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Ministry of Education Proposal to Amend Education Act - Submission to the Ontario Regulatory Registry

Categories: Advocacy

Submission to the Ontario Regulatory Registry 
Neethan Shan, Chair, ³Ô¹ÏºÚÁÏÍø 
 
Re:  

 

On behalf of the ³Ô¹ÏºÚÁÏÍø (³Ô¹ÏºÚÁÏÍø), I am submitting these formal comments in response to the proposed amendments to the outlined in the . The ³Ô¹ÏºÚÁÏÍø is Canada’s largest school board, serving approximately 239,000 students across a diverse and dynamic urban region. We are committed to student success, equity, and responsible governance, and we welcome opportunities to engage with the Ministry of Education on matters that impact Ontario’s public education system. 

We recognize and support the government’s stated goals of improving student outcomes, enhancing accountability, and ensuring safe and inclusive learning environments. However, we have significant concerns about the scope and implications of the proposed legislative changes, particularly those that would centralize decision-making authority and diminish the role of locally elected school board Trustees. 

The proposed amendments would grant the Minister of Education broad powers to intervene in school board operations, including the ability to place boards under supervision for financial or non-financial reasons, override local decisions on school naming, and mandate the implementation of School Resource Officer (SRO) programs. These changes would fundamentally alter the governance structure of Ontario’s education system. As the Ontario Public School Boards’ Association (OPSBA) has emphasized in its recent statement, , they risk undermining the democratic accountability that has long been a cornerstone of public education in this province. 

The ³Ô¹ÏºÚÁÏÍø has a strong record of transparency and accountability. Several of the proposed measures, including new audit authorities and expense policy directives, risk duplicating existing accountability mechanisms already in place at the ³Ô¹ÏºÚÁÏÍø and other boards. These duplications could introduce unnecessary red tape and administrative burden without improving outcomes for students.  

Trustee expenses have been publicly reported since 2014, and the Board has taken deliberate steps to reduce central administration in order to protect classroom funding. We support oversight mechanisms that are fair, evidence-based, and designed to strengthen public trust. However, we caution against measures that duplicate existing practices or exceed a reasonable scope. 

We are particularly concerned about the proposed requirement for school boards to implement SRO programs where offered by local police services. In 2017, following extensive consultation with over 15,000 students, staff, and community members, the ³Ô¹ÏºÚÁÏÍø made the decision to end its SRO program. While some students reported positive experiences, more than 2,000 students, many of them racialized, shared that the presence of police in schools made them feel unsafe, targeted, or surveilled. This decision was made through a transparent, community-informed process and reflects our ongoing commitment to creating safe, inclusive, and equitable learning environments. The Ontario Human Rights Commission specifically referenced this process and their engagements via a letter to the ³Ô¹ÏºÚÁÏÍø December of 2022, available at . Reinstating such programs without local consultation disregards the lived experiences of students and undermines the principle of community-responsive governance.  

Similarly, the ³Ô¹ÏºÚÁÏÍø’s school renaming process, launched in 2021, was developed in response to community concerns about school names that do not reflect the values of equity and inclusion. has been thoughtful, consultative, and grounded in the belief that public institutions should reflect the diversity and dignity of the communities they serve. The proposed legislation would allow the Minister to override these decisions, which risks politicizing what should remain a local and community-driven process. 

School board Trustees are the in Ontario, with a legacy dating back to 1807. Trustees represent the families and communities they serve, and bring essential local knowledge, cultural understanding, and lived experience to the governance of public education. Centralizing authority at the provincial level diminishes this democratic structure and weakens the ability of school boards to respond effectively to the unique needs of their communities. 

Respect for community autonomy must remain a guiding principle in education governance. School boards engage with families and communities as equal partners. This is especially important in a city as diverse as Toronto, where historical and cultural contexts shape how communities experience education.  

We urge the Ministry to reconsider aspects of the proposed legislation that would erode local governance and community voice. We also emphasize the importance of meaningful consultation with school boards and their representative associations. OPSBA, as the credible voice of public education in Ontario, plays a vital role in representing the collective expertise and experience of school boards across the province. Its input should be central to the development and implementation of any legislative or regulatory changes. 

We are also concerned that the proposed unchecked powers for the Minister, particularly the ability to reverse local decisions made in collaboration with school communities, run contrary to the spirit and intent of family engagement requirements outlined in and . These frameworks emphasize the importance of involving families in decision-making processes. Overriding locally developed decisions risks undermining that trust and could result in unintended harms to students and communities. 

We recommend a collaborative approach that includes: 

  • Clear, transparent criteria for any extraordinary oversight powers; 
  • Respect for local discretion in areas such as school naming and safety programming; 
  • Continued support for existing accountability frameworks that are already in place; 
  • And, most importantly, adequate and sustainable funding to address the structural funding challenges facing school boards across Ontario. 

The ³Ô¹ÏºÚÁÏÍø remains committed to working in partnership with the Ministry of Education to strengthen Ontario’s public education system. We thank you for the opportunity to provide this submission and would welcome further dialogue or participation in any future consultations related to this legislation.