REGENERATIVE TORONTO — DERIVATIVE CAMPAIGN ASSETS

Wave 4: FOI Filing Templates — Ready to Submit

Municipal Freedom of Information and Protection of Privacy Act (MFIPPA)

Ontario Freedom of Information and Protection of Privacy Act (FIPPA)

The Campaign for a Regenerative Ontario | Regenerative Toronto | By The Unknown Soldier

Document ID: MAIN-DERIV-004 Date: June 29, 2026 Author: The Unknown Soldier Status: Legal review recommended before filing. Sources for all facts cited internally. Three requests drafted.

OVERVIEW: THE THREE TARGET INVESTIGATIONS

How to file: - MFIPPA (City): Online at toronto.ca/city-government/accountability-operations-customer-service/city-administration/city-managers-office/city-clerks-office/access-to-information/ - FIPPA (Province): Online at ontario.ca/page/access-records - Fee: $5.00 filing fee per request (request fee waiver on public interest grounds) - Tip: File all three simultaneously on the same day; they run concurrently

FOI-001: OPERATOR SURPLUS RECOVERY

Act: Municipal Freedom of Information and Protection of Privacy Act (MFIPPA) Institution: City of Toronto — Toronto Shelter and Support Services Division Filing fee: $5.00 (include fee waiver request)

[DATE]

City of Toronto Access & Privacy Office City Clerk's Office 100 Queen Street West, 12th Floor, West Tower Toronto, ON M5H 2N2

RE: Freedom of Information Request — Shelter Operator Surplus Recovery

Pursuant to the Municipal Freedom of Information and Protection of Privacy Act (MFIPPA), I am requesting access to the following records held by Toronto Shelter and Support Services Division (TSSS):

Records Requested:

1. All operator reconciliation documents, surplus calculations, and recovery correspondence related to the warming centre and winter respite site programs for program years 2021-22, 2022-23, and 2023-24, as referenced in the Toronto Auditor General's 2025 Audit of TSSS Emergency Warming Centres and Winter Respite Sites.

2. The names, legal corporate names, and CRA registration numbers of all third-party operators referenced as "Program A," "Program B," "Program C," and any other anonymized operators in the 2025 Toronto Auditor General's report on warming centres and winter respite sites.

3. All correspondence between TSSS staff and any warming centre or winter respite site operator regarding surplus recovery, reconciliation adjustments, or disputed amounts for the period January 1, 2022 to December 31, 2025.

4. Any written policies, directives, or memoranda governing the calculation, recovery, and enforcement of surplus recovery obligations in Purchase-of-Service contracts for warming centre and winter respite programs.

5. The current balance of unrecovered surpluses owed to the City by any contracted warming centre or winter respite site operator as of the date this request is processed.

Fee Waiver Request: I request a waiver of applicable fees on public interest grounds under Section 45(4) of MFIPPA. The requested records relate to the use of public funds ($22.2 million in 2023-24), documented by the City's own Auditor General, who found $2.9 million in operator surpluses remained unrecovered as of October 2024. Disclosure serves the accountability function that MFIPPA is designed to protect.

Format: Electronic records preferred (PDF or searchable format).

Applicant: Name: [YOUR NAME] Address: [YOUR ADDRESS] Phone: [YOUR PHONE] Email: [YOUR EMAIL] Signature: _____ Date: [DATE]

Internal note for campaign use: The AG's 2025 report names operators only as "Program A, B, C." Section 10 of MFIPPA allows the City to protect third-party commercial information but the names themselves are unlikely to be protected — they are parties to public contracts. If the City denies the operator names, appeal to the Information and Privacy Commissioner of Ontario (IPC). The IPC has generally ruled that the identity of parties to public contracts is not protected commercial information, though IPC decisions are fact-specific and not guaranteed in any individual case. If the City denies and an appeal is needed, consult a lawyer experienced in FOI/MFIPPA appeals rather than relying on this general pattern alone. The denial itself becomes a story regardless of the appeal's outcome.

FOI-002: THE HOTEL NAMES

Act: Municipal Freedom of Information and Protection of Privacy Act (MFIPPA) Institution: City of Toronto — Toronto Shelter and Support Services Division Filing fee: $5.00 (include fee waiver request)

[DATE]

City of Toronto Access & Privacy Office City Clerk's Office 100 Queen Street West, 12th Floor, West Tower Toronto, ON M5H 2N2

RE: Freedom of Information Request — Hotel Emergency Shelter Operator Identification

Pursuant to the Municipal Freedom of Information and Protection of Privacy Act (MFIPPA), I am requesting access to the following records held by Toronto Shelter and Support Services Division (TSSS):

Records Requested:

1. The complete names, legal corporate names, and addresses of all hotel operators identified in the Toronto Auditor General's May 2022 report "Part 2 of the Audit of Emergency Shelters: Lessons Learned from Hotel Operations" as "Hotel A," "Hotel B," "Hotel C," "Hotel D," and any additional hotels involved in the City's hotel emergency shelter program from 2019 to 2023.

