Dear Mayor Tory,
First of all, I want to thank you for taking the time to speak with the Director and myself last week. More than ever, it’s important that the Toronto District School Board and the City of Toronto work together as we continue to navigate our way through uncertain times. As requested, below you will find more information about a number of challenges we are facing and how we think you may be able to help, including those related to Site Plan Approval (SPA), by-law enforcement and child care.
Site Plan Approval (SPA)
A number of our projects are being delayed due to the length of the SPA process, including how new and costly issues are raised in later submissions, which could have been addressed earlier on in the process yet are only brought up in later submissions. This has resulted in significant costs from both a time and financial perspective on projects that we believe are not overly complex (i.e. rebuilding schools on sites zoned for schools). For example, we submitted our initial SPA for the rebuild of Bloor Collegiate in February 2018, about 27 months ago, and it has yet to be approved. After four rounds of reviews and comments, we are stalled on the following issues, which have delayed the construction by 12 – 18 months so far:
- Easement – Recently, City Planning staff indicated that Toronto Water required a 9 meter easement over the Garrison Creek Sewer line. This easement would encroach on our existing building design and, if not altered, will require us to redesign the building to remove the overhang at the north east corner. We believe that the existing design allows sufficient space for future sewer remediation work to occur and that should be reflected in the SPA submission; and
- Storm Line – Recently, Engineering and Toronto Water requested that the site's storm line connect to the storm sewer at Dufferin. This is not viable due to the difference in storm sewer elevations and lack of capacity of the Dufferin sewer. We are requesting to connect the site's storm line into the existing combined sewer, on our site, similar to pre-existing condition.
On both of these issues, we are asking for flexibility and the agreement that we can move forward with the solutions outlined above. If not, the project will incur further delays leaving more than 800 students without a school and significant design and engineering related costs.
Unfortunately, this is not the only project that has been delayed due to the SPA process. Other recent examples include:
- Avondale Elementary School – SPA: 26 months; Cost Impact: $1,350,000+
- Lawrence Midland Secondary School / David and Mary Thomson Collegiate Institute – SPA: 37 months; Cost Impact: $1,800,000+
We are seeking your help to expedite the SPA process to help reduce the number delays and associated costs for our projects. For more examples and information, please see the attached document, Major Site Plan Approval Impact on Capital Projects.
Recently, we have been having issues with by-law officials not enforcing by-laws at our schools and administrative sites. We have been told that these officials do not have any authority on our property because it is private property; however, from our understanding, the emergency order gave by-law officials the authority to enforce measures like physical distancing. We hope that you can provide clarification on this matter and offer the assistance of by-law officials to keep our communities safe during this time.
Outside of the current health crisis, we would also like the assistance of by-law officials to help with resident complaints, such as dogs running at large on our property.
There is a general feeling of instability and uncertainty about the future viability of child care, authorized recreation and before-and after-school programs in Toronto. For the TDSB, budgetary and red-tape challenges continue to impact our planning for these programs.
For example, we have our own before-and after-school program called Extended Day Programs; however, we rely on Toronto Children’s Services to approve the annual budget for such programs. The budget approval occurs before we are made aware of how much funding will be provided for each child on a subsidy, which affects the daily rate. The gap in funding between the daily rate and the fee subsidy grant often contributes to an operating deficit. We believe that this process, especially related to budget and information sharing, could be more effective if it was more flexible and collaborative.
As you know, the City of Toronto offers Afterschool Recreation Camps (ARC). These programs are often located in schools and cannot move locations without Council’s approval. These programs are a cost-effective alternative to afterschool licensed child care programs. We would ask you to consider expanding these programs if there is a need and that City staff be given greater latitude to change locations based on changes in demand to better respond to community needs.
We are also seeking confirmation that the City will continue to fund the occupancy grant for child care leases as was previously decided by Council and whether funding for EarlyON Programs will continue.
Overall, there are a variety of risks and challenges faced by local child care operators and the TDSB in relationship to the possible impact of the Emergency Closure on child care and early years programs. We will share additional information as our contingency planning evolves.
Once again, thank you for taking the time to listen to our concerns and for your openness on how we can move forward together on a number of items. I also want to thank you for connecting us with Saad Rafi. I found our conversation beneficial as we all look toward next steps in the gradual reopening of the city. As always, please don’t hesitate to contact me to discuss anything further.
Robin Pilkey, CPA, CA, ICD.D
Chair, Toronto District School Board