Commentaire 95 – commentaires et rétroaction

Jeff Carswell

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 the Township of Southwold's concerns and emphasize our preference for maintaining the riding's current boundary. I greatly appreciate the opportunity to do so.

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 the perspective of 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 primarily on population and not having sufficient regard to local municipal boundaries will have grave implications for the communities we serve. In addition to supporting the comments from the County of Elgin (copy attached), the Township of Southwold concerns are identified in the attached Staff Report CAO 2022-42. Several highlights from the report include:

• The proposed boundary fragments the Township into two federal ridings which is not desirable or beneficial to the Township.
• The Township of Southwold and municipal 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.
• There could be the potential for risk of contradictory positions by area Members of Parliament where they represent competing political parties.
• The community identity, including the rural voice of the Township of Southwold would be significantly diluted across two ridings, one of which would have larger City of London and urban concerns and the other that would be geographically massive, stretching from Chatham, to Warwick, to St. Marys and to Bayham.
• The proposal for Elgin-Middlesex-Thames has little to no urban areas, while other neighbouring districts are primarily urban. This could accentuate the division being seen between urban and rural areas. The existing Elgin-Middlesex-London district while generally rural, does contain the City of St. Thomas and urban areas in south London.
• The proposed electoral districts split the Township of Southwold along Sunset Dr. between St. Thomas and London. This does not respect and maintain the community identity of the Municipality. There is not a rational argument to suggest that Southwold has a different community identity on each side of Sunset Dr. Both areas are an integral part of Southwold and identify as such.
• The inclusion of a portion of the Township of Southwold in the London South –St. Thomas district represents about 20% of the Township population and the area contains a significant amount of land designated industrial development. There could be significant risks that this area does not get the attention and priority needed as part of a larger urban focused London-centric electoral district.

The Township recognizes that the Commission is looking for alternatives that could be considered to address the concerns being put forward. The Township believes that keeping smaller municipalities within one electoral boundary is highly preferred and request that municipalities be fully contained in one electoral boundary. Maintaining Elgin County municipalities, St. Thomas and Thames Centre would be very close to the quota target of 116,590.

As other rural Counties such as Middlesex and Oxford are also seeing municipalities split between districts, it is suggested that these areas be further examined to determine if including them, in their entirety with Elgin - St. Thomas would result in a district of approximately116,590. This may or may not need to include a rural southern portion of London. While it may be inevitable that some municipalities may have to be split between electoral districts, it would be preferred if such splits have some logical rationale, such as a predominantly rural portion of an urban municipality being included in a generally rural electoral district.

The Township of Southwold has also worked closely with Elgin-Middlesex-London MP Karen Vecchio and is supportive of the proposed alternative she is putting forward.

Overall, the Township of Southwold believes that keeping communities and small municipalities within a single electoral district is paramount and needs to be maintained as electoral districts are finalized.

Yours truly,

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,

Township of Southwold

Report to Council

Meeting Date:

September 12, 2022

Prepared By:

Jeff Carswell, CAO/Clerk

Report No:

CAO 2022-42

Subject Matter:

Proposed Federal Electoral Districts

Recommendations:

That the Township of Southwold coordinate efforts with Elgin County, other Elgin County municipalities and the City of St. Thomas to represent interests and concerns pertaining to the proposed federal electoral boundary districts;

And that the Township of Southwold develop a submission and make a presentation at the Federal Electoral Boundaries Commission for the Province of Ontario;

And that the submission and presentation guiding principle be that the Township of Southwold be fully contained and represented within one federal electoral district with the entirety of Elgin County and the City of St. Thomas.

Purpose:

To review the proposed Redistribution of Federal Electoral Districts and put forth a course of action to raise the concerns from the Township of Southwold with the Federal Electoral Boundaries Commission.

Background:

The Federal Electoral Boundaries Commission for the Province of Ontario (the Commission) is an independent body charged with readjusting the electoral boundaries under the Electoral Boundaries Readjustment Act (the Act).

