This is our first Annual Accessibility Report in which the entire reporting period occurs in the backdrop of the COVID-19 pandemic. Notwithstanding the incredible challenges associated with operating in such times, we have been particularly mindful of the core principles of the AODA for fostering independence, dignity, integration, and equality of opportunity for people with disabilities. We have remained proudly committed to accessibility being fully integrated with the overarching values of the Human Rights Commissioner’s Office (HRCO) and York Region District School Board (YRDSB) at large. We approach our understanding of accessibility as about people and relationships in furtherance of a culture of inclusion.

Over the past year, the work of our AODA Advisory Committee has been intentionally focused on addressing and removing of barriers to accessibility. In the previous reporting year, our Annual Accessibility Report and Multi-year Accessibility Plan were more purposefully aligned with the Integrated Accessibility Standards Regulation (IASR). This resulted in the accessibility standards being built into the structure of the AODA Advisory Committee, including our supporting subcommittees and working groups. This past school year, we have been mindful on the connection between mental health and accessibility due to these pandemic times. In our work, we have been committed to encouraging good mental health practices and supporting the system with accessibility inputs specific to mental health and other key accomplishments during the reporting period, including:

• Ongoing professional learning - both in terms of ADOA compliance and accessibility acceptance beyond compliance obligations;
• Launch of Accessibility Resource Hub - presented and well-received at the 36th Annual Pacific Rim International Conference on Disability and Diversity;
• Refreshing of the HRCO website – as part of the larger new YRDSB website launch; and
• Comprehensive review and feedback report ­- on the Proposed K-12 Education Standards.

As we move forward to a post-pandemic world, we will remain committed to ensuring that accessibility remains a paramount consideration and is fully integrated into the Board’s approach to diversity, equity and inclusivity from a human rights lens.

Sincerely,

Anthony Anirud
Human Rights Commissioner

Legislated Purpose

York Region District School Board (YRDSB or the Board) has prepared this Annual Accessibility Report in accordance with the Integrated Accessibility Standards, Ontario Regulation 191/11 under the Accessibility for Ontarians with Disabilities Act (AODA), 2005.

The Board is defined as a “designated public sector organization” in the AODA. All designated public organizations are required to:

• “prepare an annual status report on the progress of measures taken to implement the [multi-year accessibility plan], including steps taken to comply with this Regulation; and
• post the status report on their website, if any, and provide the report in an accessible format upon request. (O. Reg. 191/11, s. 4).

The Annual Accessibility Report describes the measures that YRDSB has taken in the past school year and the ensuing summer months (September 2020 to August 2021) to identify, remove, and prevent barriers to accessibility for everyone who learns, works and participates in the Board community. The annual status report continues to be prepared as a separate document from the Multi-Year Accessibility Plan 2020 to 2025.

The Annual Accessibility Report is presented to Executive Council and subsequently to Board Standing Committee each fall. Following approval, this annual report will be posted on the Board’s Accessibility Reports and Plans webpage.

Commitment to Accessibility

The Board’s commitment to accessibility is led by the Human Rights Commissioner’s Office (HRCO). Specifically, the Accessibility Officer within the HRCO is responsible for managing the accessibility portfolio for YRDSB. Accessibility is further guided through the shared responsibilities and collaborative commitments of the AODA Advisory Committee.

Our commitment to accessibility is aligned with the four priorities of the Board of Trustees’ Multi-Year Strategic Plan (MYSP). Four Multi-Year Accessibility Goals have been developed in alignment with the four MYSP priorities and the Director’s Action Plan:

1. Provide Accessible Customer Service
2. Understand Accessibility as a Process
3. Engage the AODA Advisory Committee
4. Publish an Annual Accessibility Report

1.1 Accessibility Policy

Plain Language Guides and Alternative Formats

The Plain Language Guide to Policy #407, Accessibility was finalized as a more reader-friendly and accessible version of the full policy document.

The Plain Language Guide to Policy #407, Accessibility was also converted into accessible webpages as a proactive measure to meeting the subsequent requirement to “make the documents publicly available and, on request, provide them in an accessible format” (O. Reg. 191/11, s. 3).

1.2 Annual Accessibility Plans and Reports

AODA Advisory Committee Meetings

Four AODA Advisory Committee meetings were held virtually during the 2020-2021 school year. All approved meeting minutes are available to the public on the AODA Advisory Committee web page.

The first two AODA Advisory Committee meetings (in September and November 2020) were used to collectively review, provide feedback on, and endorse the renewed Multi-Year Accessibility Plan 2020-2025.

Annual Accessibility Report

This report is the completed annual accessibility report describing the measures that YRDSB has taken in the 2020-2021 school year to identify, remove and prevent barriers to accessibility.

The finalized report is posted online to the public on the Board’s Accessibility Reports and Plans web page following review and approval by Executive Council and the Board of Trustees at the November 23, 2021 Board Standing Committee meeting.

Annual Compliance Report

The accessibility compliance report for YRDSB was submitted to the Ministry for Seniors and Accessibility on December 10, 2021. A copy of the accessibility compliance report was shared with the Director’s Office.

Joint Letter to Minister of Seniors and Accessibility

On October 22 2021, a joint letter regarding specific concerns with question 14 of the compliance report was sent to the Minister of Seniors and Accessibility, Raymond Cho, from advocacy groups in K-12 and post-secondary (refer to Appendix A in PDF version for full report).

• “As of January 1, 2021, do all your organization's internet websites conform to [WCAG] 2.0 Level AA (except for live captions and pre-recorded audio descriptions)? Please indicate in the comment box provided the complete names and addresses of your publicly available web content, including websites, social media pages, and apps.”

The joint letter to Minister Cho notes that the response for question 14 requires very difficult and onerous reporting. As approved by the Board’s Executive Council, YRDSB supports these concerns as there are countless URLs, web addresses and other web assets connected to the Board. Additionally, not all YRDSB-related web content is approved by the Board (e.g., Google Sites created individually by YRDSB educators). However, all Board-approved web content through Corporate Communications does comply with WCAG 2.0 Level AA, including the new website and Board-approved videos.

The joint letter makes the following proposal for responding to question 14 in a way that would allow educational institutions to report their web assets more effectively and efficiently:

1. Main URL (i.e., www.yrdsb.ca) and top-level subpages managed by the central web/communications departments; and
2. Main social media accounts (e.g., LinkedIn, Twitter, Facebook, Instagram) used as primary sources for information sharing.

The Board has responded accordingly to question 14 of the accessibility compliance report by listing the main URL, top-level subpages and main social media accounts.

1.3 Accessible Procurement and Purchasing

A statement of accessible procurement was updated and standardized with Purchasing Services and is included in all purchasing agreements, contracts and requests for proposal (RFP) with external contractors, service providers, vendors and producers of educational materials.

The statement of accessible procurement reads as follows:

• “The Proponent covenants and agrees to ensure that the work provided hereunder shall comply with the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) and its respective Integrated Accessibility Standards Regulation (O. Reg. 191/11), including all legislated training on the requirements of the accessibility standards and on the Human Rights Code as it pertains to persons with disabilities. Without limiting the generality of the foregoing, the Proponent covenants and agrees to comply with the Board’s Accessibility Policy #407 and its related procedures and practices and accessibility training requirements, as may be in effect during the term of the Agreement and as they apply to the work to be provided hereunder by the Proponent.”

1.4 Accessibility Training

Accessibility Compliance Training

Accessibility compliance training requirements and timelines for completion were communicated as part of the 2020-2021 school year plans for reopening and compliance training requirements.

