Accessibility Progress Report
1. GENERAL
This Accessibility Progress Report is presented in response to the Accessible Canada Act (ACA) and the Accessible Canada Regulations (regulations) that federally regulated entities, which includes broadcasting enterprises such as Pattison Media Ltd. (PML), prepare and publish Accessibility Plan updates.
The ACA has been passed into law, to bring about a more accessible Canada for people with disabilities. PML has published this update not only to comply with our regulatory obligations but to also support its commitment to a more equitable and accessible environment for all.
Feedback
We have published our feedback contact and process on this Accessibility Progress Report, where one can call, email, mail, or complete a webform to submit feedback (accessibility). The contact: is Kate Marshall, Executive Assistant to the President of Pattison Media, 460 Pemberton Terrace, Kamloops, BC, V2C 1T5, (250) 851-3212, kate.marshall@pattisonmedia.com.
Our Plan – Progress Update
PML has developed this Report to share the progress that we have made to make our workplaces, information, and services more accessible for people with disabilities.
2. EXECUTIVE SUMMARY
2.1 Overview
PML’s Accessibility Plan 2023-2025, committed to review our build environment, employment practices, information and communication technologies, procurement, design & delivery of programs & services, transportation, and our organization-wide initiatives.
PML has made a commitment to examine our products, services, practices, and operations to address barriers when they are identified. We are also determined to improve our accessibility by listening to feedback and working with people with disabilities to remove these barriers and allow them to interact with us as independently as possible. Our Accessibility Plan committed to further consultations with people with disabilities.
2.2 Barriers
Through this review we have identified barriers that we have worked on and continue to work to remove. They are a) physical barriers in our buildings, b) ICT platforms that need to be improved, c) training material for our content providing employees, and d) finding accessible partners with whom we can consult.
a. Physical Barriers: Many of our locations present physical barriers of access to people with disabilities. Some of our locations have been in the same building for decades and it is the building itself and its lack of meeting current accessibility building codes that present barriers. For example, width of hallways and doors. To address this, we have taken careful review of what the current needs are for that operation in that location when the building leases are coming up for renewal. This has resulted in not only reducing our footprint in some instances and lowering our square footage but also moving locations into buildings that meet current accessibility building codes. We recognize that this will be ongoing for years beyond this current Accessibility Plan, as many of the 32 sites that hold our 51 stations have long-term leases not available for renegotiation and review for some time. This will be a consideration for all lease negotiations moving forward with no completion date as of yet.
Examples of progress made in our physical locations:
In 2023, we have been able to respond to physical accessibility issues inKelowna, BC, by moving locations completely. PML Kelowna was relocated to a second-floor office building from a stand-alone, older building. This older building was not able to fulfill current accessibility building code standards. As this is a new renovation, all accessibility codes and standards were followed. Our new location provides an accessible elevator and washrooms, wider hallways, and doorframes on one level, that meet the current building standards and accessibility requirements.
In Melfort, SK, improvements were made to our office to assist a staff member with a walking disability. A renovation was completed to one ofthe offices and made a new wheelchair accessible bathroom. Prior to this, we could not offer that employee a bathroom facility that was accessible without doing stairs.
In Medicine Hat, AB, the management has worked with the local Health &Safety Committee and local fire inspectors to find a solution for an employee who is wheelchair bound and works on the bottom floor of the building. The employee accesses this floor by an elevator, but it has been recognized that if a fire occurs, the elevator is not an option for an exit forthis employee. A solution is ongoing and will be updated in our next progress report.
We will continue to look for solutions to improve accessibility in our physicallocations and include them in our update for 2025.
b. ICT Platforms - Websites and Apps: Our PML website is on a Webflow platform which has its own standards of accessibility and audit checklist that is at a WCAG 2.1 AA standard. This checklist is a living process that is maintained by Webflow’s brand studio web team. While we are confident in this process and standard, we have undertaken an audit via our website host, Lift Interactive, of our PML site to identify any improvements that we can make. Lift Interactive used the comprehensive Webflow PML Accessibility Progress Report 20244platform along with AccessiBe’s website grader to identify and update violations that came up. They also used Toptal’s color contrasting tool.Some of these updates and edits included:
- Adding custom Aria attribute to our homepage background video.
- Adding a role ‘button’ attribute to social media links in the footer.
- Editing the labels of several buttons to be more specific. Ex: ‘LearnMore’ was changed to ‘More about Pattison Careers’
- Adding missing alternative text to several images.
- The anchor scroll was set to instant to improve interactions
We have also undertaken an audit of our public-facing radio station websites and apps. Our provider of these sites, SoCast, retains an Accessibility Officer on staff to ensure their products are compliant and has committed to ongoing training with developers to ensure they are aware and capable of bringing all of their products to WCAG standards2.0 and greater.
Our PML Digital Director has worked with SoCast to customize templates for our radio station websites and streaming apps. Their audit brought an awareness that while the main template was complaint with the accessibility standards required, our customization of that template requires further adjustments to bring it up to WCAG 2.0 AA standards.
The streaming apps of these stations were also customized and will require further updating as well. PML and SoCast are developing a schedule to address these corrections.
With our extensive websites and news portals to update, this upgrade and compliance will continue into 2025.
c. Training: We have identified a barrier in training where the PML content contributors to our websites may not be knowledgeable in the standards and practices that are required to make their content accessible at a level that is required. PML executive management is currently involved in a full assessment of the issue to bring a solution and timeline to overcome this training barrier. Our timeline to have training in place for this group of employees is by the end of 2024.
d. Consultation partners: PML has identified a barrier in finding an outside group of people with disabilities to consult with, who could assist with auditing and giving us feedback on our company. We are engaging our local EE Committees to find community groups willing to partner and consult with us to help us continue to learn about the key priority areas that effect their lived experience.
2.3 Summary of Consultations
Subsection 44(4) or 53(4) of the ACA: The manner in which we consulted persons with disabilities in the preparation of is progress report.
PML consulted directly with our employees who have disabilities and require accommodation be made and/or barriers to be removed for them to work and participate independently in the workplace. Each person’s disability is unique, and we wish to remove the barriers that impact these contributing members and find a solution that is tailored to them and their position. These consultations take place at the local level with General Managers and Department Heads who can assist with custom solutions.
PML annually reviews company policies, procedures, and practices which include our Accessibility and Duty to Accommodate Policy. These policies were last reviewed in February of 2024. The policies have created a process and practice that has allowed our station General Managers to make localized decisions on the identification and management of any barriers’ removal and support their employee’s ability to independently do their jobs.
3. ACCESSIBILITY SUMMARY
PML is dedicated to being accessible to all stakeholders, clients, employees, job applicants, suppliers and visitors who enter our premises, access our information, or use the company’s goods and services. Not one person with disabilities is the same as another. This review process is an opportunity for PML to look at our company through an accessibility lens and become aware of the perspective and barriers that people with accessibility challenges face. Our workplaces, activities and services will in turn be elevated and improved, some quickly and some taking many years for us to bring them to the standards required. To assist our accessibility progress, we are open to hearing from people with disabilities who interact with our company as an employee, client, or visitor, as this process will require evolution over time for us to address changing needs. We commit to addressing barriers as soon as possible even if they are not outlined in our Accessibility Plan.
PML strives to be a positive contributing member of each market we serve and be reflective of those communities. We will endeavor to identify, prevent, and remove barriers for persons with disabilities as they relate to our employment, communication, built environment, goods and services and transportation.
4. PROGRESS IN AREAS OF ACCESSIBILITY
4.1 Employment
As PML promotes its job openings by digital methods, this area will benefit from our audit of our ICT.
Our common practice of offering both an email address to send resumes and other requested documents to, and an online form for each job posting offers candidates several avenues to apply for our job openings.We also ask the question if they require any accommodation during the hiring process to ensure the opportunity for applicants to communicate their needs.
Our current ability to quickly create remote work environments to accommodate current members of our team that require accommodation by becoming ill or injured or transition into the category of people with disabilities, has become part of our culture at PML. We work to ensure that our team has the proper equipment and opportunities to remain a valued and contributing member of our team.
We have also completed a new redistribution of our Employee Self Identification Form to collect up-to-date data on the diversity of our employees. The results are reported in our annual Employment Equity report.
4.2 The Built Environment
PML’s local Health & Safety committees have reviewed the physical buildings of our over 30 locations across Western Canada. The accessibility status of our built environment varies across regions due to differences in municipal, provincial, and territorial building codes, as well as the age of construction. Public visits to our office spaces are infrequent as we have kept a closed door, ‘by appointment only’ policy in place since Covid and our buildings primarily serve our employees. We have identified numerous barriers within our built environments and work with people with disabilities, mainly employees, in those locations to overcome them through their consultation.
PML is focused on preventing such barriers in newly leased locations and are actively engaged in removing obstacles within existing spaces. Since many of our real estate premises are leased, changes affecting accessibility are sometimes beyond our direct control and are determined by the landlord. Nonetheless, we endeavor to address accessibility concerns during lease negotiations
4.3 Information and Communication Technologies (ICT)
PML has brought review and focus through an accessibility lens to the public facing components of our business such as our radio station websites, streaming apps, and news portals. We have consulted with both outside third parties in the field of WCAG standards, and our suppliers and are in the process of developing new standards, training contributors to those sites and templates to address deficiencies in this area of our business.
