Commentaire 27 – commentaires et rétroaction

Robert W. Barclay

By Robert W. Barclay, BA, LLB

Introduction

Earlier this year, I provided you with my thoughts and ideas on re-distribution in Ontario, prior to you commencing your work. I have made various submissions to redistribution commissions, both federal and provincial, since the 1970s. I hold a degree in political science specializing in Canadian political systems from the University of Toronto, as well as a law degree from the same institution. In addition, I have been a long-time student of redistribution, not only in this country, but also in Britain and Ireland. I wish to provide you with my comments and suggestions regarding your proposal.

In providing my comments, I will refer to riding rather than electoral district simply because it is shorter to type. Names of existing ridings will be shown in normal lower case. Riding names proposed by the Commission will be shown in italic lower case, while alternative names suggested by me will be in norrmal capitals. I have had difficulty accessing population data for dissemination areas, so in the odd case population approximations will be used.

Overview

I congratulate the Commission on its work in this matter. Generally, the proposal is an excellent attempt to resolve the difficulty of adding only one additional seat allocated to the province. I want to state my agreement in removing one seat from both Toronto and northern Ontario. It was a necessity in dealing with the paucity of seats to be added. Additionally, I wish to applaud your efforts to use only a 10% variation up and down from the quota in southern Ontario. The liberal use of the allowable 25% variations in the past has long rankled me.

Having said the above, I believe that you will find that people put more emphasis on municipal boundaries than the Commission has. I must admit that upon first viewing the maps of the proposal, my first thought was that it reminded me of the redistribution of the 1880s in that it takes pieces of many different counties and combines them to form ridings. The purpose of doing so back then, when Parliament carried out the task, was to so-called hive the Grits. I want to be clear that I am not ascribing any such nefarious purpose to the Commission, but merely commenting on how multiple pieces have been taken from many counties and distributed elsewhere. It should be remembered that an MP reports to and deals with county governments, thus the more the MP represents the greater his or her workload.

It should also be remembered that there is an advantage to a voter in having a certain degree of continuity in both riding boundaries and riding names. It makes it easier for a voter to engage in the electoral process when things are familiar. At a time when there is great concern about a drop in voter turnout, anything that encourages and assists a voter in participating is to be desired. There are a number of instances where so-called border communities which are municipally in one county, but sit physically partly in another county can be used to increase and decrease riding populations to help fit within your percentage variation parameters. These are both incorporated and unincorporated., but census recognized, population places.

Finally, I wish to comment on what I refer to as Lakeshore creep. The name first appeared in the 1960s in regard to a provincial riding in Toronto in an area generally known as such. Later, it was adopted for federal purposes for the same general area as Etobicoke-Lakeshore. In the last redistribution, it showed up in Mississauga. Now, it has been extended to Oakville, Burlington and Grimsby. Where next – Oshawa, Kingston, Haldimand? It is my opinion that it has lost all meaning as a descriptive identifier.

Northern Ontario

The Commission has done an excellent job of rearranging the northern ridings to both remove one riding and create a logical structure from what remains. I especially like he creation of an Indigenous focused riding. The only suggestion that I would make here is changing the name of Sault Ste. Marie riding to Sault Ste. Marie – Algoma, since it includes a sizable portion of the District of Algoma.

Eastern Ontario

Again here, I find the riding adjustments solid, but with several caveats. Firstly, the rearrangement of Lanark – Frontenac and Leeds-Grenville – Rideau Lakes – Thousand Islands seems extremely drastic and disruptive. The proposed Lanark - Frontenac would have an MP reporting to and dealing with five upper municipal tier governments, namely the counties of Frontenac, Lanark, Leeds-Grenville and Renfrew and the city of Ottawa. This seems excessive. Leeds and Grenville counties could be kept whole by adding the border town of Smiths Falls to them to form a continuation of the present arrangement. The town physically is located partially in the geographic county of Leeds. It would have a population of 113, 324 which is very close to quota. The name of Leeds – Grenville could continue to be used. The riding of Lanark – Frontenac – Kingston could continue as at present, less Smith Falls, but with the addition of the portion of Ottawa in the Commission's proposal, as well as the portion of Ottawa assigned to the proposed Algonquin – Renfrew – Pembroke.. It would have a population of approximately 116,000 and would be renamed Lanark – Frontenac – Carleton . I feel that Greater Madawaska should be added back to Algonquin – Renfrew – Pembroke keeping Renfrew County whole and continuing the existing Renfrew - Nipissing – Pembroke under its new name. The population would be 107,420 which is both within the 10% variation parameter and not out of line for a largely rural riding.