There continues to be three separate accessibility compliance training modules that all employees must completed as a one-time training requirement. The total completions among active employees for each training module are presented in the bar chart as of August 31, 2021.

Accessibility Training Module Name	Total Completions
Accessibility Standards for Customer Service	15,884
Accessibility and Human Rights: Working Together	16,770
Accessibility Awareness for Educators*	12,698

*Only “Educators” are required to complete this training under the AODA. Educators include all staff who are involved in program or course design, delivery and instruction, including administrators, teachers, Designated Early Childhood Educators (DECEs), Educational Assistants (EAs), and all other classroom-based support staff.

The Accessibility Awareness for Educators module was revised in August 2021 to reflect current accessibility tools and resources available to educators, including the Accessibility Resource Hub as well as other external online resources to promote accessibility in the classroom.

Beyond Compliance: Accessibility Acceptance and Professional Development

Collaboration took place with various departments, units and/or committees across the Board to plan and deliver accessibility learning sessions to build awareness and capacity beyond the one-time accessibility compliance training.

Accessibility learning and training sessions facilitated during the 2020-2021 school year are listed in the table below:

Date	Session Title + Brief Description	Participants	Facilitator(s)
September 2020	Accessibility 101 (part 1) - foundational understanding of AODA	Digital Literacy Consultants	Assistive Technology Consultants
November 13, 2020 (P.A. Day)	Accessibility training (part 2) on developing accessible materials and resources	Digital Literacy Consultants	Assistive Technology Consultants
January 15, 2021 (P.A. Day)	Accessibility training on creating accessible materials and resources (mainly slide decks) for teachers	Elementary EAs	Assistive Technology Consultants
February 2 and February 10, 2021	Human rights and accessibility update - What is accessibility and accessible content?	B Group	Assistant to HRC + Accessibility Officer
March 1, 2021	Poster presentation - An integrated Approach to Disabilities Inclusion: Connecting Accommodation and Accessibility and Principles of Equity	Pacific Rim International Conference (external)	Human Rights Commissioner + Accessibility Officer
March 2, 2021	Accessible Content Core Skills: Building more accessible learning and working environments at YRDSB	Pacific Rim International Conference (external)	Accessibility Officer
May 7, 2021 (P.A. Day)	Accessibility training on creating accessible materials and resources (mainly slide decks) for teachers	Secondary EAs	Assistive Technology Consultants
May 7, 2021 (P.A. Day)	Creating accessible web content (part 1) – alternative text best practices	Teacher Librarians	Accessibility Officer
June 8, 2021	Accessible content core skills (part 2) - best practices for how to make online content more accessible	Teacher Librarians	Accessibility Officer

 

The Accessibility Officer attended the Rick Hansen Accessibility Professional Network (APN) 2021 Conference, which was held virtually on March 29th and 30th, 2021. Key learnings and session recordings were shared with the AODA Advisory Committee members at the April 29, 2021 meeting as a call to action for “accelerating access” within their respective areas of work.

2.1 Assistive Devices (for students with special education needs)

Special Equipment Amount (SEA)

Accommodations for students with identified special education needs often include access to assistive technology through Special Equipment Amount (SEA) claims.

The Ministry of Education approved 1,109 SEA claims for the purchase of assistive technology for students with special needs during the 2019-2020 school year. This equipment includes (but it not limited to): hearing assistive technology, vision assistive technology, positioning devices (for sitting, standing and lying) and software that provides access to curriculum.

Hearing Assistive Technology

Student Services processed new SEA claims for Hearing Assistive Technology (HAT) to ensure all students who are deaf or hard of hearing had personal amplification technology or a soundfield speaker in their classrooms. The Deaf and Hard of Hearing (DHH) department launched a personal captioning pilot project whereby a NeckLoop, Touchscreen, SoundField and Webcaptioner software collectively provided automated real-time captions and transcripts for students in face-to-face learning environments. The system has multilingual capacity so students in French Immersion also have access to closed captioning.

For virtual students, Boom microphones have been purchased for teachers with additional cables, cords and splitters for students/families to connect HAT to their laptops and/or Chromebooks. Teachers of the DHH continued to collaborate with classroom teachers, Special Education Resource Teachers (SERTs) and parents to support the use of HAT in face-to-face and virtual classrooms.

Vision Assistive Technology

PC computers and laptops with screen reader software tools and refreshable electronic braille devices continued to be the best option for students who are blind in terms of online accessibility.

Student Technology Exchange Program (STEP)

The Board purchased a large volume of Chromebooks to support both local school needs and remote learning. The Student Technology Exchange Program (STEP) is managed by Information Technology Services (ITS) and Enterprise Application Support (EAS) centrally from the Dr. Bette Stephenson Centre for Learning.

During the 2020-2021 school year, a total of 8,586 Chromebooks were deployed through STEP. Specifically:

• 7,083 Chromebooks were deployed to Elementary students; and
• 1,503 Chromebooks were deployed to Secondary students.

STEP serves two main objectives:

1. Supporting local school needs

Devices were shipped directly to schools in November 2020 and February 2021. Elementary schools were prioritized given the learning model. Demand for devices increased during Board-wide shutdown periods and shifts to remote learning for all students. ITS provided support centrally if local schools could not fulfill requests.

2. Supporting virtual schools

Remaining devices were loaned out, as needed, to students enrolled Elementary Virtual School (EVS) and Secondary Virtual School (SVS) during the 2020-2021 school year. ITS also continued to distribute Rogers internet packages to support remote needs by students and staff. ITS has deployed over 1,000 internet packages to date.

Teacher Technology Exchange Program (TTEP)

ITS also leveraged laptop returns through the Teacher Technology Exchange Program (TTEP) to support the system by providing refreshed laptops to departmental and school staff. Deployment was prioritized based on critical business continuity as supply was limited for supporting staff needs.

For information on assistive devices provided to YRDSB employees with disabilities, refer to Workplace Accommodations for Staff under Section 5.1 Accessible Employment.

3.1 Accessible Web Content

New Website Launch

The Board officially launched a new, redesigned and more accessible public-facing website (www.yrdsb.ca) on March 26, 2021. The new website meets the AODA requirement that “all internet websites and web content must conform with WCAG 2.0 Level AA” (O. Reg. 191/11, s. 14).

Discussions and planning for the new website began during the 2018-2019 school year. Key highlights of the website development process are outlined below:

2018-2019 school year

• Engaged staff and community in gathering accessibility needs to inform design of new website.
• Engaged an external vendor to design website with accessibility features in mind.
• Chose a platform that enforces accessibility features (e.g., accessible font and spacing, accessible default headings, required alt text on images, etc.)

2019-2020 school year

• Embedded SiteImprove accessibility tool into the architecture of the website to check and ensure accessibility of all web content
• Built online training modules for staff that incorporated accessibility considerations and requirements.
• Began facilitating migration of existing web content in coordination with content contributors to ensure accessibility compliance.

2020-2021 school year (and beyond)

• Continued migration of existing web content into new website platform.
• Content contributors required to complete self-directed online training module.
• New website (www.yrdsb.ca) officially launched on March 26, 2021.
• Continued to provide support to content contributors to ensure ongoing website accessibility.
• Ongoing monitoring of web content by Web Portal and Communications Officer to ensure AODA compliance (2019-20 and beyond).

