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For municipalities and rural entities, the strong equity framing can create uncertainty because: • It emphasizes highest accessibility levels rather than minimum compliance • It does not yet explain how cost, scalability, or phased implementation are addressed • It does not clarify regulatory status for non-federal bodies

Because the Introduction shapes how the entire standard is understood, applied, and funded across different communities.

Because without explaining how affordability and scalability are applied, smaller and rural communities may struggle to interpret and implement the principles consistently.

Because unclear scope increases legal, financial, and operational risk for smaller jurisdictions trying to determine what is mandatory versus aspirational.

Because without a clear distinction, municipalities may over-interpret advisory guidance as mandatory, increasing cost, liability risk, and implementation confusion.

Because when excluded items are not clearly addressed, municipalities and designers are left uncertain about whether those elements are deferred, optional, regulated elsewhere, or unintentionally omitted, which increases the risk of inconsistent application, procurement delays, redesign costs, and potential accessibility gaps or liability exposure.

Because the General Requirements for Lighting and Contrast introduce highly technical thresholds and measurement methods that may exceed the practical capacity of smaller and rural municipalities, and without clearer implementation guidance they create uncertainty around compliance verification, retrofit obligations, lifecycle maintenance costs, and alignment with existing provincial building codes.

Because without clear measurement methods, phased retrofit guidance, and scalable application aligned with existing codes, smaller and rural municipalities may face disproportionate capital costs, technical verification challenges, inconsistent enforcement interpretations, and increased legal and operational risk when attempting to implement the lighting requirements.

Because without clear and proportional application guidance, municipalities may misinterpret uniform lighting thresholds as universally mandatory, leading to unnecessary retrofits, budget strain, inconsistent enforcement, and avoidable delays in delivering practical accessibility improvements. Failsafe check: Passed

Clarity.

To provide guidance on useful accessibility elements.

Same information provided in French and English.

Clarity.

Clarity.

For complete information.

To avoid inadequate illumination on key exterior and interior features such as stairs.

Clarity and ensuring complete information.

Clarity and complete information.

To ensure proper compliance.

Clarity and ensuring maximum accessibility.

Avoid duplicate information.

To ensure that information does not get lost in the future.

For ease of understanding and comprehension.

Clarity and avoiding duplication.

Clarity.

Avoid adding barriers for some users.

Clarity.

Consistency, adherence.

Clarity and proper compliance.

Clarity, ensuring that TDIs are actually installed when they need to be.

Clarity, avoid confusion.

Clarity.

Consistency, applicability.

Avoiding duplication, simplify document.

Avoid confusion and duplication.

Clarity.

Clarity, ensuring proper compliance.

Avoid confusion. For clarity.

Ensure proper compliance.

Clarity.

Ensure proper compliance.

Clarity.

Ensure proper compliance.

Ensure proper compliance, avoid confusion.

Avoid confusion, ensure proper compliance.

Clarity.

Clarity, ensure proper compliance.

Clarity, consistency with Unified English Braille (UEB) notation, grammar.

Ensure applicability for all signs with many languages.

Ensure comprehension and proper compliance.

Clarity, information.

Ensure proper installation and compliance.

Ensure proper compliance and contrast levels.

Clarity, proper adherence to standard.

Consistency, proper application of the standard.

Proper compliance.

Clarity, consistency in language.

Consistency, proper language.

Consistency, clarity.

Consistency, clarity.

Increase accessibility.

Enhance compliance and accesssibility.

Clarity, compliance.

Because it is missing in the standard

to provide proper justification behind the exclusion

The reader should know the reasoning behind the exclusions

tactile maps are a known and used, and are established wayfinding tools. Tactile maps and diagrams are well-established, essential, and effective wayfinding tools for people who are blind or have low vision (BVI). They are used to convey spatial information—such as building layouts, transit systems, or city neighborhoods—through touch, allowing users to build a mental map (cognitive map) of an environment to enhance their independence

Lighting affects more than the identified groups. Individuals with hearing limitations require good, direct lighting on a speaker's face to lip-read effectively.

10.1.5 to avoid disrupting the wildlife, and save energy, and preserve outdoor experience where darkness is required (stargazing, Parks Canada's Dark Sky Preserves, etc.)

to align with the Outdoor Spaces standard

Currently it's an application error for outdoor spaces. Would not apply broadly across outdoor spaces.

10.1.5 applies to exterior lighting but not necessarily outdoor spaces lighting. See Outdoor Spaces standard for details.

