Part B – Consultation & Public Engagement – Ontario

Before drafting the proposed redistribution plan, the Commission welcomed public input in February 2022.

Written submissions were received from interested parties, which were very helpful in the preparation of our proposal. The Commission delivered our proposed redistribution plan to Elections Canada in June 2022.

Elections Canada prepared the detailed maps and legal descriptions, translated the proposal and widely published the proposal in August 2022.

The Commission's proposal was posted on the Commission's website on August 19, 2022 (redistribution2022.ca). It was also published in the Canada Gazette and was circulated in print via multiple newspapers.

The Commission encouraged public input on the boundaries and/or names of proposed districts by written submissions or representation at virtual and in-person meetings.

In addition to the publications undertaken by Elections Canada, the Commission sent more than 200 letters and 500 emails directly to organizations in Ontario to advise them of the work of the Commission. These included media organizations (TV and radio stations, daily newspapers); current and former Members of Parliament and Members of the Legislative Assembly; Indigenous organizations and governments (including the band offices of all First Nations, and all Tribal Councils in Ontario); municipalities and related associations; the Ontario Chamber of Commerce and related businesses and labour councils; and the law faculties and political science or political studies departments at all universities within the province.

These communications advised that the Commission had prepared its proposal, which was a key starting point in the redistribution process. We invited all stakeholders and members of the public to participate in our hearings and/or to file written submissions.

In-person meetings

The Commission scheduled in-person hearings in areas where significant changes to districts were proposed. These were held at the following locations:

1. Sioux Lookout (Northern Ontario) – Monday, October 3, 2022, 6:30 p.m. to 9:00 p.m., The Royal Canadian Legion, 86 Front Street, Sioux Lookout
2. Kenora (Northern Ontario) – Tuesday, October 4, 2022, 6:30 p.m. to 9:00 p.m., Douglas Family Art Centre ‒ The Muse, 224 Main Street South, Kenora
3. Timmins (Northern Ontario) – Tuesday, October 11, 2022, 6:30 p.m. to 9:00 p.m., The Senator Hotel, 14 Mountjoy Street South, Timmins
4. Milton (Halton, Guelph, and Wellington) – Wednesday, October 12, 2022, 6:30 p.m. to 9:00 p.m., First Ontario Arts Centre, 1010 Main Street East, Milton
5. Brampton (Brampton, Caledon, and Dufferin) – Thursday, October 13, 2022, 6:30 p.m. to 9:00 p.m., Peel Art Gallery, Museum & Archives, 9 Wellington Street East, Brampton
6. Stouffville (Northern GTA) – Monday, October 17, 2022, 6:30 p.m. to 9:00 p.m., The Whitchurch-Stouffville Museum & Community Centre, 14732 Woodbine Avenue, Stouffville
7. Scarborough (City of Toronto) – Tuesday, October 18, 2022, 6:30 p.m. to 9:00 p.m., Scarborough Civic Centre, 150 Borough Drive, Scarborough
8. Toronto central (City of Toronto) – Wednesday, October 19, 2022, 6:30 p.m. to 9:00 p.m., Toronto Reference Library, 789 Yonge Street, Toronto
9. Ottawa – Thursday, October 20, 2022, 6:30 p.m. to 9:00 p.m., Canadian Museum of Nature, 240 McLeod Street, Ottawa
10. St. Catharines (Hamilton and Niagara) – Friday, October 21, 2022, 6:30 p.m. to 9:00 p.m., Mackenzie Chown Complex, Brock University, 1812 Sir Isaac Brock Way, St. Catharines
11. London (Southwestern Ontario) – Friday, October 28, 2022, 6:30 p.m. to 9:00 p.m., Ivey Spencer Leadership Centre, 551 Windermere Road, London
12. Thunder Bay (Northern Ontario) – Tuesday, November 8, 2022, 6:30 p.m. to 9:00 p.m., Valhalla Hotel & Conference Centre, 1 Valhalla Inn Road, Thunder Bay

Virtual meetings

The Commission noted the vastness of the province (the second largest geographically in Canada), the recent extensive use of remote hearings, the public's ability to utilize and access remote meeting technology in their homes or community facilities, the efficiency of remote hearings, and the potential for restrictions on in-person meetings in light of the pandemic.

