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Re: “Small but nimble consumer advocate” Letter to Editor, Toronto Star, January 31, 2013

January 31, 2013
The Editors
The Toronto Star
1 Yonge St.
Toronto, Ontario


Dear Sir/Madam

Re: “Small but nimble consumer advocate”

At heart of the government service delivery model that Tony Dean endorses (January 31, 2013) is the delegation of the Ministry of Consumer Services’ regulatory functions to non-governmental entities, termed Delegated Administrative Authorities or DAAs, whose boards of directors are dominated by representatives of the industries they are intended to regulate.

Beyond the obvious conflicts of interest inherent in these arrangements, the transfer of governmental authority and functions to non-governmental entities is a path fraught with other perils, as was so clearly demonstrated by the ORNGE air ambulance debacle. Careful attention has to be paid to the design of oversight and accountability structures for such entities.

Indeed, in the aftermath of the 2008 Sunrise propane explosion the province had to make extensive changes to oversight regime for its flagship DAA (and regulator of the propane handling industry), the Technical Standards and Safety Authority, to bring it under much closer government control, and to provide for a far more robust accountability framework than was included in its original design. The 2012 budget extended similar changes to the other DAAs in the Ministry of Consumer Services’ portfolio. More broadly, where public health and safety and other fundamental public goods are at stake, serious questions have to be raised about the appropriateness of the DAA model for service delivery, as opposed to the retention of these functions within the core institutional structure of the provincial government.

Yours sincerely,

Mark S. Winfield, Ph.D. Associate Professor Coordinator Joint MES/JD Program Faculty of Environmental Studies York University