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The Corporation of the Municipality of Clarington
By-law 2021-012
Being a by-law to establish a transparent, consistent, fair, unbiased, and effective
process for municipal law enforcement
Whereas pursuant to the Municipal Act, 2001, S.O. 2001, c.25, as amended (the "Act'),
a municipality can specify when a contravention of a by-law is an offence, establish a
system of finds for offences under by-laws, and exercise other enforcement powers;
Whereas the Municipality of Clarington administers, enforces and prosecutes
contraventions of its by-law and other applicable provincial legislation as appointed by
the Province of Ontario; and
And Whereas Council considers it appropriate to establish a transparent policy for
municipal law enforcement, and to ensure that enforcement activities are fair, unbiased,
and free from any improper influence or interference.
Now therefore the Council of The Municipality of Clarington enacts as follows,
That Attachment 1, and forming part of this By-law, be approved as the Municipal
Law Enforcement Policy.
Passed in Open Council this 18th day of January 2021.
Adrian Foster, Mayor
June Gallagher, If6unicipal Clerk
Policy Title:
Policy #:
Report #:
Resolution:
Effective Date:
Revised Date:
1. Purpose:
Attachment 1 to By-law 2021-012
Enforcement Policy
TBD
LGS-005-20
#GGC-447-20
January 18, 2021
N/A
To establish a transparent, consistent, fair, unbiased, and effective process for
enforcement and prosecution of relevant laws.
2. Definitions:
"Council" means the Council of the Municipality of Clarington;
"Officer" means a person appointed by the Municipality to enforce or prosecute a
Relevant Law;
"Relevant Law" means any Municipal by-law, or Provincial legislation, for which
the Municipality has a responsibility to enforce or prosecute.
3. Roles
Reporting Infractions
3.1. Any person who has reason to believe that an infraction of a Relevant Law has
occurred, may report the matter to the Municipal Law Enforcement Division.
3.2. A person who reports an infraction may be summonsed to testify before a court
or tribunal in the prosecution of an alleged contravention of a relevant law.
Council
3.3. Council Members will respect and abide by the legally recognized principle that
Officers have a duty to enforce and prosecute Relevant Laws in a manner that is
fair and impartial and in a manner that is independent of political direction.
Attachment 1 to By-law 2021-012
3.4. Council Members will respect that Officers have an independent discretion to
make enforcement decisions based on their knowledge, experience, and
educated judgement.
3.5. Council Members will acknowledge that the independence of an Officer includes,
for example, the discretion to investigate (or not) and to issue a ticket (or not).
3.6. Council Members will not interfere with an Officer in the exercise of their duties or
attempt to influence the actions of an Officer except in the circumstances
specifically provided in this policy.
3.7. Consistent with the provisions of the Code of conduct for Members of Council, no
member shall use or attempt to further his or her authority or influence by
intimidating, threatening, coercing, commanding or influencing improperly any
staff member of interfering with that staff person's duties, including the duty to
disclose improper activity.
3.8. As with any other person, a Council Member who has reason to believe that an
infraction of a Relevant Law has occurred may report the matter to the Municipal
Law Enforcement Division.
3.9. Upon submitting a report, a Council Member shall be treated with the same
courtesy, and with the same restrictions on access to information, as would any
other complainant.
3.10. In reporting an infraction, a Council Member shall simply communicate the facts
and not express an opinion about how a Relevant Law should be enforced.
Thereafter, in order to avoid influencing or interfering with municipal law
enforcement, the Council Member shall not communicate with an Officer about
how the matter should be handled.
3.11. It is only legitimate for a Council Member to communicate with an Officer about a
law enforcement matter if the Council Member does not seek to influence the
discretion of the Officer in the performance of their duties.
3.12. A Council Member will not inquire with an Officer about the status of any
particular enforcement matter except to query whether a file has been opened or
closed, whether an inspection has occurred, or whether a ticket has been issued.
