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MLS must have the proper resources to do its job.

MLS is responsible for the enforcement of over 29 bylaws and their services include everything from zoning to bringing animals to shelter.

Dear Councillor Palacio and Members of the Licensing & Standards Committee:

RE:   LS23.1 – 2014 Service Level Review

          Municipal Licensing and Standards (MLS) Division

The Service Level Review for the Municipal Licensing and Standards Division clearly shows how this Division is struggling to meet service levels because of vacancies and gapping.

In 2012 there were 452.6 approved positions, by the end of the year the number of positions actually filled were 398.6, leaving 54.0 positions unfilled — an 11.9% vacancy rate.

According to the Operating Variance Report at Budget Committee earlier this month, MLS had a net-overspending in the first six months of 2013.  Although the Division saved $433,000 through unfilled staff positions, they also over-spent $160,000 on contracted services.  The Division plans to recoup the over-spending by continuing to leave the vacancies unfilled.  The Report cites that process of filling staff vacancies is ‘ongoing’.

Meanwhile, Toronto residents can expect more increases in wait times for waste enforcement and resolution. Parks enforcement resolution times have been fluctuating in the past several years but for this year and next, residents will have to wait up to five days. This comes days after the Parks and Environment Committee – supported by the Mayor – voted against even investigating a faster timeline for park replacement. When you look at these service levels in relation to the Division’s refusal to fill vacancies the message is clear: unfilled vacancies impact the quality of life of Torontonians.

With its history of past staffing shortages the projected service levels in this Review for MLS are unrealistic. For example, When we look at the number of days required to achieve resolutions by investigation services, we have seen increases every year since 2011: from 69.1 days to 86.8 to a whopping 94.0 this year. And yet, the Division is proposing to achieve service levels that are 13% below 2011 levels and 36% below this year’s.

Without the resources to adequately staff these programs, such ambitious reductions will be impossible to achieve.

Indeed, when we see that the main service priorities across program areas are to “conduct service reviews of business processes” and to “develop plans”, we can’t help but wonder whether this will lead to over-spending on consultants and other contracted services when at least part of the solution is fairly clear: hire staff to fill vacancies. Not only will hiring staff help address immediate service needs, it represents an investment in in-house expertise to protect against future shortages as current staff cohorts begin to retire.

In order to meet its service level targets this Division must have adequate staff.  This Division provides by-law enforcement, licensing services, inspection and investigation services, and supports Toronto Animal Services.  MLS is responsible for the enforcement of over 29 bylaws and their services include everything from zoning to bringing animals to shelter.

This Division must have the proper resources to do its job.  It’s time to hire.

Yours truly,

Tim Maguire, President














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