A NEW MUNICIPAL ACT FOR ONTARIO: WHAT TO EXPECT

By Qunito M. Annibale

INTRODUCTION

Ontario municipalities are on the verge of change which will be unprecedented in the history of municipal governance since the enactment of the Baldwin Act in 1849; change more profound even than the radical fiscal restructuring that almost all municipalities have had to undergo recently. By this time next year, Ontario municipalities should be preparing to hold municipal elections pursuant to new electoral rules which are to be enacted within the next 2 months and will be learning to adjust to new legislative and administrative tools contained in a new Municipal Act which is to be enacted in the spring or summer of 1997.

In October 1995, the government announced the creation of an "Advisory Group on Municipal Government Reform" which is to make recommendations to the government as it seeks "to make meaningful reform to municipal structure and to legislation regulating municipalities".¹ Ernie Hardeman, MPP for Oxford was appointed chair of the Advisory Group, which colloquially came to be known as the "Hardeman Committee".

In keeping with the philosophy of the Mike Harris government, the Committee was given a short time frame within which to act and make recommendations. The timetable was ambitious to say the least. The Committee was to have reported back to the government in time to permit enactment of a new Municipal Act in the fall of 1996 and well in time for the 1997 election.

Also in keeping with the philosophy of the current government, the Committee’s mandate did not provide for any kind of meaningful public consultation, at least not the kind that had become the norm in Ontario in recent years, leading up to the NDP planning reforms of the early 90s. In keeping with the experience of Ontario governments generally however, draft legislation is not yet available (at the time of writing of this paper). Given the magnitude and importance of the task which the government has undertaken, the inaccuracy of the government’s prediction with respect to timing was, to say the least, predictable.

The Committee’s work was to have parallelled the work of Anne Golden’s "GTA Taskforce" (the "Golden Commission" and presumably reforms in the structure of government and the delivery of service within the GTA would be accompanied by legislative changes for the whole of the province in the form of a new Municipal Act. As noted below, the government has since expressly indicated an intention to deal with assessment reform, one aspect of the Golden Commission’s review as part of the ongoing reform initiative. However, we can only presume that the balance, government structure and methods of service delivery, will also be dealt with in due course as part of the same process.

"WHO DOES WHAT" PANEL ("WDW")

The work of the Advisory Group appears to have been unceremoniously subsumed into the mandate of yet another advisory group in the middle of this year. On May 30, 1996 the Government announced the creation of a new "panel" which was charged with the much broader responsibility of clarifying the role of various governments in Ontario and determining "who does what". Thus was born the "Who Does What" Panel (the "WDW"). The panel was asked to review every area of responsibility shared by the province with municipalities. Specifically, the mandate of the Panel was to eliminate duplication and over-regulation and divide responsibilities (in philosophy, similar to the "disentanglement" exercise of 1993) among levels of government.

The Hardeman Committee has not been disbanded and continues to do its work. The WDW mandate indicates that the panel will "build on" the work already (and continuing to be) done by the Hardeman Committee.² The Hardeman Committee appears now to be acting in an advisory capacity to the WDW, and many of the ideas and recommendations of Hardeman are being incorporated into the WDW recommendations.

However, it seems that the primary responsibility of Hardeman continues to be recommending what the new Municipal Act will look like (i.e. how the province will grant power or responsibility to the province) and the WDW will determine (recommend) what those powers should be.

David Crombie, former mayor of Toronto and former federal cabinet minister, was appointed chair of the now 14 member panel. Membership on the panel consists of elected and appointed municipal officials and politicians.³ The panel consists of a number of "sub-groups" of panel members, each charged with responsibility for a particular area or areas of jurisdiction. To date, 5 "sub-panels" as they are now called have been constituted. They are:

A sixth panel on Education is scheduled to be established shortly. What follows is a brief discussion of the mandate, and a summary of recommendations to date made by each sub-panel.

This sub-panel was charged with the responsibility of reviewing the plethora of information already undertaken on behalf of government with respect to reforming the property tax assessment system in Ontario. As mentioned above, the sub-panel is reviewing the recommendations of the Golden Commission on tax assessment and will recommend to government the most appropriate province wide system of assessment. All indications are that it will recommend some form of Actual Value Assessment based on the British Columbia model. The government has indicated that tax assessment will be given a priority because of the crisis in assessment in Ontario.⁴ One fact that both critics and supporters of the government’s reforms agree upon is that the current system is broken and needs fixing.

