Comment 11 – comments and feedback

Rhonda Kirkland-Gorham

xxxxxx Oshawa, ON xxx xxx

November 4, 2022

The Honourable Justice Lynne C. Leitch Federal Electoral Boundaries Commission for Ontario PO Box 37018 Southdale London, ON N6E 3T3

Via e-mail ON@redecoupage-federal-redistribution.ca

Madame Justice Leitch:

I strongly urge the Commission to reconsider its troublesome proposal for the 'new' Oshawa electoral district (ED).

There is absolutely no requirement to adjust the Oshawa ED's current boundaries. Owing to several factors outlined below, the most sensible and elegant solution to the challenge with the City of Oshawa – as a whole – and the current ED's population growth is to maintain the status quo, ensuring that Oshawa ED's current boundaries are both re-confirmed and re-adopted by the Commission.

The key driver for changes to the electoral districts across Durham Region and, in particular, Oshawa, is population growth – particularly in that area of Oshawa lying north of Taunton Rd. In stark contrast to the 2012 Commission's initial proposal – which, at that time, provided a good start for public consultation – the 2022 Commission's proposal to redefine the Oshawa district's boundary by reassigning its most northwestern portion to the new Whitby ED is a non-starter and shreds several key principles established during the 2012 Redistribution exercise and the Commission led by Mr. Justice Valin.

The basis for the Commission's proposal is Section 15(1)(b) of the Electoral Boundaries Readjustment Act which states that the Commission shall consider the following in determining reasonable electoral district boundaries:

• Community of interest;
• Community of identity;
• Historical pattern of a district; and,
• Manageable, geographic size in rural areas.

These criteria may also be considered if it is desirable to depart from electoral quota for a province. Further, the Commission may determine to set an electoral district below or above quota by as much as 25% to maintain consistency with the principles outlined in s.15 of the Act. By maintaining the current boundary and setting aside the proposal to 'fob off' the most northwestern portion of the current ED to the new ED of Whitby, the 'updated' Oshawa ED would add approximately 5,000 electors and be only slightly more over-quote versus the Commission's proposal – just as the current Oshawa ED at the outcome of 2012 Redistribution.

It is surprising and unsettling that the 2022 and Commission departed from two key principles established during the 2002 and 2012 Redistribution efforts: Firstly, Durham Region's federal seats no longer remain 'together' within one contiguous region inside Durham Region. The 2012 Commission wisely considered Durham Region as an 'umbrella' entity – similar to most other established Regions or counties across Ontario. The Commission should re-apply and follow that key principle forthwith and, thus, eliminate the widescale disruption posed by its current proposal for almost every Durham Region-based ED.

Second, the population growth in the northern (Brooklin) portion of the current Whitby ED should not impact the Oshawa ED's current or future boundary. Why the Commission has proposed to whittle out several portions of the existing Whitby ED and dispersing certain areas to other electoral districts (such as Pickering) – only to absorb approximately 5,000 residents of the northwestern most corner of the Oshawa electoral district into Whitby – is utterly senseless. This portion of Oshawa should – and must – remain within the Oshawa electoral district boundary. It was rightly returned to the current Oshawa ED during 2012 Redistribution at the urging of hundreds of western Oshawa residents.

The Commission's proposal to split the City of Oshawa among three electoral districts – as opposed to two EDs for the sake of 'quota' fails to consider communities of interest and recent history. Since Confederation, there has always been either a stand-alone or majority-anchored Oshawa ED. As we know, today's Oshawa has two unique challenges: 1) The City's population is too large for one district, and; 2) The City's population remains slightly too small for two EDs. That the previous (2002) Oshawa ED had to take 'haircut' in 2012 was widely acknowledged and understood – as was the previous Commission's decision to allow the 2012-22 Oshawa ED to remain over quota for the sake of preserving communities of interest. In 2012, the portion of the City of Oshawa lying north of Taunton Rd was rightly placed in the adjacent Durham ED and should remain within that ED after the current exercise is complete.

My suggestion to maintain the Oshawa Electoral District's current boundaries – untouched from the 2012 Redistribution exercise is the least burdensome and most elegant solution to the Commission's current quandary because it:

1. Better reflects s.15(1) principles outlined in the Act;
2. Is the least disruptive to the current districts and proposed adjoining districts. Oshawa, for the most part, will remain a distinctive Oshawa-focused electoral district with a distinct urban and suburban footprint;
3. Text BoxRespects the Oshawa's history and its status as the 'centrepiece' and most populous entity in the Region;
4. Ensures that important and highly-identifiable Oshawa-rooted and Oshawa-based entities in the northwestern portion of the Oshawa ED remain inside the 'new' ED. These include: the Oshawa Executive Airport, the Ontario Regiment RCAC Museum, 420 Wing (City of Oshawa) Royal Canadian Air Force Association, and the headquarters of Oshawa's three major radio stations remain anchored in the Oshawa electoral district as opposed to being 'fobbed off' to Whitby – with whom these entities have no shared interest, history or working relationship; and,
5. Resolves Oshawa City Council's long-standing concern (raised during the Redistribution exercises of both 2002 and 2012) regarding the challenges posed by having "three MPs representing Oshawa across three electoral districts" and, instead, ensures that the City of Oshawa continues to be represented by two MPs and split among just two electoral districts.

Owing to the Commission's highly unfortunate and regrettable delay in publishing its proposal for the Ontario electoral districts, far less time was accorded for public consultation in Ontario as opposed to other provinces. Ontario stakeholders had much less time to consider the proposed changes – and virtually no time was available for proper consultations with local municipalities including the City of Oshawa. The Commission should note that both the City and its upper-tier partner, The Region of Durham, were seized with municipal elections when the Commission's long-delayed proposal was published in late August 2022. The staff of the lower- or upper-tier municipalities did not have a fair opportunity to study and/or make recommendations about the Commission's proposal given that all 'new work' – and this politically-sensitive staff work – was delayed or entirely set aside until after election day (October 24, 2022).

Finally, I must point out that Oshawa's proposed EDs should be determined by Oshawa-based stakeholders and should based on the evidence and feedback provided by Oshawa residents. Oshawa residents, representatives, and its eligible voters are the Commission's key stakeholders in the Redistribution process – not the current Member of Parliament for Whitby.

I am grateful to you and the Commissioners for their time and consideration.

Respectfully,

Rhonda Kirkland-Gorham

cc Paula Puddy, Secretary, Ontario Commission