Fall 2017 Consultation on Proposed Revisions To PARG & CPPG: Feedback Summary

Introduction

After engaging with school boards, municipalities and community partners, Ontario launched its Plan to Strengthen Rural and Northern Education in June 2017. A central element is to strengthen the Pupil Accommodation Review Guideline (PARG) and to support improved coordination of community infrastructure planning, which includes revising the Community Planning and Partnerships Guideline (CPPG).

In the fall of 2017 the Ministry of Education (the ministry) undertook the first two-phase consultation on:

  1. Proposed revisions to the PARG
    Feedback received during the province’s rural and Northern education engagement in spring 2017 suggested that there is a need to strengthen the PARG for all school boards across the province. The ministry’s proposed revisions to the PARG aimed to create a stronger, more collaborative process to better promote student achievement and well-being and better recognizes the impact of school closures on rural communities.
  2. Opportunities to better support community infrastructure planning, including through revisions to the CPPG
    The ministry also consulted on ways to support improved coordination of community infrastructure planning for all school boards across the province. This included whether revisions are needed to the CPPG to:
    • Better align with integrated local planning processes;
    • Encourage joint responsibility for integrated community planning, with a focus on communication between school boards, municipal governments and community partners about boards’ capital plans;
    • Highlight the potential for community use of open and underutilized schools; and
    • Require that boards disclose municipal participation and non-participation in CPPG meetings

Consultation Overview

This document provides a summary of feedback received from all elements of the first phase of consultation, which involved:

  • An online posting of proposed revisions to the CPPG and PARG on the ministry’s website between October 12 and December 6, 2017, which generated 78 email responses from: members of the public (50), the education sector (16), advocacy organizations (7) and the municipal sector (5).
  • 19 in-person engagement sessions with school board staff and education sector stakeholders. These sessions took place as part of the ministry’s annual Education Funding Engagement in fall 2017. Attendees included:
    • School board representatives, including Directors of Education and senior school board officials;
    • School board trustees’ associations;
    • Principal and vice-principal associations;
    • Teachers’ federations;
    • Education workers’ unions;
    • The Minister’s Advisory Council on First Nation, Métis and Inuit Education Working Group;
    • Indigenous Trustees’ Council;
    • First Nation Lifelong Learning Table;
    • Parent groups; and
    • Student groups.
  • One Minister’s Reference Group meeting, which included representatives from the education and municipal sectors and an academic. The group’s mandate is to advise the Minister of Education on effective ways to improve coordination of community infrastructure planning from a public education perspective.

Consultation Questions

The following consultation questions were used for feedback at meetings and online.

  1. Do you think the ministry’s proposed revisions to the PARG will create a stronger, more collaborative process?
    1. If not, why? Are there other elements the ministry should consider?
    2. If yes, do you have suggested improvements or comments on the elements being proposed?
  2. Do you think the proposed measures to support improved coordination of community infrastructure planning will work to promote sustainable use of school space in communities?
    1. If not, why? Are there other elements the ministry should consider?
    2. If yes, do you have suggested improvements or comments on the elements being proposed?
  3. When making decisions about school infrastructure within communities, what measures could be conducive to fostering collaboration and cooperation between municipalities and school boards?

Summary of Consultation Feedback

Q1. Do you think the ministry’s proposed revisions to the PARG will create a stronger, more collaborative process?

Policy Proposal: Revising Pupil Accommodation Review (PAR) timeframes

Extending the current minimum PAR timeframe beyond five months

Feedback

Online

  • Over half of the responses from the general public, advocacy groups and the municipal sector supported extending timeframes.
  • Over two thirds of responses from the education sector did not support extending timeframes.

Engagement meetings

  • Many boards were concerned about the process becoming too long. Some felt five or six months should be the maximum, and were concerned about going beyond the school year. “No amount of consulting is ever going to make school closures less painful,” said one participant. Another said, “The process doesn’t need to be longer, it needs to be better.”

Minister’s Reference Group

  • Many attendees do not want timeframes extended. Some supported extensions if circumstances changed during a PAR (such as a new school introduced for closure). Concerns included increased community tension, greater workload for boards, impacts on the ability to plan for future years, and that potential partners may go elsewhere.

Policy: Proposal Eliminating the minimum modified PAR timeframe of three months

Feedback

Online

  • Half of responses from the general public, advocacy groups and the municipal sector supported eliminating the modified PAR.
  • Two thirds of responses from the education sector did not support eliminating the modified PAR.

