Two weeks ago, I wrote about the receivable on Metrolinx’ books for supposed “municipal contributions” that have not been paid, but instead have been funded temporarily by Queen’s Park. This has been going on for roughly a decade and the bills are piling up, now over a billion dollars.
I posed a series of questions to the Minister of Transportation’s Press Secretary, and received a friendly, sunny, but utterly uninformative reply.
Firstly thank you for your e-mail and questions – it is nice to e-meet you! I saw your blog piece from earlier this week and the Qs you submitted to Patrick re: the existing framework for municipal contributions to GO Transit growth and expansion capital costs, potential future municipal contributions to major transit initiatives in the region and the Province’s Dedicated Gas Tax Program.
There are two Regulations under the Metrolinx Act, 2006, which are intended to assist the Regions of Durham, Halton, Peel and York, and the Cities of Toronto and Hamilton, to collect development charges (DCs) to help offset their respective contributions to GO Transit growth and expansion capital costs:
1) O. Reg. 528/06, which sets an expiry date for GO Transit DC by-laws; and
2) O. Reg. 446/04, which prescribes the allocation of the expected municipal share of the GO Transit growth and expansion capital costs amongst the municipalities.
The municipal contributions to GO Transit growth framework were put in place to establish a fair and balanced approach to support GO capital expansion in communities across the region. All municipalities in the Greater Toronto and Hamilton Area benefit from an effective GO Transit network, and the Province remains committed to working with all of our partners to expand and deliver this network. Given the transformational $13.5 billion investment that the Province is making to strengthen the GO network through the 10-year GO Regional Express Rail initiative under the Moving Ontario Forward plan, we recognize that this commitment to working together with all of our partners to build and optimize an integrated, regional transit network is even more critical.
As you note in your email, the two Regulations permit GO Transit DC by-laws to help the municipalities offset their expected contributions – per the allocation formula set out in O. Reg. 446/04 – to Metrolinx for their share of GO Transit growth and expansion capital costs. The contributions made by municipalities are not directly linked to any specific expansion projects, but, rather, they are applied against the GO Transit growth and expansion capital program, as a whole.
With respect to your questions related to the Dedicated Gas Tax Program, the funding of two cents per litre of gasoline sold across the province was made permanent through the Dedicated Funding for Public Transportation Act, 2013. The Ministry of Transportation allocates these funds through the Dedicated Gas Tax Program based on a formula of 70% ridership and 30% population for eligible municipalities. All of the factors, including the funding envelope, ridership and population, are updated annually for each program year. The funding envelope for the 2015/16 program was $332.9 million, up from $321.5 million in 2014/15. The Province has provided the City of Toronto with more than $1.75 billion through the Gas Tax program since 2003, including $169.2 million for the 2015/16 program.
Thank you again for your questions.
[Email from Andrea Ernesaks, Press Secretary and Issues Manager, Office of the Hon. Steven Del Duca, Minister of Transportation, September 30, 2016]
Despite the reference to an “expiry date” for GO Transit Development Charge by-laws, this date has been changed every few years and currently sits at the end of 2016. Based on past experience, one might reasonable expect this will be extended again. The municipal allocations have not changed since this charge was introduced despite substantial shifts in population balance around the region and a change in the type of journey that the Metrolinx network serves, especially with planned expansion.
The concurrent mention of the $13.5 billion to be spent on GO RER and “working with all of our partners” suggests that Queen’s Park might include RER in the cost base for calculation of future contributions from the municipalities. If this is so, then the Minister should say so, and all announcements should have a little side bar, an asterisk to a footnote saying, “oh, by the way, your municipal taxes will help pay for this photo op”.
Nothing in the legislation (acts and regulations) explains how “capital requirements” are calculated, which projects would be included, nor how the proportional allocation should be assessed against municipalities. It just appears out of thin air as part of the GO (now Metrolinx) budget. The amount is a not linked to specific projects, but somehow it gets calculated.
The info about the Gas Tax program is not news, but the concern municipalities have legitimately is that an increasing portion of this grant might be clawed back by charges to support Metrolinx rather than their own local programs. This is complicated by the fact that Queen’s Park threatened to withhold the Gas Tax from municipalities that didn’t play ball with the selection of Presto as their fare card. Going forward, we know that back charges for operation of the Metrolinx LRT lines to the municipal level are likely, but the amount has not yet been settled.
