Permits correspondence, 2023 - 2024

September 27, 2023

To: Anthony Delaurentis <Anthony.Delaurentis@toronto.ca> Cc: Dufferin Grove Park <dufferingrovefriends@googlegroups.com>; Birko Montinat <Birko.Montinat@toronto.ca>; Jonathan Larkin <Jonathan.Larkin@toronto.ca>; Peter (Park) White <Peter.White@toronto.ca>; Councillor Bravo <Councillor_Bravo@toronto.ca>; Howie Dayton <Howie.Dayton@toronto.ca>; Cheryl MacDonald <Cheryl.MacDonald@toronto.ca> Subject: [External Sender] Question about religious events at Dufferin Grove Park

Dear Anthony,

I hope you can help me find the answer to my question. Last Saturday there was a city-permitted Pagan event at Dufferin Grove that included the sale of various sacred objects and also some public workshops that appeared to be religious instruction, plus at least one time involving what appeared to be a ceremony accompanied by instruments and a callout.

This confused me because I was under the impression that there is a city bylaw prohibiting any religious ceremonies in parks. During my time of involvement with Dufferin Grove there were strong warnings issued to the groups for two religious events: a Scientology folk singing event that included an exhibit of Scientology literature with church members explaining scientology to curious visitors, and a Baptist church hymn-sing with accompanying explanations by their minister.

The Pagan group had their own security guards. Then police attended, after a man objected verbally to the group with the help of a microphone. Then the Pagan group set off their car alarms to drown him out. Then the microphone-guy relocated across the street and resumed. This standoff did not come to blows, but perhaps the bylaw would have prevented the situation in the first place?

Or has the bylaw been repealed?

I have copied this email fairly widely because I assume it may be complicated enough to require public discussion.

Oct 5, 2023 from Paul Szabo

Thanks for your email and for reaching out to Parks, Forestry and Recreation (PFR). I work in the Client and Business Services branch of PFR, and our team oversees permits in City parks. In an effort to provide complete answers to your inquiry, the information below was compiled and confirmed over the past week.

Parks, Forestry and Recreation issued an event permit at Dufferin Grove Park on September 23. I wanted to further clarify that the City of Toronto does permit religious events and ceremonies in its parks.

Toronto's Municipal Code compiles the City's bylaws and arranges them in chapters by subject. Chapter 608 of Toronto's Municipal Code applies to Parks, and this chapter does not include religious ceremonies or events in its prohibited list of activities. Our team also confirmed with Municipal Licensing Standards, who administer and enforce City bylaws, that there is no other bylaw in place that would prevent a religious event in a City park.

In Chapter 608, Toronto's Municipal Code addresses use of loud speakers and amplified sound equipment. The bylaw also details the conditions for which a permit may be required in a City park, including organized gatherings, special events, and festivals.

If you have any additional bylaw questions, please reach out to 311 so that you can be connected with the correct bylaw group to assist in answering your question. If you have further questions regarding permits in City parks, please let me know and I can work to find the information that you are looking for.

Paul Szabo (he/him), Policy and Project Advisor, Client and Business Services, Parks, Forestry and Recreation | City of Toronto. 416-396-7302

---

Nov 9, 2023, to Paul Szabo

to Paul, Christina, Anthony, Councillor

Hello Paul,

I've now had a chance to go through the links you sent, and to study your responses to my questions. I will try to give you some more specific examples to clarify my questions where it seems to me your answers were insufficient.

1 Permit Process:

I asked: Are there specific areas of the park attached to a permit that includes vendors, or can they set up wherever they choose?

You sent a list of what Permits staff review. The items that relate to my question are the layout plan and a list of vendors.

Local example: Several special-event permits this summer/fall set up in close formation along both sides of a main public thoroughfare through Dufferin Grove. This set-up in effect required park users to become attendees at the event without their choosing.

Permit events that are located in this way are in danger of breaching Parks Bylaw 608-3 if they “in any way interfere with the use and enjoyment of the park by other persons.”

Question: did Permits approve those specific layouts? Which areas of Dufferin Grove Park are off limits for permits?

2 Fees:

You referred me to Municipal Code 441, list of fees. I see that the fee for a commercial special event is:

1.0002 Parks Commercial Special Event: City Policy Per Booking $616.88

Questions: Does this mean that all events involving vendors, at Dufferin Grove Park, are charged $616.88 per event, or do you sometimes put such events under a different fee category?

For example, you also have a category called “Parks outdoor stall” with fees ranging from $39.48 to $57.41 according to undefined types A (1.4832) or B (1.4743) or C (1.4833).