Engagement meetings

  • There was wide agreement that the modified review process was beneficial.

Minister’s Reference Group

  • Some attendees noted that the modified PAR allows boards flexibility, and helps move the decision along when the community agrees with the proposal. Others highlighted the potential for misuse.

Policy Proposal: Further extending time-frames under specific circumstances, such as if new closure recommendations are added mid-way through the accommodation review process.

Feedback

Online

  • Less than half of responses from the general public, advocacy groups and the municipal sector supported extending timeframes under specific circumstances.
  • Two thirds of responses from the education sector did not support extending timeframes under specific circumstances.

Engagement meetings

  • Some discussed possible extensions due to pre-determined triggers that might change a school’s viability (e.g. municipality changing zoning where the school is located). But school boards felt these would be hard to define in advance. They noted a short delay can mean a closure happens a year later with a significant impact on operating costs.

Minister’s Reference Group

  • Some attendees supported an extension, if a new closure is introduced, arguing that longer timeframes will help community members better understand the implications.

Policy Proposal: Introducing minimum requirements for the initial staff report

Require school boards to include at least three accommodation options (a recommended option, an alternative option and a status quo option).

Feedback

Online

  • Half of responses from all sectors supported at least three accommodation options.

Engagement meetings

  • Most boards expressing a view said three options would be problematic; a few others had no concerns. One objection is in rural areas where three reasonable options are not possible. Many said the process works better when the board has to defend a decision it has made.

Policy Proposal: Require school boards to include information on how accommodation options will impact: School board budget; Student programming /achievement; Student well-being; and Community and/or economic impact.

Feedback

Online

  • Half of responses from the general public, advocacy groups and the municipal sector supported the inclusion of this information.
  • Less than a quarter of responses from the education sector supported the inclusion of this information.

Engagement meetings

  • Engagement Meetings Boards want to make clear that program quality, not budget, should drive decisions. But they also said that with so many positive and negative factors, it is hard to define and quantify the student impacts.
  • Boards said other factors, especially “economic impact,” were less relevant and/or hard to quantify in a valuable, objective way. Others felt that community impact was a consideration, especially with small and remote communities.

Policy Proposal: Promoting community input in the PAR processes

Require school boards to invite elected municipal representatives and municipal staff to a meeting to discuss the initial staff report.

Feedback

Online

  • Half of responses from all sectors supported inviting municipal representatives and municipal staff to a meeting to discuss the initial report.

Engagement meetings

  • Some boards said involving municipalities can complicate and slow the process. Elected officials can advocate positions contrary to the board’s goals, and municipal and school boundaries differ.

Minister’s Reference Group

  • Views varied, but many suggested that building stronger local relationships is the only lasting solution to increasing community and municipal input.

Policy Proposal: Require school boards to disclose municipal participation / non-participation in PAR and Community Planning and Partnership (CPP) processes.

Feedback

Online

  • The majority of responses from the general public, advocacy groups and the municipal sector did not provide feedback on this proposal.
  • Half of responses from the education sector did not support this proposal.

Engagement meetings

  • There was no support for publicly naming municipalities that did not respond to invitations to take part. It would harm boards’ relationships with municipalities.

Policy Proposal: Require a broader role for trustees throughout the PAR process, beyond ad hoc membership of Accommodation Review Committees, hearing public delegations and making the final decision.

Feedback

Online

  • The majority of responds from the general public, advocacy groups and the municipal sector did not provide feedback on this proposal.
  • Half of the responses from the education sector did not support changes to the trustees’ role.

Engagement meetings

  • It was virtually unanimous – boards said that trustees should not be required to attend public meetings. Actual practice appears to vary widely (possibly in line with how contentious the proposal is). However, trustees could be involved at the planning stage as long as meetings were not public, as well as in the final decision.

Minister’s Reference Group

  • A student trustee stated that while student trustees have experienced harassment, it is important for students to be a part of the process. There was a suggestion that students from Grades 7-12 could be on Accommodation Review Committees.

Policy Proposal: Require a participatory role for secondary student representatives in PARs involving secondary schools.

Feedback

Online

  • The majority of responses from the general public, advocacy groups and the municipal sector did not provide feedback on this proposal.
  • About half of the responses from the education sector supported this proposal.

Engagement meetings

  • Many felt that secondary students/student trustees should be engaged since they provide a valuable, and often more objective perspective – although not necessarily as decision-makers. Students could explain why a proposal would benefit the student body and help to curb “bad adult behaviour.” However, concerns were raised about the risk of students being bullied or intimidated.
  • A student trustee suggested boards should make more of an effort to educate students, even those in elementary school, about the issues and encourage them to express their views in surveys and other forums.

Minister’s Reference Group

  • Student trustees spoke of the need for a strengthened student voice in the process.

Policy Proposal: Reforming the PAR administrative review process

Extending the timeframe to submit an administrative review petition from 30 to 60 calendar days.

Feedback

Online

  • The majority of responses from the general public, advocacy groups and the municipal sector did not provide feedback on this proposal.
  • Two thirds of responses from the education sector did not support this proposal.

Engagement meetings

  • Some concerns were raised about reforming the administrative review process, including extending the timeframe to submit a petition. Most boards were opposed to this.

Policy Proposal: Reviewing the signature thresholds and requirements for launching an administrative review request.

Feedback

Online

  • The majority of responses from the general public, advocacy groups and the municipal sector did not provide feedback on this proposal.
  • There was a mixed response from the education sector; one third of responses supported this proposal, while one third did not.

Policy Proposal: Developing Ministry Supports

A PAR toolkit to standardise type and format of initial staff report information.

Feedback

Online

  • The majority of responses from the general public, advocacy groups and the municipal sector did not provide feedback on this proposal.
  • Over half of responses from the education sector supported this proposal.

Engagement Meetings

  • Some interest was expressed for a business case model for closures and a standard template to present school data to the public during a Pupil Accommodation Review.
  • Standard toolkits/templates would need flexibility for boards’ differing situations.

Policy Proposal: A template for use by community partners to engage boards with proposed alternatives to school closures or other proposals for community use of schools.

Feedback

Online

  • The majority of responses from the general public, advocacy groups and the municipal sector did not provide feedback on this proposal.
  • A third of responses from the education sector supported this proposal.

Engagement meetings

  • A template for community partners to propose alternatives would provide the right information and understand parameters boards use to assess proposals.

Policy Proposal: New support for the review and validation of initial staff report information and community proposals by independent third parties.

Feedback

Online

  • The majority of responses from the general public, advocacy groups and the municipal sector did not provide feedback on this proposal.
  • Over half of responses from the education sector did not support this proposal.

Engagement meetings

  • Boards and some others felt that third-party review would undermine the role of staff, although having this available on a voluntary basis might be good. Also, who would do the review and what qualifications would be needed? One board said that formal endorsement should take the form of the ministry’s approval in principle of the relevant capital improvements.

Q2. Do you think the above measures to support improved coordination of community infrastructure planning will work to promote sustainable use of school space in communities?

Feedback

Online

  • The PARG and CPPG already support municipal engagement and information sharing. But partners must share responsibility in the process and proactively share information about their interests and needs.
  • The education sector said schools must be schools first and foremost, and that partnerships can complement a school, but cannot always prevent closures.
  • Some said collaboration has worked well at the staff level. However, decisions about partnerships are ultimately in the hands of trustees and municipal councillors. Projects can be rejected at the political level, even if there is support at the staff level.

Engagement meetings

  • The biggest concern is that organizations who may be interested in partnerships or community hub opportunities do not have funding for operating costs. In many cases, boards said groups continue to expect free space. Extending the discussion period does not address this.
  • Boards in the Toronto area reported there is high demand for space in schools in specific locations (usually accessible by transit) – that are newer, air-conditioned, accessible and have gyms/double gyms, and also fit the organization’s budget.
  • In some cases, schools do not have space available for interested partners. It is also hard to find partners or potential buyers when the school property’s size is not suitable. One board has successfully partnered with local police, who run training workshops.
  • Boards in the Toronto area said they prefer to keep buildings in the public realm because they are very difficult to get back from the private sector. Others said that boards should not be able to keep schools that are not being used for full-time students, and that the ministry should have a say in boards' decisions to sell or keep their schools.
  • Indigenous participants expressed a need for more incentives to explore joint-use schools with provincially-funded boards. Access to schools is critical, they said, for organizations like the native friendship centres. They noted that more remote communities are often hard-hit by school closures because, for example, the school might have the only gym in a very large area. As well, their students might now face a much longer bus ride, and the First Nation is often required to cover the added transportation costs.
  • Indigenous participants felt that many school boards lacked the knowledge or relationships to engage effectively. Boards need to set up formal meetings with clear protocols about what will be discussed to foster collaboration between all education stakeholders. The Indigenous lead should also be involved. They noted that two Indigenous groups – First Nations people living outside their traditional territory and Metis – are particularly at risk of being overlooked because they are less visible. Organizations like the friendship centres and Metis Nation of Ontario could help identify them, they said.
  • They also suggested meetings with Indigenous residents should not focus just on students and their parents, but should acknowledge the broader sense of community that is central to Indigenous life. As well, shared facilities should consider the need for dedicated spaces for sacred ceremonies, meetings with elders, on-the-land learning and other cultural uses.
  • While Francophone schools are the centers of their community, and thus natural candidates for acting as hubs, there were questions around boards being compensated for the added costs of this role. French-language participants also expressed concerns about assimilation if facilities are shared between anglophone and francophone boards.