Either this sub-panel or the sub-panel dealing with Education will deal with the issue of how our school system should be funded (should it be funded through the municipal tax system? should assessment revenue be pooled?). Already the government has indicated that one option being considered is the abolition of school boards and the setting of curriculum by the province, with some input at the local level. Locally elected municipal representatives seem like good candidates for this role.

On August 20, 1996 this sub-panel reported to the Minister with the following specific recommendations:⁵

iv) exempt properties;

This panel is attempting to unravel and clarify responsibilities and jurisdiction for utilities, roads, transit, sewer and water. With respect to roads, it is rumoured that responsibility for all but "4-series" highways in Ontario will be devolved to municipalities.

In an interim report,⁶ this sub-panel has already recommended that municipalities be given responsibility for the inspection and approval of septic systems. The cost of undertaking this function will be recovered from applicants (a continuation of the "user fee" reforms contained in Bill 26⁷) and all provincial subsidization of this function will end. The government has recognized a continuing provincial interest in ensuring minimum health and environmental quality standards, monitoring of the quality of the overall environment and in ensuring a consistent quality of septic system installation across the province. Therefore, the sub-panel has recommended that the province continue to be responsible for the licensing and certification of septic system installers.

In the area of community transportation, the sub-panel has endorsed the recommendations of the Community Transportation Action Program (CTAP) of the MTO to assist communities in co-ordinating and integrating transportation services (school buses, public transit, disabled transit and ambulances).

The sub-panel has given a preliminary endorsement to the principle of municipal jurisdiction over the treatment of sewage and water.

It is also expected that this sub-panel will make recommendations on GO Transit and ferry services.

3. Municipal Administration

This sub-panel will look at all aspects of municipal administration, including provincial offences, the Ontario Building Code and Act, and labour relations. This sub-panel has already made some significant and far reaching recommendations with respect to municipal legislation (discussed below).

Generally speaking, this sub-panel has recommended flexibility in the legislation, less provincial regulation and removal of the need for complex provincial legislation to authorize municipal action in an increasingly complex local environment. In tandem with this, the panel is recommending that the philosophy of allowing municipalities to develop and access new sources of revenue, commenced with the expansion of user fee powers in Bill 26, will be expanded. Since many of the WDW recommendations appear to be "down loading" new areas of service delivery to municipalities, new sources of revenue must be found.

In order to have legislation in place for the November 1997 Ontario municipal elections, the government has indicated it will be phasing Municipal Act reform. Phase 1 will consist of new electoral rules, which must be in place by January 1, 1997 to be effective for the next election. This legislation is to be introduced this fall. The balance of the reforms (Phase 2) are now scheduled for legislative introduction in the spring of 1997.

Some⁸ of the more significant recommendations of this sub-panel are:

a. Legislative

A new Municipal Act giving municipalities "natural person powers" for the purposes of carrying out administrative functions and granting legislative authority on the basis of the "spheres of jurisdiction" model (as done in the Municipal Government Act of Alberta (the "MGA")⁹) rather than the "prescriptive grant of authority" model as in the existing Act, is proposed. This model of legislation is discussed below. It is intended that the new act will also result in new powers of taxation and regulation.

b. Municipal Elections

c. Other Phase I Recommendations

d. Debt and Investment

e. Pensions

The Minister has indicated that the government will not be moving on the recommendations of this sub-panel on pensions in the first phase of amendments (for this fall).¹³ The reason given is that these recommendations will be reviewed when the government moves to reform pensions in general.

f. Municipal Liability

Of greater interest to municipal lawyers will be this sub-panel’s recommendations with respect to municipal liability. Over the last decade, we have seen the increasing exposure of municipalities to liability and the erosion of municipal statutory and common law defences in our courts. The sub-panel on Municipal Administration has made some significant recommendations in this area:

ii) Joint and Several Liability

iv) Negligence Liability for Discretionary Functions

The sub-panel has made the following recommendations with respect to Provincial Offences:

4. Emergency Services

This panel will examine the delivery of emergency services, including police, fire and ambulance services. Presumably the issue of whether the delivery of fire services at the local level is the model for the future (especially in the Metro and many regional municipalities where there are a number of local departments providing firefighting services). To date, no specific recommendations have been released by this sub-panel.