An alternative which the Commission might want to consider is a modification of its proposed division which would involve combining all of Leeds and Grenville Counties with the portion of Kingston lying north of Hwy. 401 ( ie. the portion presently in Lanark – Frontenac – Kingston). You could also consider adding the portion of Kingston lying south of Hwy. 401 and east of Road 16, which lies next to Leeds and Grenville and may feel affinity with Gananoque. The population would be approximately 112,500 and the name Leeds – Grenville – Kingston could be used. Leeds and Grenville Counties would be kept whole and the MP would only need to deal with two upper tier municipalities. The second riding would consist of all of Lanark, including Smith Falls, plus North, Central and South Frontenac and the areas of Ottawa noted in the paragraph above. The population would be approximately 118,000 and the name would be Lanark – Frontenac – Carleton. Again, Greater Madawaska would be added back to a revised Algonguin – Renfrew – Pembroke .as in the paragraph above.

If you find it necessary for geographic or population reasons to continue with the division proposed by the Commission, I would suggest using the name Lanark – Frontenac – Rideau to recognize the parts of Leeds and Grenville included. All parts, at a minimum, abut the Rideau River and the name would have meaning to the residents of those parts. The southernmost riding could be called Leeds – Grenville – Southern Frontenac. I must stress, however, that I prefer the alternatives suggested by me above for population purposes and familiarity to voters.

Ottawa

I have no comments on this area as it all seems logical and reasonable.

Central East Ontario

The only change that I would suggest here is removing the area of Cavan-Monaghan north of Hwy. 115 and west of Hwy 7 from Haliburton – Kawartha Lakes – Brock and adding it to Northumberland . It does not seem right that a small municipality like Cavan- Monaghan should be split between three ridings. Keep all the area west of Hwys. 7 & 28 in one riding. It has the additional benefit of reducing the population of Haliburton – Kawartha Lakes – Brock a bit and increasing the population of Northumberland a bit, thus bringing both closer to the quota.

Durham Region

My only comments in this region relate to names. I would suggest keeping the name Durham for the proposed Bowmanville – Oshawa North for continuity and familiarity to voters. The area in this proposed riding is all in the present Durham riding and the area has employed that name through several redistributions.

Since the proposed Lake Simcoe – Uxbridge riding contains much of the most easterly and northerly areas of York Region and the central areas of Durham region, I would propose using the name York - Durham. If, in the alternative, you wish to retain reference to Lake Simcoe, then I would suggest using the name Lake Simcoe – Scugog as it gives a better indication of the extent of the riding and provides recognition to the Mississaugas of Scugog Island First Nation.

York Region

I have no comments on this area, other than those relating to the name of the new riding outlined under Durham Region above.

Mississauga

Once again, my only comments here involve naming. I have made my feelings about Lakeshore creep known earlier in this submission. The name Mississauga South was a perfect descriptor for the southernmost riding in the city. If names had to change at the last redistribution to reflect localities, then the name used should have been Mississauga – Port Credit and I would suggest a change to that name now. Port Credit was an incorporated municipality prior to the creation of Mississauga, similar to Streetsville whose name was used in the northwest riding of the city. I would also suggest that the name Mississauga – Streetsville continue to be used for that riding for familiarity to voters. It gives recognition to a former municipality as does the use of Port Credit.

Brampton, Caledon and Dufferin

Quite a bit of scrambling of names has occurred within Brampton, with usage jumping around the city. Much of the area of Brampton East has suddenly become Brampton North. I feel that it would be more familiar to voters and provide continuity if the following changes from the proposal occurred:

• Brampton Southwest to Brampton West
• Brampton Southeast to Brampton South
• Brampton North to Brampton East
• Brampton – Mayfield West to Brampton North – Mayfield

The only changes in boundary that I would suggest relate to the proposed Dufferin – Caledon. Both the townships of East Garafraxa and Mulmer should be returned to the riding and the geographic township of Adjala should be returned to Simcoe County. East Garafraxa has very strong ties to Orangeville, which it abuts. The new population of the proposed riding would be 120,812, a net increase of just over one thousand, but still well within the 10% variation parameter. The change would allow the county of Dufferin to remain whole. It would also reduce the upper tier municipalities for the MP to deal with from three to two. The effect on the population of the proposed Wellington – Halton would be to reduce it to 108,361. This is still within the proposed variation and could be increased with changes within the city of Guelph which I will refer to below.

