Mickle Park Playground – How Useable?

Below is an email to Councillor Pouget and Councillor McArthur on June 12 in advance of the council meeting.

After watching the June 5 Amherstburg Accessibility Advisory Committee Meeting, and reading some of the documents, I have some concerns regarding the recommendation to ENDORSE the playground design proposed for Warren Mickle Park’s playground redevelopment.

I’m writing to both of you because Councillor McArthur is council’s rep on the AAAC and Councillor Pouget consistently represents the interests of people with disabilities.

Ms. Heidi Baillargeon advised the AAAC an RFP resulted in three proposals that went through a Review and Scoring committee, and this was the design that was selected for installation at Warren Mickle Park. Ms. Baillargeon also advised the AAAC that it is partly a ramp structure, there are a number of accessible components, and that ‘a wheelchair can only go up to the first deck.’ It is preferable to use person first or identity first language and not refer to the assistive device alone.

How did a Review and Scoring committee approve this proposal?

What Makes a Playground Inaccessible? (aoda.ca)

  • Multilevel platforms
  • Stairs
  • Narrow walkways
  • Monkey bars
  • Bucket swings
  • Swings
  • Slides (plastic or metal)

Would someone please explain how the proposed Warren Mickle Park will be AODA compliant and inclusive if children with disabilities can’t access or use all the equipment? 

From the Parks Master Plan 2018, “It is essential that parks are inclusive and barrier-free, as guided by the Accessibility for Ontarians with Disabilities Act (AODA). To ensure that the parks system is able to serve people from all segments of the community, accessible seating, washrooms, shade (structures and trees), parking, connections to key destinations and safety must be prominent considerations.”

While Ms. Baillargeon mentioned the CSA Z614:20, a safety standard, there was very little discussion regarding the AODA, Regulations, inclusive playground guidelines and mandatory public consultation.

The Integrated Accessibility Standards Regulation of the AODA mandates public consultation as follows:

When constructing new or redeveloping existing outdoor play spaces, obligated organizations shall consult on the needs of children and caregivers with various disabilities” and shall do so in the following manner: 

1. designated public sector organizations and large organizations must consult with the public and persons with disabilities. (emphasis added).

2. Municipalities must also consult with their municipal accessibility advisory committees, where one has been established in accordance with subsection 29 (1) or (2) of the Act. 

Outdoor play spaces, accessibility in design 

80.20 When constructing new or redeveloping existing play spaces that they intend to maintain,obligated organizations shall,

(a) incorporate accessibility features, such as sensory and active play components, for children and caregivers with various disabilities into the design of outdoor play spaces; and

(b) ensure that outdoor play spaces have a ground surface that is firm, stable and has impact attenuating properties for injury prevention and sufficient clearance to provide children and caregivers with various disabilities the ability to move through, in and around the outdoor play space. O. Reg. 413/12, s. 6.

There was also no discussion regarding the 2021 survey that no children under the age of 18 participated in. 

Will the four benches be accessible? Will the bike racks be accessible? Will there be any braille elements? Will accessible washrooms be installed? Will accessible parking spaces be available? Will accessible signage and wayfinding be installed? The concept plan 2021 included a picnic area and in answer to the question, What park amenities would you like to see at Warren Mickle Park, 50 (74.6%) said picnic table: will accessible picnic tables be installed?

Also of concern is an AAAC member’s comments regarding the slide: he could only see one problem with it – that is you put it in this park and people find out about it, they’re gonna want it in all the other parks and that means retrofitting. Then the member asked about the cost for that.

In is my understanding that AAAC members identify barriers and ‘provide advice and recommendations to Council on accessibility issues within our community’ and council makes budgetary decisions for what accessible projects it prioritizes.