And you have a “½ stall” category specific to farmers’ markets (1.8001) for $34.40.

And you have a category called

Community Recreation Outdoor-Parkland – All Groups / All Ages -Vending

ranging in cost from $2,194.76 to $3.669.96 depending on undefined class 1 or 2 or 3 contracts.

Could you let me know on what basis Permits staff determine which vending category number and fee amount you will apply?

And what, exactly, is the service the event organizers in each fee package are paying to get?

3 Monitoring and supervision:

I asked: “Do your staff monitor permits by doing site visits? Can permit holders contact your staff directly for problem-solving if there is a glitch when they set up at the park (i.e in real time, not just during your office hours)?”

I think your answer means NO, am I right? Permits staff don’t monitor to see how permits are set up or are playing out. Did you mean that parks maintenance staff who “conduct routine visits,” are expected to keep an eye on things? (In reality they generally just pick litter if it’s a weekend or after 3pm.) You wrote that Permit holders or unhappy park users can call 311 and be logged for later, (or 911 if there’s danger). Did I understand you right?

4 Communication:

I asked “Are specific permits public information, i.e. the name of the permit holder and the areas/activities included in the permit?”

You wrote that Permits information is considered private, except that Permits staff can say

“there is a permit in place for a given location, time or facility.”

Am I right that this means that park friends and park neighbours cannot be told ahead of time even the name of a group that has a permit, nor what they are proposing to do? Section 608-48 of the Parks Bylaw implies that a permit specifically allows the group – if it wishes – to put up posters describing who they are and what they plan to do. But there is no requirement to let park users know. That information is apparently kept private between the permit applicant and the Permits staff. Please let me know if I misunderstood you.

As I mentioned in my previous letter, my questions are to prepare for opening a Permits conversation between city staff and some park friends from a few neighbourhoods across the city. There are some additional issues that I’d like to ask you about in a follow-up letter, but I’ll wait on that until you’ve had a chance to respond to this one.

Hoping – in the short run – that this letter allows your response to be more specific, and – in the long run – that a helpful conversation develops.

---

Nov 10, 2023, from Nicole Gliwinski, assistant to City Councillor Alejandra Bravo

to Wyndham, me

Thank you for including Councillor Bravo on your email regarding parks permits.

I wanted to let you know that we are organizing a meeting with City staff to answer questions about the Parks permit policies. I will be in touch with further details as soon as we nail down a date and time.

---

Nov 16, 2023, from Paul Szabo

to Christina, Anthony, Councillor, Kevin, me

Hi Jutta,

Thanks for your follow up. Park supervisors and permit officers work to identify, evaluate and approve site plans, including workable layouts and any potential prohibited areas in Toronto parks. This evaluation would consider things like ingress and egress routes or ease of access for delivery, set up and tear down.

The City’s Parks, Forestry and Recreation Client Services staff are available to respond to location specific inquiries and questions regarding permit categories and fees. The Client Services Call Centre is available Monday to Friday (8 a.m. to 5 p.m.) at 416-396-7378, option 2.

City parks staff routinely visit and monitor conditions across the City's parks system and flag any issues when they arise. Residents and permit holders are encouraged to report issues, including violations of City by-laws, by calling 311 or by calling 911 in emergency scenarios.

The City cannot share or distribute personal information that has been collected to process permit applications. The City can disclose the types of activities for which permits are issued and if there is a permit in place for a given location, time or facility.

---

Wed, Feb 7, 2024, to Sandra McCallum, manager of Recreation

to Sandra, Cathy, Cheryl, Sabina, jode, Joël, Christina

Hi Sandra, At the Visitor Economy meeting, you said several times that it would be helpful to specify which permits are a problem, since there are all kinds of permits. I agree, and giving specific examples is certainly our intention. We have a considerable list, citywide, collected from various activist park friends over time. After the Partnership Office meeting tomorrow, we'll want to take the next step and focus in on the permit problems. I think the permits meeting would work better if it includes the Rec director, because of Permits' profound effect on community programming, and so I've copied her here, as well as your colleague Cheryl.

It may be that citywide problems of this kind are ultimately a City Council matter, but it seems to me it's a good idea first to see where management stands on making changes.

I've included, below, an email thread of a previous attempt to engage with Permits directly, which fizzled out. I've added the director of "client and business services" to this email, since she was on the original thread.

We'll be back in touch next week. Maybe there can be a fruitful conversation.

---

Content last modified on October 14, 2024, at 01:22 AM EST