Halton, Guelph and Wellington

I have long thought that it would be more reasonable to divide the southernmost part of Halton Region into three ridings each fronting on Lake Ontario. It would produce more block-like ridings which would be less lengthy between their extremes. In order to achieve this, I would propose that the proposed ridings of Oakville North and Oakville Lakeshore be re-arranged. The dividing line between the two ridins would be Sixteen Mile Creek from Dundas St. to Upper Middle Road, Nottinghill Gate from Upper Middle Rd. to the Queen Elizabeth Way, and Third Line from QEW to Lake Ontario. The easterly riding would have a population of approximately 115,500 would carry the name of Oakville. The westerly one, with a population of approximately 113,000, I would name BRONTE or Bronte Creek. The westerly riding would contain the community of Bronte in its south end and Bronte Creek Provincial Park in its north end, so the names would be familiar and relatable to residents. The proposed riding of Burlington Lakeshore would stay as proposed, using the name Burlington.

It has always been my opinion that an urban area with enough population to support at least one whole riding should not be divided into two parts which are placed into different abutting ridings. This is precisely what has occurred with the proposed ridings of Burlington – Milton West and Georgetown – Milton East. A riding can be constructed with most of Milton's core and a population of about 118,215. The northerly boundary would be Steeles Ave, from Regional Rd. 22 to Hwy 401 and thence to James Snow Pkwy. The westerly limit would be Regional Rd, 22 from Steeles Ave. To Britannia Rd.. The southerly boundary would be Britannia Rd. fron Regional Rd. 22 to Thompson Rd., Louis St. Laurent Ave. from Thompson Rd. to Fourth line and Derry Rd. from Fourth Line to James Snow Pkwy. The easterly boundary would be James Snow Pkwy, from Derry Rd. to Hwy 401. This riding would contain almost all of the built up urban core of Milton. The remaining lands set aside for the proposed Burlington – Milton West and Georgetown – Milton East would be merged into one riding wrapped around Milton riding similar to how Wellington – Halton wraps around Guelph. This riding would have a population of about 114,562 and be named Halton.

If you decide for physical or population reasons that you must retain your proposed division, I would suggest two name changes. Burlington – Milton West should be renamed MILTON – BURLINGTON or Milton West – Burlington, as it is Milton which is contributing the lion's share of the population. Since Georgetown- Milton East includes substantial population from three different municipalities, I suggest the use of the collective name Halton for the proposed riding. Having said the above, I must stress, however, how strongly I feel about forming one riding with the bulk of Milton's urban core in it.

I would also suggest a different division in the city of Guelph. I would propose using the Hanlon Expressway as the dividing line up to Woodlawn Rd. W. and Silvercreek Pkwy. N. north of Woodlawn Rd. W. The area to the west of this line would be placed in Wellington – Halton giving it a population of approximately 111,700 even after the removal of East Garafraxa. The remainder of the city of Guelph would form Guelph riding with a population of approximately 115,300. The Hanlon Expressway makes a natural boundary separating the western side of Guelph from the remainder of the city.

Central Ontario

I agree with the construct of the proposed New Tecumseth – Bradford riding, but feel that a change of name might be in order. A sizeable area of both King and East Gwillimbury are included in the riding, contributing about 27% of its population. A recognition of this fact should be shown in the name. The Holland River flows through part of King and then along its northerly boundary. The East Holland River flows through the part of East Gwillimbury included. I would suggest that the name be changed to Simcoe South – Holland River Valley in light of the above. The term Simcoe South accurately reflects its location in Simcoe County.

Barrie is another example of a city that should have one urban riding entirely within its urban area. This can be done by taking the Barrie portion of the present Barrie – Springwater – Oro-Medonte and adding to it the portion of the city lying south of Tiffin St. and east of Hwy. 400. It produces an urban riding with a population of 113,185 which would be named Barrie – Kempenfelt after the bay whose head it wraps around. In the alternative it could be named Barrie Northeast as it contains the northern and eastern areas of the city. The remainder of the city would be combined with Innisfil, Essa and Adjala-Tosorontio to produce a riding with a population of 110,339 under the name Barrie – Simcoe Centre. An alternative name would be Barrie Southwest – Simcoe Centre.