As a result, the Commission also scheduled many opportunities for participation in a virtual hearing:

1. Central Ontario; Northern GTA; Eastern GTA; and Central East Ontario – Monday, September 26, 2022, 6:30 p.m. to 9:00 p.m.
2. Hamilton and Niagara; South Central Ontario; Southwestern Ontario; and Southernmost Ontario – Tuesday, September 27, 2022, 6:30 p.m. to 9:00 p.m.
3. Halton, Guelph, and Wellington; Brampton, Caledon, and Dufferin; and Mississauga – Wednesday, September 28, 2022, 6:30 p.m. to 9:00 p.m.
4. City of Toronto – Thursday, September 29, 2022, 6:30 p.m. to 9:00 p.m.
5. Ontario Open Virtual Hearing – Friday, September 30, 2022, 12:00 p.m. to 2:00 p.m.
6. Ontario Open Virtual Hearing – Tuesday, October 18, 2022, 9:00 a.m. to 11:00 a.m.
7. Ontario Open Virtual Hearing – Wednesday, October 19, 2022, 2:00 p.m. to 4:00 p.m.
8. Northern Ontario; Eastern Ontario; and Ottawa – Wednesday, October 26, 2022, 6:30 p.m. to 9:00 p.m.
9. Ontario Open Virtual Hearing – Saturday, October 29, 2022, 12:00 p.m. to 2:30 p.m.
10. Ontario Open Virtual Hearing – Tuesday, November 1, 2022, 10:00 a.m. to 12:00 p.m.
11. Ontario Open Virtual Hearing – Wednesday, November 2, 2022, 6:30 p.m. to 9:00 p.m.

Extensive public participation

The Commission was very impressed with, and grateful for, the extensive public participation in this important democratic process. Evening in-person meetings and remote hearings proved to be very popular with the public.

The Commission's in-person and remote hearings were observed by 1,137 interested parties.

The Commission heard oral submissions from 462 persons and received 1,899 written submissions. The written submissions will be published on the Commission's website.

This number of written submissions is exclusive of multiple petitions signed by upwards of 6,000 people.

Not surprisingly, areas where the proposal envisioned more significant boundary changes (notably: Northern Ontario; the City of Toronto; Eastern Ontario; Halton, Guelph, and Wellington; Southwestern Ontario; Ottawa) generated the most submissions.

Public submissions

The Commission received specific, and often very valuable, input in relation to proposed boundaries, which is referenced below in the discussion relating to particular districts.

However, other submissions were of a more general nature.

(a) Issues that were beyond the mandate of the Commission

Some raised issues that were beyond the mandate of the Commission. These issues are important, and we have set them out below.

The difficulties in exercising the right to vote

There were numerous submissions expressing concern with the practical difficulties faced by many, including Indigenous peoples, students and Franco-Ontarians, in exercising their right to vote. There was confusion over where they could vote, and the need for French language services was highlighted.

The Commission notes these concerns with the recommendation that Elections Canada consider ways to resolve these difficulties.

It was suggested that Elections Canada, or another agency, develop and maintain ongoing relationships with First Nations communities so that such relationships are in place before elections are called to facilitate hiring and training of staff, the delivery of supplies and the procurement of appropriate polling stations. It was also suggested that internet and telephone voting be implemented, that a voter engagement campaign be developed and that the challenge of delivering election services in remote communities be addressed.

The timing of the redistribution and public consultations

The Commission received a number of submissions which included expressions of concern regarding the fact that municipal elections across the province occurred in October 2022, during the public consultation phase of the redistribution. Some municipalities suggested that this made it difficult for newly elected mayors and councillors to participate.

The Commission developed our proposed redistribution plan as quickly as possible to ensure that it was in the hands of Election Canada in June 2022 to allow time for the detailed maps and legal descriptions to be prepared prior to publication. The public consultation was scheduled as quickly as possible following publication in accordance with the requirements of the Electoral Boundaries Readjustment Act, which unfortunately coincided with municipal elections.

The Commission extended the time by which written submissions could be filed by 30 days to October 29, 2022 and provided a further extension in relation to hearings held after that date.

While there were assertions that the public consultation period was too brief and at an inopportune time, as noted, public participation was thorough and extensive and included submissions from many municipalities and their leaders, elected representatives, First Nations Chiefs, First Nation Councils, Tribal Councils, a Grand Council, the Metis Nation of Ontario, and various associations and organizations.