5. Social Services

This panel will examine the role of the province and municipalities in the delivery of social services, including social assistance, employment services, public health, homes for the aged, child care, child welfare and social housing. To date, no specific recommendations have been released by this sub-panel.

However, left vague (purposely, I think) in all the recommendations of the WDW panel is a clear indication as to which level of municipal government (local or upper tier) will be responsible for these new areas of jurisdiction. Presumably this will be made clearer when the government announces its intentions with respect to the restructuring of municipal boundaries and responsibilities as between local and upper tier municipalities (if any). It is expected that the Golden recommendations will be dealt with at that time.

ALBERTA’S MUNICIPAL GOVERNMENT ACT: THE MODEL FOR ONTARIO?

Although neither the press releases surrounding the WDW recommendations, nor the recommendations themselves indicate so, there appears little doubt that the new Municipal Act for Ontario will be modelled on the MGA of Alberta and the principles of "natural person powers" and "spheres of jurisdiction" (certainly both the press releases and the recommendations do say that the concepts of natural person powers and spheres of jurisdiction will be adopted). This conclusion is inescapable given the similarities between the language used and the concepts being put forward in Ontario and those which came to the fore during the development of the MGA. For example, when making recommendations with respect to a new Municipal Act for Alberta, the Municipal Statutes Review Committee expressed a concern about the potential of the natural person power approach; it foresaw that some restrictions would be necessary in relation to other municipalities, the province and the general public interest.¹⁶ In the August 14, 1996 recommendations of the WDW sub-panel on Municipal Administration, the following statement appears:

As a result, the Committee recommended, and the legislature adopted, the safety net (from the province’s point of view) provision that the natural person powers and spheres of jurisdiction would be subject to any limitation set out in provincial legislation. Ontario appears poised to do the same.

In order to get a feel for how the new Ontario Act will be drafted, it is useful to review the principles underlying the MGA and the structures of the Act itself. Since the Act itself was adopted in 1994 and proclaimed in force as well as amended in 1995, there is not a lot of jurisprudence available to guide us in predicting how the courts in Ontario might interpret these new powers. The decisions rendered since the MGA came into effect are listed in Appendix "D". Unfortunately, they are not terribly insightful in understanding the new concepts in the MGA and amazingly, none of the cases deal with a challenge to the natural person powers or spheres of jurisdiction approaches.

The Process

The legislation which pre-dated the MGA in Alberta was enacted in 1967.¹⁸ In the 1986 Speech from the Throne, the Alberta government of the day committed itself to a review of the MGA and related legislation. In 1987, the government established the Municipal Statutes Review Committee, which embarked on a seven year process, culminating in the enactment of the MGA in 1994.

By contrast, the Ontario Municipal Act finds its origins in the Baldwin Act of 1849. The provincial government established the Advisory Group on Municipal Government Reform almost exactly one year ago and gave it a mandate to recommend a new Municipal Act for introduction into the Ontario legislature within one year (by now). Quite a difference in timing.

The Approach

As mentioned, the MGA adopts the "Natural Person Powers" and "Spheres of Jurisdiction" principles of delegation of powers. The majority of municipal legislation in Canada is what is referred to as "prescriptive" in nature meaning that it prescribes in detail all of the powers of a municipality. In Ontario, and in most provinces, a municipality is established as a "creature of statute"¹⁹ and therefore has only those powers which are expressly granted to it or which can necessarily implied or are necessarily incidental to the express grant.²⁰

The Municipal Act of Ontario contains precious few broad grants of power and those that do exist (such as the health, safety, morality and welfare provision contained in the current Section 102 and the authority to abate public nuisances in Section 210, paragraph 140) have been narrowed by the courts to the point where they are almost²¹ meaningless. Thus, municipal legislation has ballooned to some 150 separate pieces of legislation²² taking up over 1400 pages in the provincial statute books. The current Ontario Act sets out in "mind numbing detail",²³ what powers a municipality has and the areas in which it may legislate. While the MGA does many other things, this paper will primarily review the provisions of the MGA related to the concepts of Natural Person Powers and Spheres of Jurisdiction.