On August 19, 2022, the Commission released its proposed new electoral map for consideration at public hearings this fall. The population in Ontario has increased from 12,851,821 in 2011 to 14,223,942 in 2021. Thus, the representation formula in the Constitution Act, 1867 has determined that Ontario has been allocated 122 seats, raising the total number of electoral districts in the province from 121 from the last redistribution plan prepared in 2012.

The Act directs the Commission to ensure that the population in each electoral district shall, as closely as reasonably possible, correspond to the electoral quota for the province. The quota for electoral districts in Ontario is 116,590, which was established by dividing the census population by the number of electoral districts assigned to the province.

The Act permits the Commission to depart from the quota where necessary or desirable in order to:

• respect the community of interest or community of identity in, or the historical pattern of an electoral district in the province, or
• maintain a manageable geographic size for electoral districts in sparsely populated, rural or northern regions of the province.

When considering these factors, the Commission must make every effort to ensure that, except in circumstances it views as extraordinary, the population of each electoral district in the province remains within 25% (plus or minus) of the electoral quota. The upper limit of deviation from the quota is 145,738, and the lower limit of deviation from the quota is 87,443.

The Commission has proposed and will be discussing at public hearings this fall, new federal electoral district boundaries for the next regular federal election. The proposed district boundaries for the Township of Southwold are on the Southwestern Ontario map attached hereto as Appendix 'A'. The proposed district boundaries would mean that the Township of Southwold would be split between two federal electoral districts:

Proposed Federal Electoral District, Proposed Federal Electoral District Population, Township of Southwold Population Share, Elgin County Population Share, City of St. Thomas Population Share

Proposed Federal Electoral District	Proposed Federal Electoral District Population	Township of Southwold Population Share (4,851)footnote 1		Elgin County Population Share (51,912)footnote 1		City of St. Thomas Population Share (42,840)
Elgin – Middlesex - Thames	117,082	4,131	3.53%	44,022	36.62%	0	0.00%
South London – St. Thomas	120,208	720	0.60%	7,890	6.74%	42,840	35.64%
Return to footnote 1 Electoral district population share for Central Elgin and Southwold calculated utilizing 1.99 persons/property

Elgin – Middlesex – Thames

Consists of:

1. the Town of Aylmer;
2. the municipalities of Bayham, Brooke-Alvinston, Dutton/Dunwich, Middlesex Centre, Southwest Middlesex, Strathroy-Caradoc and West Elgin;
3. that part of the Municipality of Central Elgin lying southerly of John Wise Line;
4. that part of the Municipality of Chatham-Kent described as follows: commencing at the intersection of the northerly limit of said municipality and the Sydenham River; thence generally southwesterly along said river to Dawn Mills Road; thence southerly along said road to Base Line; thence westerly along said line to Kent Bridge Road; thence southeasterly along said road and its production to the southerly limit of said municipality; thence northeasterly, northwesterly, northerly and westerly along the southerly, easterly and northerly limits of said municipality to the point of commencement;
5. those parts of the Municipality of Thames Centre described as follows:
   1. that part lying northerly of a line described as follows: commencing at the intersection of the westerly limit of said municipality and Thorndale Road; thence northeasterly along said road to Nissouri Road; thence northwesterly along said road to approximate latitude 43°06'21"N and longitude 81°09'32"W; thence northeasterly in a straight line to Fairview Road at approximate latitude 43°06'39"N and longitude 81°08'35"W; thence southeasterly along said road to Thorndale Road; thence northeasterly along said road to the easterly limit of said municipality;
   2. that part lying southerly and easterly of a line described as follows: commencing at the intersection of the easterly limit of said municipality and Highway 401 (Macdonald-Cartier Freeway); thence westerly along said highway to Westchester Bourne road; thence southerly along said road to the southerly limit of said municipality;
6. the townships of Adelaide-Metcalfe, Malahide and Warwick;
7. that part of the Township of Dawn-Euphemia lying easterly of a line described as follows: commencing at the intersection of the northerly limit of said township and Forest Road; thence southerly along said road and its southerly production to the Sydenham River; thence generally southerly along said river to the southerly limit of said township;
8. the Township of Southwold, excluding the part lying easterly of Sunset Road;
   1. that part of the Township of Zorra lying northerly and westerly of a line described as follows: commencing at the intersection of the westerly limit of said township and Road 84; thence northeasterly along said road to 23rd Line; thence northwesterly along said line to the northerly limit of said township;
   2. the Village of Newbury; and
9. the Indian reserves of Chippewa of the Thames First Nation No. 42, Moravian No. 47, Munsee-Delaware Nation No. 1 and Oneida No. 41.

