Chief Electoral Officer
11 June, 2019
Dear Mr. Perrault,
RE: Request to investigate Ontario government gas station stickers
The Government of Ontario is planning to put stickers on all gas pumps in Ontario. The purpose of the stickers is self-evident and admitted by the Premier of Ontario. It is to attack the Government of Canada’s carbon pricing program, the Prime Minister, and the Liberal Party during an election. See Ontario eyes date for anti-carbon tax gas pump stickers.
These stickers are Third Party election advertising as defined by the Canada Elections Act, if not according to the letter of the Act (because it involves a provincial government), but certainly in regards to the spirit, intent, and purposes of the Act’s Third Party advertising provisions.
Election Advertising is, according to the 2019 Political Financing Handbookfor Third Parties, Financial Agents and Auditors,
“The transmission to the public by any means during the election period of an advertising message that promotes or opposes a registered party or candidate, including by taking a position on an issue with which the party or person is associated.”
Prima facie, the stickers in question are intended to attack the federal Liberal Party and its candidates by ‘taking a position on an issue with which the party or person is associated.’ As well, the Premier and Ministers of Ontario have made the partisan political intent of the stickers repeatedly and abundantly clear. The stickers will be on the gas pumps across Ontario during the federal election period.
I would appreciate it if your office would determine if provincial governments are subject to the Canada Elections Act regarding Third Party advertising. And, if they are, investigate and rule on these highly partisan Government of Ontario stickers to see if they are subject to the Acts “Third Party” provisions, and make a determination accordingly.
As the federal election is imminent, time is of the essence in this matter.
Thank you for considering this request and I look forward to your response.
Animal Protection Party of Canada
cc. Liz White, Leader, Animal Protection Party of Canada
Hon. Doug Ford, Premier, Ontario
Hon. Justin Trudeau, Prime Minister, Canada