3.2 Accessibility Awareness for Educators

Accessibility Resource Hub

The HRCO officially launched of the YRDSB Accessibility Resource Hub on November 20, 2020 for YRDSB staff, students and community members. The Accessibility Resource Hub is an open-access and centralized web space that was re-established on the new website on March 26, 2021.

The Accessibility Resource Hub has been a passive strategy for educating and supporting the system about how to make learning and working environments more accessible for all through general core skills and specific accessibility guidelines. The following best practice resources and guidelines were finalized and published as PDF documents and accessible webpages in the 2020-2021 school year:

• Accessible Content Core Skills
• Accessible Document Guidelines
• Accessible Slide Deck Guidelines
• Accessible Web Conferencing Guidelines

Accessible Document Training

The in-person accessible document training was converted into virtual training sessions offered by Enterprise Application Support (EAS). Training content continues to be focused on making accessible documents in Microsoft Word, including the conversion process to a PDF document and passing the accessibility check in Adobe Acrobat.

Considerations for Developing Online Content

A resource outlining considerations for developing online content was created by Learning Design and Development and shared internally with educators. The resource included accessibility considerations and links to the Accessibility Resource Hub, as well as equity, inclusivity and copyright considerations.

• Use font larger than 12 points
• Use a consistent sans serif font (ie. Gill Sans, Arial, Verdana)
• Avoid use of all caps, italics, underlines and justified text alignment
• Use bold to emphasize important information
• Avoid using table tools to create columns or format the layout of information in a document
• Ensure videos or audio content have captions (for videos) or transcripts (audio)
• Ensure strong contrast ratios between text and background colours
• Ensure hyperlink text is brief, descriptive and meaningful even without context
• Include audio buttons as an alternative format to access text when possible
• Offer a plain text doc as an alternative format to a slide deck (this can be translated and used with a screen reader)
• Add alternative, or “alt” text to images. This is especially important with graphs and charts or other images where students need to retrieve information
• Ensure activity can be accessed independent of a teacher (ie. avoid logins that young children may not be able to access independently)
• Limit the amount of ‘clicks’ it takes to get to the activity
• Full list of considerations for accessible slide decks
• Full list of considerations for accessible documents

Proposed K-12 Education Standards

The 2021 Initial Recommendations Report for the Proposed Kindergarten to Grade 12 (K-12) Education Standards were shared with the public on July 7, 2021.

The Accessibility Officer worked with AODA Advisory Committee members to review the proposed K-12 Education standards, as well as received additional feedback from members of the Board community at large. A YRDSB Feedback Report on the Proposed K-12 Education Standards was completed and submitted to the Education Standards Development Committee on September 22, 2021.

While the YRDSB feedback report was submitted at the start of the 2021-2022 school year, much of the preparation took place in the summer months of the previous school year. The Board’s internal review and feedback process of the proposed K-12 Education standards was led by the HRCO.

Following a meeting with members of Senior Leadership team, a series of system memos were shared internally via the Board’s “News Digest” email. The memos included options for reviewing the recommendations, and a Google Form link for providing feedback. The completed Google Forms, along with the AODA Advisory subcommittee and working group meetings, were used to draft the feedback report.

The YRDSB feedback report was also shared with Ontario Public School Boards Association (OBPSA), the Special Education Advisory Committee (SEAC), and presented to the AODA Advisory Committee at the September 30, 2021 meeting.

3.3 Accessible Formats and Communication Supports

Accessible Format Board Policies

The Accessibility Officer supports the ongoing process of updating Board policies and procedures into an accessible formats as part of the Board’s four-year policy review cycle.

A Plain Language Guide to Human Rights Policy #240 was created as a second exemplar of a more reader-friendly version of the full policy document.

Accessible Board Videos

All Board-approved prerecorded videos produced by Corporate Communications and/or Learning Design and Development included open captions in meeting WCAG 2.1 Level A requirements.

The Accessibility Officer was consulted by various departments (e.g., Learning Design and Development, Corporate Communications, Education and Community Services) throughout the 2020-2021 school year to share strategies and best practices for providing more accessible videos.

Purchasing Services approved the procurement of five business licenses for an automatic transcription software. The transcription software supported and will continue to support a more efficient process of captioning Board-approved videos as a regular practice. One license was provided to Corporate Communications, two licenses were provide to Learning Design and Development, and two licenses were retained by the HRCO. To date, a total of 546 minutes have been transcribed through the transcription software.

BLV and Teachers of Students with Visual Impairments

Blind / Low Vision (BLV) Services ensured that students with low vision were provided with accessible materials in a timely manner during virtual learning. Many educators were new to Google Classroom and creating Google Docs, and did not consider that students with low vision need both captions and described video to access video content in a meaningful way.

Teachers of Students with Visual Impairments (TSVIs) were available to assist in procuring copies of videos with described video or could provide the described video for their students. TSVIs also worked to reformat Google Docs to make them accessible for screen reading software, and provided in-servicing to educators on how to make more accessible Google Docs.

Accessible Online Gaming

TSVIs engaged students through online games that are accessible for people with low vision. Some mainstream online games were adapted with tactile materials so that they can play alongside their sighted peers and foster friendships, while remaining socially distant.

Camp in a Bag Program

Orientation and Mobility Specialists developed their fourth iteration of “Camp in a Bag” to engage students with games, crafts, inquiry-based learning, and an interactive series of online events. All activities focused on developing spatial skills and mobility strategies in their home, neighbourhood and community.

Accessible Online Learning and Training

A best practice resource was created with accessible video conferencing guidelines to support staff in making online/virtual learning and training sessions more accessible to all learners and/or participants.

The Accessible Video Conferencing Guidelines are available online to the public as part of the YRDSB Accessibility Resource Hub.

The process was confirmed with Purchasing Services for requesting accessible or conversion-ready formats of educational textbooks and/or any other printed learning resources for students with disabilities, as required under the AODA (O. Reg. 191/11, s. 15).

An Accessible Format Request for Printed Textbooks resource is available internally to Board educators via the BWW.

4.1 Scheduled Accessibility Projects

Plant Services annually schedules and completes projects to update, modify and retrofit existing buildings in order to make them more accessible. Plant Services works in conjunction with Student Services, Human Resource Services and the HRCO to identify and support the needs of students, staff and the wider community. During the 2020-2021 school year, approximately $1.98 million was spent on accessibility projects and work on YRDSB buildings and facilities.

A complete list of accessibility projects started and/or completed on YRDSB facilities during the 2020-2021 school year is presented in the table below.