General

The MGA itself is quite lengthy, consisting of some 645 sections when it first came into effect, and 740 sections when the 1995 amendments came into effect (in May of that year). The length of the Act is largely due to the fact that it contains most of the legislation applicable to municipalities (including planning which was added in 1995, the establishment and operation of public utilities, access to information, property assessment and taxation, a planning appeal tribunal (the Municipal Government Board) and matters of expropriation). A complete index of the 1994 MGA is set out in Appendix "A". Parts 1 and 2 of the MGA set out how the concepts of natural person powers and spheres of jurisdiction are to work. Part 3 of the MGA contains additional powers which the drafters of the legislation felt that the grant of natural person powers did not give to municipalities, in addition to the inability to make laws (covered by Section 7 spheres of jurisdiction approach). As well, Part 3 contains the limits on the grant of natural person powers which the drafters felt were necessary because they might be interpreted as having been included.²⁴ Therefore Part 3 includes the power to expropriate, the power to regulate and manage roads, the power to tax, the ability to provide services in other municipalities and the power to declare public holidays. We also see restrictions on the disposal of land, the acquisition of mines and minerals, the acquisition of land beyond the municipal boundaries, the control of for profit corporations and the regulation of firearms.

These sections are the culmination of a process in which the drafters of the MGA reviewed all of the existing legislation applicable to municipalities and made a determination as to whether the existing power or authority would be included in the grant of natural person powers or fall within one of the general spheres of jurisdiction. It also had to undertake the opposite exercise of trying to anticipate all of those new powers that a general grant of authority and a grant of natural person powers would give to municipalities. This was necessary to determine if such a grant of authority needed to be specifically restricted in this or another provincial act. If the MGA model is adopted in Ontario, legislative counsel at Queen’s Park will have to undertake the same monumentous task with respect to the 1400 pages of municipal related Ontario legislation.

Natural Person Powers

Broadly stated, the "natural person powers" concept reverses the concept of "prescriptive" delegation of authority by giving to municipalities all of the powers and capacity of a natural person. Thus, the municipality is given the power to enter into contracts, deal with all matters of an administrative nature, buy and sell goods and services, buy and sell land, hire and fire employees, make investments and borrow money. However, as a natural person, a municipal corporation does not have the power to make laws. Therefore, "natural person powers" are intended to give municipalities greater latitude in its ability to act administratively. Flexibility is achieved by the grant of "spheres of jurisdiction", rather than specific prescriptions of power (discussed below).

Section 6 of the MGA reads as follows:

Sub-section 1(1)(t) of the MGA defines "natural person powers" as "the capacity, rights, powers and privileges of a natural person". "Natural person" however is not defined in the MGA, nor is it defined in the Alberta Interpretation Act. The latter does however define "person" to include a corporation. The Ontario Interpretation Act is similar.

Therefore, it will be left to the common law and the courts to determine the full extent of the "natural person" powers, based presumably on the plain and ordinary meaning of the words.

Also of relevance is Section 4 which states "A municipality is a corporation".

Spheres of Jurisdiction

Section 7 of the MGA sets out the 9 general spheres of jurisdiction. It reads as follows:

Upon review of Sub-section 7(a), one sees obvious similarities between the language used and the language used in Section 102 of the existing Ontario Act, which reads as follows:

As we know, the courts have over the years gradually narrowed the ability of municipalities to rely on Section 102 as a grant of substantive powers to the point where Section 102 now has more symbolic meaning than anything else.²⁵ This leads to the obvious question of what then is to prevent the courts from interpreting the spheres of jurisdictions in the same manner that the Ontario courts have interpreted Section 102?

The answer lies in the language of Sections 8 and 9 of the MGA. In these 2 sections the MGA drafters have attempted (just as they did in Part 3 with the grant of special powers in addition to natural person powers on the one hand and the restrictions on the general grant on the other) to strike a balance between flexibility and control. Section 8 sets out how the powers of Section 7 are to be utilized. It enumerates, with greater clarity the full extent of the by-law making power granted by Section 7. It provides:

By contrast, Section 3 sets out what the "municipal purposes" mentioned in the pre-amble to Section 7 are meant to be. It sets out the larger parameters of the spheres of jurisdiction. It reads:

Despite the pronouncement in Section 4 that the municipality is a corporation and the broad grant of natural person powers in Section 6, it is Section 3 that ensures that these powers will be exercised for municipal purposes only. In this way, the municipality will not have all of the powers of a business corporation, nor all of the powers of a natural person. However, within the sphere of municipal purposes, it will share all of the characteristics of those two entities (or concepts).

The only other restrictions on the by-law making power are found in Sections 10 (conflicts with by-law making powers granted by other statutes), 12 (applicable within municipal boundaries only (with exceptions) and 13 (which gives paramountcy to provincial legislation).