Minister’s Reference Group

  • A formal mandate and coordination from the province is required to facilitate joint planning and policy integration. The province should define clear roles and responsibilities for all parties involved in the planning process and create reporting requirements for disclosing participation.
  • Sectors such as education, municipal affairs, health and social services should align their long-term planning.
  • Boards could align their capital planning with a region’s demographic projections, and consider areas of future population growth during PARs.
  • The province’s data on several sectors can assist long-term planning at the local level, as each sector doesn’t usually see data outside their own sector (i.e. municipalities don’t have access to board’s data and vice versa). This data can help all stakeholders in an area plan together – planners could create a map for an area of future demographic trends and demand for all services (education, health, housing, social services) which would help boards, municipalities, health and social services work together.
  • Joint responsibility only works if there is joint decision making, and joint decision making only works if joint funding exists. For example, boards are responsible for the maintenance and renewal of school buildings, but other organizations often use the space, either as a hub or after school hours. Financial resources were suggested as an incentive to encourage cooperation.
  • Each sector’s reporting periods and budget timelines are not aligned with other sectors in their region which report to other ministries (education, health, social services, municipal affairs). This is an obstacle to integrated regional planning with other public services, but all sectors are simply operating within the parameters set out for them by the province.
  • There was a request for more cooperation between coterminous boards in a region, and that the province mandate cooperation as part of a local integrated planning approach.

Q3. When making decisions about school infrastructure within communities, what measures could be conducive to fostering collaboration and cooperation between municipalities and school boards?

Feedback

Online

  • Multi-year capital funding commitments from the ministry could allow boards to better plan and improve coordination with local partners and coterminous boards.
  • Communication between ministries (such as education and municipal affairs) can strengthen coordination and communication between municipalities and boards. The Ministry of Municipal Affairs should encourage municipalities to proactively engage with boards. Boards should not be the only ones responsible for communication and engagement about community partnerships. There needs to be information sharing; two-way communication about planning needs and data is essential.
  • There could be dedicated provincial funding streams and a provincial capital program aimed at community partners. Similar to the Capital Priorities program, communities should be able to apply for funding for new community infrastructure, and the Ministry of Infrastructure could run this program.
  • Amend the regulation governing the disposition of surplus school board property (Ontario Regulation 444/98) to allow municipalities to buy schools at a price based on the property's institutional use and value and not fair market value.
  • There is a desire to see greater cooperation between coterminous boards about sharing information before initiating PARs and more sharing of space.
  • Annual CPPG meetings should require discussion of capital plans to permit two-way sharing to facilitate integrated community planning. Board’s capital plans should include families of schools to be recommended for PARs within next the next five years.

Engagement meetings

  • Boards commented fairly consistently on the difficulty of working with municipalities. The feel municipalities have a different agenda (one board reported the experience of the city buying a surplus school building and then selling it immediately to developers).
  • In areas of growth, there was considerable criticism that municipalities planned their communities poorly – such as in ways that increased school boards’ costs and often threw up roadblocks when boards wanted to build schools, yet they expected to be able to influence boards’ decisions about closures. Participants noted that because economic activity drives the viability of neighbourhoods and communities, there needed to be more (and better) ties to community partners, including municipalities.
  • Boards with schools in rural and remote communities felt the pressure from the municipality to keep a school open because of its role in the community. But the board’s job is education, not community sustainability. There were also problems because small municipalities lacked the resources and funding to work effectively in partnership. There was a comment that different parts of government need to work together more effectively to achieve these outcomes.
  • Many participants suggested factors that would help foster collaboration:
    • A toolkit for partnerships, including templates to help potential partners provide the right information
    • Design of infrastructure (when building schools, for example, some boards have included community-use sections that are self-contained)
    • Communication with the community
    • Funding to cover the additional costs (such as wear and tear on property and equipment, longer opening hours, enhanced security) and to encourage principals to keep space available. A major concern was ensuring initial and ongoing costs for community use of space are covered. (Conversely, Indigenous partners said they needed to be compensated for their capital investments in school facilities that later close.)