To enable a commission to offer a different or more expansive public consultation period, it would be necessary for Parliament to amend the timelines established in the Electoral Boundaries Readjustment Act.

The Commission shares the concerns expressed by First Nations and the Metis Nation in relation to appropriate consultation and ensuring their effective representation, as we will discuss more fully below.

The request to add more districts

The Commission was asked to add districts in certain areas and to not reduce the number of districts in Northern Ontario and the City of Toronto. There were queries as to why districts in various parts of Ontario could not, for example, approximate the population of districts in Atlantic Canada. There were many submissions reflecting articles in the media suggesting that growing disparity from representation by population across the country, and the relative underrepresentation of Ontario under the terms of the representation formula, should be addressed. Such requests are beyond the mandate of the Commission as it must fix the boundaries for the number of districts assigned to Ontario pursuant to the representation formula in the Constitution Act, 1867. This issue is one to be raised with, and addressed by, Parliament.

The request that the redistribution of Northern Ontario conform with the process and conclusions of the Far North Electoral Boundaries Commission

The Far North Electoral Boundaries Commission (FNEBC), established by the Ontario Representation Act 2015, was given a mandate to make recommendations to create at least one and no more than two additional electoral districts within the provincial electoral districts of Kenora—Rainy River and Timmins—James Bay, Ontario's two geographically largest and northernmost ridings, taking into account the following factors: communities of interest; representation of Indigenous people; municipal and other administrative boundaries; sparsity, density and the rate of population growth in the geographic areas; geographical features; the availability and accessibility of means of communication and transportation in the geographic areas; representations by members of the Legislative Assembly who represent constituencies in Northern Ontario, and other interested persons; and anything else that the Commission considered appropriate.

The FNEBC was given 90 days to conduct two rounds of public consultation, one before and one after the proposal. It used this time to carry out public hearings concerning exclusively the far North.

The FNEBC interpreted its mandate as permitting larger than normal deviations from voter parity; the Commission was more attentive to voter parity among Northern Ontario's geographically vast districts (rather than across all of Ontario) and concluded the more specific objective of Indigenous representation must be given greater weight in light of the need to remedy past injustices and provide a means for Indigenous communities to meaningfully participate in the governance of the province.

The FNEBC recommended that two additional districts be created, with the result that there are now four provincial electoral districts (PEDs) in this area of Ontario's far north:

• PED of Kenora—Rainy River – including Dryden, Fort Frances, Kenora and Rainy River;
• PED of Kiiwetinoong – including the northern portion of the former riding of Kenora—Rainy River;
• PED of Mushkegowuk—James Bay – including Weenusk (Peawanuck) First Nation, the James Bay coast, and the corridor along Highway 11 from Smooth Rock Falls to Hearst;
• PED of Timmins – including the City of Timmins.

The FNEBC highlighted that the PED of Kiiwetinoong would be a majority Indigenous district and that the PED of Mushkegowuk—James Bay would be a majority Francophone district.

Our Commission does not have the mandate provided to the FNEBC, and the FNEBC was not subject to the obligation to achieve voter parity throughout Ontario as much as reasonably possible.

It was recommended to our Commission that a committee be struck to investigate the possibility of entrenching into law a minimum of 10 federal representatives in Northern Ontario and/or providing for 12 federal representatives in line with the conclusions of the FNEBC established by the Province.

Further, we note that 49 of the municipalities in Northern Ontario that passed resolutions in relation to the proposed redistribution plan included in their resolutions a petition to the Federal Government to introduce legislation that would provide for a minimum number of guaranteed ridings for Northern Ontario, to ensure that the voices of Northern and rural communities are heard.

Our Commission recognizes and appreciates the value of these recommendations, and notes such considerations could also address the related issues of effective representation for Indigenous peoples and Francophone communities. However, these recommendations fall outside the mandate of our Commission and the timelines imposed by the Electoral Boundaries Readjustment Act. These issues are within the sole jurisdiction of Parliament.