The basic point here is that the provincial largesse and support for transit comes at a price, and that will be carved out of money that nominally flows to municipalities for their own use on transit. Toronto’s $169.2 million is now split between the operating and capital budgets. Other monies do flow from Queen’s Park for TTC projects, but they are earmarked to those specific works such as the subway extension to Vaughan.
Moreover, given the state of provincial finances, will this billion dollar “debt” become payable by the municipalities? Toronto’s half-billion share would take a huge bite out of the city’s budget, and an ongoing charge of roughly $90 million could more than halve the value of the gas tax grant.
The Minister might contemplate some of the background information to the Metrolinx Investment Strategy reports which includes a history of GO Transit development charges, a description of the wide gap between the amounts actually collected and the amount anticipated (25% of GO’s capital program). Specifically the Metrolinx Review of Development Charges at pages 6-7. Note that this report dates from January 2014 and therefore does not reflect all of the charges that have accumulated to date. It also speaks of $100 million in revenue from municipal development charges, but the chart below clearly shows that this is far short of the “expected” contribution.
These are not trivial questions, and so I have asked, again, for an explanation. To date, nothing has come to my mailbox. My latest query follows below.
1. Which projects now underway or planned will trigger additions to this outstanding balance including, but not limited to, such things as:
- Ongoing GO improvements (non-RER)
- GO RER
- LRT and BRT projects
In other words, although Ontario has not actually collected on the receivable, will it continue to grow and, in effect, will municipalities be expected to eventually contribute to “provincial” projects, and at what level?
It takes some digging through the statutes to figure out where the authority for making any levy against the municipalities actually exists because of the successor organizations down the years. This appears to lie in the Greater Toronto Services Board Act which contains language respecting both operating and capital costs (sections 66 and 68 respectively).
However, there is no information in this act about how the “capital requirements” are calculated, that is to say which projects are included, nor the proportion of the total to be assessed against the municipal level. This amount is being calculated each year and appears as a growing balance in the financial statements, now standing at over $1 billion. The amount has not actually been collected for years and has instead been advanced by the government.
It is also intriguing that s.68 of the Act contemplates a 100% recovery of GO’s net operating cost from municipalities, but this does not appear to be done currently.
And so I reiterate my questions:
- How is the annual amount that is added to this outstanding balance calculated? Is it prescribed anywhere, or simply set by an annual Metrolinx bylaw? Where is this published?
- To what degree will the projects listed above be back-charged to municipalities through this mechanism? (GO, RER, LRT, BRT)
- Given that this receivable has been outstanding for close to a decade, does the government have any intention of attempting to collect this from the municipalities?
- Can you confirm that there is no authority existing today for Metrolinx to recover the net operating cost of GO from the municipalities?
2. Many projects do not fit into the classic GO Transit model of serving downtown Toronto. For example, York VIVA BRT, The Hurontario and Hamilton LRTs, and the Toronto Crosstown and Finch LRTs serve a very different travel demand from GO’s rail network.
Will the formula for allocating these costs be changed to reflect the service territory and areas benefiting from the projects that where municipalities are expected to make a contribution?
The formula apportioning the capital levy between the municipalities has not changed over the years, only been extended by various regulations. Meanwhile the population of the regions has changed substantially, and the types of service now in operation, and particularly those under construction, are very different from the peak period commute to downtown Toronto that was GO’s function a decade ago. Depending on which projects will be included in the calculation of future levies, the proportions in the regulation may unfairly assess costs among the regions.
- Will the formula be updated to reflect population shifts?
- Will the formula be updated to reflect the different services provided now and in coming years?
3. Although Ontario makes significant investments in transit, its budgetary effect at the local level will be offset by chargebacks including:
- The deferred Metrolinx receivable above
- Future costs for Presto which is expected to become self-sufficient and will require increases in service fees to local providers to do so
- Future costs for LRT operations
Starting in FY 2011-2012, there was a large increase in the annual charge added to the receivable, an average of $183m/year over the last five years, of which Toronto is responsible for $81.6m/year. What projects contributed to this charge and what was their total value (in effect, my question is what proportion of these projects was back-charged to the municipalities)?
