provided no better parity than the newly-implemented 47-ward structure, and a consultant argued that the roughly doubled ward population reduced councillors' capacity to serve their communities—another aspect of effective representation. In an affidavit, Toronto city manager Giuliana Carbone disputed the claimed cost savings, stating that it would only save $6 million over four years, taking into account the increased staffing that would be required to operate the larger wards, and the costs incurred by realigning the election to match the new boundaries. On September 10, 2018, the Better Local Government Act was struck down as unconstitutional by Superior Court Justice Edward Belobaba, ruling that the larger wards infringed on citizens' rights to effective electoral representation, and that unilaterally changing electoral boundaries in the middle of a campaign infringed on candidates' freedom of expression. He explained that "passing a law that changes the city's electoral districts in the middle of its election and undermines the overall fairness of the election is antithetical to the core principles of our democracy", and questioned the province's intent and timing of the legislation. Ford criticized the ruling, contending that its only supporters were a "small group of left-wing councillors looking to continue their free ride on the taxpayers' dollar and a network of activist groups who have entrenched their power under the status quo." The Ford government introduced the Efficient Local Government Act, also known as Bill 31, on September 12, 2018. The bill would have invoked Section 33 of the Canadian Charter of Rights and Freedoms, also known as the notwithstanding clause, to implement the effects of Bill 5 in defiance of the court ruling. If passed, it would have been the first time that the notwithstanding clause had ever been invoked in Ontario. The Toronto city council voted 29–7 in favour of directing the city solicitor to challenge the new legislation in court, and to ask the federal government to invoke a constitutional clause allowing it to disallow provincial legislation (a mechanism only used once since 1943) should it pass. At a Liberal Party caucus retreat in Saskatoon, Prime Minister Justin Trudeau stated that he would not contribute to the discussions surrounding the sizes of municipal governments in Ontario, as it was "[not] a role that the federal government needs to take on". On September 19, 2018, the Court of Appeal for Ontario issued a stay on the previous Superior Court decision, ruling