The difficulties in accessing federal government services and the need for more resources for constituency work

A common concern expressed in hearings and written submissions was the impact of population levels, population characteristics, and geographic size on the ability of Members of Parliament to deliver service representation to their constituents. It was asserted that access to federal services has been diluted over the years and it is the elected representatives who are the face of government, providing services and resolving problems in their constituency offices. In other words, the constituency office of an elected representative is where people receive access to government services. As observed by one Member of Parliament in the north, our caseloads are high and we are the Immigration Services, the Passport Offices and the Service Canada of the North.

It is also noteworthy that in Southern Ontario, the lack of public transportation services to constituency offices was frequently mentioned as a problem for exactly the same reason – people need assistance from constituency offices more and more.

Importantly, different and sometimes contradictory concerns were expressed. Members in geographically large constituencies often described the difficulty constituents face in gaining access to their Member because of distances. Members in geographically small but highly populated constituencies often suggested that the larger number of constituents stretched caseloads beyond capacity. Members in linguistically and culturally diverse constituencies submitted that service provision for such diverse communities was uniquely challenging. The common thread through all of these concerns is that service representation in the constituency is a primary occupation of Members and can be challenging.

These observations are important. They suggest that equitable public access to federal services is a significant problem. One way to address this would be to establish more constituency offices or hire more constituency staff. What are portrayed as problems of district boundaries could likely be addressed if Parliament were to approve substantially increased constituency office budgets in order to enhance public accessibility and help Members of Parliament manage their workload within the district, and thereby enhance the effective representation of constituents.

A related issue highlighted in submissions to the Commission, which also can be addressed by Parliament, is the funding allowance provided to Members of Parliament to support their travel and responsibility of serving constituents across the vast geographic area of the far North.

The implications on provincial and municipal representation

The Commission was mindful that the Province of Ontario has drawn its 111 southern electoral districts with names and boundaries that are identical to those of the federal districts that were in place in 2013, while creating 13 northern electoral districts that are distinct from the federal map for this region, according to the Representation Act, 2015. Further, the Commission is aware that in 2018 the Province revised the municipal ward boundaries of the City of Toronto to make them identical to those provincial electoral districts that are within the boundaries of the City, according to the Better Local Government Act, 2018. Understandably, this raised concerns about the wider implications of changes to the federal districts. In particular, there were concerns about whether the loss of one federal electoral district in the City of Toronto would be reproduced at the provincial and municipal ward levels.

However, the Commission was obliged to fulfill its mandate and was unable to maintain the existing number of electoral districts in Toronto, as will be explained more fully below. Moreover, we note that it is within the Province of Ontario's power to draw its own boundaries for provincial and/or municipal elections.

(b) Submissions that raised concerns that were not accurate or valid

Other submissions raised concerns that were not accurate or valid, as we explain below.

The preference for the status quo

The Commission received many submissions requesting that the electoral districts be left the way they are. There were several aspects to these submissions.

Some individuals questioned the need to undertake the redistribution process at all. Some criticized the cost of the exercise. Some believed that, given the COVID pandemic, the process should be postponed until 2031. These submissions spoke neither to the obligations under the Electoral Boundaries Readjustment Act, nor the wide population disparities in existing districts that, if unaddressed, would most certainly be exacerbated over time.

Some did not want any changes which would affect their current electoral district. Even in instances where a district exceeded the limit of deviation from Quota allowed by the legislation (+/-25%), the Commission heard arguments that the status quo was reasonable in order to respect the community of interest or the historical integrity of existing boundaries.

Some contended that any changes would confuse residents and erode voter turnout. The Commission notes that there is no conclusive empirical evidence that changes to electoral boundaries in Canada erode civic or political engagement, or undermine public confidence in elections.

Overall, we heard numerous accounts that our proposal went too far in making many changes where none were needed. It was suggested that the Commission should add a single riding where it was most needed but leave others well enough alone.

To address this specific point, we modeled a status quo map that adds one district to the most overpopulated area and leaves unchanged all districts beyond that geographic piece. For the sake of simplicity, our model adds the district to Halton, Guelph, and Wellington, calculates a new average population of 115,042 across each of the seven districts in that geographic piece, and leaves all 115 other districts unchanged.

To represent the implications visually, the table below covers the current 121 seats, the allocated 122 seats under the status quo model, and the 122 final districts. It shows the frequency distribution of variances based on 2012 and 2022 deviations.

