of progressive realization of timelines.

I think ARCH will probably have the first comments to make on this. With regard to Bill C-81, the largest organization that will have to obey this legislation is the federal government. I want to ask about independence from the government. Under the bill right now, there could be some perceived weakness in independence. I'd like to hear your thoughts on that.

[Kerri Joffe]

Thank you for the question.

Certainly we would agree that independence is crucial for key components of this bill. It is crucial, especially for CASDO, to ensure that the proposed accessibility standards are as robust and progressive as they can possibly be, and really address the needs of a cross-section of persons with disabilities without being encumbered by the government of the day or the particular politics of the day. That's an area where we have made recommendations for enhancing independence.

We've also made recommendations around independence in relation to other key accessibility components in the bill, and we're happy to provide those to the committee. Those are contained in our written submission to the committee.

[Cheryl Hardcastle, NDP, Windsor—Tecumseh, ON]

Does anybody else want to talk about independence, and where these agencies should report?

[Scott Shortliffe]

From the CRTC's perspective, it's a bit of a double-edged sword. We will of course implement whatever legislation is passed; we're not going to take a view on whether it should be with us or not. The CRTC has always zealously guarded its independence. Numerous governments of the day could testify that they haven't always been delighted with CRTC decisions.

We are working with the other agencies to say that we've seen the thrust of the bill and we will implement what it has passed, but, for example, we're forming working groups to make sure there's a “one front door” approach. If a complaint came into the CRTC that belonged to the transportation agency, we wouldn't simply send them on their way. We'll process it the moment it comes in.

I think, as independent tribunals, we can maintain our independence from the government, but that doesn't mean we can't also work together efficiently and effectively to make sure that the intent of this bill is always respected. I believe that we have shown in the past that we can be independent. I also believe that means we can work together for the benefit of persons with disabilities.

[Cheryl Hardcastle, NDP, Windsor—Tecumseh, ON]

Thank you.

Let's go back to the concern we heard from Mr. Shortliffe about exemptions. A big concern is that there are exemptions without any reason having to be given. We talk about this bill moving us into an era of culture change, of human rights for persons living with disabilities, but there's no appeal process. Let's talk about if, worst-case scenario, the exemptions stay for these federal jurisdictions. Can we flesh out the idea of reporting, an appeal mechanism, a rationale for it?

[Scott Shortliffe]

It's important to remember that from the perspective of the CRTC, we already have established procedures. There's nothing that goes to the CRTC that isn't based on a public record or a public hearing comment, which includes comment by disability groups. Once we make decisions, they can be appealed. They can be appealed to cabinet in the case of a telecom for a review on variance.

On the broadcasting side, they can be appealed to the Federal Court. In the issues that have been raised, the CRTC operates on the public record and on the basis of public testimony. We do not issue exemptions issued by a star chamber with no public record and without—

[Cheryl Hardcastle, NDP, Windsor—Tecumseh, ON]

Absolutely, and that's all good. The track record of the CRTC is all public knowledge.

We'll give the last little bit, then, to ARCH.

[Kerri Joffe]

We addressed this in our opening remarks, but I think our recommendation has been to have no exemptions. The policy reason for that is, as Mr. Lattanzio said, that accessibility is everyone's responsibility, and no one should be exempt from moving towards a more inclusive and accessible Canada.

You asked about keeping the exemptions, and we've made some recommendations for tailoring those exemptions much more specifically to the particular requirements of the organization that is asking for an exemption. We would say that those exemptions should be granted only in the very narrowest of circumstances. They should be time-limited. There should be a review process in place so that as the organization works towards meeting its accessibility requirements, if and when that exemption can be lifted, it is lifted, and before the decision is made to grant that exemption, there should be a process in which persons with disabilities can engage to provide their input and perspective about whether that exemption is actually required and what the impact of that will be on the community.

[The Chair, Liberal, Bryan May]

Thank you very much.

MP Sangha, go ahead, please.

[Ramesh Sangha, Liberal, Brampton Centre, ON]

Thank you very much, Mr. Chair.

Thanks, everyone, for coming today and making your presentations. They're really very educational.

I'm from Brampton Centre. There are people whom I generally sit with and talk to and do some consultations with regarding the things I'm coming to committee with and asking questions about.

I had a chance to talk to Ms. Bains. She has an accessibility professional certification. She is an expert in digital accessibility and she advises teams and management about creating inclusive accessible online services.

Being an expert in this, she says she has no grudges. She has good facilities that are being provided through the Accessibility for Ontarians with Disabilities Act. Things are favourable, but sometimes she says there are disappointments.

She says there is a complaint process that disabled people sometimes have to go through. They have to hire their own lawyer. The other side's organizations have their firms and big lawyers, and the disabled person's side has very big problems getting suitable results from the tribunals. Being a lawyer, I also have that concern.

Ms. Joffe, my question is to you. Being a house lawyer, what do you think of this proposition? What is your reply to how to tackle these complaints?

[Kerri Joffe]

How do I address the issue about people with...?

[Ramesh Sangha, Liberal, Brampton Centre, ON]

I mean the complaints about accessibility for these people.

[Kerri Joffe]

We experience every day in our clinic that people with disabilities are very disempowered. There are many complaint processes because, as you said, the respondents or the organizations that are being complained about usually have a lot more resources, and they have lawyers and in-house counsel, and they can bring a lot of resources to bear in defending themselves.