Facility Name	Description / Scope of Work	Status	Cost
Alexander Mackenzie High School	Installing ramp to field (part of larger project)	Substantial Completion	$100,000
Armadale Public School	Replaced fire alarm horns with horn/strobe visual fire alarm devices Installed curb cut at crosswalk and repaired surrounding asphalt	Complete	$22,873
Armitage Village Public School	Installed automatic door opener for barrier-free washroom Provided asphalt ramps at two exterior exits; and repaired two catch basins in front driveway to garbage bins.	Complete	$15,372
Aurora Heights Public School	Upgrading elevator	Substantial Completion	$85,690
Aurora High School	Relocated bidet accommodation; and installed automatic door opener on office	Complete	$15,000
Beckett Farms Public School	To install braille signage throughout school	Not Started	$10,000
Blue Willow Public School	Replace fire alarm system (as part of larger project)	In Progress	$150,000
Carrville Mills Public School	Install ramp and sidewalk to play structure from rear tarmac area	Site Plan Approval	$200,000
Crossland Public School	Replace fire alarm system	Contract Awarded	$119,900
Education Centre - Aurora	Replacing fire alarm system	Substantial Completion	$150,000
H.G. Bernard Public School	Installed automatic door opener on the gym doors (complete) Installing braille signage throughout school	In Progress	$17,300
Highview Public School	Replaced fire alarm system	Complete	$150,000
James Robinson Public School	Installed ramp to portable 1153	Complete	$8,733
Lakeside Public School	Replacing fire alarm system	Substantial Completion	$143,900
Maple High School	Replacing passenger elevator controls, hydraulic storage tank, valve and pump Installing braille signage throughout school	In Progress	$78,025
Markham District High School	Installed automatic openers on main office door and entrance to library	Complete	$8,360
Nellie McClung Public School	Added barrier-free door opener to existing barrier free washroom 103	Complete	$6,740
Randall Public School	Installed automatic door openers on barrier-free washroom 139	Complete	$6,000
Richmond Hill High School	Create all access washroom (part of a larger project)	In Progress	$200,000
Sir William Mulock Secondary School	Replacing passenger elevator controls, hydraulic storage tank, valve, pump	Substantial Completion	$95,000
Stonehaven Elementary School	Replacing fire alarm system	Substantial Completion	$108,800
Stuart Scott Public School	Replacing fire alarm system	Substantial Completion	$114,975
Summitview Public School	Installed automatic door opener on third floor stairwell door (by room 301)	Complete	$3,800
Sutton District High School	Installed ramp to dance studio; request through Barrier Buster	Complete	$150,000
Tommy Douglas Secondary School	Added barrier-free opener to main office door	Complete	$6,690
Wilshire Elementary School	Installing braille signage throughout school	In Progress	$10,000

Total Cost of Accessibility Projects in 2020-2021 School Year: $1,979,658

All Access Washroom Project

All access washrooms are intended for use by students or staff who self-identify as gender diverse or feel the need for privacy due to religious or other personal reasons.
During the 2020-2021 school year, Plant Services continued with the full-scale implementation phase of the Board's All Access Washrooms Project. A total of 483 school washrooms have been converted to an all access or all gender washroom (gender-neutral but not barrier-free).

Braille Signage Project

Blind / Low Vision (BLV) Services continued to identify and update a priority list of YRDSB schools with students who require Braille signage to access their school environment in a meaningful way. The identified list of schools below are part of Plant Services multi-year plan:

Priority Schools

1. H.G. Bernard Public School
2. Maple High School
3. Wilshire Public School
4. Beckett Farms Public School
5. Doncrest Public School
6. Hodan Nalayeh Secondary School
7. Newmarket High School

Completed Schools in 2020-2021

• Stonehaven Elementary School
• Michael Cranny Elementary School
• Keswick High School

4.2 Barrier Buster

Barrier Buster remains the Board’s formal process for receiving and responding to feedback about barriers to accessibility. The Barrier Buster and Built Environment subcommittee review Barrier Buster submissions and determine actions to remove barriers where appropriate.

Barrier Buster Protocol

The Board Protocol for the Barrier Buster Process (PDF) was finalized as way of making the formal process for receiving and responding to feedback about barriers to accessibility more transparent and accessible to the public.

The Barrier Buster Process is also available as HTML content directly on the Barrier Buster web page.

Barrier Buster Reporting

During the 2020-2021 school year, the Barrier Buster and Built Environment subcommittee received, responded to, and/or followed up on a total of 10 Barrier Buster submissions.

• Barrier Buster files carried over from the 2019-2020 school year: 7
• New DM files opened in 2020-2021: 3
• DM files closed in 2020-2021: 5

Two submissions related to the lack of captions on videos, while the third new submission reported on the removal of the Barrier Buster button/icon from the new YRDSB main page. A total of 4 submissions were closed in the 2020-2021 school year. The open submissions carried over from previous school years are related to larger projects, such as all-access washrooms or accessible paths of travel to playgrounds or track and fields.

It is important to note that most barrier removal requests are made informally and locally at the school or work location. Physical barriers identified are often communicated and addressed directly through Plant Services, as reflected in the Accessibility Projects table.

5.1 Accessible Employment

Disability Management

The Disability Management (DM) team within Human Resource Services had a total of 3,449 DM files for the 2020-2021 school year.

• DM files carried over from the 2019-2020 school year: 1,213
• New DM files opened in 2020-2021: 2,236
• DM files closed in 2020-2021: 1,718

Workplace Accommodations for Staff

Disability Management approved 1,282 employees with virtual workplace accommodations in the 2020-2021 school year. Assistive devices provided by HRS for workplace accommodations are listed below.

Assistive Devices provided by DM

• Air cleaners and humidifiers for scent sensitivities / allergies,
• American Sign Language (ASL) interpreters,
• Arranging worksite ergonomic assessments,
• Communication Access Realtime Translation (CART) and computerized notetaker services
• Custom noise cancelling ear plugs,
• Document cameras,
• Mobility devices (scooters, wheelchairs, wheeled carts, stools),
• Modified work stations (e.g., special chairs, desks, keyboards, monitors and lighting),
• Specialized phones and headsets,
• Speech to text software,
• Voice amplification and hearing systems (e.g., FM transmitters, receivers, auto hubs, microphones, Rogers NeckLoop, iPad apps and sound barrier devices)
• Zoomtext Plus technology.

Hearing Accommodations Process

A new process was implemented if an employee requested a hearing accommodation through Disability Management during the 2020-2021 school year.

• DM partnered with Regional Special Education Services and worked with an Education Audiologist during periods of remote learning.

• DM advised all the unions and federations that they may have members who have hearing impairment(s) and who may require continued or revised accommodations related to their hearing impairment.

• The employees were asked to have the Functional Abilities Report completed with information that was required to assist DM in determining how best to accommodate their hearing impairments.

• Once DM received the Functional Abilities Report, they worked with their Assistive Technology / Education Audiologist to determine an appropriate accommodation.

• Accommodations were explored and put in place based on individualized needs, hearing abilities, hearing aid(s), position, etc.

• DM worked with employees on an ongoing basis to review their accommodation needs and revise any accommodations, as needed.

Candidate Support

Human Resource Services (HRS) has fully transitioned to Zoom as the primary video conferencing platform for virtual interviews. GoToMeeting is no longer used by HRS. The Recruitment and Promotion team has reviewed the Accessible Video Conferencing Guidelines and included the resource in the Administrator Toolkit sent out in June 2021 for use with school-based interviews.

Human Resource Services reviewed all job postings to ensure only bona fide occupational requirements and educational credentials are included to reduce barriers to entry, consistent with Recommendations 14 and 15 of the Employment Equity Plan.

A standardized accommodation statement is now included in all communication with candidates at each stage of the recruitment process.

The accessibility portfolio for York Region District School Board (YRDSB or the Board) is a mandate of the Human Rights Commissioner’s Office (HRCO), which provides leadership over the Board’s AODA Advisory Committee. Accessibility at YRDSB is guided through the shared responsibilities and collaborative commitments of the AODA Advisory Committee. The HRCO has worked with AODA Advisory Committee members to review the Proposed Kindergarten to Grade 12 (K-12) Education Standards - 2021 Initial Recommendations Report, and to request additional feedback from members of the Board community at large.

Synthesizing the Report for Internal Use

The proposed K-12 Education standards and recommendations were initially reviewed and synthesized by the Accessibility Officer into Shared Google Docs based on the seven barrier areas. The K-12 Education Standards Development Committee (SDC) executive summary report was also integrated into the shared Google Docs. The synthesized Google Docs were created to chunk the contents of the initial recommendations in order to provide an easier way for AODA Advisory Committee members and other Board staff members to review and comment directly on specific recommendations related to their respective areas of work.

