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Byrnes Communications Inc.



This Accessibility Plan is presented in response to the Accessible Canada Act (ACA) and the Accessible Canada Regulations (regulations) that mandates that federally regulated entities, which includes broadcasting enterprises such as Byrnes Communications Inc.hereafter referred to as BCI, prepare and publish Accessibility Plans.

The ACA has been passed into law, to bring about a more accessible Canada for people with disabilities. BCI has published this plan to not only be in compliance with its regulatory obligations but also to support its commitment to a more equitable and accessible environment for all.


Our Plan

BCI is developing an Accessibility Plan to help make our workplaces, information, and services more accessible for people with disabilities. This Plan will be in effect for 3 years, from 2024 – 2027. We will review and publish a new plan before the third anniversary of this plan. We are committed to providing barrier-free access to all Canadians who interact with our services or seek employment with our company.

Our accessibility goals are:

  1. To review our physical locations with the goal of exploring how access and exit can be improved for persons with disabilities to independently access our facilities.
  2. To review our methods of company communications and research ways to improve the accessibility of the material by persons with disabilities.
  3. To provide feedback mechanisms for improvements to our company communication platforms that would provide more accessibility to people with disabilities.
  4. To review and encourage feedback from applicants as part of our job posting protocol to ensure that there are steps taken to eliminate barriers for people with disabilities in applying for available positions.
  5. To provide appropriate training to all our staff about accessibility.
  6. To review our websites with the goal of making them more accessible for people with disabilities.
  7. To write guidelines about accessibility applicable to our purchasing practices to ensure in as much as is possible that new equipment purchased and installed at our radio stations are accessible to people with disabilities.


Getting Feedback from People with Disabilities

To help us make this Accessibility Plan, we intend to survey our BCI Team members. Contributing Team members may also have family members who are persons with disabilities and have contributed to this plan from the valuable perspective of caregiver. We will be reaching out to organizations in the communities we serve to better understand and help our company respond to accessibility issues. We published in 2023, a contact process enabling the public to give us feedback on accessibility issues. We intend to use any feedback we receive to help create this plan.


Statement of Commitment

BCI is dedicated to being accessible to everyone. We see this plan as an opportunity for our company to bring our workplaces, activities and services to a level that would provide accessibility for all persons with disabilities. 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 this Accessibility Plan.


Description of Bynes Communications Inc.

Headquartered in Burlington Ontario, BCI owns and operates three FM radio stations, one HD2 station, and three websites in Ontario .


Contact Information & Feedback Process

BCI welcomes feedback about our Accessibility Plan. This feed back can an anonymous or they can leave their contact information. BCI is committed to reviewing all contributions we receive and to taking steps to address barriers identified through this feedback. The links to submit feedback can be found are found at https://www.heartfm.ca/info/accessibility/ https://www.105theriver.ca/info/accesibility https://www.101morefm.ca/info/accessibility

The person responsible to collect and retain any feedback we receive is Trish Beauchemin at 905-802-0199 or trish@byrnesmedia.com  

It is our goal to respond to any feedback, unless it is submitted anonymously, within 5 business days.

We will maintain an archive of all feedback submitted via this online link and any other method of submission in a single document for the duration of 7 years. This information will be used as a measurement of our progress towards our accessibility goals, document identified barriers and help us to refine our Plan in future editions.


Aternative Formats

This Plan is available in alternative formats and a description of our feedback process can be requested by contacting:

Trish Beauchemin at 905-802-0199 or trish@byrnesmedia.com  

BCI will provide this Plan in print within 15 days of a request.



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 in 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.




Build Environment


BCI has physical office locations in buildings located in Niagara Falls and Woodstock Ontario. The current state of accessibility across our buildings differs from building to building based on the various municipal, and provincial building codes along with the year of building construction. While there may be some barriers, prevention of barriers will be our primary goal moving forward.

Members of the public and clients occasionally visit our offices in Niagara Falls or Woodstock. Primary access is by our employees.

Accessibility Goals:

  • By December 2024 we will review emergency evacuation plans through the lens of people with disabilities for all our locations.
  • By June of 2025 we are planning to review accessibility for all our buildings and assess the need for further accessibility features where possible.
  • As office leases expire, BCI will look at leasing space that is as accessible as possible.




BCI has approximately 32 full-time or part-time employees. In the fall of 2024, we will be issuing the Employee Self-Identification Form to collect up-to-date data on the diversity of our personnel.

Our personnel include people who work in our offices in each market, and some employees who work remotely as well. Some jobs in the broadcasting industry can be performed remotely while others are limited to being in a broadcasting facility.

We strive to be reflective of Canada’s diversity and report on our employees with disability data annually though Employment Equity reporting. Achieving the goals outlined below will help us to improve accessibility for our current and future employees with disabilities.

Accessibility Goals:

  • By the end of 2024, BCI will conduct a review of hiring processes to look for barriers including reviewing the process for job applications for individuals with disabilities who experience barriers to the online system.
  • By the end of March 2025, BCI will review and update our corporate policy about accommodations for employees and candidates with disabilities.
  • By the end of 2025, BCI will conduct a review of the accessibility of the platform where we post jobs. Once this review is complete, we will strive to remove any barriers.


Information and Communication Technologies (ICT)


As a company, BCI uses the following technologies:

Our  radio station websites  have some  accessibility  features.  However, we intend to conduct a review to see if any improvements can be made. We will undertake a review of these within the next 12 months and see what can reasonably be done to make them more accessible.