2. All hotel program contracts, including all schedules, amendments, and renewals, entered into by the City of Toronto (through TSSS or SSHA) with hotel operators for the purpose of emergency shelter accommodation for the period January 1, 2019 to December 31, 2023.

3. All invoices submitted by hotel operators under these contracts for the period January 1, 2019 to December 31, 2023, and all related payment records showing amounts actually paid.

4. All occupancy reports, room utilization reports, and vacancy records provided by hotel operators under these contracts for the same period.

5. All correspondence and records relating to the City's identification, quantification, and recovery of the $13.2 million in charges not permitted under hotel contracts, as documented in the 2022 Auditor General report. This includes: amounts recovered to date; amounts written off; any settlement agreements.

Fee Waiver Request: I request a waiver of applicable fees on public interest grounds under Section 45(4) of MFIPPA. The requested records relate to the expenditure of $320 million in public funds in 2021 alone on hotel emergency shelters, and a documented $13.2 million ($14.9 million including HST) in charges not permitted under contract. These amounts were documented by the City's own Auditor General in May 2022. Public disclosure serves a significant accountability function.

Format: Electronic records preferred.

Applicant: Name: [YOUR NAME] Address: [YOUR ADDRESS] Phone: [YOUR PHONE] Email: [YOUR EMAIL] Signature: _____ Date: [DATE]

Internal note for campaign use: The Auditor General is legally empowered to disclose findings but may redact third-party operator names in its public reports. However, these are parties to public contracts — the City has no legitimate basis to refuse their names. Key follow-up questions if names are obtained: (1) Did any hotel operator donate to Toronto municipal election campaigns? (2) Are any hotel operators connected to developers who received City approvals? (3) Was $13.2M ever fully recovered, and from which operators?

FOI-003: THE COHB SUSPENSION CORRESPONDENCE

Act: Freedom of Information and Protection of Privacy Act (FIPPA) Institution: Province of Ontario — Ministry of Municipal Affairs and Housing (MMAH) Filing fee: $5.00 (include fee waiver request)

[DATE]

Freedom of Information Coordinator Ministry of Municipal Affairs and Housing 777 Bay Street Toronto, ON M5G 2E5

RE: Freedom of Information Request — Canada-Ontario Housing Benefit Suspension 2024

Pursuant to the Freedom of Information and Protection of Privacy Act (FIPPA), I am requesting access to the following records held by the Ministry of Municipal Affairs and Housing (MMAH):

Records Requested:

1. All correspondence (including emails, letters, briefing notes, meeting minutes, and memoranda) between the Ministry of Municipal Affairs and Housing and the City of Toronto (including the City Manager's Office, Toronto Shelter and Support Services, and the Housing Secretariat) regarding the administration, suspension, restriction, or restoration of Canada-Ontario Housing Benefit (COHB) allocations for the period March 1, 2024 to January 31, 2025.

2. All internal MMAH briefing notes, decision records, and ministerial correspondence regarding the basis and rationale for any pause, restriction, or delay in COHB allocations to the City of Toronto during the period April 1, 2024 to October 31, 2024.

3. All correspondence between MMAH and the federal government (Housing, Infrastructure and Communities Canada; IRCC; Treasury Board) regarding COHB allocation decisions affecting the City of Toronto for the period March 1, 2024 to January 31, 2025.

4. Any conditions attached to the restoration of COHB allocations and/or the $5.5 million COHB "top-up" announced in December 2024 in connection with the Safer Municipalities Act, including any written agreements, letters of understanding, or terms requiring municipalities to take specific actions regarding encampments as a condition of receiving COHB funding.

5. All impact assessments, briefing notes, or analytical documents prepared by MMAH staff regarding the effect of the April-October 2024 COHB allocation pause on shelter-to-housing exits in the City of Toronto.

Fee Waiver Request: I request a waiver of applicable fees on public interest grounds under Section 57(4) of FIPPA. The City of Toronto's TSSS 2026 Budget Notes documented a 26.7% drop in shelter-to-housing exits in 2024 (5,927 in 2023 to 4,344 in 2024), with the COHB allocation pause during April-October 2024 as the most visible policy correlation. The October 2024 homeless count of 15,418 was a record high. These decisions by the Province directly affected thousands of individuals. Public disclosure serves the accountability function that FIPPA is designed to protect.