Meetings were held with various subcommittees and working groups under the AODA Advisory Committee in order to collaboratively review specific barriers recommendations. For example, the Accessibility Officer met with the Barrier Buster and Built Environment Subcommittee on several occasions to review the barrier seven recommendations on physical and architectural barriers.

Communication to the System

Following a meeting with members of YRDSB’s senior leadership team, a series of system memos were shared internally via the Board’s “News Digest” email. The memos included four different options for reviewing the recommendations:

1. Summary of the recommendations posted on the YRDSB accessibility web page under Accessibility Reports and Plans;
2. Full initial recommendations report available online to the public;
3. Executive summary report from the K-12 Education Standards Development Committee; or
4. Video summary by David Lepofsky, Chair of the AODA Alliance.

The proposed the K-12 Education standards were also shared through social media postings on the Board’s Instagram and Twitter pages. All staff and community members who reviewed the recommendations were asked to complete the YRDSB Review and Feedback Form by Friday, September 17, 2021. The completed Google Forms (19 in total), in addition to the AODA Advisory subcommittee and working group meetings, were used to draft this feedback report. The majority of the feedback forms were completed by YRDSB teachers, with the remaining forms completed by a combination of administrators, school-based support staff, non-school based staff, consultants and parent/guardians or community members.

All feedback received on the proposed K-12 Education standards was reviewed by the Accessibility Officer and grouped into themes. General feedback themes are presented first, followed by the main themes that emerged for each barrier area, which comprise the remaining sections of this feedback report.

General Feedback

Ease of Reading and Understanding

The majority of survey respondents, as educated school board employees, agreed that “overall, the report was easy to read and understand.” From a more critical accessibility lens however, we need to recognize that some YRDSB community members can better understand more plain language writing, particularly for English language learners or individuals with learning disabilities.

A primary example of the need for simplified language is the report’s 12 guiding principals. Despite drawing out the key idea in each guiding principle, there was notable overlap between the guiding principles in terms of some phrases and “key words” (e.g., dignity, equality, equity, inclusion, human rights, etc.). As a result, the 12 guiding principles were synthesized before being shared internally.

As we continue to adopt more inclusive language in education, it has become clear that words matter. There should be a conscious consideration for the words, language and sentence structure of the final report, as well as throughout the process of passing the proposed K-12 Education standards into law under the AODA. Traditional legislative language is a barrier to accessibility. Plain language alternative formats should accompany any current and new accessibility standards.

Consistency of Recommendations

The methodology section outlined how all initial recommendations were discussed and reviewed by the full committee through a collaborative and engaged process. However, it was clear that the different barrier areas of the recommendations report were drafted by different individuals/small groups from the SDC. In addition to different writing styles, the recommendations were not formatted consistently across the different sections or barriers areas of the report.

Some recommendations included up to 20 sub-recommendations presented as numbered lists (e.g., 49.1 - 49.20 parent and student participation recommendations), lettered lists (e.g., 92a - 92m elevator recommendations), or separate recommendations (e.g., recommendations 43 - 48 all relate to IEPs, but are short and separate recommendations instead of sub-recommendations). The recommendations and respective sub-recommendations should be formatted and presented with consistency in the final report.

All YRDSB survey respondents agreed with the barrier one recommendations, with one respondent adding the following comment:

• “It is my experience that Special Education & ELL supports are the first to be reduced when schools attempt to balance their budgets at the grassroots level. This sends a message.”

Overlapping Barrier Areas

It is not clear why the barrier one and two recommendations were presented as separate barriers areas in the initial recommendations report. Two of the five barrier one recommendations relate to accessibility training (or “in-servicing”), which is also the focus of the three awareness and training recommendations. Awareness and training are often the first steps to addressing and changing attitudes, behaviours, perceptions and assumptions about people with disabilities.

Undervalued Impact of Ableism and Attitudes

Attitudinal barriers are the most pervasive barriers to accessibility, with ableism still very prevalent throughout education. The initial recommendations reports does address ableism in the guiding principles statement and recognizes that “attitudes, behaviours, perceptions and assumptions underpin the work of all other small groups”. However, only five of the 184 total recommendations are focused on addressing attitudes, behaviours, perceptions and assumptions. The undervalued impact of ableism and attitudes in this report is particularly clear when compared to the 50 physical and architectural barriers recommendations (with hundreds of sub-recommendations).

Out of the five barriers one recommendations, the training recommendations should be expanded to include, where possible, experiential learning and working with students with disabilities. Case in point recommendation 3 on training for teacher candidates:

• “Pre-service teacher education needs to have much more theoretical and practical experience working with students with disabilities. [Co-op] teaching opportunities should expand to special education placements, including self-contained programs. Secondary teaching qualifications needs to expand to include those with experience working with students with complex and special education needs.”

A major attitudinal and systemic barrier in education continues to be the socially acceptable discomfort level when it comes to teaching or engaging with students from community classrooms. Teaching in a community classroom should not be accepted as a “stepping stone” or “checkbox” to teaching in mainstream or advancement with the Board. Teachers and support staff should not be considered “brave” or “patient” for wanting to work in community classrooms; in fact, it is quite frankly ableist for any teacher who does not want to teacher in a community classroom. This systemic ableism needs to be more purposefully challenged in the barrier one recommendations.

A much larger focus on the attitudes, behaviours, perceptions and assumptions recommendations is the need to establish a proper foundation for affecting a meaningful and lasting cultural shift in education towards accessibility and acceptance of differences as part of life.

Limitations of Universal Design for Learning

Recognizing the value of Universal Design for Learning (UDL), a few survey respondents were quick to note some of its limitations. UDL is a good and essential starting point for building a culture of accessibility, but we must also ensure the diversity of disabilities are recognized and supported.

• “It is critical that UDL encompass the invisible disabilities in addition to the visible (often physical).” These are often harder to measure, and more difficult for people to understand because they are unable to 'see' the result of the UDL measure or accommodation. Often one can appear to be doing fine but the underlying effort and stress of managing in an environment goes undetected in a classroom setting.”

• “… sometimes the concept of UDL can be used to exclude those on the far margin or disability. Those with severe disabilities are often not served. Also, recognize that it is nearly impossible to know what the needs are until you have lived with or cared for someone with a disability. Assumption of need(s) is a danger here. We must gather input from multiple stakeholders to ensure the full picture is being gathered and even the rarer needs are being considered. Don't act on the "stereotype" version of disability.”

Recommendation 6 to standardize UDL training should be elaborated to include more specific recommendations on the extent to which the concept of UDL should be covered in the UDL training. For example, is the recommendation to address the UDL contents from the Ministry’s 2013 Learning for All resource guide (Learning for All - A Guide to Effective Assessment and Instruction for All Students, Kindergarten to Grade 12)? Or is it to go more in depth into the concept of UDL? What are the recommended resources and research to support this recommendation?

Anti-Oppressive Curriculum Reforms

The curriculum, assessment and instruction recommendations essentially calls for substantial reforms to Ontario curriculum in recommendation 9. These significant reviews and renewals of curriculum should seek community participation, as expressed by a member of the AODA Advisory Committee’s Curriculum Working Group:

• “This review must include community, particularly communities who have been marginalized so that they are centred in the review; continue to work with community when making changes, and when monitoring for impact. This would be an anti-racist, anti-oppressive approach.”

