Sept 2021 Changes To S.172 & Reg 455/07 - Private Property Vs Highway

Hi folks,

I have not been charged under the HTA but I'm hoping to improve my understanding here, if possible.

As various news outlets have been sharing with the public, there are new changes to Section 172 of the HTA and Regulation 455/07, dealing with the exact vehicle operations that are deemed to be "stunts" and also dealing with the places where those operations are prohibited and punishable.

I have the following questions, which I don't know who to turn to for an answer, perhaps my MPP...but here they are:

1. It is my understanding that historically, prior to the new changes effective 2021-09-12, the Highway Traffic Act has only been applicable to (enforceable on) "highways", those being not-privately-owned thoroughfares for motor vehicles, and also including privately owned ones where the owners have made agreements with whatever appropriate authority (e.g. 407). Accordingly, as an example, my local grocery store parking lot would be a place where the HTA would not apply, and the HTA could not be enforced against such things as teaching a non-G1-holding teenager how to operate a vehicle, or doing donuts in the snow.

2. It is my understanding from reading the changes, specifically Reg. 455/07, s. 5 (6), that the Stunt-specific provisions of the HTA are (effective 2021-09-12) now applicable to any private property "parking lot" if it is accessible from a highway (in normal speak, road). Example: it would be valid for the police to charge a driver with stunting for doing donuts in the snow of a grocery store parking lot (455/07 S. 3 (3))

3. If #1 is correct, and #2 is also correct, is there a more advanced or public-consulted legal process that should have taken place before changing the scope of the HTA so dramatically? What recourse does the public have if dissatisfied with this change?

4. If #1 is correct and #2 is also correct, does this have any wider-reaching implications across the rest of the HTA, where you could for example be charged with Failure to Yield at an intersection wholly contained within a grocery store parking lot?

Looking forward to any insight that is available. Obviously it is understood that I'm not literally speaking to the writers of the HTA and anything given is an interpretation, not authoritative, unless qualified as being so.

Thanks!