Because extensive area is a vague and unknown term, subjective to interpretation

duplication and conflicts with Outdoor Spaces Standard

To avoid confusion and provide clarity

to be consistent with the Outdoor Spaces standard

CSA/ASC B651 is appropriate for only for indoor and built spaces but for outdoor spaces the standard should reference the outdoor spaces standard instead.

CSA/ASC B651 is appropriate for only for indoor and built spaces but for outdoor spaces the standard should reference the outdoor spaces standard instead.

Because the level of care children with severe disabilities require to not only be able to be present in a space physically, but to learn, grow, develop and thrive to the best of their abilities is dependent on the presence of all of these factors, not simply the physical space considerations. Without nursing on-site, children with feeding tubes, breathing support, epilepsy, T1 diabetes and other disabilities are unable to safely attend childcare or preschool. Without special education teachers and therapists, differences in learning styles, sensory, motor and cognitive disabilities become liabilities that render children "parked" rather than taught. Without educational assistants or personal support workers receiving adequate training and support themselves from nurses, special education teachers, and therapists, the repetition needed to practice new and emerging skills is grossly limited, assistive devices (such as AAC, prosthetics/orthotics, sensory tools) are poorly utilized, and safety for individual children is compromised. For a best practice model for top-tier accessible childcare, please see Kayla's Children Centre in Thornhill, ON.

Children with disabilities may or may not use wheelchairs. One or more of their parents may or may not use wheelchairs. One or more of their teachers may or may not use a wheelchair. As such, spaces intended for family waiting, consultations and other purposes should allow for the presence of at least three wheelchairs at any given time.

Independently transferring individuals above workplace standards limits puts both caregivers individuals at risk of injury.

Parents use mobility devices as well as children. When parents and children who both use mobility devices enter a reception area that is primarily made up of existing seating, they face a significant challenge, as they cannot separate from one another, but to stay together often requires parking in the middle of the seating space or blocking multiple seats in the process.

When wheelchairs come indoors in winter/rainy weather they bring in an enormous amount of snow/moisture. Wherever they park, this moisture pools, creating the potential for slippery surfaces and falls for walking individuals. Traditional solutions such as requests to change out of boots in a vestibule are not possible to comply with.

While it is great to include ramped access to play structures, more often than not these access ramps simply lead to a dead end, with no meaningful engagement possible. The JumpStart playgrounds installed across Canada by Canadian Tire's Foundation should provide a model for this section.

provides increased access for wheelchair users

As this section points out, currently, children with disabilities face barriers to early learning opportunities. While some of these barriers are physical, many of them are attitudinal. We were turned down by a number of childcare centres on the basis of my granddaughter's disabilities, even when they were physically able to accommodate her medical devices, and even though she qualified for funding for a one-on-one worker through government programs. A similar situation exists for parents/caregivers with disabilities (whether the child in question has disabilities or not), who may find themselves in the difficult position that the only option for where their child can find care is inaccessible. This document currently sketches out the necessary steps a childcare operator would need to adhere to should they wish to invest in accessible childcare, but does nothing to mandate that newly built childcare centres conform to this standard across the board (as other Accessibility legislation in Canada has required). Attitudinal barriers are similarly left unresolved for children with disabilities, who often face or that they use the same criteria for accepting children with disabilities as those without. In an ableist world, children with disabilities will always be deemed an additional challenge that's easier to let "someone else" take care of. Likewise, in a for-profit world, the costs of creating a physically accessible space will remain a "nice-to-have" or even a luxury easily dismissed as untenable unless/until government mandates inclusion and equity. That being said, there is a reality that service delivery is both more affordable and more effective when multiple children with disabilities receive care in the same space. It may not make sense from a financial or educational perspective to insist that ALL childcare centres be able to provide full care for children with ALL types of disabilities. Given the complexity of these realities, I believe this issue needs deeper consideration and consultation to ensure that all children with disabilities have access to the safe, effective, and individualized care they require to meet their full potential. The reverse integration childcare model found at Kayla's Children's Centre in Thornhill ON should be considered as a best practice standard for large communities, with modifications considered intentionally for smaller and especially rural communities where therapeutic intervention for children with disabilities is already at a disadvantage.

While recognizing that more consideration is needed before establishing standards for tactile maps, etc. is reasonable, completely excluding these items from discussion in this document is excluding people who would rely on this information. For example, CNIB includes tactile maps and pre-recorded instructions in their design guidelines: https://clearingourpath.ca/index.php/design-needs/exteriors-and-interiors/information-and-communications-systems/tactile-maps-and-pre-recorded-instructions/. At the very least, ASC 2.4 can have a section on this to acknowledge their need and importance in the built environment, and provide whatever appropriate guidelines are available currently, with a note that more research is needed in this area.

While recognizing that more consideration is needed before establishing standards for tactile maps, etc. is reasonable, completely excluding these items from discussion in this document is excluding people who would rely on this information. For example, CNIB includes tactile maps and pre-recorded instructions in their design guidelines: https://clearingourpath.ca/index.php/design-needs/exteriors-and-interiors/information-and-communications-systems/tactile-maps-and-pre-recorded-instructions/. At the very least, ASC 2.4 can have a section on this to acknowledge their need and importance in the built environment, and provide whatever appropriate guidelines are available currently, with a note that more research is needed in this area.

In the bulleted list, a) and b) have a note providing rationale for exclusion, however, c) has no note. Please provide a note here as well so that the reader can understand the reasoning for exclusion.

To avoid any conflicts or gaps between Standards, consider keeping each Standard specific to its topic, and reference other Standards for supporting information. In this case, general lighting and contrast requirements could be part of ASC 2.3 or other Standards, with references to those clauses (plus any modifications) can be included in this document. Meanwhile, this Standard could focus on being the source for wayfinding and signage specific lighting/contrast requirements.

Providing the context to why certain colour combinations are to be avoided can help inform the reader on different types of vision disabilities, including low vision and colour blindness.

Providing the context to why certain colour combinations are to be avoided can help inform the reader on different types of vision disabilities, including low vision and colour blindness.

The current description allows there to be cracks, potholes, or uneven/bumpy pavement, which can create safety hazards for walking or using a mobility device.

Please also mention separation from automobiles/vehicle traffic. Even through this may be common knowledge and there are usually curbs separating roads from sidewalks, many new road/plaza designs are reducing the curbs in attempt to create pedestrian-friendly zones. The new designs are lacking cane-detectable cues to alert someone of the change from sidewalk to road, creating a safety hazard. Consider including "automobiles" or similar word in the list to help address this.

The current phrasing is unclear with "connect/connected" used twice; provided a suggested revision for your consideration.

Add "cane-detectable" in the sentence to clarify which types of cues are being referred to. The current phrasing could imply TWSIs are needed in the absence of any other types of cues (e.g., visual cues) which may not be the intended meaning.

Need clarification of the first sentence. The current statement is vague and not recognizing that TWSIs can also create accessibility barriers (e.g., small/caster wheels from manual wheelchairs, strollers, luggage, etc., can get stuck in between truncated domes). While this challenge with TWSIs is mentioned in 11.4.2.2 Note, it may be better to rewrite the statement here.

Please remove "long" as this might create confusion that white canes of a specific length need to be considered.

The destabilizing of wheels can happen at the top or bottom of the ramp, creating hazardous situations in both cases. Please also mention the top of the ramp so that the TWSIs can be installed with adequate setback space before the ramp begins. Also, please clarify what distance would provide a "proper setback."

Guidance is required on the consistent application of TWSIs at curb ramps, which this Standard can provide. Similar to the note for 11.4.2.2 a), please provide clarity here on where TWSIs should be installed with the proper setback. TWSIs on the slope of the curb ramp or on the bottom of the curb ramp could create destabilization at a location that is too close to vehicular traffic. Please also clarify what distance would provide a "proper setback."

Current language implies that direction indicators are not required if there are visual cues such as signage with text/images only. Therefore, suggestion is to specifically say "where no other cane-detectable cues...".

Currently, a reader has to flip back and forth between these sections to make sure all details are understood. To help better understand and apply the requirements, please consider reorganizing the sections to improve reader flow, and to easily recognize any repetitions or gaps in content.

Current language can create confusion in regards to which symbol is being discussed: a specific symbol, or generally one of the symbols of access. Please clarify and refer to other clauses such as 12.9 where symbols will be discussed further. The language "designed to meet the needs of specific people" is not considering the fact that people could have diverse needs and implies that one feature/provision could address all of their needs. Please revise the language.

There is no mention of evacuation signage in this Standard. Please considering adding an example in the Notes to remind the reader to include evacuation routes in their accessible signage planning.

This Standard is intended to first be applied to federal facilities, so it would be helpful to understand examples relevant to these spaces.

Clear signage and wayfinding for motorists is important for navigation, and to avoid collisions, especially where vehicular and pedestrian routes cross in a parking facility. Focusing only on parking implies that motorists only need this type of signage. Please consider revising to include the different signage types required by motorists.