London South – St. Thomas

Consists of:

1. the City of St. Thomas;
2. that part of the City of London lying southerly and easterly of a line described as follows: commencing at the intersection of the easterly limit of said city with the Thames River; thence generally westerly along said river to the Canadian National Railway; thence southeasterly along said railway to Commissioners Road East; thence westerly along said road to Wharncliffe Road South; thence southerly and southwesterly along said road to Wonderland Road South; thence southerly along said road to Highway 402; thence generally southwesterly along said highway to the westerly limit of said city;
3. that part of the Municipality of Central Elgin lying northerly of John Wise Line;
4. that part of the Municipality of Thames Centre lying southerly of Highway 401 (Macdonald-Cartier Freeway) and westerly of Westchester Bourne; and
5. that part of the Township of Southwold lying easterly of Sunset Road.

Prior to the redistribution, the Township of Southwold was singularly represented by the riding of Elgin - Middlesex - London, as documented on the map attached hereto as Appendix 'B':

2011 Census Population Data, Current Federal Electoral District, Current Federal Electoral District Population, Township of Southwold Population Share, Elgin County Population Share, City of St. Thomas Population Share

Current Federal Electoral District	Current Federal Electoral District Population	Township of Southwold Population Share (4,494)		Elgin County Population Share (49,556)		City of St. Thomas Population Share (37,905)
Elgin – Middlesex - London	114,294	4,494	3.93%	49,556	43%	37,905	33%
2011 Census Population Data

2021 Census Population Data, Current Federal Electoral District, Current Federal Electoral District Population, Township of Southwold Population Share, Elgin County Population Share, City of St. Thomas Population Share

Current Federal Electoral District	Current Federal Electoral District Population	Township of Southwold Population Share (4,851)		Elgin County Population Share (51,912)		City of St. Thomas Population Share (42840)
Elgin – Middlesex - London	126,428	4,851	3.83%	51,912	41%	42,840	33%
2021 Census Population Data

Elgin – Middlesex – London

Consists of:

1. the County of Elgin;
2. that part of the County of Middlesex comprised of the Municipality of Thames Centre;
3. the City of St. Thomas; and
4. that part of the City of London lying southerly of a line described as follows: commencing at the intersection of the westerly limit of said city with Dingman Creek; thence generally easterly along said creek to the westerly production of Southdale Road West; thence easterly along said production, Southdale Road West and Southdale Road East to White Oak Road; thence southerly along said road to Exeter Road; thence easterly and northeasterly along said road to Highway No. 401; thence northeasterly and easterly along said highway to the easterly limit of said city.

The Commission now has the proposed federal electoral district map out for consultation where the public is invited to share their perspectives on the proposed federal electoral district map by scheduled representation at any of the public hearings.

The applicable public hearings for the Township of Southwold is as follows:

Public hearings for the Township of Southwold

Location	Address	Date	Time
London	Ivey Spencer Leadership Centre, 551 Windemere Rd, London, ON	Monday October 24, 2022	6:30PM
Virtual Hearing	Hamilton and Niagara; South Central Ontario; Southwestern Ontario; and Southernmost Ontario	Tuesday, September 27, 2022	6:30PM

Pursuant to the Electoral Boundaries Readjustment Act, the Commission has established the following rules to regulate its proceedings and the conduct including public hearings.