There are several alternatives as to what can be done with Springwater and Oro-Medonte if they are decoupled from Barrie. The least disruptive one would be to keep the present riding of Simcoe North intact. As I recall from the last redistribution, the portion of Oro-Medonte placed in that riding was done at the request of residents who felt a strong community of interest with Orillia and I think that that feeling should be respected again. The proposed Penetanguishene – Couchiching riding also serves to sever Hwy 12 which is the east-west spine of the north Simcoe area. I would suggest that the current riding of North Simcoe be renamed Simcoe North – Couchiching. The present riding has a population of 120,656 which is within the 10% variation. The term North Simcoe is familiar to voters and residents. In this alternative, the remainder of Oro-Medonte would combine with Springwater, Clearview, Wasaga Beach, Collingwood and The Blue Mountains to form a new Simcoe – Grey with a population of 109,971.

The second alternative would be to place all of Oro-Medonte into Simcoe North – Couchiching, while removing Tiny, Penetanguishene and the Christian Island First Nation from the riding. The resultant riding would have a population of 111,297. Springwater, Tiny, Penetanguishene, Christian Island First Nation, Clearview, Wasaga Beach, Collingwood and The Blue Mountains would then form a riding with a population of 119,330. This riding would be called Georgian BAY as it fronts on a good portion of the lower side of that bay.

In either of the above alternatives, the present riding of Bruce-Grey-Owen Sound could remain as presently constituted with a population of 113,348. A knock-on benefit is that the present riding of Huron-Bruce could also remain largely unchanged. Both of these would aid voter and resident familiarity.

Hamilton and Niagara

I am in favour of the arrangement of ridings in this area. My sole comments would be in regard to names. I feel that the proposed Flamborough – Glanbrook should be renamed Hamilton – Wentworth. This would recognize that these areas are now part of Hamilton, while at the same time preserving the name of the old county of Wentworth which was amalgamated into the city, similar to how Carleton perpetuates the name of Carleton County which was amalgamated into Ottawa. To get rid of Lakeshore creep I would rename Hanilton East – Stoney Creek – Grimsby Lakeshore to Hamilton East – Stoney Creek – Lower Grimsby. This recognizes that the portion of Grimsby included in the riding is the area below the Niagara Escarpment. Finally, I would recognize the portion of Haldimand County included in Niagara West by changing the name to Niagara West – Dunnville, as the latter is the largest community within that portion of Haldimand.

South Central Ontario

I was surprised to see the return of the proposed Kitchener – North Dumfries riding in the Commission's proposal, as it was also included in the proposals at the last distribution, but was discarded in the final report. I believe that this was based on strong objections from the residents of North Dumfries, who felt a greater community of interest with Cambridge. In addition, I was surprised to see that the community of Hespeler is being divided. Using the Speed River as a dividing line removes the Silver Heights neighbourhood from the Hespeler community. While usually I favour putting as much of a city in one riding as possible, in this case I am not. There is very definite barrier between Hespeler and the rest of Cambridge in the form of a wide Hwy. 401 and the township of North Dumfries fits more naturally with Cambridge than Kitchener.

With one exception, the present riding boundaries should be left unchanged in Waterloo Region. The most severe population variations are easily fixable by transferring one area from the present Waterloo to the present Kitchener-Conestoga. The area to be transferred would be that portion of Kitchener lying east of the Conestoga Parkway and north of the CNR line, essentially the Bridgeport neighbourhood. This reduces the existing Waterloo riding to the city alone with a population as noted in the proposal. It raises Kitchener-Conestoga's population to 112,933. The portion added to Kitchener-Conestoga has good connections to nearby communities already in the riding, such as Bloomingdale, Breslau, Maryhill and Conestogo. The remaining ridings and their populations would remain unchanged from the present. The population of all ridings in the Waterloo Region would be well within the 10% variation parameter.

