May 21, 2019
Mr. Randy Horton
Executive Director, Ontario Union of Martial Artists
179 Graham Street, Glencoe, ON
Honourable MPP _________________
Re: Regulation Definition of Combat Sports Act, 2019
CC: List of other MPPs and Minister of Culture, Tourism and Sport.
I am writing you today on behalf of the Ontario Union of Martial Artists (OUMA) regarding the impact of Schedule 9, Bill 100, “Protecting What Matters Most (Budget Measures)”, referred to as the Combat Sports Act, 2019 (CSA,2019).
The concern of the OUMA is the potential negative impact CSA, 2019 may have on Amateur Martial Arts based on un-informed regulations created after the bill has received Royal Ascent. CSA 2019 focuses largely on professional competition and is ambiguous in some areas regarding amateur governance.
We ask that the health and longevity, cultural and business development of Ontario’s smaller communities are considered in the formulation of CSA 2019’s regulations. We would like to have a voice to be considered in regulation and prescribed definitions.
The Ontario Union of Martial Artists (OUMA) is a not-for-profit organization recognized by the Canada Corporations Act.
- Our mandate is to unite martial artists and their organizations to have a single voice; to educate and advocate for the autonomy of practice, commerce and cultural development of the martial arts.
- We seek to develop a recreational, cultural and commercial preservation policy that respects and maintains the integrity of all individual martial arts, welcomes the participation of cultural activities unique to those arts, and to develop a governance policy that ensures the safety of all participants.
- More details on the OUMA, its membership and structure are available in the appendices of this document.
Our membership includes martial art club owners and practitioners throughout Ontario and represents martial arts students, teachers and practitioners from small communities that normally aren’t a focus for representation.
With respect to the Combat Sports Act,2019; we would like to express the following concerns:
Interpretation, 1(2)(a): Combat Sport
o Grouping all martial arts practices as Combat Sports is problematic because in many situations, there is no sport aspect to the martial art however they do participate in exhibitions and demonstrations.
o Many martial arts are considered as non-combative by their practitioners. In the case of Tai-Chi, Kung Fu, Aikido and other similar martial arts forms being regulated by Combat Sports policies is counter intuitive and may pose a risk to their cultural development.
o Safety is always the utmost of importance in amateur martial arts competition and in many cases, rules are based on no-contact whatsoever. We would ask that a prescribed exclusion be included to address that non-contact competitions by their nature are non-combative and should be excluded from Combat Sports governance.
The above exclusion would provide a clear guideline for inspectors or other officials when interpreting the act during its enforcement.
License: 6 (4):
o Previous items in this section are focused on governance of professional combat sports. We ask that Item 4 specify professional activities to avoid confusion of application to amateur activity. E.g. “Engage in any other prescribed professional activity.”
o Further ask is to specify that amateur events do not require licensing in the context of section 6.
It seems counter to social development and community best interests to require amateur martial arts coaches, instructors or practitioners to obtain a license to participate or promote a community event. Example: a martial arts demonstration at a community fair or as part of a community parade, or as part of a fund-raising event.
Event Permit, 19(b):
o It is the hope that the prescribed criteria that exclude a person or organization from requiring an event permit include
non-contact amateur competitions or contests
amateur martial arts exhibitions where there is no competitive element
o In the event where a permit is required for an amateur contest or exhibition, we ask that the permit fee be waived if the organization is a not-for-profit recognized by the Canada Corporations Act, or if the event is run as a charitable or fund raising event.
Event Administration Fee, 27
o In many small communities throughout Ontario, martial arts organizations consist of fewer than 10 or 15 members. These organizations rely on fees from amateur tournaments, seminars or other exhibitions to maintain their organization. For the majority of these organizations the profitability is minimal. Adding additional fees will increase the burden they already experience in maintaining their operations and martial arts culture in their community.
o We would argue that requesting an administration fee from such an organization is against the public interest and counter to community and cultural development of martial arts.
o We ask that there be no administration fee for event permit processing for Amateur martial arts.
In summary of the above, the OUMA would request that amateur martial arts have greater consideration in the definitions and regulations of The Combat Sports Act, 2019. Specifically, our position is that even permits, and related fees, should not be required for amateur martial arts competition that Is based on non-contact rules.
Moreover, events such as exhibitions, fund-raising or charitable activities based on recreational and amateur martial arts practice should receive exemption from sanctioning and event permit requirements.
I would like to thank you for your attention to this letter and would welcome any feedback you may have regarding topics herein. On behalf of the Ontario Union of Martial Artists, I would like to invite a meeting between you and some of the Club Owners within our community to share ideas, experiences and information to lead to a well-informed definition of The Combat Sports Act 2019 regulations.
Ontario Union of Martial Artists – www.ontario-uma.ca
7th Degree Blackbelt Koryu Aikijujitsu
6th Degree Blackbelt Chitoryu Karate
4th Degree Blackbelt Kenjutsu and Iaido
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