In the case of a matter that has been fully resolved, a Council Member is also
permitted to inquire as to the outcome. In making such inquiries, Council
Members will refrain from stating or insinuating an opinion about any action
taken, or decision made, by the Officer with respect to the matter.
Attachment 1 to By-law 2021-012
3.13. It is also consistent with the objectives of this policy for a Council Member to
inquire with the Director of Legislative Services or the Manager of Municipal Law
Enforcement about general concerns that do not relate to a specific enforcement
decision, or about standard operating procedures, processes, or practices of the
Municipal Law Enforcement Division.
3.14. Reports from a Council Member must be based on direct (first-hand) knowledge.
3.15. Council Members will refrain from relying on second-hand information as the
basis of their complaint. If information about the alleged infraction originates from
a third party, the Council Member should explain how to contact the Municipal
Law Enforcement Division so that the third party may, if desired, make the report
directly.
3.16. Council Members shall refrain from forwarding third party communications or
complaints to an Officer for a response.
3.17. In referring a third party to the Municipal Law Enforcement Division, a Council
Member will only provide contact information and information about the reporting
process and will neither encourage nor discourage the third party from taking
action. Reporting a matter must be an independent decision.
3.18. A Council Member will refrain from the exercise of any official function that could
impact the outcome of any complaint or investigation.
3.19. With respect to enforcement of Relevant Laws, Council may,
a) From time to time establish, amend or repeal Municipal by-laws;
b) Establish the budget for and policies related to the enforcement of
Municipal by-laws; or
C) At meetings of Council or one of its Standing Committees, ask general
questions of, and receive information from, the Director on general
questions relating to the enforcement activities of the Municipality.
Staff
3.20. In consultation with a supervisor, it is the responsibility of an Officer to,
a) receive complaints regarding alleged contraventions of relevant laws;
Attachment 1 to By-law 2021-012
b) continuously communicate and coordinate call investigations to provide
the most efficient time management and customer service;
C) screen complaints to determine if the subject matter of the allegation(s)
falls within their jurisdiction;
d) undertake investigations by making one of the following determinations:
i. there is insufficient evidence to proceed with enforcement in
response to the complaint;
ii. the subject matter of the complaint has been resolved though
compliance;
iii. the complaint is trivial, frivolous, vexatious or made in bad faith;
or
iv. the matter the subject of the complaint requires enforcement
action.
e) For such matters for which a determination has been made pursuant to
clause d), cause to be undertaken enforcement by such means as may
result in compliance as efficiently and effectively as possible, including
as applicable, by
request;
ii. commencement of a proceeding pursuant to the Provincial
Offences Act; or
commencement of remedial work by the Municipality.
4. Complaint Requirements
4.1. A complaint related to an infraction of a Relevant Law may be submitted to the
Municipal Law Enforcement Division via email, telephone, on-line form, or in
person. The following information must be provided by the complainant:
a) name;
b) address;
Attachment 1 to By-law 2021-012
C) contact number; and
d) details regarding the issue (e.g. address/area, timing, alleged violation)
4.2. Inaction will result if there is failure to provide this necessary information, unless
there is an apprehension of a significant risk to health or safety of the public, in
which case the matter will be dispatched with an emergency priority.
4.3. Notwithstanding the above requirements, a complaint about property standards
shall be submitted in writing (including email, or online complaint form). Where a
person is unable to submit in writing, they shall be offered the option to attend the
Municipal Law Enforcement Office where a staff member can assist them in
documenting their concerns.
5. Prioritizing Calls
5.1. Investigations will be distributed by the Manager of Municipal Law Enforcement,
or their delegate, to Officers based on their assigned patrol areas and by priority.
