Comment 33 – comments and feedback

David Bailey

Federal Electoral Boundaries Commission for Ontario

c/o Ms. Paula Puddy

Commission Secretary

PO Box 37018 Southdale

London, Ontario N6E 3T3

September 19, 2022

Re: County of Brant Council's Response to the initial proposal of the Federal Electoral Boundaries Commission for Ontario

On behalf of the Council of the County of Brant I provide this response to the initial proposal of the Federal Electoral Boundaries Commission for Ontario (the Commission) for its review and consideration. I note that our Council has yet to ratify a final direction on its response to the Commission's initial proposal as the submission deadline for written comments is misaligned with the meeting cycle of many municipal Councils, but the input from members of Council has been sought and I present the consensus of that consultation.

We acknowledge the difficult task facing the Commission as the redistribution of existing electoral boundaries, primarily in the initial proposal, elicits significant concern from interest parties due to the nature of the Commission's work to equalize riding populations instead of maintaining ridings established by previous Commissions. County of Brant Council's comments on the initial proposal are focused on the general principles it believes the Commission should approach when refining the redistricting plan, specifically as it relates the citizens of the County of Brant.

Traditionally the federal (and since 1999, the provincial) electoral boundaries encompassing the County of Brant have focused on maintaining the County's traditional communities of interest, being the separated City of Brantford, and our First Nations neighbours. This structure had been maintained throughout recent history and was understandably disrupted by the lowered quota for representation that faced the 2012 Commission.

First, we appreciate that the initial proposal recommends electoral boundaries that would lead to a reduction in the number of ridings that divide the County of Brant from the current 3 ridings (Brantford-Brant, Oxford, and Cambridge) to 2 ridings (Brantford, Oxford-Brant.) We believe that a reduction in the number of residents separated from their traditional communities of interest, mainly other areas of the County itself, is a positive step and further refinements could be made on this principle to reduce the separation further.

Second, we recommend that, on principle, the alignment of electoral boundaries should be as consistent as possible across all 3 levels of government as it provides for the best model for good, and effective governance for all citizens. We recognize the reality the Commission faces in providing for effective boundaries for the County of Brant through the grander principle of equal representation. We request that as the Commission refines its proposal that any changes to electoral boundaries that divide the County be consistent with ensuring that as much of the County as possible is aligned with its traditional communities of interest, and that the County's municipal electoral boundaries are considered as to avoid overlapping representation at the federal, provincial, or municipal level. It was noted during our Council's discussion of the matter that the Commission could examine a division of the County that would involve north and south division instead of east and west division as currently proposed.

Finally. we note an awareness that an increased population quota and as such, an increased deviation limit, is available for the 2022 Commission to apply compared to the 2012 process, which can assist the Commission in applying the principles the County has articulated above. We further note that the initial proposal represents a significant improvement from the 2012 Commission's final report, appreciate the work that the Commission will undertake in the coming months, and look forward to further discussions regarding this important subject matter.

Respectfully submitted,

David Bailey,

Mayor

Country of Brant