One survey respondent shared their thoughts on how to reform curriculum and assessment practices:

• "Curriculum needs an overhaul to make these changes work in a meaningful way. Curriculum must come away from grade-specific, and be outlined as a continuum. Curriculum should be more skill-based than content-based (i.e., science - skills of inquiry, hypothesis, testing/experiment; in history - skills/ concepts of chronology, critical analysis, perspective-taking) as opposed to specific units to be done in each grade."

• "Assessment needs an overhaul as well. Remove grades/leveling for up to grade 6; reporting should be clear and easy for students and families to understand; what has the student learned? What can they do? What can they work on next?"

Physical Health and Wellness, Mental Health and Well-Being

The Board’s mental health leads were consulted directly on recommendation 25, and shared feedback and questions regarding three main themes: terminology, related research and resources, and evaluation concerns.

Clarify Terminology

“Wellness” and “well-being” are terms that are often used interchangeably. Are these recommendations associating physical health specifically with wellness? And mental health specifically with well-being? If so, recommendation 25 that “the ministry develop a Health and Well-being strategy and action plan…” suggests it is a mental health action plan, yet the recommendation mentions physical health as well as sexual health? Sub-recommendation 25.1 also references “inclusive design” without context:

• “Elsewhere in the document, Universal Design is referenced, [but] here, inclusive design is referenced. Both hold value and promise. However, I do not believe Inclusive design has been defined here.”

Clarification with respect to the terminology used throughout recommendation 25 is needed.

Align Research and Resources

What role, if any, does the Ontario Health and Physical Education Curriculum play in this proposed Health and Well-being strategy and action plan? Additionally, it was noted that the concept of social-emotional learning (SEL) is currently under review by School Mental Health Ontario (SMHO) alongside the Equity Secretariat with a view towards equity and an anti-oppressive practice approach.” The K-12 Education standards need to be aligned with existing and new research and resources as they relate to mental health and well-being.

Evaluating / Measuring Recommendation 25

Concerns were raised about how the Ministry will evaluate and measure the implementation of recommendation 25 and its many sub-recommendations that include (but are not limited to):

• coordinated resources,
• guidelines,
• materials,
• programming, 
• beyond the school environment,
• sexual health education,
• incorporating training for educators, and
• awareness and lived experience of disabilities are part of the overall learning opportunities.

“How are guidelines different from materials versus resources in this context?” It was also noted that educators cannot be equipped to measure or “assess the resiliency needs of all students” (recommendation 25.6):

• “Teachers are not able to ‘assess’ resiliency. Resilience is a factor both informed by the individual and system elements”

A recommendation such as this cannot be appropriately implemented and supported with so many moving parts in one recommendation. Concerns with proper implementation and evaluation also applies to the other lengthy recommendations in this report (i.e., that include 6 to 20 sub-recommendations). The proposed timelines also need to better reflect and respond to competing priorities and the amount of dedicated time and system learning necessary.

Indigenous Education

In consulting a number of the Board’s Indigenous consultants and lead staff, it was questioned whether recommendation 26 was made in consultation with Indigenous communities. It was specifically noted that:

• “[sub-recommendation 26.1] is infringing on the two row wampum teachings (treaty agreements) and Indigenous sovereignty... which will create issues at the board level for learning on the land. One does not supersede the other.”

The sub-recommendation should be revised to express that the ministry will work in collaboration with Indigenous communities/partners to support “curriculum design and content including Indigenous curriculum is accessible and available for students with disabilities.” The following sub-recommendation 26.2 raised implementation concerns regarding Indigenous pedagogy, ways of knowing and experiences.

• “Is this an expectation for classroom teachers? How will teachers be provided with cultural competency training needed to understand what Indigenous pedagogies are? How will cultural appropriation be avoided?”

Accessible Procurement Limitations

YRDSB adopted a statement of accessible procurement that is now included in all Purchasing Services contracts and Requests for Proposals. However, ensuring “that all technology purchased by a school board ensures full digital accessibility” (recommendation 35.1) is not always possible. Many of the major digital tools/resources procured by YRDSB (and most school boards) are US-based vendors, such as Google and Microsoft. Increasingly more and improved accessibility features have become available in Google Workspace for Education (formerly Google Apps or GAPPS) and Microsoft Office 365 over the past 18 months. However, software updates are beyond the control of school boards, and can often present new learning curves for staff to refamiliarize themselves with new interfaces.

Long-Term Funding Commitments

Consistent with recommendation 36 regarding long-term funding for assistive technologies and related hardware, one survey respondent believed that:

“All school boards should ensure full, open access to web applications for education (e.g., Google Apps for Education, TextHelp Read & Write) to provide universal access to assistive technology (e.g. text-to-speech, speech-to-text, screen reading, masking and organization) for all students, staff and employees. This will reduce barriers for students or employees with non-identified barriers. Setting minimum standards for access would ensure equal access to all stakeholders in Ontario.

Virtual Meeting Platform Flexibility

Recommendations 39.1 reads that “only accessible virtual platforms shall be used by a school board…” This fails to recognize other factors that are considered in procuring and supporting certain web conferencing platforms, including: privacy and confidentiality, the need to restrict access at times, internal capacity and know-how, as well as cost. The recommendation should have allowances for web conferencing platforms that are not “fully accessible” if the virtual environment is still accessible. For example, GoToWebinar is one of the only web conferencing platforms with a built-in feature that requires all attendees to pre-register (i.e., pre-event registration). However, GoToWebinar does not have an integrated automatic captions or transcripts feature, but can be made available through different ways (e.g., CART or Google Live Captions).

Recommendation 39 should instead support accessible online or virtual learning environments as a whole, rather than narrowly recommending that “only the most accessible virtual meeting platforms should be used...” The individual hosting the virtual meeting needs to know how to foster an accessible virtual learning and/or working environment for all participants.

Digital Accessibility Capacity Building

Consistent with the previous feedback theme, the barrier four recommendations on digital learning and technology should, in general, consider strategies that build staff capacity to better support and implement the proposed the Digital and Technology Action Plan. Learning and training sessions need to be made available and mandatory for all staff to develop the core competencies needed to host an accessible online learning or working environment.

Format of Recommendations

As mentioned in the “consistency of recommendations” general feedback, recommendations 43 to 48 all relate to IEPs and are presented as separate recommendations. This format is easier to follow compared to the recommendations with up to 20 sub-recommendations. Using recommendations 43 to 48 as the example, all recommendations should be concise where possible, and split into separate recommendations if more than five sub-recommendations are included.

IEP-specific Feedback

A number of Student Services staff reviewed the barrier five recommendations and provided feedback related to the Individual Education Plan (IEP) process:

Simplify IEPs

• “IEPs should be simplified/shortened. Ensure they are true working documents, focused on a few key learning objectives at a time and updated regularly.

Standardize IEPs

One survey respondent provided feedback that expands on recommendations 44 to revise the format and content of IEPs:

• “The IEP format should be designed centrally within the Ministry of Ed. to present the same information in a way that is easily shared between school boards. This should be reviewed regularly, to ensure they can capture all necessary and relevant details. Consider providing access to all IEPs through a coordinated platform that allows for common access to staff between boards as well as parents from home. Using a common platform would allow programming goals, transition plans and SEA equipment to be tracked, monitored and shared between boards more easily. The OCT should establish standards that allow for alternative training to serve as teaching qualifications (working with students with complex needs), rather than traditional subject areas to ensure that the most qualified teachers are teaching the high-needs populations.”

