Victoria OCP excludes People with Disabilities

Honourable Anne Kang
Minister of Municipal Affairs
Province of British Columbia

Honourable Sheila Malcolmson
Minister of Social Development and Poverty Reduction
Province of British Columbia

Sam Turcott, Assistant Deputy Minister
Accessibility Directorate
Ministry of Social Development and Poverty Reduction

April 8, 2024

Dear Minister Kang, Minister Malcolmson, and Deputy Minister Turcott

I am writing to you regarding the City of Victoria’s Official Community Plan and the engagements related to that plan. Resident engagements designed to solicit feedback exclude people with disabilities. It is my belief that this is both a systemic and ongoing issue. I bring this matter to your attention as it is my experience that the City disregards these matters and/or forces people with disabilities to file human rights complaints if we are to have our rights exercised. Further, as per my letter of April 1, 2024, there are very few channels where I can communicate openly with the City about this matter.

The City of Victoria’s ten-year Official Community Plan(OCP) and invitation to have your say on the plan is located here. I have reviewed the survey, which is one of the key ways one can provide input into this vital community plan and have noted the following:

1. The City of Victoria excludes people with disabilities from the survey’s standard demographic data collection. They ask for age, gender identity, ethnicity etc., but they do not ask anything related to disability.

The city states that the data is collected to “help us determine if the feedback we are gathering represents and reflects the community we serve”. As far as I am aware, Victoria is not a disability-free zone and people with disabilities still represent close to 25% of the population. Further, understanding this demographic is fundamental to removing barriers in the City as required by the Accessible British Columbia Act. Our exclusion from the demographics is an egregious omission at best.

2. There are a number of questions in the survey that may create expectations from the non-disabled community that put them in conflict with people with disabilities, for example, one should not be asked to prioritize a general service over one for people with disabilities –such as accessible parking. I believe these types of questions are discriminatory in nature, as they do not take into consideration access rights.

3. The survey excludes the needs of people with disabilities from most if not all of the questions and further, uses language that excludes segments of the disability community. As an example, question 2 identifies “Walkable Areas.” Some residents cannot walk and require accessibility devises to move throughout the community. Language that excludes is a front-line barrier to access. 

This is an image of a screen shot from the City of Victoria OCP Survey. The image demonstrates how the city uses language that excludes people with disabilities

4. AudioEye, a tool used to detect website accessibility violations, detected 72 violations on the first page of the survey alone. These violations limit the ability of, and in some cases prevent, people with disabilities to participate in providing OCP feedback. They are a barrier to access.

5. The survey relies heavily on images, such as maps, and does not provide alternative descriptions – a well-established standard in the web community. It is not rocket science to conclude that images cannot be viewed by blind residents. I consider the use of them without alternative description willful discrimination.

This image is a screen shot taken from the City of Victoria OCP. It shows how the survey calls upon those filling it in to look at images to answer questions

6. According to Flesh-Kinciad, the survey requires a college entry level reading ability. Residents with reading disabilities, and many with intellectual disabilities, will not understand the documentation. Plain language, written for people ages 13 to 15 years, has been the standard for years, including for the BC Government and other public sector organizations. The use of college level language is a barrier to access.

7.  Finally, as a person living with a disability, I take exception to the City asking residents to prioritize indigenous identity, multicultural identity and diversity over one another. These types of questions positioned as human popularity contests only serve to cause conflict and splinter our community. They are volatile in nature and breed hatred amongst community groups. It is 2024, we are all of equal value.

I thank you for reading my concerns and hope that you will work with the City of Victoria to take corrective action. It would be a shame if the OCP went forward as the City’s official plan knowing that it was built discriminating against and / or excluding people with disabilities.


Susan Simmons

CC: Honourable David Eby
Premier and President of the Executive Council
Province of British Columbia

CC: Honourable Kevin Falcon
MLA, Vancouver-Quilchena

CC: Honourable John Rustad
MLA Nechako Lakes

CC: Kasari Govender
Human Rights Commissioner

CC: Marianne Alto
Mayor, City of Victoria

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