When we post jobs to industry websites, they are to third party websites that we do not have control over, and therefore, we have limited abilities to influence the degree of accessibility on these sites.

The technology that our employees use has not been reviewed for accessibility. Our plans to address these are outlined below:

Accessibility Goals:

  • By June 2025, BCI will conduct a website accessibility audit that ideally will include user testing by persons with disabilities. We will identify and then do our best to remove the minor website barriers found throughout consultations and others that are discovered. These include:
    • Changes to text font and size
    • Improvements to structure and formatting
    • Improving navigation of the website for people who are using a screen reader.
  • By December 2025 BCI will provide web accessibility training for all employees who create or edit webpages or content for the web.


Communication, other than Information and Communication Technologies (ICT)


We produce content including news reports, and we sell advertising on our radio stations, and digital platforms. We communicate internally with our Team as well as externally with the public.

As a media company, our main source of communicating our information is by Information and Communication Technologies (ICT). However, each of the locations in which we operate has its own autonomy to communicate with their audience, public and internally, in a manner that best suits their needs.

BCI President, Chris Byrnes, visits each of our locations frequently, to provide an update on what is going on in the broadcast industry and in our company. He also makes himself available for one-on-one meetings during his in-market visit or virtually, at any time, with any member of our team who wishes to communicate with him in the manner that best suits their needs. This allows for personal communication and connection to instill and support a workplace environment that has open and honest conversations, and helps those who have a difficult time with virtual meetings or group meetings.

We work with a number of organizations in order to promote diversity and facilitate support and removal of barriers. Examples include:

  • Ingersoll's Diversity, Equity, and Inclusion Committee
  • Woodstock's Accessibility Advisory Committee
  • Oxford County's Officer of Diversity, Equity, and Inclusion
  • We have a close working relationship with Oxford County Pride. We run news stories, and we raise awareness of Pride events via on air interviews, crusier cut-ins and we proudly fly the Pride flag in the radio station window in the month of June
  • We work closely with Tami Murray, who owns a Diversity Counselling company to promote awareness and inclusivity in our broadcast area.


Accessibility Goals:

  • By the end of 2024, any document for the public will be available in alternative formats.
  • By the end of 2024, all BCI markets will do a review of their non-ICT communications (Information and Communication Technologies) to identify barriers for people with disabilities and will endeavor to remove these barriers.
  • By the end of 2024 we will increase the accessibility of our social media by doing the following:
    • Making our contact information and website address visible on all platforms
    • Writing posts in plain language and without acronyms
    • Capitalizing the first letter of each word in hashtags and placing hashtags at the end of captions
    • Adding alt-text for images
    • Making sure photos have sharp colour contrast
  • By  December  2025,  BCI  will  provide  accessibility  training  for  all employees who work on communication activities.




As a small business BCI has limited procurement of goods services and facilities, nevertheless, we have identified the need to develop a policy which takes into account the need to remove barriers in these areas.

Accessibility Goals:

  • By the end of 2024, BCI will develop rules for accessibility in procurement. These rules will include:
    • When and how accessibility should be considered
    • Identifying areas where accessibility can/should be considered


Design & Delivery of Programs & Services


BCI is federally regulated to provide the essential services of radio. As a broadcast license holder, it is our duty to ensure that our representation of the local area and its people is accurate, entertaining, timely and fair.

Most of the way that people interact with our company is through our Information and Communication Technologies (ICT) or communication, other than ICT. Because of this, the goals contained in the previous sections of this plan will help 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.




BCI does not provide transportation services to the public.

BCI does have station vehicles, in each location, 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. BCI currently has policies in place to either send an alternate employee or pay a mileage fee if ansd when an employee is required to use their personal vehicle. No further actions are planned at this time.


Organization-wide Initiatives


BCI is committed to organization–wide training.

Accessibility Goals:

  • By the end of 2024, BCI will commit to training all employees on disability and accessibility awareness.






BCI is committed to listening to and learning from people with disabilities. To uphold this commitment, BCI will continue to consult people with disabilities in all aspects of this Plan. We recognize that consultations need to continue. We are dedicated to building relationships of trust with people with disabilities to engage in effective consultations going forward.

For this Plan, we intend to consult with our employees, some of whom are people with disabilities and some of whom are their caretakers.  We will communicate the feedback process by 31 December 2024, to encourage feedback on accessibility issues.

By 31 December 2024 we will consult with all our employees through an anonymous survey but will give the option including their contact information. The survey will ask our staff to share any barriers that they have encountered, or have witnessed others experiencing, as if they wish our head office to respond to their feedback. This feedback will also include questions about the buildings that our locations are in, and identify any technical barriers within our communication platforms.


Consultations with Other People Who Have Disabilities


By 31 December 2024 BCI will consult with other people outside of our own employees who have disabilities through the activities of our EEC to help develop and refine our plan.

It is in the best interest of all parties to consider health and safety in every activity. Commitment to health and safety must form an integral part of each radio station BCI operates. BCI is committed to protecting employees from injury and illness by establishing safe work practices in compliance with occupational health and safety legislation.

Accessibility Goals:

  • By the end of 2024, BCI will consult with persons with disabilities outside its employee group to find ways that we could improve this Plan.





BCI is committed to improving accessibility by implementing this Accessibility Plan in the upcoming years. We are committed to making sure that we are accessible to everyone. We will continue examining our practices and operations to address barriers when they are identified. BCI is determined to improve our accessibility by listening to feedback and working with people with disabilities to remove these barriers and allow for them to interact with us as independently as possible.