Our three TV channels already use Closed Captioning and Described Video for our shows as per the Broadcasting Act. We have company protocols in place to ensure these services are there for people with disabilities whenever they watch our broadcasts.
4.4 Communications other than ICT
We produce content, report news, and sell ads on our radio stations, TV channels, websites, podcasts, and online platforms.
As a media group, we mostly use computers and the internet to share our material. Each PML location, however, communicates with their audience, internally, and the public in a manner that best suits their market’s needs. As mentioned above, we have identified barriers within our radio stations and news portal sites that are being addressed by our site provider and PML Director or Digital.
Our company internal communications tool, Webex by Cisco, has its own built-in accessibility requirements and review that reports it is compliant with WCAG 2.1 AA standards and offers accessibility options within the platform settings.
4.5 The procurement of goods, services, and facilities
Our accessibility journey has given us the opportunity to communicate our new requirements and work with our partners, vendors, and suppliers to improve all goods, services, and facilities.
We have made progress in our awareness of how accessibility standards are affected by our procurement of goods, services, and facilities and where we can make changes to improve them. With this awareness, we are in the process of developing new policy to guide decisions being made at the time of planning and procurement.
To make the most impact on our public facing platforms, we have focused on our software service providers, where we will create a new requirement of accessibility that includes the WCAG 2.0 AA or higher in order for us to renew our contracts.
4.6 The design and delivery of programs and services
As PML is a federally regulated broadcast license holder, we provide an essential service via our TV and radio broadcasts. We pride ourselves on being a true representation of the local area and its people by broadcasting accurate, fair, entertaining, and timely, news and information.
Most of the way that people interact with us as a company is either through our Information and Communication Technologies (ICT) or Communication other than ICT. As we continue to work with providers to move through the audit process of our apps, websites, streaming platforms, and news portals, these will all benefit and make the design and delivery of our programs and services more accessible.
We will continue to monitor internal and external feedback to identify any additional barriers related to design and delivery of programs and services to address any existing barriers and prevent any new ones.
4.7 Transportation
PML does not provide transportation services to the public.
PML provides station vehicles, in most locations, for use by team members primarily in the programming, technical, news or promotions departments. These vehicles require a valid driver’s license from our employees in order to be approved to use them.
Our current company Accommodation Policy addresses the need for flexibility and allowances in this area, such as when an employee with a disability is unable to drive or needs to use their own accommodated vehicle to perform their job duties. PML currently has policies in place to either send an alternate employee or provide mileage for use of their personal modified vehicle
5. CONSULTATIONS
PML consulted our own employees directly when they had been identified as people with disabilities. Local managers have been given the autonomy to problem solve and assist in a manner that specifically addresses the barriers and challenges that the disabled employee encounters while doing their jobs and working in our places of business.
6. FEEDBACK
Subsection 44(5) or 53(5) of the ACA: information concerning the feedback received by the regulated entity through its feedback process and how that feedback was taken into consideration.
PML did not receive feedback directly through our feedback process from any group or person with disabilities regarding our activities, services, or buildings.As previously mentioned, we did identify employees with disabilities, who required barriers to be removed and consulted with them directly to address their individual needs. Their feedback was essential to the removal of barriers.
We maintain our published feedback process and contact information on our company website at (accessibility) and on all radio stations’ sites. We state that we welcome all feedback about this progress report, or any accessibility issues found. Feedback can be submitted anonymously or include name and contact information. We are committed to reviewing the feedback we receive in good faith and taking steps to make any changes needed.
We also offer to provide documents in different formats such as braille and audio of our Accessibility Plan, or a description of our feedback process.
7. BUDGET AND RESOURCES
Budget and resources will be made available as required to identify and eliminate barriers.
PML works with many local organizations in support of accessibility and offers them promotional resources to assist their events. Some examples of promoted events bringing awareness to accessibility groups in the last year are:
Chilliwack - Our station promoted the Chilliwack Society for Community Living Career Fair in April through on-air mentions and community calendar. This society supports those with developmental disabilities, and they have exciting opportunities for full, part-time, and casual employment in Chilliwack and the surrounding area.
Kelowna - Spotlighted Motionball Kelowna – a national not-for profit organization whose mandate is to introduce the next generation of donors, volunteers, and sponsors to the Special Olympics movement through integrated social and sporting events. This includes kids with spectrum disorders like autism and ADHD, the ability to participate in sport. They hosted a Special Winter Olympic day at Big White Ski Hill.
Kamloops – Our station interviewed with a woman living her life as a legally blind person to raise awareness during White Cane week.
