Every once in a while Town staff seems to ‘put a foot in it’. The latest example is the Draft Special Event Planning and Policy Guide. It replaces a 3 page document dating from 1993 with one that comes in at about 50 pages. It caused ripples of shock and consternation among community volunteers when it came forward to Council. The public comments gave me the impression that there was little or no prior consultation with people who would be directly affected.
I can imagine this draft Guide being used instead as a case study at a university somewhere as an example of classic bureaucratic group-think. It’s not so much the content but the language and the approach behind it. Here’s what I noticed:
An Internal Focus
“The proposed changes would streamline the process of getting a Special Event Permit within the Town of Innisfil.”
The focus is on creating a single point of service within the Town administration for event planners. A Community Events Team (CET) would review applications, obtain response from affected departments and provide a custom checklist of requirements (permits, inspections, certifications, fees and insurance) to obtain an event permit. From an administrative view, streamlining means more uniform compliance, better enforcement, and improved ‘cost recovery’. But it is also the most short-sighted approach to something that is a key component of the Inspiring Innisfil 2020 strategy. ‘Streamlining’ internally may be a necessary first step but organizers were looking for streamlining that would effectively encourage and support more community events.
No Added Clarity
- Minimum application notice is 120 to 150 days. A penalty fee is proposed if the application is within 90 days of a planned event but the timeline to secure a permit is actually left open and indeterminate – “Depending on the event specifics, 120-150 days (or more depending on event specifics) may be required …” This sentence appears 3 times in the Guide.
- “The Town requires a minimum of $5 million liability insurance for each special event… specific activities may require additional insurance.”
- “Damage deposits are based on the proposed activities and anticipated attendance. A damage deposit is typically between $500 to $10,000 for each site/facility used for an event and is calculated based on the information provided …”
- It’s not clear how the permit process applies to some events on private property: (“Events that are open to the public which are not currently zoned for special events.”) How would this affect an annual Studio Tour or a garden tour? Would you count 100 attendees in total, or 100 attendees per location?
Emphasis on Enforcement
A bylaw is a law after all. The ‘need’ was defined in terms of enforcement so it’s logical that that’s where the emphasis is.:
“Currently, there is some variation in the way permits are issued for events which have resulted in some events taking place without sufficient regard for health and safety requirements, permits or insurance.”
Four references are made in the Guide to shutting down an event due to non-compliance. What’s missing is any suggestion that Town staff are interested in helping to make your event a success. Experienced event organizers who attended the Council meeting felt that some requirements were more onerous than any other jurisdiction. For instance, think about that common hot-dog fund-raiser in the parking lot, or the volunteers’ ‘thank-you’ BBQ on Pitch-In Day. Besides an event permit, you’d need a permit from the Simcoe Muskoka District Health Unit, a Propane Safety Certificate from a certified gas fitter for the BBQ, and if you plan to serve more than 200 people, having a paid and certified First Aid Provider on standby “is recommended”.
People were surprised to hear that the Building Code requires a building permit “for a tent or tents with a combined floor space of over 60 square meters in size” [645 sq. ft.]. It might have been better to simply say that any tent structures of 60 square metres or more are not recommended.
My feeling is that this document – or an outline of it – should not have originated within the confines of Town Hall at all. One of the stated objectives of Inspiring Innisfil 2020 was to let residents become more engaged in the objectives of the strategic plan allowing local organizations to take greater ownership of community activities. As part of that process, an agonizing amount of time was spent creating and organizing an Arts, Culture and Heritage Council. Would it not have made more sense to let the AC&H Council and members prepare an initial draft with Town staff acting as coordinator and liaison with regulatory agencies such as fire, police and public health? If the process had started with a community members’ wish list of events it might have created an ambitious goal to work toward and challenged everyone to consider how it could be reasonably implemented.
Instead we’ve been handed a catalogue of legal, regulatory, financial and liability hurdles that essentially dares potential organizers to surmount them. There is a big disconnect in this document and its stated objectives.
If streamline means “to improve the efficiency of a process, business or organization by simplifying or eliminating unnecessary steps…” it wasn’t clear how that is being achieved. The notice of scheduled public meeting to review and discuss the Special Event Planning & Policy Guide is a little more specific:
- the permit process applies mostly to events on Town property
- events of less than 100 people would not require a permit
- an event in a rented facility (ex. hall, library) usually does not require a separate permit (Town of Innisfil Hall Rentals & Fees)
- the existing mandatory fee of $100 is open to revision
- municipal Customer Service will act as a one-stop service centre
The biggest concern was the proposal to require up to 150 days notice (or more) of a proposed event. With many events scheduled for the summer months, this would effectively rule out a lot of them this year. Some felt multiple fees and permits could price their event out of existence.
Is it any easier anywhere else to organize a major community event? Probably not, judging by the events page at the City of Toronto where they do events big time. But it does suggest ideas for some other helpful resources that could be provided here:
- A planning & permit flow chart based on event specifics; for instance, Is your event on town property or private property?; Do you expect 100 or more attendees?, etc.
- A quick reference guide to regulations and permits such as this Toronto Quick Reference Chart
- A sample event timeline for securing permits and approvals (Toronto provides four different event examples)
- A directory of local service providers with event experience
The Council agenda helpfully notes that this Draft Special Event Planning and Policy Guide was:
- prepared by the Development and Marketing Coordinator,
- reviewed by the Economic and Community Development Officer, and
- approved for submission by the Director of Economic Development, and the Town Clerk
Wow. That’s a lot of expertise.
There’s room for some ‘bottom-up’ as well as ‘top-down’ participation in this process. It may be a big opportunity, I think, for the Innisfil Arts, Culture and Heritage Council to step into the void and act as consultant, advisor and facilitator for any ‘newbies’ who think they might want to organize a community event in Innisfil. A public meeting is scheduled for Thursday, February 21 at the Town Hall to review and discuss this Guide. Town staff are going to receive the community input that should have been the starting point of this process. Is that a victory for Inspiring Innisfil 2020? And you can expect some revisions to that draft Policy Guide.