February 2020
AMCTO Prepares Burden Reduction Submission to Government

2020-02-04 9:41:31 AM


AMCTO has prepared a submission to the Ministry of Small Business and Red Tape Reduction identifying areas that pose a significant burden to Ontario's local governments.

Developed with input from the association’s Legislative and Policy Advisory Committee, three areas of municipal burden have been identified:

Special Occasion Permits: Local businesses, community groups and individuals seeking to hold events that include the service of alcohol, a designation of municipal significance is needed. This is through a resolution from Council or by letter from a delegated municipal official. Since there is no definition of ‘municipal significance’ in the Liquor License Act, clerks may be apprehensive to designate events making permit requests that may need a resolution. The process also creates an excessive regulatory provincial process on local governments.

Moreover, applicants making permit requests are required to submit an application at the provincial level and be responsible for contracting multiple agencies at the local and regional levels prior to the event. This process can create confusion among applicants that do not notify the correct groups within the legislated timelines. This process is particularly cumbersome if the event is small and only involves the incidental use of alcohol.

It is recommended that regulations under the Liquor License Act be amended to better define or remove the requirement for municipal significance. Moreover, the AGCO could reform their administrative process for the permits by either becoming responsible for managing municipal notifications or removing the requirement all together.

Wading Pools and Splash Pads: O. Reg 565 (Public Pools) does not provide a minimum depth of water in the designation of a Class C Wading Pool. Due to this, many water features that would have previously considered splash/spray pads are now classified as wading pools. Class C Wading Pool requirements differ greatly from those of public splash/spray pads and require costly and unnecessary changes to operations.

Costs can be as high as hundred thousand dollars depending on the number of affected facilities a municipality operates. The costs often result from Regulation 565 requiring supervision “whenever the wading pool contains water and is accessible for use” despite many splash pads and wading pools containing no standing water. In most cases, this requirements means hiring at least two attendants to ensure continued supervision while water testing or other required maintenance activities are taking place.

It is recommended that the government review Regulation 565 and implement a range of water depth in the designation of Class C Wading Pools. More specifically, allowing for bodies of water that are 15 centimetres or less to be regulated by Public Health Units as splash/spray pads rather than Class C Wading Pools. 

Marriage License Forms: Municipalities struggle with Ontario’s perforated pre-printed, marriage licence forms, which has been changed little since the advent of computers. There are often unnecessary difficulties around inputting data and printing incompatibilities.

Since many municipalities do not have the IT staff and resources to properly align the forms to print, many complete the forms using typewriters or by hand. This creates multiple opportunities for data entry errors, a time and resource burden for staff, and cost implications often associated with developing and maintaining systems to print the licenses electronically. Applicants may also be impacted as it creates additional wait times (can be anywhere from a few minutes to even days) if there is incorrect data or printer misalignments.

It is recommended that AMCTO, the Office of the Registrar General (Service Ontario), and the Province work to create a common marriage license portal to streamline the application, license issuing, completion of data by officiant and Registrar’s registration.

As recommended in AMCTO’s 2020 Pre-Budget Submission to the provincial government, AMCTO will reach out to its membership in the future to tackle areas of significant burden that are affecting local government administration and service delivery. Any improvements will help ensure movement towards enhancing the efficiency of Ontario’s local governments.



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