Format: Electronic records preferred (PDF).

Applicant: Name: [YOUR NAME] Address: [YOUR ADDRESS] Phone: [YOUR PHONE] Email: [YOUR EMAIL] Signature: _____ Date: [DATE]

Internal note for campaign use: This is the highest-political-value FOI of the three. If the correspondence confirms the COHB suspension was deliberate, politically motivated, or tied to housing target negotiations with the City, it is a publishable story. If the correspondence shows conditions attached to the December 2024 restoration (specifically: municipalities must clear encampments to receive COHB), that is documented coercion and strengthens both the HMK-003 accountability case and HMK-007 legal rights case. The Province has 30 days to respond (extendable to 60 with notice). Expect a 60-day extension. If denied, IPC appeal — the denial itself confirms the files exist and are sensitive.

FILING TIPS

Timeline management: - File all three simultaneously — they run concurrently, each with a 30-day clock - Note that MFIPPA and FIPPA allow institutions to extend to 60 days; plan for 60 days as baseline - Mark your calendar for follow-up if no response within 30 days

Fee waivers: Each request includes a public interest fee waiver. Do not pay fees before the institution rules on the waiver. If the fee waiver is denied, appeal to the IPC — $35 appeal fee, and the IPC has broad discretion to grant waivers in public interest cases.

IPC Appeals: If any request is denied in full or part, or if the institution claims excessive fees, appeal to the Information and Privacy Commissioner of Ontario within 30 days of the decision. The IPC appeal fee is $25 (MFIPPA) or $35 (FIPPA). The IPC regularly orders disclosure of records the City or Province initially refused.

Third-party notifications: For FOI-001 and FOI-002, the institution must notify hotel/shelter operators that a request has been made about them. Operators have 20 days to make representations about why their information should be exempt. This adds time but operators have limited grounds to object to disclosure of their names as parties to public contracts.

Journalist use: These templates are also available for direct journalist filing. Journalists typically have somewhat stronger public interest grounds for fee waivers and expedited processing. Filing in your own name and offering to share results with journalists may be more tactically effective than the campaign filing directly.

All factual claims in this document are sourced to primary-sourced verified library. AG 2025 (warming centres); AG 2022 (hotel operations); 2024 SNA (COHB suspension). Legal advice recommended before filing any FOI request.

FOI-004: THE MINISTRY'S OWN "UNOFFICIAL ESTIMATE" — 234,000

Act: Freedom of Information and Protection of Privacy Act (FIPPA) Institution: Province of Ontario — Ministry of Municipal Affairs and Housing (MMAH) Filing fee: $5.00 (include fee waiver request)

[DATE]

Freedom of Information Coordinator Ministry of Municipal Affairs and Housing 777 Bay Street Toronto, ON M5G 2E5

RE: Freedom of Information Request — Ministry "Unofficial Estimate" of Provincial Homelessness (234,000)

Pursuant to the Freedom of Information and Protection of Privacy Act (FIPPA), I am requesting access to the following records held by the Ministry of Municipal Affairs and Housing (MMAH):

Records Requested:

1. The complete transition binder (or relevant excerpted sections concerning homelessness statistics) prepared for the Associate Minister of Housing in or around July-August 2024, including the page(s) referencing an "unofficial estimate" of approximately 234,000 individuals experiencing homelessness in Ontario, as reported by The Trillium on August 13, 2024.

2. All underlying data sources, calculation methodology, and analytical notes used to produce the 234,000 figure cited in that transition binder.

3. Any internal Ministry correspondence discussing the accuracy, sourcing, or public characterization of the 234,000 figure following the August 13, 2024 Trillium report, including the basis for the Ministry spokesperson's subsequent public statement that the figure was "inaccurate."

4. Any corrected, revised, or alternative homelessness estimate the Ministry has produced internally since August 2024, if the 234,000 figure was in fact determined to be inaccurate.

5. The underlying data and methodology behind the related figure in the same transition binder that 59,100 Ontario Works/ODSP recipients were homeless as of April 2024.

Fee Waiver Request: I request a waiver of applicable fees on public interest grounds under Section 57(4) of FIPPA. The Ministry's own internal document contains a homelessness estimate roughly nine times higher than the Auditor General's previously calculated rate, yet the Ministry has publicly disputed this figure without providing a corrected number or explaining its methodology. Given that Ontario's homelessness response — funding, strategy, and public communication — depends on an accurate understanding of the population's true scale, disclosure of this methodology serves a clear and substantial public interest.

Format: Electronic records preferred (PDF).

Applicant: Name: [YOUR NAME] Address: [YOUR ADDRESS] Phone: [YOUR PHONE] Email: [YOUR EMAIL] Signature: _____