5.2. The priority ratings of files in descending order are:
a) Emergency — matter of public safety; immediate threat such as uncovered
well, hazardous broken tree limbs, or aggressive animal at large (i.e. not
confined nor restrained);
b) High - time sensitive; a pressing necessity to act such as a vehicle blocking
driveway, active site alterations, boulevards and fill operations, injured
animal/wildlife, dog bites, or confined animal;
c) Low — long-term issue which is just now being reported such as long grass,
weeds, public nuisance, parked more than 3 hours, or failure to retrieve pet
waste;
d) Routine — matter is a known re -occurring issue affecting multiple residents
such as 3-5 a.m. parking, snow removal, school zone enforcement, or dog
off leash patrols; and
e) Information Only — e.g. wildlife sighting.
5.3. Investigative response to all files shall be attended/completed in a timely manner,
within the established policies and procedures. The following shall be a guideline
to assist in initiating investigations to calls as prioritized:
Attachment 1 to By-law 2021-012
a) Emergency priority calls will be attended at the earliest opportunity by
the most available Officer. The most available Officer may be
determined by response time, ability to attend based on active field
investigations, and will be assisted by the Officer assigned to the area
at the earliest opportunity;
b) Investigations of High prioritized calls will be initiated by the Officer
within 12 business hours after being assigned; and
C) Investigations of Low and Routine prioritized calls shall be initiated by
the Officer based on existing call load.
5.4. In addition to the above, several factors shall be taken into account when
determining appropriate timelines for an initial response and complete processing
of any complaints up to, and including, voluntary or court ordered compliance. It
is acknowledged that an officer's ability to process any complaint efficiently and
effectively is greatly impacted by issues and factors beyond their individual
control. Some examples of factors that could impede an enforcement response
include:
a) threats to public safety (which always take priority over other
complaints);
b) Council requests;
C) court preparation and appearance;
d) ticket review session attendance;
e) special projects (e.g. taxi, mobile signs);
f) administration and revisions of current by-laws (e.g. research and
drafting of new by-laws);
g) Municipal events (e.g. Canada Day, Ribfest, Food Truck Frenzy,
Municipal Elections);
h) scheduled review and administration of license and permit applications
(e.g. mobile signs, taxi drivers);
i) responding to calls for actions from other departments and agencies;
Attachment 1 to By-law 2021-012
D coordination with contractors for completion of work orders on private
property;
k) holidays and vacation;
illness;
m) staff vacancies;
n) inclement weather; or
o) Provincial Order.
6. Investigations
6.1. All investigations shall follow the appropriate Policies and Procedures with due
diligence with the objective of fairness and consistent application of Relevant
Laws.
6.2. Once assigned a file, an Officer shall undertake an investigation to better
understand the situation. All investigations shall be initiated based on the priority
system identified in, this policy, and in accordance with any other applicable
policies and procedures.
6.3. For by-law matters which have a high frustration level or emotional component
for complainants (e.g. noise, dog incident), the Officer shall contact the
complainant to acknowledge the complaint and discuss the matter before
initiating any action.
6.4. If requested, an Officer shall maintain contact with a complainant to keep them
apprised of the investigation as it progresses and of the outcome.
7. Frivolous, Vexatious or Malicious Complaints
7.1. For the purposes of this policy, frivolous or vexatious refers to any action made
with the intention to embarrass or annoy the recipient or that is part of a pattern
of conduct that amounts to an abuse of the infraction reporting process.
7.2. In the assessment of whether a pattern of conduct has been established in
relation to the above, the factors to be considered include but are not limited to:
Attachment 1 to By-law 2021-012
a) whether the complaint concerns an issue which staff have already
investigated and determined to be groundless, or an issue which is
substantially similar to an issue which staff have already investigated and
determined to be groundless (e.g. with respect to the same neighbour or
same property);
b) whether the complainant engages in any unreasonable conduct or
aggravating behaviour, including, but not limited to:
harassment, verbal abuse or intimidation;
making excessive or multiple lines of enquiry regarding the same
issue (e.g. pursuing a complaint with staff in multiple departments
and/or elected officials simultaneously) while their complaint is in the
process of being investigated;
iii. repetitious and unreasonable criticism of an investigation or
outcome;
iv. repetitious and unreasonable denial that an adequate response has
been given;
V. unreasonable refusal to acknowledge that an issue falls outside the
Municipal jurisdiction;
vi. unreasonable demands (e.g. insisting on responses to complaints
and enquiries within an unreasonable timeframe);
vii. statements or representations that the complainant knows or ought
to know are incorrect, or influencing others to make such
statements;
viii. demanding special treatment from staff (e.g. ignoring established
complaint protocols);
X. shifting basis of the complaint and/or denial of previous statements
made;
X. refusal to cooperate with the investigation process while still wanting
their complaint to be resolved; or
A failure to clearly identify the precise issues of the complaint, despite
reasonable efforts of staff to assist.
