Letter to Attorney General Downey about Civil Rules Changes

Kristyn Wong-Tam

MPP TORONTO CENTRE

March 11, 2025

Honourable Jill Dunlop

Ministry of Education

315 Front Street West, 14th Floor   

Toronto, Ontario 

M7A 0B8

RE: Accommodation in Childcare Licensing Regulations Regarding Temporary Outdoor Play Spaces at the St. Lawrence Co-operative Daycare

Dear Minister Dunlop,

I am writing this letter today regarding a significant concern to families in my riding of Toronto Centre. Specifically, the operator and parents of the children attending the St. Lawrence Co-opertive Daycare has come to me facing challenges in complying with the Ministry of Education’s regulations around outdoor play spaces under the Child Care Centre Licensing Manual and the Childcare and Early Years Act (CCEYA). 

As you know, dense urban communities such as ours in Toronto Centre face unique challenges when it comes to finding adequate and safe space for children’s educational and recreational needs. The St. Lawrence Daycare currently operates within the constraints of limited outdoor space, which is not unusual for downtown Toronto when open space is at a premium cost and deficient in quantity. The daycare is seeking to temporarily expand its outdoor play area to accommodate the growing number of children in their care, yet the regulations, particularly the interpretation of the requirement for “permanent” outdoor space, have presented a significant roadblock for the St Lawrence community.

Parents and daycare workers have been in contact with the Ministry’s Interim Program Advisor, Kristal Sotelo. She conveyed to the daycare manager that despite their best efforts, there is no flexibility within the regulations that would allow for a temporary outdoor play space. While the safety and quality of our children’s care should not be considered lightly, this rigidity has halted the expansion and opening of the St. Lawrence’s Daycare outdoor space. This means that dozens of our children are not getting the care they need, and parents are not getting the support they need. Keeping parents and children out of affordable daycare spaces is not in the best interest of the children and families who rely on this essential service. 

The Childcare and Early Years Act (O. Reg. 137/15) does not explicitly require that  "designated spaces" need to be permanent. This legislation, as outlined in Section 24, mandates that outdoor play space must meet certain size requirements, but it does not specify the permanence of ownership or lease agreement or location. The Act allows for Director approval of alternatives, including smaller or non-adjacent outdoor spaces or the use of rotating schedules to accommodate outdoor play, however. Flexibility is key to ensuring that daycare centres in urban areas can continue to provide safe, functional spaces for children. 

Right now, the St. Lawrence Daycare operates under a lease agreement with the City of Toronto that expires in 2027. While this lease is secure for the time being, the daycare’s current outdoor play space is not sufficient to meet the needs of the growing community. Expanding the play area would allow the daycare to accommodate more children and provide a safe and functional space for outdoor play. Due to the Ministry’s staff rigid interpretations of the regulations, this plan cannot be realized unless exceptions are made. 

There has been a growing concern across Ontario about the availability of affordable childcare. We have seen reports of daycares unexpectedly closing, leaving parents scrambling to find alternative care. Many centres are forced to reduce their capacity due to lack of appropriate space. These closures are particularly damaging to families in urban areas like ours, where access to childcare is already limited. 

Given the urgent need for more daycare spaces in our community, I respectfully ask that you review this case and consider making an exception to the regulation. Allowing for a temporary outdoor play space, or providing greater flexibility for daycare centres in urban areas to meet the requirements of the Act, would help ensure that families can continue to rely on daycare services without the added concern of losing their place in line.

For these reasons, I urge you to consider this request and provide a response, as it would have a lasting positive impact on the well-being of children and families in Toronto Centre and other urban ridings facing similar challenges. If you have any additional questions, contact my office at [email protected] or 416-972-7683.

Respectfully submitted, 

Kristyn Wong-Tam

Member of Provincial Parliament for Toronto Centre

120 Carlton Street, Suite 401

Toronto, Ontario

M5A 4K2 

TORONTO — The Supreme Court of Canada has struck down Doug Ford’s unconstitutional law to limit third party campaign spending. Ford used the notwithstanding law to limit participation from teachers, health care workers, families, labour unions in elections and used taxpayer dollars to continue fighting them in court.

NDP Critic for the Attorney General MPP Kristyn Wong-Tam has released the following statement in response to the ruling:

“Doug Ford is handed yet another defeat in court after he wasted more taxpayer dollars fighting to silence critics and defending unconstitutional laws. Ford is all too quick to pull the trigger on the Notwithstanding clause, especially if it means targeting those impacted the most by his record of bad policies and cuts – like teachers, health care workers, families, unions, and more.

Ontarians deserve a healthy democracy where they can cast an informed ballot. Civil society is a core pillar of Ontario’s democracy that should be allowed to flourish and engage in our elections. This defeat should be a wake-up call for Ford.”

Background note:

The Auditor General’s latest report into government advertising shows $103.5 million spent on government advertising in 2023-24 alone, a significant portion of which was spent on promoting ‘the governing party.’