One benefit of leaving the above ridings unchanged is that the present Cambridge riding contains a small strip of Brant County. This serves to reduce the population of the proposed Oxford – Brant and Brantford ridings. This takes on some importance, as I would propose adding back into Oxford – Brant the strip on the west side of Zorra Township which the proposal has removed. This helps to keep Oxford County as whole as possible. I see no problem in having Tillsonburg added to Haldimand – Norfolk – Six Nations as it was previously included in the provincial riding of Norfolk prior to Ontario adopting federal ridings for the composition of the provincial legislature.

Southwestern Ontario

As noted in my comments on Central Ontario, re-arranging the ridings there allows the present riding of Huron –Bruce to remain as exactly as it is ( including leaving the township of Howick in it). This allows Huron County to remain whole. I would also add to it the border community of Grand Bend, which is considered a population centre by Statistics Canada with a population of 3,031. This community lies partly in geographic Huron county. The total population of the riding , which would retain its present name, would be 115,960. Removing Grand Bend would reduce the population of the riding of Sarnia – Lambton which I will propose later.

I also suggest adding the border community of Tavistock, another Statistics Canada population centre, to the present riding of Perth-Wellington which would otherwise remain constituted as at present. Tavistock lies partly within geographic Perth county and is, in fact, closer to Stratford than to Woodstock. It has a population of 3,171. By removing Howick from the proposed riding and adding Tavistock it produces a riding under the same name with a population of 117,100. This change also reduces some of the population pressure on Oxford – Brant and allows the transfer of the western-most strip of Zorra Township to that riding.

I believe that there needs to be a total restructuring in London, Middlesex and Elgin. I would suggest altering the proposed ridings to produce four ridings within a combined London and Middlesex. The population of these ridings would admittedly be on the high side, but it appears that this is common in the proposal for the ridings from London to Windsor. It seems clear to me that if the redistribution formula had produced another riding for Ontario that it should have gone to this corner of the province.

I would start the restructuring with the proposed riding of London Centre and add to it census tract CT 0031.00 which lies immediately to the north of the area of the proposed riding that juts east of Adelaide St. S. This produces a riding with a population of around 126,100. Then, I would take the proposed London West and remove from it all parts of the proposed riding lying south of Southdale Rd. W., while adding the area between Southdale Rd. W. and Commissioner's Rd. W. from Wharncliffe Rd. S. to Wellington Rd. The area being added lies within the present riding of London West. The resultant riding would have a population of around 126,000.

Next, I would re-create the riding of London – Fanshawe. It would consists of all of the city of London lying east and north of a line described as follows : Commencing at the intersection of the north city limits with Adelaide St. N., thence south on Adelaide St. N. to Dundas St. E., thence east on Dundas St E. to Ashland Ave., thence south on Ashland Ave, to Brydges St, thence east on Brydges St. to Highbury Ave. S., thence south on Highbury Ave. S. to Bradley Ave., thence east on Bradley Ave. to Veterans Memorial Pkwy, thence north on Veterans Memorial Pkwy. To the Thames River, thence east on the Thames River to the east city limits. This produces a riding with a population of around 125,000.

Finally, I would combine the remaining areas of the city of London with all of Middlesex County to create a riding of Middlesex – London South with a population of around 123,000. This riding would have the advantage of involving only two upper tier municipalities which would be a benefit to an MP. As noted above, these ridings have somewhat higher populations, but all are within the 10% variation parameter.

I would propose uniting all of Elgin County with the East Kent Ward of the city of Chatham-Kent, whose west boundary is similar to that included in the Commission's proposal. This should produce a riding with a population around the provincial quota. If more population is required, the area around Dresden could be added or, in the alternative, that portion of South Kent Ward lying northeasterly of City Road 10 and southeasterly of Hwy. 401, depending on how much additional population is desired. The riding would be called Elgin – Kent. This proposal allows all of Elgin County to be included in one riding and produces a riding which involves just two upper tier municipalities. The riding would be then concentrated along the north shore of Lake Erie and be well connected by east west transportation routes.

Southernmost Ontario

Again I would propose some restructuring of the Commission's proposal in this area to provide more definition to the ridings. I would start by putting the city of Sarnia and all of Lambton County ( with the exception of the Grand Bend statistical population centre) into one riding with a population of 125,123 under the name Sarnia – Lambton. While the population is on the high side, it is important to keep in mind that together Sarnia and Lambton County have grown by only 1.2% over the last five years which is well less than one-quarter of the provincial average of 5.8%. The riding population is still within the 10% variation parameter and, given its slow growth rate, is likely to be much closer to the provincial quota by the time of the next redistribution. The suggested riding would have good definition, as it includes virtually of the county and the MP would only be dealing with two upper tier municipalities.

