Commercial Focus Advisory Services

Commercial Focus Advisory Services

New City of Toronto Draft City-Wide Zoning By Law—Adult Entertainment Association of Canada

Commercial Focus Advisory Services has been retained by the Adult Entertainment Association of Canada(A.E.A.C.) for the purpose of evaluating and making recommendations on the proposed new draft City Wide Zoning By law.

The A.E.A.C. is concerned about adult entertainment parlours being categorized with other activities such as body rub and holistic uses. The proposed zoning by law very inadequately differentiates between adult entertainment parlour land uses and these other land uses. Adult entertainment parlours should be categorized as similar land uses as night clubs, amusement arcades, etc. with appropriate land use standards to protect the greater public interest.

Stephen Fagyas of Commercial Focus Advisory Services made a deputation to the Planning and Growth Management Committee of the City of Toronto on Monday June, 18, 2012. The attached correspondence outlines the approach suggested by the A.E.A.C. for the New Draft City Wide Zoning By-law.

Download AEAC-Committee-Letter


Presentation to the Licensing and Standards Committee

Delivered by E Mail

June 26, 2012

Licensing and Standards Committee
City of Toronto 100 Queen Street West, 2nd Floor
Toronto, Ont. M5H 2N2

Dear Chairman Palacio

RE: Item LS14.3 & Motion MM23.29 - Request for a Staff Report to increase and ensure effective prosecution of charges against body rub, holistic and adult entertainment establishments - Motion MM23.29 referred by City Council on May 8 and 9, 2012 (Ward All)

We have been retained by the Adult Entertainment Association of Canada for the purpose of evaluating and making recommendation on the proposed new draft City Wide Zoning By law, as it pertains to the land use regulations proposed for adult entertainment parlours. We made representation to the Planning and Growth Committee on June 18, 2012 stating that there is a nominal understanding of the land use impacts and implications of adult entertainment parlour land uses, versus that of body rub and holistic establishments. We reiterated that the adult entertainment industry recognizes the need to protect the greater public interest and wishes to contribute to the establishment of appropriate land use regulations in the zoning by law for adult entertainment parlours.

Subsequently, we examined Motion MM23.29 referral to the Licensing and Standards Committee. To our surprise, again there is no separation between the adult entertainment parlors and other uses such as body rub and holistics. Again we wish to bring to your attention that the Adult entertainment parlor industry is not to be categorized with such problem establishments as Body rub and Holistic establishments.

35 The Links Road, Suite 202. Toronto, ON M2P 1T7

Tel: 416 907-8109 Fax: 416 972-9588

E Mail: Stephen@commercialfocusadvisoryservices.ca  June 26, 2012

As well, the adult entertainment parlor industry is currently and actively working together with city staff to return a comprehensive city review and follow-up staff report due in October. As you are aware, the purpose of the review is to define appropriate amendments for some of the invalid and flawed existing by-laws in their particular section of the Municipal Code.

Consequently, the timing of this intensification towards the industry would not be prudent as there is no need to increase prosecution of properly licensed and operation adult entertainment establishments.

We respectfully suggest to you that the greater public interest will be better protected with this separation and recommend intensification towards unlicensed and/or illegal adult entertainment establishments only. This would appear to address existing challenges that the city is experiencing in this regard.

Our client wishes to continue to work with the committee to address problems. However, the place to start is to recognize that Adult Entertainment parlours should be viewed and regulated as a form of entertainment rather than activities typically associated with body rub and holistics establishments.

Consequently, it is desirable to further intensify the prosecution of unlicensed and illegal adult entertainment facilities, body rub, holistics, and other problem establishments in Toronto.

In conclusion, we offer to work with your committee and staff to address our mutual objectives of addressing problem establishments while recognizing the need to separate the adult entertainment industry from other less desirable activities.

Yours Sincerely,

Stephen I. Fagyas, M.A. , M.C.I.P., R.P.P.
Commercial Focus Advisory Services