8. TRAINING
PML offers optional and free training via Canadian Centre for Diversity andInclusion (CCDI) on Accessibility. PML Executive Assistant distributes a schedule of webinars several times a year along with reminders of the opportunity to access these free materials.
PML includes accessibility discussions in quarterly meetings of our local and corporate Employment Equity committees. We share training outcomes from webinars, identify barriers, discuss solutions, and share advancements amongst our locations. This scheduled discussion and reporting has assisted in maintaining accessibility in front of mind in our corporate culture and has created an environment where requests for assistance for barrier removal is not a barrier in itself.
PML will be focusing on training for our content providers to meet the WCAG 2.0AA requirements by the end of 2024. This will reduce accessibility violations on our sites and provide the groundwork for awareness of accessibility issues and requirements when designing web products.
9. GLOSSARY
This plan uses these definitions:
Disability: An impairment, or difference in physical, mental, intellectual, cognitive, learning, or communication ability. Disabilities can be permanent, temporary or can change over time.
Barrier: Anything that might prevent people with disabilities full and equal participation in society. Barriers can be based on attitudes, the built environment, technology, in how information is communicated or can be the result of a policy or procedure.
Accessibility: Greater accessibility is achieved through the design of products, devices, services, environments, technologies, policies, and rules in a way that allows all people, including people with a variety of disabilities to access and use them, as independently as the person wishes.
10. REGULATORY CONDITIONS
Broadcasting Act Requirements
As required by section 42(1) and section 51(1) of the ACA, we have set out the following applicable conditions and provisions:
42(1)(b) - the conditions imposed by license, issued under Part II of the Broadcasting Act, to which some or all PML broadcasting undertakings are subject that relate to the identification and removal of barriers and the prevention of new barriers
License Conditions under Part II of the Broadcasting Act
License conditions that relate to the identification and removal of barriers and the prevention of new barriers are set out below.
42(1)(c) - the provisions of any order made under subsection 9(4) of theBroadcasting Act that relate to the identification and removal of barriers and the prevention of new barriers and that apply to some or all PML broadcasting undertakings; and
Provisions of any Order made under subsection 9(4) of the Broadcasting Act
Provisions of any order that relate to the identification and removal of barriers and the prevention of new barriers are set out below.
42(1)(d) - the provisions of any regulations made under subsection 10(1) of theBroadcasting Act that relate to the identification and removal of barriers and the prevention of new barriers and that apply to some or all PML broadcasting undertakings.
Provisions of any Regulations made under subsection 10(1) of the BroadcastingAct
Provisions of any regulations that relate to the identification and removal of barriers and the prevention of new barriers are set out below.
Accessibility Requirements for Programming Undertakings
- Offering Closed Captioning
- Television Stations must caption 100% of English language programs broadcast over the broadcast day.
- Television stations must ensure that advertising, sponsorship messages and promos in English languages are closed captioned.
- Television stations must implement a monitoring system to ensure that, for any signal that is closed captioned, the correct signal is captioned, the captioning is included in its broadcast signal, and this captioning reaches the distributor of that signal, in its original form.
- When providing Closed Captioning, English language Television stations must meet quality standards about, among other things, lag time and accuracy.
- Offering Audio Description (AD)
- “Audio Description” or “AD” refers to announcers reading aloud the textual and graphic information that is displayed on the screen during information programs.
- Television stations shall provide Audio Description for all the key elements of Canadian information programs, including news programming.
- Offering Descriptive Video (DV)
- PML television stations shall provide Descriptive Video for all English language programming that is broadcast during prime time (i.e., from 7p.m. to 11 p.m.) and that is drawn from specific program categories, the exception of U.S. programming received without described video less than 24 hours prior to air. Such programs will be broadcast with described video for any repeat airings scheduled greater than 24 hours from delivery. In such cases, a logo is to be displayed at the start of the first airing and an audio notification is to be provided indicating that repeat broadcasts will be aired with full DV at a future time.
- Filing reports with the CRTC
- a. For English-language services, every year, broadcasters must provide the Commission with a report describing their efforts made in-house and requests to caption providers to improve the English-language CC accuracy rate for live television programming during the broadcast year.
- Alternative Formats and Website Accessibility
- Accessibility plans, progress reports, and descriptions of feedback processes published under the ACA must be made available, upon request, in print, large print, braille, audio format, electronic format that is compatible with adaptive technology that is intended to assist persons with disabilities, or any other format that the person and the regulated broadcasting entity agree upon and for which there is proof of the agreement.
- Accessibility plans, progress reports, and descriptions of feedback processes published under the ACA must be published in a way that meets WCAG guidelines.