Another survey respondent suggested a standardized model for IEPs:

• “Even though IEP is very personalized, due to its complication, it is still preferred to have a universal model with SMART goal examples. It can be designed on school board level, Ministry of Education level, or a federal based body level. Parents need shared information in a central place to access IEP knowledge. Besides being classified as different disorders, the model can also find the common ground. For example, many students have behavioral, executive functioning, social and self-advocacy concerns. The model can break down each executive functional skills and give guidance.”

IEP Accountability

• “All staff teaching/supporting a student with an IEP must sign the IEP, acknowledging that they are legally obliged to implement it. This legal obligation needs to be enforced; it is currently not and more often than not, IEPs are written that do not reflect what is actually happening in the classroom. Families must be able to rely on the IEP; they need to feel confident that it is being implemented.”

IEP Access for All

One Board community member shared their child’s IEP journey, highlighting the importance of recommendation 46 to make IEPs more accessible to all students:

• “I would like to share my child's IEP journey. One of my children was referred to a specialist by the school when he was in JK. Even though nothing was diagnosed, he got an IEP for behavioural/social concerns. In grade 1, the school recommended that we withdrew from the IEP since his hitting issues were gone. In grade 4, another school referred my son to a specialist, and ADHD was diagnosed. With my constant request, my child got his IEP in grade 7. In between, I learned bunch of educational courses regarding special needs. And then I found out that my child may be twice exceptional. I shared my thoughts that my child may be twice exceptional two years ago. However, my child's case was considered lower priority for school psychological assessment. I had to arrange a private assessment and confirmed 4 exceptionalities when my child is 12. We are heading another journey to update the IEP. My child is lucky and unlucky at the same time. His exceptional identification was missed by parents, educational professionals, or health specialists for many years. I recommend that the school board provide universal guidance for interventions/strategies for all the students, even if they don't have a chance to get a formal diagnosis, or missed their identifications. Not every student will go through the formal IPRC/IEP process. For most students, it is very obvious to be seen who may need further interventions with SMART goals. Don’t wait for a formal diagnosis. Make those strategies available for every student. Share the best practices and resources in a central place for teachers, school staff, students and parents.”

Social Isolation

Recommendation 67 that proposes staff assistance for social interaction and play should be moved to the IEP-related recommendations given that its implementation would carried out through a student’s IEP. One survey respondent was echoed the importance of creating school support teams to promote social inclusion:

• “For social isolation, I recommend a school support team actively monitoring social interactions. A student’s social life will change his view in his classwork, school and life. It is one of the most important aspects at school. Recess time is a great time to detect social concerns as well.”

Inter-Ministry Collaboration

One survey respondent shared feedback and questions specifically in response to recommendation 41:

• “Effective intersectoral collaboration is a huge barrier (Ministry of Health, Social Services). How will the Ontario Health Teams be leveraged to support his recommendation? We are seeing now Ontario Health Teams collaborate across siloed care in health and leaning into the need to effectively collaborate with social service agencies at the local level. How might the ministry of education and boards be involved in this work?”

Accessible Field Trips and Transportation

Similar to the feedback regarding "virtual meeting platform flexibility", there should be flexibility with the educational and online events recommendation 57. The recommendation should ensure an accessible overall experience for students and staff with disabilities during field trips, rather than to “only hold educational events at venues whose built environment is accessible to students and staff with disabilities”.

A narrow recommendation to only hold educational events at accessible venues shifts the responsibility for accessibility almost entirely on the venue. The teacher(s), staff or school board department organizing the event would only have to ask if the venue is accessible or not. However, accessibility is a shared responsibility. The person or group organizing the educational event should know to ask about different accessibility features (refer to AODA.ca Accessible School Field Trips article) at the venue, including:

• Ramps, lifts or elevators whenever there are stairs,
• Automatic doors and wide doorways into buildings and common areas,
• Accessible public washrooms,
• Accessible seating areas (in auditoriums, arenas or picnic areas),
• Accessible pools and change rooms; and
• Whether support persons or staff are required to pay entrance fees.

The event organizer(s) should have a basic understanding of how to make the event experience accessible for all, which includes proactively supporting accommodations including transportation considerations. One survey participant shared their thoughts on how legislating accessible transportation on field trips without any understanding may in fact perpetuate ableism:

• “While I agree with the need to facilitate inclusiveness in the social realm like field trips, the fact is that [accessible] busing and transportation will likely mean students needing that transportation travel separately... Also, specialized services cost more. Will there be a plan to subsidize specialized transport? Otherwise, I foresee an issue with ableist and reactionary thinking if this leads to fewer or cancelled or more expensive trips and events… "because we need a wheelchair bus" or whatever the issue. Careful attention needs to be paid to ensure we do not inadvertently worsen relationships and perpetuate negative thinking towards those with disabilities.”

Recommendation 57 should be expanded to include some of the elements of recommendation 65, including establishing a process to affirmatively reach out to potential venues (adapted from 65.2), ensuring the venue is informed of their duty to accommodate (adapted from 65.3), sharing supports and advice for venues who need assistance (adapted from 65.4), and surveying students with disabilities at the end of any educational event or field trip (adapted from 65.6).

Transitions Facilitator/Navigator

One survey respondent supported the proposed transition facilitator/navigator in recommendation 58:

• “For the transitional plan, I recommend making the transitional support available and automatically for every student, especially for students with autism. A model with different levels of support can be designed. Current teachers may assess the transitional support needs and record the suggestions for the next teacher/school. The communication channel needs to be opened to parents and students before the end of the school/transition time to determine who needs transitional support for the next transition.”

Bullying/Cyberbullying Workshops

One survey respondent supported recommendation 64, while urging earlier interventions for anti-bullying workshops and learning:

• “Early work on respect, bullying and consent are needed to proactively mitigate exclusion and combat self-esteem and mental wellness deterioration at the elementary level, where identities and feelings of self-worth are largely shaped. It is my experience that peer responses to individuals with disabilities have the greatest impact on their development and performance.”

Access to Co-op Education and Employment Opportunities

Related to recommendation 65 on experiential/co-op learning opportunities, one survey participant suggested school boards explore internal placement opportunities within schools as well as in Board administrative positions:

• “School boards should work with unions to expand and standardize access to in-school placement opportunities (with custodians, office staff and food service providers). School boards should be compelled to use their administrative sites to support co-op placements; it's an opportunity to demonstrate the success of co-op partnerships with neurodiverse students. Opportunities should be available at all post-secondary institutions for students who don't graduate with an OSSD. Community Integration through Co-operative Education (CICE) and vocational-type programs should be available at all institutions to provide social, employment and academic opportunities. Post-secondary institutions are like small, self-contained towns. Within each, are opportunities to work in almost every employment sector, as well as opportunities to socialize and build community. Students who graduate with fewer than 30-credits should be eligible to access a CICE or vocational-type program at any institution.”

The Built Environment and Barrier Buster subcommittee under the AODA Advisory Committee, in addition to members of the Board’s Plant Services, were directly consulted on the proposed recommendations specific to the physical and architectural barriers. Additional feedback was provided through the internal review and feedback form.

Ministry Funding

The vast majority of the recommendations intended to remove physical and architectural barriers in school boards is dependent on substantially increased capital funding from the Ministry of Education, as alluded to in recommendation 77. In fact, recommendation 77 to revise the funding formula for school construction should be the first and foremost recommendation to remove physical and architectural barriers.

