The Ontario Regional…

The Ontario Regional Committee of the Canadian Association of Physicians for the Environment (CAPE Ontario) respectfully submits its formal comments on Bill 5, the proposed Protect Ontario by Unleashing Our Economy Act.

CAPE is a non-partisan, physician-led organization with over 36,000 supporters across the country. It plays a unique role at the intersection of health and the environment, bringing a credible, evidence-based perspective delivered by the trusted voices of doctors, other health professionals, and researchers to support community and planetary health, and environmental justice.

As physicians living and working in Ontario, we have serious concerns about the impact that Bill 5 would have on our patients, and the health and wellbeing of all Ontario residents. The Bill introduces undemocratic mechanisms that could enable the rapid implementation of poorly considered and unregulated projects—initiatives that lack transparency, bypass expert consultation, conflict with Indigenous rights, and pose significant risks to the environment, economy, and public health.

With respect to the proposed Special Economic Zones Act (Schedule 9 of Bill 5), the legislation grants disproportionate power to the Premier and Cabinet, while diminishing the role of the rest of the elected legislature. It also excludes key stakeholders from the decision-making process—including subject-matter experts with the training and knowledge to inform critical decisions, as well as the public whose tax dollars fund these projects.

It is of major concern that the proposed Special Economic Zones would bypass critical checks and balances by circumventing existing provincial and municipal legislation. The creation of vaguely defined “Special Economic Zones” of unspecified scope—opened to undefined “vetted projects” by unidentified “trusted proponents,” at the sole discretion of a small subset of elected officials—effectively sidelines broader democratic oversight. Even more troubling is that Bill 5 grants these “trusted proponents” unrestricted authority to carry out projects in zones intentionally exempt from provincial and municipal laws and bylaws, effectively creating legal voids.

Ontario’s laws and bylaws, along with the expertise of professionals such as land-use planners, engineers, economists, scientists, and health officials exist to ensure that major decisions are made responsibly and in the public good. By bypassing these safeguards, Bill 5 undermines both democratic governance and evidence-based decision-making, with the potential for large-scale, long-term harm to the province’s economy, environment, and public health.

The creation of such “Special Economic Zones” is particularly egregious for Indigenous communities, especially when paired with Schedule 7, which weakens the Ontario Heritage Act by bypassing mandated archaeological assessments. The undemocratic reach of these measures is further amplified by Schedule 5 of Bill 5, which undermines the Mining Act by granting new ministerial powers and enabling select public servants to fast-track mining activities while eliminating public scrutiny of mining claims.

Given the current Ontario government's well-documented interest in mining the Ring of Fire, the combined effect of these Schedules—bundled into the omnibus Bill 5—would create a powerful mechanism for advancing projects without proper oversight or consultation with First Nations. This approach disregards Indigenous rights to free, prior, and informed consent and environmental protections. Moreover, it risks triggering serious ecological damage with far-reaching consequences for community health and wellbeing. It threatens to contaminate water, soil, vegetation and wildlife, undermine local livelihoods that depend on a non-contaminated natural environment, exacerbate existing social challenges, and significantly reduce community resilience to the impacts of climate change.

The process by which the Bill is being advanced through the legislature raises significant concerns about transparency and public participation. Despite its far-reaching implications, the Bill was introduced with minimal notice and is being expedited through readings at an unusually fast pace. The public consultation process has been limited, with insufficient time allocated for meaningful engagement and an ERO submission deadline that coincides with the first long weekend of the summer.

The environmental risks posed by the Special Economic Zones Act are severe and far-reaching. While the global economy is rapidly decarbonizing and transitioning to renewable energy, the current government of Ontario has cancelled a record number of renewable energy projects early in its first term and prioritized the expansion of methane gas-fired electricity.

Ontario’s policies today support rampant urban sprawl, leading to the loss of a record 319 acres of farmland daily. This undermines our ability to grow food locally and fosters greater dependence on U.S. food imports. Sprawl also contributes to the destruction of wetlands and green spaces, which are critical to supporting a healthy liveable environment for Ontarians.

The Special Economic Zones under Bill 5 would accelerate the degradation of nature, which is vital for both environmental and human health. If the Ontario government truly wants to promote security, as it has claimed, it will withdraw Bill 5 and listen to the province’s physicians, Indigenous peoples, environmental experts, and others who are sounding the alarm about the foreseeable short- and long-term negative impacts of the Bill on the health and wellbeing of our communities.