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June 17, 2020

Dear Mr. Colucci:

Re: Proposed changes to provision and consumption of alcohol on municipally owned properties

The Windsor-Essex County Health Unit (WECHU) is writing in response to the recent announcements from the Alcohol and Gaming Commission of Ontario regarding the allowance of licensed patio extensions for the duration of 2020, provided the municipality does not object to the extension, and that certain criteria are met. The WECHU is also writing in response to the Council Report: C 108/2020 Subject: Response To Correspondence From Spirits Canada Re: Municipal Liquor Policies To Support Local Bars and Restaurants as received by members of council of the City of Windsor on June 1, 2020. The WECHU supports the recommendations made by Administration in their review of the suggested regulatory changes from a public health and safety perspective, specifically, with respect to discouraging the consumption of alcohol in Parks outside of areas licensed through a permit, and discouraging post-facto inspections for premise alterations of licensed establishments.

Public health considerations for expanding spaces for alcohol sales, service and consumption

Should Council support the expansion of licensed patios, or propose amendments to the Municipal Alcohol Policy for the City of Windsor (2015), special consideration should be given to the potential health, safety, and liability risks it may cause to patrons, event staff, and the public, including any inequitable harms to vulnerable populations (e.g., youth and those struggling with alcohol dependency). Alcohol use remains a leading, preventable cause of injury, chronic disease, and death in Ontario and consistently contributes to the highest number of substance-related emergency department visits in Windsor-Essex (WECHU, 2019).

Alcohol policy research has strongly identified that increasing access through alcohol outlets and on premise establishments increases use and associated harms, and normalizes drinking. Such harms include violence, injury (e.g. falls, motor vehicle collisions), alcohol poisoning, and public nuisance issues from noise and public intoxication. This causes not only increased poor health outcomes, but also increased use of municipal emergency medical services, police, and hospital services (Stockwell et al., 2019; OPHA, 2019; Liem, 2018). Maintaining a strong municipal alcohol policy is one way that the City of Windsor can protect residents and reduce the burden on municipal services.

The impact of alcohol policy changes on the ability to comply with smoking and vaping legislation should also be considered. The Smoke-Free Ontario Act, 2017 (SFOA, 2017) aims to reduce exposure to second-hand smoke, denormalize smoking behaviour, and create healthier environments for all. Under the SFOA, 2017, the smoking of tobacco or cannabis and vaping of any substance is prohibited on and within nine (9) metres of a patio where food and drink is served. This includes outdoor areas where seating tables are provided for patrons to consume their meal or beverage. It is also important to note that the SFOA, 2017 prohibits the smoking of tobacco or cannabis and