1. All persons wishing to make an oral submission must complete the Public Hearing Participation Form by September 25, 2022.
2. In the interest of transparency, the Commission will make public all written submissions that it receives in response to the proposed redistribution plan. These will be published on the Commission's website and will include the person's name and the date of the submission.
3. Two members of the Commission shall constitute a quorum for the holding of a hearing.
4. If a quorum cannot be present at a hearing, the Commission may postpone that hearing to a later date.
5. If the Commission cannot complete hearing representations within the time allowed, the Commission may adjourn the hearing to a later date at the same place or may–

taking into account the convenience of persons whose representations have not been heard or have been only partly heard–adjourn the hearing elsewhere or to a virtual hearing.

6. At each hearing the Commission shall decide the order in which the representations are heard.
7. The Commission may restrict the time available for oral representations if necessary to meet timing constraints.
8. Only one person shall be heard in the presentation of any single representation, including a representation on behalf of an association or group, unless the Commission, in its discretion, decides otherwise.
9. The link to the virtual public hearing is not public and may only be shared with participants/observers who have registered with the Commission and with members of the media.
10. A moderator will manage the agenda, the speaking time and microphones of the participants.
11. The use of a headset by presenters at a virtual public hearing is recommended.

The Commission makes final decisions about where the federal electoral boundaries will be located following consultation, giving the public and Members of Parliament an opportunity to express their views and participate in the consultation process.

Comments:

As stated in the proposal:

The Commission proposed many new electoral boundaries for Ontario. These proposed boundary changes are necessary due to the allocation of one additional district; and to correct wide variations in voter equality that have emerged across the province over the past decade due to population changes.

The population of Southwestern Ontario grew by 11.1%, from 782,285 in 2011 to 869,137 in 2021. The remainder of Ontario grew by 10.6% in the same period. The existing seven electoral districts in this geographic piece would have an average 2021 population of 124,162 and an average deviation of 6.5% from the Quota. The absolute range between the least and most populous districts would be 24.1 percentage points.

The Commission noted that the three existing and largely urban districts within

the City of London are underrepresented with populations that are 9%,

18.6% and 19.5% above the Quota. Consequently, considerable redrawing was

required. Recognizing the urban growth in all directions, the boundaries of these three districts are reconfigured to better balance populations with adjacent and more rural districts.

Recognizing the development in the southern part of the City of London and the northern part of the City of St. Thomas, these areas are both included in the proposed district of LONDON SOUTH - ST. THOMAS.

In the more northern part of the City of London, the boundaries

of LONDON WEST and the newly named LONDON CENTRE (the existing

district of London North Centre) are modestly changed.

The boundaries of the existing district of London - Fanshawe are shifted to the east, and this district is renamed LONDON NORTHEAST.

In the southern portion of this geographic piece, the newly named ELGIN – MIDDLESEX - THAMES extends from Kent Bridge Road (County Road 15) in Chatham-Kent at its western edge and wraps around the City of London along the east. This district comprises portions of the existing districts of Elgin – Middlesex - London and Lambton – Kent - Middlesex.

In the northern portion of this geographic piece, the districts of PERTH - WELLINGTON and the newly named SOUTH HURON SHORES (the existing district of Huron - Bruce) are largely unchanged.

Many of the districts in this piece are renamed to better describe their locations and reflect their communities of interest.

No one electoral district can be considered in isolation from the others immediately surrounding it. Any change to one boundary has an inherent effect on at least one adjoining electoral district. The Commission endeavored to respect existing municipal boundaries whenever possible. However, in some instances, the location and density of population growth required the Commission to establish electoral districts that crossed municipal boundaries.