Necessity of a By-law: Natural Person or Sphere of Jurisdiction

Traditionally, municipalities have been granted authority to do some things specifically by by-law only, some things by resolution and some things by either method. Section 180(2) of the MGA attempted to clarify this distinction by providing that:

However, this section created a problem because of the very fact that natural person powers were intended to remove the requirement of specific statutory or by-law authority for acts considered to be of an administrative nature. The issue arises²⁶ when there is an overlap between an act authorized under natural person powers and also authorized under the spheres of jurisdictions. For example, the natural person power to hire, fire and remunerate employees might overlap with the sphere of jurisdiction power to run a public transit system.

Section 180(2) might be interpreted to mean that the hiring or firing of employees of a Transit Commission might require a by-law. Section 11 solves this problem. It provides:

Thus, the hiring or firing of employees in this scenario could be done by by-law or resolution or could be delegated to the Chief Administrative Officer.

Generally speaking, it appears that natural person powers can be exercised by council by either by-law or resolution or may be delegated to the Chief Administrative Officer. Spheres of jurisdiction powers, generally speaking, must be exercised by council, by by-law only, unless it also involves the exercise of a natural person power, in which case the Section 11 exception mentioned above kicks in. This seems to be the combined effect of Sections 202, 180, 11, 7 and 6 of the MGA.

CONCLUSION

The balancing act of competing interests demonstrates how difficult moving away from a system of prescriptive grants of power can be. The effectiveness of the drafting will remain to be seen. While a number of decisions, both reported and unreported, have been given by the Alberta courts under the new act, few of them really test the effectiveness of the new approach (evidence either of the superb drafting or the relative newness of the legislation (a combination of both I think)).

While the radical departure in approach of MGA probably will make it "the model for municipal legislation in Canada well into the next century, just as the Ontario Act has been the model for this century",²⁷ the MGA did not go so far as to grant municipalities constitutional status, nor did it even adopt the plenary powers approach (i.e. municipalities authorized to legislate in any field in which the province is competent to legislate and in which it has not). These approaches have been advocated by a number of people or organizations over the years.²⁸ It stopped short of both of those more extreme models of local governance. Notwithstanding, it appears so far to have worked for the province of Alberta. Whether it can be effectively harnessed in Ontario will be seen shortly. I think it is safe to say that, in Ontario at least, there is very little, if any consideration being given to either of the constitutional or plenary power models. I believe a constitutional amendment for municipalities is out of the question and I think the granting of the kind of power inherent in the plenary powers approach is politically out of the question given the population skews in the Greater Toronto Area, as compared to the rest of the province. It has been long said that the province would never create a local authority with as much (or nearly as much) power as itself. If that is true, the best we could hope for as municipal solicitors is an act modelled on the Alberta Act.