I would take the remaining portion of Chatham-Kent not used in Elgin – Kent and combine it with all of Lakeshore municipality from Essex County and the Walpole Island First Nation to create a riding called Chatham – Kent – Lake St. Clair. I feel that the name would be appropriate as the west side of the suggested riding would wrap around two sides of Lake. St. Clair. Good east-west links occur in the riding using Hwy. 401. The population of this riding would be above the provincial quota, but still within the 10% variation parameter. Chatham-Kent is also growing at significantly less than the provincial average which will tend to keep the population closer to a rising provincial quota going forward. Its boundaries are easily defined and only one municipality needs to be divided (the city of Chatham-Kent).

The chief problem in dealing with the rest of this area is trying to create three ridings that do not go above the 10% variation parameter. I would start by leaving the existing ridings of Windsor-Tecumseh and Windsor West largely intact with two exceptions. I would move all of the area lying northeasterly of Walker Rd. in the present riding of Windsor West into the present Windsor-Tecumseh. This would bring the population of the later up to 127,405. I would then add a small area of the town of Lasalle to Windsor West to bring my proposed Essex riding within the 10% variance parameter. The area transferred would be bounded on the west by Matchette Rd., on the east by Malden Red., on the north by the Town limits and on the south by Naples Creek. This represents the east part of census tract CT 0101.03. This should give Windsor West a population of approximately 127,000. Finally, I would combine Lasalle ( less the above part), Essex. Amherstburg, Kingsville and Leamington into a restructured Essex with a population of approximately 127,500. This riding would run along the north shore of Lake Erie and have Hwy, 3 as a spine. I believe that all of the suggested ridings would just fit within the 10% variation parameter.

Toronto

I have left this for the last as I do not propose to go into any great detail on it. I am pleased that the Commission has seen fit to take one riding from the city. This is certainly warranted given the low populations for some of the existing ridings in the eastern part of the city. In hindsight, going from 22 ridings to 25 ridings in the last redistribution was probably over-reach. Please resist all pressure to return an extra riding to Toronto. I think that the Commission has done an excellent job in the manner that it has arranged the ridings in Etobicoke. I commend the Commission's bravery in breaking through the physical and psychological barrier of the Humber River. Equally, I applaud the Commission for finally breaching the barrier of Victoria Park Ave..

There are a few problematic areas that I can see in the central portion of the city between Hwy. 401 and Lake Ontario, however, I will leave it to those actually residing in the city to comment upon them. The one that I would point out is the awkward placement of part of the Flemingdon Park neighbourhood in the proposed The Beaches –East York . The valley of the East Don River provides a significant physical division of the neighbourhood from the balance of the riding. It has much better connections to the balance of Flemingdon Park along Spanbridge Rd. and St. Dennis Dr. which both cross the barrier posed by the Don Valley Pkwy. Surely, a small part of Scarborough Southwest (CT 0339.00 ?) could be substituted for that neighbourhood. Putting the whole of Flemingdon Park into Don Valley East would allow the return of census tract CT 0267.00 to Don Valley West and re-establish Leslie St. as western boundary of the former.

I like the arrangement of the ridings north of Hwy, 401, but would change two names. Bayview-Finch should retain the name Willowdale for its familiarity to voters and residents and for the fact that it includes much of the present Willowdale riding. Similarily, Scarborough Northwest should keep the name Scarborough – Agincourt for the same reasons. In addition, the name Toronto – St. Paul'S should continue to be used for the proposed St. Clair – Mount Pleasant , again for the same reasons as set out above. I, also, think that you will hear from the residents of Parkdale about the dropping of its name from the proposed Taiaiako'n – HighPark riding, which is really just a slightly altered version of the present riding of Parkdale-High Park. Personally, I prefer to retain the name Parkdale – High Park for its familiarity. I am generally supportive of the Commission's desire to introduce some Indigenous names to ridings, but I do not feel that it is appropriate here.

Conclusion

In my opinion, the Commission has generally done an excellent job in allocating ridings around the province. My comments should not be viewed as criticism, but just as another way of looking at the manner in which the seats are drawn up. I am hopeful that my submission will find favour with you and assist you in carrying out a difficult task.