Attachment 1 to By-law 2021-012
7.3. If an Officer concludes that a complaint is frivolous, vexatious, or malicious, the
Officer shall provide to the Manager of Municipal Law Enforcement any
documents or other materials in support of their conclusion, together with any
relevant details, including but not limited to the number of interactions with the
complainant, the amount of time invested, the repetitiousness of interactions, and
presence of any of the above-mentioned factors, and the Manager shall make a
final determination. In making a final determination, the Manager may contact the
complainant to discuss the background information.
7.4. If the Manager of Municipal Law Enforcement determines that a complaint is
frivolous, vexatious, or malicious, the Manager may issue a warning letter to the
complainant which may include the imposition of limitation concerning future
interactions with staff (e.g. restricting interaction with a single point of contact with
the Municipality, instructing staff to not respond to further written
correspondence, or ensuring no staff member is left alone in the presence of the
complainant).
7.5. If the Officer, in consultation with the Manager, determines that a complaint is
frivolous, vexatious, or malicious in nature, the file shall be closed, the reasons
for the decision documented, and the complainant shall be advised of the status.
No further action will be taken on the file.
7.6. Notwithstanding a determination that a complaint is frivolous, vexatious or
malicious, a file may be re -opened in the future where there is sufficient reason to
do so, or the situation has changed.
8. Communication about a Particular Enforcement Matter
8.1. A complainant shall be notified at the first opportunity, that their complaint has
been received, together with the name of the Officer who will be investigating the
matter, and the Occurrence Tracking System File Number.
8.2. Where the complaint is received through a channel other than in person or over
the phone, prior to assigning the complaint to an Officer, and where deemed
necessary, a staff member will contact the complainant within one business day
of receipt to clarify the information that has been previously provided.
8.3. Staff will ensure that complainants are provided the information required to
adequately understand the role of the Officer, and the extent of their ability to
assist them with their concern. General information may be provided to assist
them in finding a solution, including information on our website or re -directing to
another Department or agency.
Attachment 1 to By-law 2021-012
8.4. An Officer shall not disclose any confidential information including personal
information gained in the performance of their duties except as required for
prosecution purposes or otherwise as legally authorized.
8.5. Every Officer shall report to the Manager of Law Enforcement, who will in turn
report to the Director of Legislative Services, any attempt at improper influence or
interference, financial, political or otherwise, respecting the Officer's performance
of his or her duties.
8.6. Each Officer who is contacted by a member of Council with respect to an
outstanding complaint or investigation matter, other than a complaint made by or
against the Council member, or in which the Council member is a witness, shall
immediately report such contact to the Manager of Law Enforcement who will in
turn report it to the Director of Legislative Services.
8.7. The Director may report to Council with the particulars of any reports received
from an Officer pursuant to Section 8.5 and 8.6.
8.8. No action shall be taken against an Officer or the Director, as the case may be,
for reporting in good faith pursuant to sections 8.5, 8.6, or 8.7.
9. General
9.1. Enforcement related records shall be managed through the Occurrence Tracking
System Database. Access to this system is limited to those staff members who
require access in the performance of their duties. Records shall include personal
information pertaining to complainants and any witnesses, investigation notes
and details, communications, photos and any other supporting materials.