The School Condition Improvement (SCI) allocation would need to be increased in particular given that the “Beyond Building Code accessibility requirements” (recommendations 81 to 119) are being proposed for existing schools and other educational facilities in addition to new school builds. It is well documented that retrofit requirements for existing buildings are substantially more costly than incorporating accessibility into new construction.

Members of Plant and Planning Services were quick to point out how quiet rooms and sensory rooms, referred to as “unloaded rooms” (that do not count towards the student capacity of the school), are often the first to go when asked by the Ministry “how can you reduce capital costs?” upon reviewing new school plans. It is important to note that capital funding constraints not only perpetuate physical barriers, but are also a function of systemic barriers related to the absence of meaningful accessibility considerations in the Ministry of Education funding formula.

Competing Priorities

It was also noted by members of Plant and Planning Services that many of the technical accessibility requirements are very prescriptive and appear to have been included without consideration for competing operational, safety and/or financial priorities. Specific examples of overly prescriptive and competing priorities are provided below:

• Recommendation 81 to install heated paths of travel to the entrances of schools. Heated floors or pathways are considered a luxury item in private homes let alone for public schools. The operational implications for removing existing pathways, installing heated paths and repaving pathways across 222 YRDSB schools would be considerable. The increased financial implications become even more evident in doing a cost analysis between the installation, maintenance and hydro costs associated with heated paths compared to the cost of salt and human resources required to shovel and/or snowplow paths of travel during winter months.

• Recommendation 95h that requires at least two accessible stalls in each washroom to avoid long wait times. YRDSB is currently implementing its all-access washroom initiative whereby 36 schools were identified as requiring major renovations in order to accommodate an all-access washroom. A requirement to add two accessible stalls in every washroom would essentially require major renovations to now every YRDSB school, including moving walls, plumbing, doorways, etc. The financial implications of this beyond Code recommendation would, again, be considerable.

• Recommendation 102e regarding weighted blankets is too prescriptive and can present safety issues. Weighted blankets are only one example of a sensory accommodation for some people with disabilities, such as Autism Spectrum Disorder (ASD). Additionally, a suitable weighted blankets has to be approved through a Board Occupational Therapist to meet specific requirements (usually 10% of the person’s body weight). Sensory elements or objects should be recommended in general, rather than just the specific weighted blankets recommendation.

• Recommendation 104b regarding outdoor spaces. This sub-recommendation does not take into consideration that parcels of land for new YRDSB school builds are often inherited by the York Region municipality or township. The inherited lots have often been rejected by private builders due to large slopes, flood plains or other limitations with the land. School properties with large slopes between the school and school yard or playground are extremely difficult to make fully accessible (as noted in some existing YRDSB schools). Naturalization efforts for outdoor spaces is another competing interest that needs to be considered if major leveling or infrastructure is needed to make outdoor spaces fully accessible to everyone.

Accessibility Design Experts and Consultants

Feedback from the Plant and Planning Service also raised the following questions related to accessibility design experts and consultants referenced in recommendations 71, 72 and 79:

• Who would be considered to “have sufficient demonstrated expertise in accessibility design” as per recommendation 71?

• Similarly, who would be considered a “properly qualified and experienced accessibility consultant” as per recommendation 72?

• What are the industry and/or ministry standards for being considered an accessibility design experts or consultant?

• Given that the Rick Hansen Foundation Accessibility Certification (RHFAC) was highlighted as “substantially inadequate and has significant problems”, what are the alternative accessibility design standards or qualifications?

• Is there any sort of existing database of accessibility design experts and accessibility consultants available?

For consistency with implementation of the recommendations, it was suggested that a list or database of accessibility design experts and accessibility consultants be made available to school boards.

Additionally, assuming criteria for accessibility design experts are established, they should further have “sufficient demonstrated expertise in accessibility design” specific to school built environments. The Built Environment and Barrier Buster subcommittee are considered subject matter experts of school built environments, and noted how a number of recommendations appeared to be based on accessibility design in public settings (e.g., recessed fountains, floor mountain urinals, no labyrinth entrances into washrooms, tactile attention indicators, etc.). As outlined in the Education Act, a school is a highly regulated space and is not generally accessible to the public. There are unique considerations and competing proprieties that differ between school built environments and public spaces, such as shopping malls or restaurants.

Assistance Listening

A staff member of the Board’s Deaf and Hearing department shared comprehensive feedback related to various references to assistive listening in the specific room requirements recommendations 101 through 112:

• “There was a great deal of reference to assistive listening, such as hearing loops. There are a variety of SEA tools used by students in the Board already. I have not encountered a hearing loop in any school thus far. Having assistive listening does not preclude that fact that some people with hearing loss will not hear a public address or speaking regardless of the technology or reduced background noise. Visual reinforcement is often necessary (e.g., school announcements that are visible on a screen as well as over PA system). Assistive listening is referenced often but never defined [in the recommendations]. Hearing loops are one very finite example. Not all of those with hearing loss use hearing loops. Many use other strategies or technologies… Also many of the built environment recommendations address physical needs. Only in some cases was the acoustic environment of a space even mentioned. There are strategies that can be implemented at the building stage that can improve the acoustics and sound to noise ratio of a room. This should be considered at the building stage. Improved acoustics in rooms benefits all kinds of learners. There was also no mention of accessibility of portables. The acoustics of portables, regardless of mitigation factors, are abysmal. Some of the equipment students use through SEA is not as effective in portables due to reverberation and background noise from ventilation systems and thin walls.”

It has often being stated that education is the great equalizer. Our schools are the place where we first develop an understanding of the societal value placed on individuals. To this end, the concept of accessibility in education must embrace a human rights based approach in which we recognize that all students will have different needs at different times and in different circumstances. Students with disabilities are part of human diversity and humanity.

We commend the K-12 Education Standards Development Committee on completing the vital first phase in the work towards the development of new accessibility standards for K-12 education. The removal of barriers, both visible and invisible, that impede and marginalize K-12 students with disabilities in Ontario schools is critical to fostering inclusion so that students are able to fully benefit from Ontario’s education system. The YRDSB’s position, as expressed by the HRCO, is that accessibility can best be understood as a process of proactively identifying, removing and preventing barriers to people with and without disabilities. Indeed, this must be a student-centred approach where we actively consider and think about accessibility from the outset to ensure that nobody is excluded.

Meaningful accessibility can only be realized through a human rights based approach that recognizes the integral relationship between rights-holders and duty-bearers:

1. Right-holders are students with disabilities (those we serve in education) who need to be empowered to claim and exercise their rights; and

2. Duty-bearers are the educational system in general (and our Board in particular) which need to build capacity in order to fulfill our obligation to respect, protect, promote, and fulfil human rights, including disability rights.

While the proposed K-12 Education standards are an important first step, only recommendation 22 embodies a human rights based approach. A consistent theme throughout the report is the overly prescriptive nature of many recommendations, which overlook the core need for ongoing capacity building and addressing the fact that systemic ableism and attitudinal barriers continue to present the greatest obstacles for full participation and inclusion. Rather, many recommendations continue to perpetuate the compliance culture that is apparent throughout the other accessibility standards under the AODA.

To foster a culture of accessibility, the K-12 Education standards need to be more intentional and purposeful in drafting recommendations that promote a respect for dignity, difference and acceptance of disabilities as part of human diversity and humanity. It is our hope that greater attention will be accorded to the approach articulated in UN Convention on the Rights of Persons with Disabilities in the eventual drafting of the K-12 Educational standards.

Sincerely,

Anthony Anirud
Human Rights Commissioner