Given our experience in Ontario, I would concur with my predecessor's view. One of the issues I know he was very troubled about was the fact that, as you alluded to, Elections Ontario was perceived to be biased because of the role they performed on the public education front.
The legislative framework established by the regulation under the Electoral System Referendum Act did not provide for umbrella groups. In fact, it provided for what were called “registered campaign organizers”.
In Ontario we had ten registered campaign organizations sign up. They were any entities or individuals who collectively were going to raise or expense more than $500. There was no public funding provided by the government. As in Quebec, there was no ability on a per capita basis for the political parties to make donations to these registered campaign organizers, as well.
So I do concur with my predecessor's view that, yes, having umbrella organizations would be preferable. I think the most recent example occurred in B.C., and it is a prime example of where, in their second referendum, they did in fact provide for an equitable funding to the yes and no campaigns. From my perspective, I would certainly make a recommendation that you give this some serious consideration.