Frequency distribution of existing electoral districts, Status Quo model, and Final Electoral Districts

Size of deviation	Existing Districts (2012 Quota)	Status Quo Model (2022 Quota)	Final Electoral Districts (2022 Quota)
Greater than -25%	1	6	3
-25% to -15%	9	7	2
-15% to -10%	9	9	5
-10% to -2%	27	26	34
-2% to +2%	20	28	21
+2% to +10%	33	24	47
+10% to +15%	19	7	8
+15% to +25%	3	10	2
Greater than +25%	0	5	0
Total number of electoral districts	121	122	122

Comparing the three columns of the table, it is clear that simply adding one electoral district to a geographic area and leaving the rest of the map unaltered is not an adequate response to population changes across the province.

Beyond this modeling exercise, to say that district boundaries should be preserved at all costs would introduce a status quo bias that is beneficial, above all, to elected representatives. In performing our legislated mandate, we do not consider the interests of incumbents.

The Commission cannot fulfill its obligations under the Electoral Boundaries Readjustment Act by a commitment to the preservation of the status quo.

The Commission did however consider historical patterns, as required by the Electoral Boundaries Readjustment Act. In preparing its proposal, the Commission considered, and respected where possible, the historical pattern of electoral districts. We were persuaded by certain public submissions to alter boundary districts to further reflect historical patterns, as will be outlined below.

The questioning of the reliability of the Census data

As described, the Quota is calculated using data from the 2021 Census of Population in accordance with the Electoral Boundaries Readjustment Act.

In the course of its public hearings, the Commission heard many submissions and anecdotal claims about the reliability of the Census data especially as regards undercounting of vulnerable and marginalized populations, and the possibility that this problem was exacerbated during COVID.

Several submissions regarding Northern Ontario expressed concerns about whether Indigenous populations were adequately counted.

The Commission also heard submissions stating that recent immigrants, frontline workers and people living in rooming houses would not be at home or unwilling to open their door to Census takers. We were told that residents of collective dwellings (e.g., retirement homes, assisted living) were not counted or were undercounted. Comments were also made that data collection only in the English language compromised the reliability of the data.

Many of these submissions concerned Toronto's population count, and there were several references to the City of Toronto's backgrounder 2021 Census: Population and Dwelling Counts, which described a slower rate of growth than expected over the preceding decade, an actual decline in the City's population between 2020 to 2021 due to losses in both Non-Permanent Residents and net inter- and intra-provincial migration rates, and a higher-than-expected number of dwellings deemed unoccupied in the Census count. Many of the submissions referencing this report claimed that the City's population was undercounted by 50,000 or more individuals.

Outside of Toronto, one submission suggested that Census population counts in cottage country were exaggerated by the temporary presence of cottagers who had moved from the city during the pandemic.

While the Commission understands the public's apprehensions about Census inaccuracies, it is important to clarify several points.

The Commission is mandated to use the 2021 Census data pursuant to s. 13(1) and (2) of the Electoral Boundaries Readjustment Act.

The Commission noted that Statistics Canada undertakes a postcensal coverage study, with reporting anticipated two years after the enumeration date. In 2016, net undercoverage (that is, the difference between undercoverage and overcoverage) was estimated at 2.36% for Canada and 2.76% for Ontario. Further information on the coverage of the 2016 Census, including methods and results, is available here: Coverage Technical Report, Census of Population, 2016 (statcan.gc.ca). However, the Commission is bound by the provisions of the Electoral Boundaries Readjustment Act that state that the population counts from the decennial Census must be used by the Commission, without allowing for a later adjustment.

Further, it is important to state that many of the claims and anecdotal observations submitted on this matter are based on misconceptions of how the Census is administered.

It should be noted that the Census was conducted in Canada's official languages, as well as a number of other languages, including immigrant and Indigenous languages. The languages included:

Indigenous languages, Immigrant languages

Indigenous languages	Immigrant languages
Atikamekw	Chinese (simplified)
Northern Quebec Cree	Chinese (traditional)
Denesuline (Chipewyan)	Arabic
Oji-Cree	Punjabi
Tlicho	Spanish
Ojibway	Vietnamese
Inuktitut (Nunavik)	Persian
Plains Cree	Italian
Inuktitut (Nunavut)	Portuguese
Swampy Cree	Russian
Montagnais	Korean
Naskapi	Urdu
Mohawk

It should also be noted that special protocols were adopted during COVID to ensure data quality. For example, the protocol with respect to enumerating populations living in collective dwellings (e.g., hospitals, senior and long-term care homes) relied on administrative data from such facilities rather than requiring residents to complete the forms themselves.