Regardless of indoor or outdoor spaces, vertical signs should not obstruct or intrude into path of travel. Separating these into two points could create confusion. Please consider combining.

The title says "Signs for outdoor spaces" but the content only discusses trail signage. Please discuss other outdoor signs as well, or provide references to that information elsewhere in the Standard. If the section is intended to only focus on trail signage, then please revise the title to provide clarity.

Trail maps are not mentioned aside from Note 3 and would help communicate important information at a trailhead. Depending on the type of trail and its location, there may be other safety information or instructions that need to be communication before entry (e.g., a notice that a specific trail is difficult and requires appropriate gear, etc.) and there may be the need to post emergency contact information (especially if it's a tourist attraction, where travelers may not be immediately aware of local emergency or search and rescue contact numbers). This section only discusses trailhead signage and no other trail signage such as trail markers, which would be important for navigation.

For brevity and to provide consistency between standards, instead of repeating some of the requirements already listed in CSA B651, consider referring to the relevant clauses and only listing out what is different.

In this sentence, it is confusing why "the symbol of access" is being used instead of "the International Pictogram Symbol of Access" and whether or not both are referring to the same symbol, or if the former is referring to a different symbol. Please keep terminology consistent to help understand and apply the requirements.

Including entrance on the list is important, especially for buildings where there may be special entry instructions such as ringing a doorbell, etc. The audible sign for entrances should also say what business/organization the entrance is leading to.

Audible descriptions of evacuation routes can help more people safely and independently exit during an emergency. This can help with evacuation route planning in advance if posted in predicable areas such as the reception area and where evacuation maps are posted.

Audible signs that are outdoors are not considered here, but guidance is needed for that. What is the acceptable sound level and distance range for an outdoor audible sign? Is there any weatherproofing requirements? Are there any other unique requirements for outdoor audible signs?

Does automatic imply motion-sensor/proximity based activation, activation at a consistent time interval, activation based on action, or other? Providing clarity on the requirements (or at least listing examples of what is implied) could help reader better understand and apply the requirements.

Communicating emergency alerts via existing signage systems would be a reasonable application, as people are already paying attention to these signs.

For clarity in reading and interpreting the Clause, consider listing the ratios first, and then the bullet point that references it. Also, directly state the bullet point being referenced rather than saying "in this Clause." This will avoid confusion with the reader.

Since this is a Standard related to accessibility, the accessibility discussion should be included under the requirements rather than as a side comment. Otherwise the current language is implying that alternative formats to visual information is optional and not required.

Important to alert readers to this being an impactful feature on many users.

If readers are using screen reading programs and scanning through by links, they will hear "1" and "2" which has less meaning than "Table 1" and "Table 2". This may occur in other instances in this document, but is only noted here.

By changing to two separate sentences, we very clearly state the minimum value, then go on in the next sentence to discuss higher values. More clear language and less cognitive load.

Careful of "i.e." versus "e.g." In most cases, it should be "e.g." which means 'some examples' whereas "e.g." means 'in other words', to clarify or rephrase a statement. There may be other instances in this document.

No space before percentage sign, consistent with other instances in this document.

No space before percentage sign, consistent with other instances in this document.

11.4.3.3.2 states that "Flat-topped elongated bars shall have a height between 4 mm and 5 mm." If note 1 is providing a recommended height for indoor settings with highly smooth surfaces, I would expect a recommended height that is higher than the minimum (which is 4 mm). Should this be higher? If not, why mention that we should have a recommended height that is the minimum?

Change "using" to "through." People don't use the soles of their shoes to detect, they use their feet through their soles. There is another instance of this, but it does say "through".

Capitalize "Clause", consistent with other instances in the document.

Add a comma after "mapping", since this is effectively a parenthetical addition to the phrase “have signs ... tested”

Consider consistency of “people with disabilities” vs “persons with disabilities.” In most cases "persons with disabilities" will work gramatically, and tends to be more common and reflective of inclusive language than "people with disabilities."

"identification" does not need to be capitalized in this context, and lowercase is consistent with 12.2.1 "Examples of orientation signs include..."

Missing word "include", consistent with sentence structure in previous note "Examples of orientation signs include maps, sketches,..."

Pluralize signs, for grammatical consistency and consistency with examples listed in 12.2.2 (e.g., "Examples specific to outdoor environments campsite number signs, cabin or yurt identifiers, accessible beach or picnic shelter identification signs." However, do consider 12.2.4 that has singular. Either way, ensure consistency of singular or plural for sign(s) in these adjacent sections.

