While there are parts of the…

While there are parts of the proposed new act that may be helpful to communities, I am very concerned about the proposed amendments to the Ministry of Community and Social Services Act. This is not what is needed under this legislation and will not be of assistance in emergency management activities. The lack of definition of what constitutes "extraordinary matters" is extremely problematic and opens the door for things that are not emergency management related. Also, by threatening to fine, pull finding, and issue orders that cannot be argued with, we are going to even further stretch our already underfunded and overburdened social services system. There is no justifiable reason for Schedule 2. What many emergency managers have asked for over the years, and during the consultations that took place this past summer, were regulations that more clearly identified the roles for those Ministries that had an Order in Council. They have never been clear and they have never provided the assistance that many entities, such as unincorporated communities, require from the province during an emergency.

I also have a huge issue with the lack of definition on the authority having jurisdiction over resources that come into a community to support a response. We have always said that the province is there to support and not to take over. Understanding that oversight or provincial resources is very important, I would like to see language in the new act that clearly defines the support role versus a "take over" role.

The Ontario Corp announcement was very disappointing as the groups that are already doing this work would benefit greatly from additional resources and funding. Instead, we have created another volunteer based group that is going to bear the burden of response. It is hard enough to find volunteers already and so investments in those groups that already have established volunteer management capacity would have been more beneficial. And, as I stated above, I would like to see language in the Act that notes this Corp is there to support and not take over a response from a community.

I have attached a PDF of the Act here with my comments and hopefully it will be viewable for you.