Details on the protocol for administering the Census, as well as steps taken to ensure data quality, are reported in Statistics Canada's Guide to the Census of Population, 2021, Appendix 1.4 – Impact of the COVID-19 pandemic.

As explained in detail in the Guide:

COVID-19 presented some challenges for conducting the 2021 Census of Population but despite these, the collection response rate for the country as a whole was a resounding success at 98.0%, thanks to Canadians who completed the Census in the midst of the third wave of the pandemic. Additionally, unique challenges were encountered in Northern or remote regions of the country, such as travel restrictions, border closures, shorter and shifted collection periods, unavailability of local staff, and wildfires. Ensuring the health and safety of Canadians and our employees by adapting our collection operations to ensure high quality, trusted Census data was a high priority for Statistics Canada.

As noted, the Commission received numerous submissions alleging substantial undercounting in relation to ridings in the City of Toronto. Some of these submissions asserted that, if not for undercounting, Scarborough would have a sufficient population count to keep its current six districts (and Toronto maintain its 25). This assertion is problematic in that it takes no account of potential undercounting in other parts of the province. The same concern arises with regard to the comparable argument that, but for flawed Census data, the population in Northern Ontario would justify 10 ridings.

The Commission also heard assertions that the Census data should be adjusted by taking into account factors such as approved housing and transportation projects, future immigration rates, and even measures of local economic productivity. With respect to the 2021 Census, the Commission was criticized for looking in the rear-view mirror rather than relying on data that looks to the future. Again, the Commission is bound by subsections 13(1) and (2) to use the decennial Census.

Nevertheless, we did compare the final redistribution plan against projected growth in population, based on applying the Ontario Ministry of Finance's Ontario Population Projections (published June 23, 2021). This helps, as much as possible, to assure that the populations of electoral districts across the province do not vary substantially over the period of time to the next Census.

Unnecessary concerns regarding the consequences of redistribution

The Commission heard from numerous individuals who objected to proposed changes that would, as they suggested, require them to cross electoral district boundaries to do their shopping, banking, go to school, visit their local community centre or gymnasium, or attend their place of worship. Some expressed worries that being transferred into another riding would result in them being sent to a different hospital or doctor for medical services. Some did not want to be separated from family members in another district. It is important to note that the boundaries of electoral districts can be crossed at any time and do not impair access to friends and family, schools, community and shopping centres, health and social services, police or emergency services, places of worship or other venues one wishes to attend.

The Commission also received submissions asserting that a change in a property's electoral district would alter the property's value and impact its municipal tax rate. Federal electoral boundaries are not used in the allocation of health and social services, police or emergency services, or in the setting of property tax rates.

Unnecessary concerns of funding reductions

Particularly within geographic pieces where the Commission proposed a reduction in the number of districts (Northern Ontario and the City of Toronto), but also in other parts of Ontario, there were concerns expressed that the loss of a district would result in local losses of federal funding under the New Horizons for Seniors Program and the Canada Summer Jobs wage subsidy program.

The amount of federal funding allocated for such programs is not based on the number of electoral districts in a region, but rather is a function of local population needs as derived from long-form Census data (e.g., number of unemployed youth). The local funding allocation will therefore not be impaired by redistribution, and no local organization that meets the eligibility criteria will be excluded from applying based on a reduction in districts. (See Canada Summer Jobs wage subsidy and About the New Horizons for Seniors Program).

(c) Submissions adopted by the Commission

Other submissions were adopted by the Commission and are reflected in this report.

The value of maintaining the established partnerships of municipalities, regions and counties

While the Commission is not mandated to draw district lines according to municipal, regional or county boundaries, we were urged repeatedly to keep municipalities whole wherever possible. We found many of these arguments highly compelling and supportive of effective representation.

Municipal leaders – especially those in smaller municipalities – expressed concerns where the proposed redistribution plan split their community across districts, creating the additional burden of having to liaise with multiple elected representatives. For their part, elected representatives described synergies and alignments with municipal leaders and other stakeholders as essential in advancing the needs of the district. One MP noted this is where the rubber meets the road in terms of his capacity to be an effective representative of his district in Ottawa.