Minister’s Reference Group

  • Boards and municipalities should be obligated to share information and planning needs. Municipalities often do not share their long-term planning needs until a PAR is announced in their jurisdiction, but they should share information continuously with boards.
  • The annual meeting mandated by the CPPG usually has low municipal turnout. Two-way information sharing should occur more than once a year. Some boards mentioned that they often have conversations with municipalities outside of this annual meeting.
  • Mandating a meeting will not facilitate discussion on its own. There must be clearly defined roles, responsibilities and deliverables. There should be a formal structure or process to share information, and accountability measures such as reporting required on who attends meetings, or a joint report together on what was discussed.
  • There was a suggestion that boards share data on the “life expectancy” of schools, and their renewal and long-term capital needs, so they have a better idea of future closures, and can try to plan around it.
  • Participants identified the need to communicate to the public earlier in the process about the reasons and benefits of potential closures or consolidations. (e.g. advantages of building modern, technologically advanced schools, counter the perception that it is easier to build a new school instead of fixing it, explain that they are strategically building schools where population is growing).

Other Comments about Community Hubs and Partnerships

Feedback

Engagement meetings

  • While principals are key in planning for community use, they are often not consulted.
  • Working with a partner slows the process of putting a new school in place.
  • The Province should co-ordinate funding from all relevant ministries, including Education, to deliver child and family support services in schools
  • The ministry should create a new category for schools that are critical to the long-term viability of a community (for example, the only school in a large area); generally, rural and urban schools may require a different funding model.
  • It appears that there are two conflicting policies – for boards to sell properties and to arrange community hubs.
  • There is no definition of community hubs. For example, is partnering with a developer or locating a movie theatre in a school facility considered a community hub?
  • Better communication to public and stakeholders, especially municipalities, would be helpful.
  • Currently, the public perception is that community hubs will save schools from closing and this is not always true.
  • Listing vacancies and needs for space on the ministry website would be better than boards trying to coordinate this themselves.
  • Cities consider school yards as city green space, but do not own the land. A city-board partnership would be ideal, but would require the city to pay the school board for maintenance.

Minister’s Reference Group

  • Some participants felt that the current public perception is that a hub will save a school from closing. Boards emphasized that that their primary objectives are supporting student achievement and ensuring programming quality, while a municipality’s agenda is very different.
  • Parents care which services are in schools and who enters the building, especially if these services do not cater to a student population.
  • Participants stated that regardless of a hub in a school, it is important to note that school space is often used outside of school hours by community organizations.
  • Hubs may be difficult to operate in rural areas, since a stable population base is needed to sustain both schools and other services. Partners or service providers may not want to be in a school if the area lacks sufficient population or a lack of clients to serve.
  • Hubs should be considered sooner in the planning process, such as once a board identifies declining enrolment. There was a request for the ministry to mandate a hub model, which considers hubs sooner before a school closure is initiated.
  • The ministry was asked if it will consider changing O. Reg 444/98 so communities can purchase surplus schools based on an institutional value/price instead of fair market value which is based on residential or commercial value.
  • The concept of scalability was suggested to accommodate shifting demographics in a school hub. This involves adjusting the amount of space in a building for both the school and other service providers as demand changes for any occupant’s services.

Other Comments not related to PARG or CPPG

Feedback

Online

  • Feedback from the public suggested that the ministry should revise the funding formula for rural schools and that Rural and Northern Education funding should be a permanent part of the Grants for Student Needs.

Minister’s Reference Group

  • There was a recurring suggestion to revise the funding formula to recognize the differences between rural and urban areas, and the unique variables in different regions of the province.
  • The funding formula needs to consider community uses of the school, and other educational programs in a school such as Special Education and English as Second Language.
  • There is a gap in resources for rural and urban schools. Urban schools have a wider range of programming (such as music teachers and other specialized subjects) and support services (such as guidance counsellors).