Comment 122 – comments and feedback

Mary French

Please find attached correspondence from Mary French, Warden of the County of Elgin.

September 23, 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

Dear Ms. Puddy, Commission Secretary:

Re: Federal Electoral Districts Redistribution

I am writing in response to the Commission's proposed redistribution to communicate Elgin County Council's numerous substantial concerns and emphasize our preference for maintaining the riding's current boundary. I greatly appreciate the opportunity to do so.

In the proposed redistribution, two (2) of Elgin County's seven (7) constituent municipalities, namely the Municipality of Central Elgin and a portion of the Township of Southwold, would be split between two (2) federal electoral districts. For context of the geographic scope of the proposed changes, the existing Elgin-Middlesex-London electoral district is 3,557km² while the proposed Elgin-Middlesex-Thames electoral district is 6,262km².

We appreciate that regular boundary review is required in order to reflect population changes and respect the challenging work of the Commission in so doing. However, from our perspective as elected officials responsible for serving in the best interest of our residents while weighing a range of local priorities and contexts, deciding these boundaries based on population alone would have grave implications for the communities we serve.

Our greatest concerns include the following:

• Meaningful representation – Elgin County holding a significant minority share of the riding population would dilute our ability as local representatives to influence the local Member of Parliament to concentrate on and address municipal and resident interests. Elgin County, and in particular the Municipality of Central Elgin, Township of Southwold, and community organizations, would face greater time and complexity when seeking to engage the federal government with the increased likelihood of having to organize two meetings rather than one. Also, there could be the potential for contradictory positions taken by area Members of Parliament representing competing political parties.
• Detriments to government customer service – Having multiple constituency offices and multiple members serving singular municipalities would complicate system

navigation for residents seeking assistance for often serious and urgent matters. Specific implications to the administration of these critical services include:

-obscurity in which member's office to reach out to based on boundaries that bisect not only whole communities but specific roads;

-accessibility of the Members' offices in the context of vast rural regions that are not served by public transit;

-representing such a large number of distinctive communities would limit a Member's ability to become reasonably familiar with all local contexts and needs, inherently reducing the amount of time and resources available for individual concerns, issues, and initiatives and effectively exempting a large segment of the population from having meaningful representation by a connected and engaged Member.

• Breakdown of distinctive local communities and long-established relationships – Under the proposed changes, the community identities and distinctively rural voices of the Municipality of Central Elgin, the Township of Southwold, and Elgin's other constituent municipalities would be significantly diluted across two ridings that would be inherently dwarfed by City of London and urban concerns due to population distribution. Bisecting the Municipality of Central Elgin on John Wise Line is arbitrary and facilitates scenarios where neighbours could be forced to seek assistance from different Members of Parliament for the same concern. The inclusion of a portion of the Municipality of Central Elgin in the London South – St. Thomas electoral district would take Elgin County's most populous municipality and dilute its voice across two electoral districts. The justification provided by the Commission for the creation of the South London – St. Thomas electoral district neither considers nor acknowledges the Municipality of Central Elgin. In name alone, it incorrectly assumes that growing parts of Municipality of Central Elgin, such as Lynhurst, are part of the City of St. Thomas and embeds that in federal representation. The revised boundaries would also effectively end the deeply embedded historical connection between with the City of St. Thomas and the County of Elgin, where St. Thomas serves as the County seat. This connection has endured since Confederation. Formal integration of services between the City and the County has only grown in that time, particularly when it comes to areas such as courts, social services and land ambulances.
• Strong potential for further impacts detrimental to service delivery – The proposal, if endorsed, will inevitably impact provincial riding boundaries, which tend to mirror federal boundaries. This would only magnify the complexities of severing municipal boundaries between two ridings where the provincial-municipal relationship is bound even more tightly across a number of service areas, ranging from court administration and transportation to long-term care and delivery of social services. Elgin County's constituent municipalities, through Elgin County, partner with the City of St. Thomas on the provision of services including Emergency Medical Services and Social Services.

The Commission requires that representatives proposing alternative federal riding boundary scenarios must be prepared to indicate to the Commission not just the representatives' concerns, but to set out alternatives and, importantly, set out in as much detail as possible, including in a map, how other communities would be affected by the proposed alternatives. Due to the constraints facing the Municipality, the best avenue present to pursue alterations to the proposed federal electoral boundaries is via collaboration with the City of St. Thomas and Elgin County municipalities.

It is for these reasons that we provide this written submission and ask that the County of Elgin's seven (7) constituent municipalities remain fully contained and represented within one federal electoral district with the entirety of Elgin County and the City of St. Thomas. 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.

Yours Very Truly,