Finally, from the perspective of residents of smaller communities, such communities tend to be fairly good proxies for groups of people who share a common interest and electoral boundaries should respect the boundaries of their communities.

Based on these submissions, the Commission found it important to consider and recognize the role of these local building blocks in effective representation. We are mindful that the alignment of federal boundaries with those of lower-level jurisdictions can help to facilitate more coordinated action among representatives at different levels in the advocacy, funding and delivery of complex services, and in major economic development initiatives.

We describe where we have modified our proposed redistribution plan accordingly in our discussion of our geographic pieces.

The importance of respecting communities of interest and identity

The overwhelming majority of submissions received by the Commission concerned communities of interest and communities of identity. These are important factors for the Commission to consider and weigh; however, the terms community of interest and community of identity are neither defined in statute nor case law. Nor is there any precise framework by which to assess the effectiveness of the act of representation as it relates to such communities.

While the Commission accepts the strong basis in principle for respecting communities of interest and identity, it is not self-evident in practice what constitutes a bona fide community of interest or community of identity.

In some cases, it seemed to be a highly subjective judgement. For example, at more than one hearing, the Commission was faced with stark differences of opinion presented by residents of the same neighbourhood with respect to the community of interest (and district) with which that neighbourhood was aligned.

Often, the invocation of communities of interest appeared to be a stand-in for a partisan or other status quo interest, rather than one rooted in deeper conceptions of community. Though shared political interests may well have their own community, the Commission did not take partisan or voting preferences into consideration in drawing its map.

Some constituents expressed a strong sense of identity with their existing district, and a bond of appreciation for the services provided by their local Member of Parliament. They indicated that they preferred not to be transferred into a neighbouring district where they were less familiar with the Member of Parliament and worried they may not enjoy the same level of service. However, it is worth noting that most of our existing districts, which would be unrecognizable 20 years ago, now appear to residents today as reasonably drawn.

A more important consideration is the distinction drawn between urban, suburban and rural communities of interest. The Commission heard that issues and perspectives varied significantly between large urban centres and smaller, remote, rural areas and accepted the assertion that these realities had to be considered in determining effective representation.

The 2021 demographic data was released after the publication of the Commission's proposal, and we had the benefit of that current data in considering communities of interest when preparing this report.

In addition to public input regarding communities of interest and identity, the Commission relied on Census data to assess patterns with respect to demographic and socio-economic indicators (e.g., official languages understood and first spoken, Indigenous, immigrant and visible minority populations as a percentage of residents, household income, percentage of households renting, etc.). While such analyses cannot always provide clarity as to how people perceive their interests and organize themselves collectively, it did help us in considering how groups may be clustered in such a way as to create natural communities of interest within electoral boundaries. Wherever possible, the Commission has endeavoured to protect such clusters, particularly in the case of more marginalized members of our community who may perceive their political power as being diminished with certain shifts to electoral boundaries.

Notwithstanding our reservations discussed above, the Commission interpreted communities of interest and identity as broadly as possible and modified the proposed redistribution plan to reflect these submissions in a number of districts, as set out in our discussion of each geographic piece.

However, the Commission notes that legislative clarity with respect to criteria to define communities of interest and identity would be helpful. This is a further issue for Parliament's consideration.

The importance of respecting historical patterns

The Commission took a broad view with respect to historical patterns of electoral districts. In drawing boundaries, we looked not only at their current configuration but were attentive to also understanding how the lines were drawn in prior readjustments, and how residents may have related to those changes.

The Commission also appreciated the attachment that residents expressed to certain district names that reflect both a sense of history and place.

It would be statutorily unacceptable not to take historical patterns (and communities of interest and identity) into account. To do so would mean drawing boundaries arbitrarily with population parity as the only criteria. However, the Commission determined that it would be an error to prioritize these factors above the more objective and neutral baseline of population equality.

Nevertheless, we have identified several contexts in which the importance attached to historical patterns (and to communities of interest or identity) seemed paramount, such that greater deviations from population parity should be accepted to achieve more effective representation. These circumstances are described in relation to the applicable geographic piece.