When we're looking at the bill and how this bill sets up a complaint mechanism to the accessibility commissioner and to other bodies, but specifically to the accessibility commissioner, it appears to us that the process is intended to be relatively quick and non-legalistic, and to provide a remedy or a result in a manner that doesn't create these power imbalances in which the other side has a lot of lawyers and the person with the disability is really at a disadvantage.

I think if we can work to get a complaint process that does create a bit more of a power balance and that can really support people with disabilities meaningfully participating in that process, and if that process can be really accessible, then hopefully there will be a chance to avoid some of those concerns you have raised.

[Ramesh Sangha, Liberal, Brampton Centre, ON]

Taking into comparison the Canadian Human Rights Commission Tribunal and the new set-up that will now be under Bill C-81, do you think that the process under Bill C-81 will be more favourable to complainants or will it be more tedious?

[Kerri Joffe]

Yes. It's very—

[The Chair, Liberal, Bryan May]

Give a quick response, please.

[Kerri Joffe]

It's very difficult to say, because we don't know what that process looks like right now, so I'm not really able to answer as to whether it's going to be more favourable to people or not. What will determine whether it's going to be more favourable is how accessible the process is, how much it allows people with disabilities to meaningfully understand and participate in the process, what kinds of results or remedies we get, how well trained the decision-makers are, and how deeply they understand human rights and accessibility issues.

[Ramesh Sangha, Liberal, Brampton Centre, ON]

Is the dispute resolution process the same as this one? Is there already a dispute resolution process in existence?

[The Chair, Liberal, Bryan May]

Answer very quickly, please.

[Kerri Joffe]

Is there a dispute...?

[Ramesh Sangha, Liberal, Brampton Centre, ON]

Is there a dispute resolution process already in existence to resolve complaints?

[Kerri Joffe]

I think some of the issues that people with disabilities will complain about to the accessibility commissioner may also be able to be brought to the Canadian Human Rights Commission under their legislation, the Canadian Human Rights Act.

[Ramesh Sangha, Liberal, Brampton Centre, ON]

Thank you.

[The Chair, Liberal, Bryan May]

Thank you very much.

MP Long is next, please.

[Wayne Long, Liberal, Saint John—Rothesay, NB]

Thank you very much, Mr. Chair.

This is for ARCH and Mr. Lattanzio. I want to talk about the “no wrong door” part of the legislation. Obviously if you go to a department, you don't just get bumped to another department; there's onus on the department. Would you not agree that's a step in the right direction?

[Robert Lattanzio]

It's certainly better than.... If that's going to be the system, then we want to make sure that the complaint lands where it needs to land. I think the real issue is that when you have an overly complex system, it's best to remedy that system, as opposed to creating band-aid solutions.

As we discussed earlier, we already have various incredibly complex tribunal processes that persons with disabilities really struggle through. There is a lack of legal representation and a lack of legal aid that covers a lot of these areas like human rights, for example. It's really difficult for us to say that this is a solution.

We also might think about, from an accessibility perspective and an access to justice perspective, what it means if someone can make a complaint to a body, and it's up to that body, up to a bureaucratic decision, where that complaint goes. I think we would have some very serious concerns around the lack of control and the disempowerment that this mechanism plays on the complainant.

Again,if we had a system in which we had assurances of legal support, for example, I think my answer might be a little bit different—probably not—but there are no supports in place here.

[Wayne Long, Liberal, Saint John—Rothesay, NB]

Thank you for that.

I also want to get your opinion on the CASDO board, diversity on the board, and subclause 23(2). Is there a way to amend that, potentially, that allows for more diversity on the board in the disability community?

[Robert Lattanzio]

Certainly we would suggest, as do our colleagues in disability communities, that we would want as much representation as possible given the diversity, intersectionality and multiple disabilities.

I want to make a point that I haven't heard yet. We talk a lot about the makeup of the CASDO board, but we haven't really talked about the makeup of the committees that are doing a lot of that work in standards development. I think we have a concern that there hasn't really been a lot of attention to ensuring representation on those committees.

[Wayne Long, Liberal, Saint John—Rothesay, NB]

Thank you.

[The Chair, Liberal, Bryan May]

You have about a minute left.

[Wayne Long, Liberal, Saint John—Rothesay, NB]

Well, if we have a minute, does anyone else want to comment on the makeup of the CASDO board? Should each disability community be represented as best possible? Should it be 50% plus 1 or 70%? There are those who say 100%.

Mr. Shortliffe, would you comment?

[Scott Shortliffe]

As a regulatory body, we try to avoid commenting on the government's decisions on the compositions of boards and other regulatory bodies. Certainly we believe there should be strong representation, but we don't have a specific formula that we would advise.

In our case, when we're doing consultations, we consult regularly with groups. Whether they're national like CNIB and the Neil Squire Society or the alliance for deaf Canadians in Alberta, we see that having different points of view represented is key, because as with any Canadians, disabled Canadians have a variety of different views. It's not a monolith. The greater diversity you have, the more informed your decisions will be.

Having said that, we have no specific formula to propose.

[Wayne Long, Liberal, Saint John—Rothesay, NB]

Thank you.

[The Chair, Liberal, Bryan May]

Thank you very much.

I'm afraid that's going to have to be the last word.

Not only are we coming up to our time but we can see that the bells are ringing for votes.

I want to remind committee members that some unique times are associated with the next few meetings.

We are going to be meeting tomorrow evening, October 24, from 6:45 to 8:45. Then on the 25th we will be here very early, at 8 a.m., so it will be a late night and an early morning.

I want to thank the witnesses for being here today to contribute to our study on Bill C-81.

As well, thank you to my colleagues and all the people who made today possible.

The meeting is adjourned.