At the same time, there has been almost no change in the level of gas tax provided, and the amount coming to Toronto has been sitting at about $160m for many years. (Toronto apportions this partly to capital and partly to operations.) The effective value of this contribution falls due to inflation. If Toronto had actually paid their Metrolinx assessment in recent years, this would have wiped out half of the gas tax grant.
In 2017, the TTC is making provision in its budget for additional costs related to Carbon Taxes. This will further erode the contribution from Ontario.
The combined effect of all this will be that, at some point, all of the provincial contribution via gas tax will be consumed by paybacks under various levies and fees.
My questions repeated:
- Why did the levy against the municipalities change so dramatically in FY 2011-2012?
- Does the government have any plans to increase the gas tax allocated to municipalities at least to offset inflation?
- Does the government have any plans to recover a portion of the operation of transit service by Metrolinx/GO from the municipalities served?
- Why is public transit, itself a major contributor to reduction of pollution, to be charged with Carbon Tax, yet another means by which the province will claw back the gas tax allocation?
Sounds to me like something that Bonnie Lysyk the Auditor General of Ontario might want (or need) to look at. While it is all ‘our money’ it is probably good if we know which pocket it is being taken from.
Steve, as always, your analyses are amazing! You are a true transit ombudsman.
I was thinking, wasn’t the Greater Toronto Services Board disbanded many years ago, maybe at the time of Mayor David Miller?
Just Googled it, and actually the Board was disbanded at the time of Mayor Mel Lastman in 2001, during the amalgamation of Toronto. The Board only lasted a couple years. However, the Board’s main raison d’ètre was to administer the capital costs and expansion of GO Transit.
Steve: It also gave Gordon Chong some place to nest awaiting better political fortunes (which never arrived).
The allocation of costs for the period 2001-2016 are outlined in the GO Transit Act, 2001 and the subsequent Metrolinx Act, 2006. Since then, GO rail service has been extended to Kitchener-Waterloo, and there seems to be no allocation to there.
Steve: Yup, the original percentages have not changed despite the huge shifts in GO’s network. The Metrolinx background paper I linked from the article actually contains an explanation of the original calculation based on O-D info for trips on the GO network as it existed at the time.
The fixed allocation to the City of Toronto is 44.6%. No explanation of how this is calculated, right down to one decimal point! I think that Queen’s Park will eventually have to write off these accumulated sums. But, a big accounts receivable looks good on the books. As long as it isn’t expensed, it will not be an operating deficit. Politics being what it is, it will take a new government to write it off and say “We inherited a huge fiscal mess.”
Here is the link to the legislation.
Steve: Yup, that and its predecessors stretch back in time, but the money has not actually been collected as the Metrolinx financial statements make clear.
Ontario Regulation 446/04
Steve: Similar regulations have been passed every few years extending the end date of the period.
Didn’t you just answer your own question?
Steve: Of course. But I want the Minister’s office to admit it too.
Your last question about the carbon tax has direct implications for fare policy. As it stands right now, Go Transit and every other transit system in Ontario are entirely fossil fuel powered except for the TTC which has a huge bus fleet.
The carbon tax will weigh on electricity bills since a portion of that is generated from natural gas and that’ll affect the operating costs of streetcars and subways as well, and eventually the LRT lines in Toronto, Kitchener, and Ottawa that are under construction as well as the ones slated for Mississauga and Hamilton assuming they actually get built. If there isn’t a public transportation exception to the carbon tax, this will translate into every transit system having to figure out how to handle the increase in operating costs between a rise in subsidy or fares, or a combination of the two.
For the TTC, does the city increase it’s subsidy next year right after John Tory’s 2.6% budget cut routine this year or hit passengers with a potentially large fare increase? The City of Toronto could take a massive financial hit between that and the $500 million being called due if that comes. And for Go Transit, they’ve been hitting passengers with large fare increases every February for the last few years, does that mean this coming February there’s a huge fare increase for Government of Ontario Transit looming right after Kathleen Wynne said she’d be tackling pocketbook issues?
Then there’s the whole issue that if people are being forced to pay a carbon tax no matter how they travel, there’s a disincentive to using public transit there in that if people are going to be stuck paying it whenever they travel, they might as well pay it from the comfort of their own cars and this would seem to act counter to the stated intent of it. For many, many reasons, I’m deeply surprised there isn’t a public transportation exception from the carbon tax.
People who walk or cycle don’t have to pay a carbon tax. People who take electric-powered transit will have to pay a very small amount. People who take fossil fuel-powered transit will have to pay little. People who drive cars or trucks will have to pay a lot more.
Transit agencies have a responsibility to lower carbon dioxide emissions just like everyone else and should not be exempted. They should have the incentives to switch to hybrid and then entirely electric buses in the coming decades. The fact they transit it much less emitting then cars means there will be a significant financial incentive to use transit from carbon taxes on top of all the others.
Steve: The problem here is that the transit system faces a marginal cost of up to $15m which is not trivial in the context of budgetary discussions. Any move to alternate fuel vehicles is a long-term issue given the longevity of the fleet, and is further complicated by the ongoing poor experience and higher cost of what the TTC has tried to date. To put it in the context of someone looking at buying an electric car, it’s not just the price of the gas they put in their auto today, but the capital and operating costs of whatever might be the replacement. Given that the fluctuation in gas prices has been over the same range as the expected carbon tax, and people have not shifted on a large scale to other vehicles, I am leery of thinking this is going to make much difference, certainly not in the short term.
This is just special pleading. The carbon tax is applied based on CO2 production. If public transit is lower in carbon than private auto use, which it usually is, then public transit is advantaged over private auto transport vs. the status quo. A decade from now, when the carbon price is much higher, the tables will be significantly tilted towards public transit. Note that active transportation (biking, walking) is even further advantaged, over both public transit and private transport.
This way nearly everyone feels the pain – but crucially, in different amounts.
If public transit was exempted from carbon taxes, they would become unmoored from their purpose, a farce. Also, more difficult politically. If we exempted public transit, carbon taxes would be rightfully seen as a thinly-veiled attempt to grab more money from drivers.
Public transit offers other social goods, largely recognized through municipal subsidies. If you want more municipal subsidies for public transit, advocate for it, by all means.
Steve: I hate to say this, but carbon taxes are a thinly veiled form of fuel tax, at least as they apply to drivers. Their reach is greater because they affect what might broadly be called industrial fuel uses as well (factories, buildings, etc.). People will not switch to transit if there isn’t good service for them to switch to.
The impact of carbon pricing of electricity in Ontario is definitely overblown. At full 2022 pricing ($50/tonne) and ignoring any existing built-in price, it’s approximately $24.05/MWh of carbon-based fuels (natural gas 0.50t/MWh; biofuel 0.54t/MWh), but over the year, we average 10% of our electricity is carbon-based (no base load is carbon generated, only variable peak load). Using the 3-year average (65.99 g/kWh in 2013; 38.15 g/kWh in 2014; 44.03 g/kWh in 2015), you have an average of 0.05t/MWh or $2.47/MWh.
An Orion Model VII diesel bus produces around 1848gCO2/mi. Assuming a trip of 15km (90-95% of TTC trips are below this) and only 10 people per bus (TTC minimum if no alternative service within 600m), that’s a price of $0.09/trip. Compare that to a 2016 1.6L manual Honda Civic at 94gCO2/km or $0.07/trip.
In looking up this last bit, I saw an interesting number…
minimum ROI threshold = 0.23 new riders / net [operating] dollar cost
Steve: A point about that number: The TTC has claimed for years that it is dimensionless, but quite clearly it is not because the operating cost of providing “x” amount of service rises every year. Therefore more riders are needed to “pay for” the cost of the same service. The origin of this number goes back a few decades when the TTC service standard was that the subsidy per new rider should be no more than 5x the system average subsidy. At the time, the average subsidy per rider was about 87 cents, and so 5x was about $4.35 which equates to .23 rides per dollar. Depending on fluctuations both in subsidy levels and in operating cost, this value should change over time.
This has been replaced with a new metric during the Ford era cuts based on minimum boardings per added vehicle hour. Using the amount of service directly, rather than its cost or any relationship to fares, makes the value truly dimensionless with the only adjustment being simply a decision on how generous we want to be with extra service. It also ties in the existing usage and does not depend only on net new riders, and thus is also used in deciding whether to cut service.
With the move back to full service 19 hrs/day on almost all routes, the point is currently moot.
Saying “at least as they apply to drivers” is a meaningless statement, since they don’t just apply to drivers like a fuel tax. The fact that carbon taxes tax all carbon is rather the point, and the distinguishing characteristic.
Steve: It is not a meaningless statement in the context of attracting drivers to transit. What other effects they may have on industrial uses is beside the point. I am not knocking carbon tax, but it must be recognized as a tax on fuel that should have been increased years ago.
It’s true that people won’t switch to transit that isn’t good. Carbon taxes are an argument to get going on building better transit, because transit is being made more attractive – gradually – over time.
Carbon taxes are a long term play that do present mild short term problems, which could be spread over the long term if we chose to do so.
Fuel demand is not at all inelastic, but since it’s consumed by a durable good, the delay in reaction is long (and getting longer). Fuel prices do have a measurable effect on both modal share and size of new vehicle purchases. Working against this is the rise in wealth in our society. Fuel prices may outpace inflation, but unless they outpace income growth, fuel remains a small (and shrinking) share of the household budget for a lot of people. Carbon taxes are set to make fuel prices race far ahead of income growth, and in 10 years we will see a large cumulative effect in vehicle and mode choices.
It’s important that we build transit as transit demand inevitably increases due to the pricing of carbon, else we won’t be able to serve a change in mode. I haven’t seen the exact budget figures, but I wouldn’t be surprised if the transit infrastructure spending needed to support the shift caused by carbon taxes will outstrip the revenues ($17B/year fully implemented I estimate, in 2016 dollars).
Steve: There is a very good chance that the type of transit needed to be attractive will be a long time coming, if ever, while the taxes are “now”. We could very well wind up spending all of the new money on a few gradiose projects and leave a huge proportion of the regional travel without good transit for trips that don’t happen to lie along favoured corridors.
A carbon tax is actually a good idea, and overdue. So is being honest about our carbon and other GHGs; this would be a start.
Yet even within this broad effort, there are major gaps, echoing how ‘green’ Toronto is by just leaving out all that pesky concrete, which is doubly CO2 emitting from cement making. How many millions of tonnes of concrete do we have in this City? EAs should/must include all the concrete emissions/tonnage,if we’re serious about climate change, which we aren’t, sigh, and we confuse transit spending with actual smart/good investments eg. Stupid Subway Extension though of course we need to spend $$$$ in Scarborough. Would that we could do that tax hike in the same way we do bike lanes – up to the Ward Councillor.
I would also note, Steve, that people’s behavior is not continuously variable, and well, they adapt at a certain point, with both short, long term and very long term adjustments. A very high cost of fuel, will induce people to change the type of car they buy. If it is very high, and expected to remain that way, the type of neighborhood they choose to move into, at the time of household formation, and what type of neighborhood they want to live in. It has been clear in the US, that there are critical points of fuel costs that induce people to not buy trucks. The difference between Canada and the US in terms of vehicle size would appear to be largely driven by differences in fuel costs. I would fully agree people will not switch to transit if the service is not there, but this should be part of a two pronged strategy, the other one, is to create new development that is far easier to service. Carbon Tax with an Avenues type development model, where there is steady, frequent and rapid transit close at hand, can alter the nature of a city over time. Similar pressure in the outer areas, where zoning is for fewer parking spaces, and more transit, would start to lay bare the implicit subsidy the car receives as well. Those seas of parking around apartment buildings and shopping malls are not free, but the zoning requires them, and thus they are built into rent, purchase price etc. A carbon tax, with a focus on creating areas of high transit service, easy bike and walking options, and a real cost to driving, would help make this a reality. I would say yes to Carbon taxes that reflect the cost of pollution, and yes to getting rid of high mandated parking, and let the market charge the cost of creating parking spaces, and then people may be less inclined to make auto reliant life choices going forward. The real answer in development, pollution, and society, needs to be to reflect to people the real costs of their choices, and have them pay it.
Steve: But as you and others have noted, all of this has a long time frame, far longer that the attention span of any politician, and certain to fall across major swings in external factors such as the prevailing political mood or world financial situation. The business about changing vehicle types is important. I worked for several years at Scarborough City Hall, and almost everyone in my office drove because transit was not a reasonable option for where they lived. When fuel prices went up, they stopped driving their SUVs and started driving their “beaters”, but they still drove.
It’s also worth noting that many drove because, thanks to municipal amalgamation, people who formerly lived closer to work (and in many cases could and did use transit) no longer had this option when their jobs were relocated. The idea that people will simply move to suit their commute is total folly, never mind the problems with multi-job families.
While the regulations regarding provincial-municipal responsibilities are complex and hard to ascertain, the overriding principle is that the municipalities are effectively “departments” of the provincial governments, and the province has the power to charge whatever it wants. Think back to the amalgamation of the Metropolitan Toronto municipalities into the current City of Toronto. Even though the individual cities were opposed, the premier of the day wiped them out with the stroke of a pen.
The true issue is politics. The provincial governments all want to get re-elected, so they will always avoid picking fights unless necessary. So when Rob Ford walked into Premier McGuinty’s office with demands. the premier said effectively “we will respect the wishes of the Toronto voters” (and let the game play itself out over time). So all the discussion will revolve around apparent equitability, but will try to prevent municipalities from “overspending” or continual flip-flopping.
Look at the urban sprawl that is Toronto. Our real urban area covers multiple municipalities, so taking transit funding out of the municipal tax bases and putting it into the provincial agenda makes more sense. We do not need political debates about cost sharing of the Yonge Street subway between Toronto and York Region (for example). We need a system that works, effectively and safely.
Neither makes perfect sense. The City of Toronto is not inclusive enough. The province is much more than the GTA. The GTA needs an effective regional transit agency able to levy taxes across its geography. It has a transit agency, just not an effective one.
Steve: The problem is that the GTA covers a lot of territory, and one cannot argue that some costs should be “local” if not to individual municipalities, then at least on a sub-regional level. With the growing importance of non-416 oriented trips, can Toronto be expected to regard all GO/Metrolinx subsidies as a benefit to the city, or expect the 905 to pay for service and facilities there? Equally, how far away from the Queen car or the Dufferin bus can we expect people to pay toward’s their operation? How close should the Eglinton LRT get to, say, Peel before it becomes a benefit to them and they are expected to pay toward it through a regional agency? If a Don Mills subway opens up capacity on Yonge-University for more riders from York Region, is the Don Mills line “regional” or “local”?
This is not a simple question, no matter how you draw the map or what sort of agency you concoct to administer the network. And if anyone thinks politics won’t be involved, they are dreaming.
Yes, it is, and to make it work, the public needs to understand the impact of zoning, in terms of outcomes. They need to understand they are paying for that “free parking” at the malls, and for the spot included at their apartment. They must also look around when they examine the notions being sold them, and ask does it make sense. How long is their job tenure, that of their kids, friends, and how many permanently single income families do they know. The city and region needs to start working with a vision and a plan of what the region will look like. However, the voter needs to be able to stop with getting sold on things that a moment’s thought shows to be ridiculous. The notion of subway, subway, subway, is something the city can self evidently not afford. The notion of Smart Track could also be seen to be ridiculous.
The public needs to start asking, “what did the planners recommend”. The Sheppard subway was a mistake, and is still a mistake, because of ego. TYSSE well, fairly sure 20 years after opening, it will still be a planning mistake. SSE, well, it will mean no proper network for the area. ST, well, frankly every step forward shows it is not viable.
Public, must understand, that it is a matter of voting for the realistic. Soknacki and Chow had the most realistic plans, yet, where did they finish? The public must be told, and understand, that if they want a solution, and the truth, vision, not dreams, and realism means looking at what will work, not what is wanted. The city will work, or not, based entirely on whether the voters chooses to be an adult, or a spoiled child.
I think everyone knows politics will be involved. But those politics flow from the structure of the institutions. Metrolinx as currently constituted is designed to be a plaything for Queen’s Park, and therefore inevitably a failure.
An elected regional transit agency with taxing power, by gathering planning and funding functions in one body, greatly reduces the interference from other levels of government, and pressure from citizens who don’t even live in the transit area. It’s not a panacea, but it’s much superior to our current structure.
I’d even consider voting Liberal in the next provincial election if they promised to restructure Metrolinx into something designed for success. Although they’d have to fix their hydro screwups too, and that’s impossible.
Steve: I have two words to counter your argument: “Scarborough Subway”. This is not a Metrolinx project, but the confluence of political factors produced it. A regional elected agency will never be created because it would have powers beyond those either the cities or the province would want to concede with no guarantee it would produce a coherent plan. The key word here is “elected”, and the last time I looked that means “politics”. Would you prefer a Liberal or a Tory regional agency?