Comment 101 – comments and feedback

Joe Preston

October 20, 2022

Federal Electoral Boundaries Commission for Ontario
c/o Ms. Paula Puddy, Commission Secretary
PO Box 37018 Southdale
London, Ontario N6E 3T3

Sent via email: ON@redecoupage-federal-redistribution.ca

Re. Proposed Federal Electoral District Redistribution

Dear Ms. Puddy, Commission Secretary:

I am writing in response to the Commission's proposed electoral redistribution to communicate St. Thomas City Council's many significant concerns, and to emphasize our preference for and the importance of maintaining the riding's current boundary. You will find that our concerns and apprehensions are consistent with many of our affected area municipalities.

The proposed district boundaries, if approved, would mean that the City of St. Thomas would be included in a London based riding, South London- St. Thomas and would be split from most of the rest of Elgin County and its lower tier municipalities. In addition, the City's closest municipal neighbour, Central Elgin would be split across two different ridings in this new proposal.

St. Thomas Council understands that timely boundary review is necessary as populations change and grow, however, from our perspective as elected officials responsible for serving in the best interest of our residents and our community, we feel that population alone should not dictate boundary decisions, and that doing so has serious implications for the people and City we serve.

Since the Commission's report was released, representatives from the City of St. Thomas, Elgin County and other local municipalities have met, including with the local Member of Parliament, to review the proposals, discuss areas of concern and consider alternative boundary proposals. There is general consensus that the proposed electoral boundaries are not in the best interest of local municipalities and that the St. Thomas/ Elgin County community, and its citizens will be adversely impacted with their possible implementation.

Our specific concerns, in line with those of other neighbouring municipalities, highlight issues regarding meaningful rural representation and support, harmful impacts to service delivery, and complexity in engaging with Members of Parliament. More broadly, we share and support the concerns of other regional partners as they relate to manageable geographic size of districts, and the division of municipalities into multiple districts.

As noted, in recommending a new London South- St. Thomas riding, the Commission has suggested it relates to growth and the development in the southern part of the City of London and the northern part of the City of St. Thomas

While growth has occurred, the proposal to create a new electoral district, removing the City of St. Thomas from its current riding which includes other Elgin County communities with shared / similar services for which St. Thomas (as a small urban municipality) is a central point, and adding it to a more London-centric riding, is most challenging. The plan ignores well-established systems of service and county-wide collaborations within the community.

In addition, the City acts as the service manager for income and employment assistance, child care and housing and homelessness prevention services for Elgin County and provides planning supports to the Municipality of Central Elgin. City stakeholders would also need to engage with federal representatives in the Elgin-Middlesex-Thames electoral district, as necessary. Although some may suggest that the City might benefit from an additional representative at the Federal level, the proposed federal electoral districts unnecessarily removes St. Thomas from a current electoral district that supports long standing collaborations and it results in fragmentation of the Elgin County community of which St. Thomas and its surrounding municipalities are the core.

Additionally, under the proposal, concerns for the City of St. Thomas include:

1. The inclusion of the City of St. Thomas in the London South – St. Thomas electoral district takes a small urban city and adds it into a new more urban based riding, creating a reality of potential competition with the City of London for federal discussions and supports.
2. The City of St. Thomas and municipal community organizations, including those that provide supports and services across the county would face greater time and complexity when seeking to engage federal government with the increased likelihood of having to organize two meetings rather than one. Also, there could be the potential for risk of contradictory positions by area Members of Parliament where they represent competing political parties.

3. The community identity including rural voice of the St. Thomas/ Elgin County community would be significantly diluted across two ridings that would have City of London and larger urban concerns.

   More broadly, additional concerns include:

4. The proposed ridings of Elgin – Middlesex - Thames and London South – St. Thomas do not respect the historical pattern of Elgin electoral districts.
5. The Elgin – Middlesex - Thames electoral district is difficult to be considered as a district of manageable geographic size in southwestern Ontario. The existing Elgin – Middlesex – London electoral district is 3,557km2 while the proposed Elgin – Middlesex – Thames electoral district is 6,262km2.

6. In support of the City's closest neighbouring municipality, Central Elgin, the municipality has been divided into two. Splitting the Municipality of Central Elgin on John Wise Line does not respect the community identity of the Municipality, as it would be practically impossible to argue John Wise Line divides two community identities within the Municipality of Central Elgin.

   The justification for the proposed change provided by the Commission does not effectively explain the significant changes recommended, nor regrettably, result in a proposed boundary adjustment that creates a reasonable or appropriate revised electoral district for St. Thomas. Moving forward, given the issues identified here, any new boundary adjustment must take into consideration long standing systems of service and collaborative activities that have built and sustained the St. Thomas/ Elgin community.

Therefore, it is the recommendation of St. Thomas City Council that the City of St. Thomas be fully contained and represented within one federal electoral district with Elgin County including all local municipalities. The current composition of the Elgin-Middlesex-London riding satisfies the Commission's stated requirement for population size, thus making it feasible to do so.

St. Thomas City Council appreciates the difficult work of the Commission and your meaningful reflection of the concerns we have outlined in this written submission and looks forward to further engagement and conversation as we work towards a redistribution plan that is appropriate and suited for all affected parties.

Sincerely,
Joe Preston
Mayor
City of St. Thomas