May 11, 2020

Mr. Onorio Colucci
Chief Administrative Officer
The Corporation of the City of Windsor
350 City Hall Square West, 5th Floor
P.O. Box 1607
Windsor, ON N9A 6S1

Dear Mr. Colucci:

Proposed cannabis retailer in the City of Windsor, located at 398 University Ave West, Windsor

The Windsor-Essex County Health Unit (WECHU) is writing in response to the recent pending approval of the Cannabis Retail Store Authorization application located at 398 University Ave West, Windsor . Should you wish to review this location and provide feedback to the Alcohol and Gaming Commission of Ontario during the public consultation period, the following considerations may assist in determining whether it poses a risk to public health and safety, and exposure/access to youth and other vulnerable populations in the City of Windsor.

At this time, the Ontario Regulation (O. Reg) 468/18 under the Cannabis Licence Act does not allow for a cannabis retail store to be located within 150 metres from a school or private school as defined in the Education Act; however, there are no other restrictions imposed from other sensitive use lands (e.g. daycares, playgrounds, mental health and addictions facilities). Additionally, municipalities are currently prohibited from using licensing or land-use by-laws to control the placement or number of cannabis retail outlets. Having a strong Policy Statement and providing feedback to the Alcohol Gaming Commission of Ontario is one way that the City of Windsor could reduce any risk to public health and safety.

Public Health Considerations and WECHU Recommendations for Cannabis Retail

When considering a location for a cannabis retailer, special consideration needs to be given to vulnerable populations (e.g., children and youth, those already struggling with substance addictions, etc.) and the inequitable impact that a chosen site location may have on particular populations within your community. It has been well established that closer retail outlet proximity to sensitive use spaces increases normalization among vulnerable populations.1,2 In addition, retail outlet proximity to youth-serving facilities normalizes and increases substance use.3,4 By supporting a more effective minimum distance requirement from youth-serving facilities such as schools, child care centres, libraries, and community centres, municipalities can prevent the role-modeling of cannabis use and reduce youth access.5,6,7

In order to minimize the potential for vulnerable populations to access cannabis and reduce public exposure to environmental cannabis smoke, the WECHU recommends the following: