Thank you for the…

Thank you for the opportunity to provide feedback on ERO 019-9467 regarding the proposed amendments to the Emergency Management and Civil Protection Act as outlined in Bill 238, the Emergency Management Modernization Act, 2024.

Updates to the Emergency Management and Civil Protection Act will help address evolving needs and help ensure the effectiveness of emergency management programs across Ontario.

Please find detailed feedback on further proposed changes below:

Joint Program - Section 2.1
Recommendation to repeal Section 2.1, which allows two or more municipalities to develop and implement a joint emergency management program. This recommendation is based on the following concerns:
• Challenges in aligning the priorities, policies, and governance structures of multiple municipalities
• Potential for disputes over financial contributions
• Complexity in maintaining clear and consistent messaging to the public during emergencies across municipalities
• Limited effectiveness in emergencies requiring rapid, localized response in joint programs across large or remote areas

Specific Emergency - Section 3(3)
Recommendation to repeal Section 3(3), which mandates the inclusion of specific emergencies in municipal emergency management plans for the following reasons:
• Potential misalignment with a municipality’s unique risk profile, leading to the inefficient use of resources
• Additional strain on limited staff and resources, particularly in smaller municipalities
• The existing all-hazards planning approach already promotes preparedness for a wide range of scenarios and emphasizes critical capabilities

Joint Plan -Section 3(4)
Recommendation to repeal Section 3(4), which permits two or more municipalities to develop and implement a joint emergency management plan for the following reasons:
• Joint emergency management plans may not adequately address unique local risks or individual municipal priorities
• Coordination challenges between municipalities can slow down decision-making during planning and response phases
• Difficulty in maintaining consistent and timely public messaging across municipalities who may be experiencing different impacts related to a regional emergency
• Delayed response times if resources are not positioned close to the affected area
• Differences in commitment, preparedness, or capabilities among municipalities could hinder joint emergency management plan effectiveness

Request for Assistance -Section 4(11)
Recommendation to update Section 4(11) to provide greater flexibility regarding who can request provincial assistance on behalf of a municipality during emergencies.

Suggested updated wording:
For greater certainty, the head of council, the council of a municipality, or such other person(s) as may be specified in the municipality’s emergency management plan, may request assistance respecting an emergency from the provincial emergency management organization, the Commissioner of Emergency Management, or the Minister without declaring an emergency under this section.