The primary consideration in the Electoral Boundaries Readjustment Act is that the population of each electoral district in the province be as close to the provincial quota as is reasonably possible. If an electoral district contains a population that is significantly larger than the quota, it is underrepresented. Similarly, an electoral district with a significantly smaller population is overrepresented. However, the principle of representation by population cannot be perfectly implemented. It is virtually impossible to establish an electoral map for 122 electoral districts of equal population that reflects existing municipal boundaries, that recognizes the distinctions between urban, rural and remote communities, and that takes into account community of interest or identity, and historical attachment.

Analysis

Some may suggest that the Township of Southwold may be better off with the Commission's proposals of two Members of Parliament, rather than any other alternative that would provide only one. This certainly has some merit and could increase the likelihood that the Township of Southwold would have a representative in the Federal Cabinet and more Members of Parliament to potentially advocate on its behalf. Conversely, the proposed federal electoral districts unnecessarily fragment the Township of Southwold. Furthermore, under such proposal:

1. Elgin County, including Township of Southwold residents, would hold only a minority share of the population of any of the proposed electoral districts that include the Township of Southold, diluting the ability to influence the local Member of Parliament to concentrate on and address Southwold and Southwold residents' interests.
2. The Township of Southwold and municipal community organizations 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 Township of Southwold would be significantly diluted across two ridings, one of which would have larger City of London and urban concerns and another that would be geographically massive, stretching from Chatham, to Warwick to St. Marys to Bayham.
4. The proposed ridings of Elgin – Middlesex - Thames and London South – St. Thomas do not respect the historical pattern of Township of Southwold electoral districts.
5. The inclusion of the Township of Southwold in 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.

1. Splitting the Township of Southwold along Sunset Dr. does not respect the community identity of the Municipality, as it would be practically impossible to argue Sunset Dr. divides two community identities within the Township of Southwold.
2. The inclusion of a portion of the Township of Southwold in the London South – St. Thomas represents about 20% of the Township population and the area contains significant amount of lands for industrial development and there could be risks that this area would not get the attention and priority needed as part of a larger urban district.
3. The justification provided by the Commission for the creation of the South London – St. Thomas electoral district does not even consider or acknowledge the Township of Southwold and the industrial nature of this area. Recognizing the development in the southern part of the City of London and the northern part of the City of St. Thomas, these areas are both included in the proposed district of LONDON SOUTH - ST. THOMAS.

4. The Township of Southwold, through Elgin County, partners with the City of St. Thomas on the provision of services, including social services. The proposed electoral districts separate Elgin County from the City of St. Thomas with regard to services that may be closest to the federal sphere of jurisdiction.

   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 Township, 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.

   By coordinating efforts and presenting a united front representing Elgin County to the Commission, the Township of Southwold has the best opportunity to prevent the division of the Township of Southwold and prevent the lessening of full representation of the Township and the Township's residents' interests. Coordination provides an opportunity to present a case for an alternative option to the Federal Electoral Boundaries Commission for the Province of Ontario through the submissions process.

Financial Implications:

None.

Strategic Plan Goals:

The above recommendation helps the Township meet the Strategic Plan Goal of: ☐ Promoting residential, agricultural, commercial, and industrial development by ensuring policies and services are in place to support growth in The Township of Southwold.

☐ Promoting a healthy, naturally beautiful, and community-oriented municipality by encouraging and supporting involvement of volunteer organizations wishing to provide cultural and recreational activities in the Township of Southwold.

☐ Providing improved transportation and a strong commitment to asset management with a goal of maintaining the Township's infrastructure in the promotion of public safety

☐ Exercising good financial stewardship in the management of Township expenditures and revenues.

☒ Promoting public engagement, transparent government, and strong communications with all members of the community across various mediums for the strengthening of civic participation.

Respectfully Submitted by:

Jeff Carswell, CAO/Clerk "Submitted electronically"