Consistency of "forbidden actions" and "mandatory actions"

Add "include"

Is this telling us to consider guidelines under a different section, and apply them to content in 12.2.7? If so, reference by number the section(s) and include the section name(s).

add semicolon after list item

These seem redundant. Are they saying something different? If so, suggest revising for clarity.

Is this the width or height of the painted symbol. The term “long” is unclear here.

Add comma for clarity.

Sentence is wordy and hard to read. Suggest separating into two sentences.

Add parentheses for example. Use "e.g." rather than "i.e."

Long sentence is hard to read and not in plain language. Start by telling the reader what these things are (the 'valid options') then go on to list them, rather than stating that they are valid options at the end.

I imagine this is an angled, but generally horizontal sign. Could be helpful to indicate which part of the sign is measured between 730 mm and 860 mm.

Specify latch edge, consistent with CSA B651:23 4.6.6.4 a)

I would consider mounting height to be part of location. Even if it is also located elsewhere, readers may come to here to find the height. Could include a reference to the reference (elsewhere) to mounting height, but should also list it here.

Following plain language principles, put the most important information first. The first time I read this section, I saw 'signs meant to be read looking down' followed by 'for outdoor toilet facilities' and I felt like these were reasonably niche and uncommon applications and didn't expect to find more broad-reaching specs such as general mounting height, etc.

CSA B651:23 4.6.6.4 e) states that tactile signs “be mounted with the horizontal centreline 1500±25m from the floor. " This height appears to be different, and suggest specifying whether this measurement is horizontal centreline or bottom edge of sign.

One mentions “when they are visual and do not contain tactile or braille elements.” The other mentions “...for those required to include tactile and braille elements.” Suggest changing the second to “...for those containing...”

Remove comma within number, consistent with other larger numbers in this document.

Emphasize that font size is part of the sign being viewable from a comfortable viewing distance, and point people to reference within the document.

If signs are near doors, point people to where to read the specs for this. If readers are not aware that there are specifications on where to place on handrails (BLC), then they may place them in an unsafe location.

If specific locations, or reference to requirements within the document, are not in this section, users may not consider the best placement of these signs.

This seems to be more of a placement feature, rather than feature of the sign itself. Suggest moving it to 12.7.2 and/or 12.7.3

Change “percent” to “%” for consistency within document.

Change “letters” to “characters.” While each braille cell may contain an individual letter, it is more accurately called a “character,” especially if numbers or contracted braille are involved.

Consistency of "mm" and hyphen spacing.

Is it more accurate to say “if the doors are opening or closing” as it is the action of the door moving that is pertinent to the user, than a static state?

This is not very specific. Recommend referencing 12.11.7 b) that provides best viewing times.

Not sure about the use of the term “locations plans” here. The 13.1 introduction states that “A wide range of map types, including location plans, guide maps, and navigation maps.” Are location plans just one kind of map? If so, perhaps define it somewhere. If 13.10 refers to construction and maintenance of all maps, then rename to “Maps shall”

Suggest providing the “Tactile Walking Surface Indicator” before TWSIs, since they haven’t been mentioned for a while in the document.

Ease of reference for readers.

Ease of reference for readers.

More clarification on who is applies to

Safety is only mentioned regarding technologies, otherwise.

Important to include as part of navigation

Clarity

Consistent with CNIB Clear Print Guidelines. 14 pt. is quite small

Ensure consistency

The term is used a few times but not referenced- is there a guideline?

Provide a technical measurement for design clarity

Does this prevent the design and construction of multi use pathways?

Pavers create many accessibility barriers and should be discouraged.

Maintenance requirements

Another accessibility feature

Easier to understand

Is this the general population's reading level?

More accessible

If adopted positively by ASC and its Board, requirements could be recommended for regulation and formal enforcement.

• Consider requesting third‑party verification as part of project delivery

• 3000 K alone is not a robust quality measure; Colour Rendering Index (CRI) and spectral distribution should be considered • In lived experience, 2700 K performs better for some users, though context matters

• Add tools/practical examples to support implementation (e.g., guidance on assessing uniformity and mitigating shadow bands).

• Observation that portable map guidance appears to be a gap; suggestion to add content in the relevant section and submit formal comments online.

• Always validate with people with disabilities; requirements are task‑ and context‑dependent.

The trend to environmentally friendly marking paint has resulted in wayfinding, parking lot, crosswalk, and other types of markings being completely or almost completely worn off prematurely. They often remain this way for long periods due to inadequate repainting schedules (likely still on a schedule for the previous types of paint, which would remain relatively intact for years).