1. Terms of Reference of the Advisory Group on Municipal Government Reform (October 18, 1995, Minister of Municipal Affairs at the 1995 Annual Conference of Association of Municipalities of Ontario).
2. Memorandum from David Crombie, Chair, "Who Does What" Panel and Peter Meyboom, Chair, Municipal Administrations Sub-panel to The Honourable Al Leach, Minister of Municipal Affairs and Housing containing recommendations of the sub-panel on municipal administration, August 14, 1996.
3. "Who Does What" Panel Members: David Crombie, Chair, William F. Bell, Mayor, Town of Richmond Hill, Gordon Chong, Councillor, Municipality of Metropolitan Toronto, Morley L. Daiter, Chief Administrative Officer, City of North Bay and President, Ontario Good Roads Association, Grant Hopcroft, Deputy Mayor, City of London and Member of the Advisory Group on Municipal Government Reform, Giséle LaLonde, former Mayor the City of Vanier and former Chair of the Ottawa Roman Catholic Separate School Board, Steve B. Lowden, past President at Metropolitan Toronto Board of Trade and Vice-Chair of Sobeco Ernst & Young, Hazel McCallion, Mayor, City of Mississauga and Chair of the Greater Toronto Area Mayors' Committee, Tom McCormick, Consultant and President of Strategic Projections Inc., Peter Meyboom, Interim Chief Administrative Officer, City of Ottawa and Principal of P. Meyboom Consulting Services Inc., Marion Millman, Reeve, Township of Yarmouth and Second Vice-President of Ontario Good Roads Association, Enid Slack, Economic Consultant and President of Enid Slack Consulting Inc., Douglas Pearcy, Reeve, Village of Norwood and Warden of Peterborough County, Terry Cooke, Chair, Region of Hamilton-Wentworth.
4. The Honourable Al Leach, Minister of Municipal Affairs and Housing in the Ontario Legislature, May 30, 1996.
5. Letter from David Crombie, Chair, "Who Does What" Panel to the Minister of Municipal Affairs and Housing dated August 20, 1996 setting out the second report from the "Who Does What" Advisory Sub-panel on assessment and property tax reform.
6. Letter from David Crombie, Chair, "Who Does What" Panel and William F. Bell, Chair, Transportation and Utilities Sub-panel to The Honourable Al Leach, Minister of Municipal Affairs and Housing dated August 14, 1996 containing the status report of the Transportation and Utilities Sub-panel.
7. Now section 220.1 of the Municipal Act, R.S.O. 1990, c. M.45.
8. Memorandum from David Crombie, Chair, "Who Does What" Panel and Peter Meyboom, Chair, Municipal Administration Sub-panel to The Honourable Al Leach, Minister of Municipal Affairs and Housing dated August 14, 1996 containing recommendations of the sub-panel on municipal administration; the balance of the recommendations are contained in Appendix "E".
9. Municipal Government Act, S.A. 1994, c. M-26.1, as amended by the Municipal Government Act, 1995, c. 24.
10. Minister Leach's letter to all heads of council dated October 14, 1996 under cover of the Ministry of Municipal Affairs and Housing, Office of the Minister.
11. Trustee Act, R.S.O. 1990, c. T.23.
12. Ontario Municipal Employees Retirement System Act, R.S.O. 1990, c. O.29.
13. Minister Leach's letter to all heads of council dated October 14, 1996 under cover of the Ministry of Municipal Affairs and Housing, Office of the Minister.
14. Ibid.
15. Fines and Forfeitures Act, R.S.O. 1990, c. F.13.
16. Forgrave, Tom, The Alberta Municipal Government Act: How We Got There, Canadian Institute for the Administration of Justice, Regulations and By-laws; Real Laws in the Real World, November 27-28, 1995, Ottawa, page 12.
17. Memorandum from David Crombie, Chair, "Who Does What" Panel and Peter Meyboom, Chair, Municipal Administration Sub-panel to The Honourable Al Leach, Minister of Municipal Affairs and Housing dated August 14, 1996 containing recommendations of the sub-panel on municipal administration; the balance of the recommendations are contained in Appendix "E".
18. Municipal Government Act, S.A. 1967.
19. I. MacF. Rogers, Q.C., The Law of Canadian Municipal Corporations (2d) Carswell 309.
    
20. Ibid.
21. For example, Section 102 has been held by the courts to be insufficient authority for the enactment of a by-law regulating gambling devices (Re Morrison and the City of Kingston, [1938] O.R. 21 (C.A.) (1932)). An example of where the provision has been successfully used is Re Weir v. R. (1979), 26 O.R. (2d) 326.
22. Association of Municipalities of Ontario, Ontario Charter: Proposed Bill of Rights for Local Government, Policy Direction Series 1994, page 7.
23. News Release of the "Who Does What" Panel recommending a new Municipal Act, August 14, 1996, page 1.
24. As expressed by Brand Inlow of the City of Calgary Law Department in a paper presented to the Canadian Institute for the Administration of Justice in Ottawa on November 27, 1995 called The Alberta Municipal Government Act: A Municipal Perspective, page 5.
25. See footnote 21.
26. As pointed out by Alex Fyfe, Legislative Counsel, Government of Alberta in a paper called A New Approach to Enabling Legislation - Alberta's Municipal Government Act presented to the Canadian Institute for the administration of justice in Ottawa on November 27-28, 1995, page 5.
27. Forgrave, Tom, an article called The New Alberta Municipal Government Act presented to the National Institute of Municipal Law Officers at its conference in Edmonton on September 14, 1992, page 2.
28. The Association of Municipalities of Ontario in Ontario Charter: A Proposed Bill of Rights for Local Government, Policy Direction Series 1994; Don Lindstone, both in Municipal Lawyer, July/August 1996 at page 36 and in Municipal World, August 1996, as well as to a certain extent Craig MacFarlen in Municipal Law Reform in Ontario in a paper presented to NIMLO on October 13, 1995 in Chicago.
    

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