To: Environmental Registry…

To: Environmental Registry of Ontario
Subject: Opposition to Bill 5 – Protect Ontario by Unleashing Our Economy Act, 2025

I am writing to express my strong opposition to Bill 5, the Protect Ontario by Unleashing Our Economy Act, 2025. This omnibus legislation poses grave risks to Ontario’s environment, Indigenous rights, democratic oversight, and public health.

Ontario Place - The public deserves proper notification about all of the troubling development at Ontario Place.

Removal of Environmental Protections - Bill 5 proposes to repeal the Endangered Species Act and replace it with a much weaker Species Conservation Act. This new framework removes the requirement for species recovery, making it nearly impossible to prevent further decline or extinction of at-risk species. The Bill hands Cabinet the power to determine which species deserve protection, turning what should be a science-based process into a political decision. Permitting processes are replaced by simple online registrations, allowing developers to begin work immediately, even if it threatens critical habitats, with no meaningful review or mitigation requirements.

Creation of lawless “Special Economic Zones” Without Oversight - The Bill grants Cabinet the authority to establish “special economic zones” anywhere in Ontario. Within these zones, provincial and municipal regulations-including those protecting the environment, labour rights, and public safety-can be suspended or overridden at the government’s discretion. There are no clear limits on the size, location, or scope of these zones, nor is there any requirement for public or legislative oversight in their creation. This is an unprecedented transfer of unchecked power to the executive, undermining the rule of law and democratic accountability.

Threats to Indigenous Rights and Lack of Consultation - Despite government assurances, Bill 5 contains no explicit mechanisms to ensure meaningful consultation with Indigenous communities. The creation of special economic zones, particularly in sensitive regions like the Ring of Fire, risks violating constitutionally protected Indigenous rights and could result in the destruction of burial sites, artifacts, and traditional lands. The absence of any process for Indigenous engagement or recourse is contrary to the province’s duty to consult and accommodate.

Undermining Public Participation and Environmental Assessment - Bill 5 removes requirements for environmental and archaeological assessments in designated projects and zones, eliminating crucial safeguards that protect land, water, wildlife, and human health. It also exempts certain controversial projects from posting on the Environmental Registry, thereby shutting out public input and transparency that are fundamental to Ontario’s environmental decision-making process.

Risks to Labour Rights and Community Well-being - By enabling the suspension of labour laws and health and safety standards within special economic zones, Bill 5 threatens the rights and protections of workers, families, and communities across Ontario. The potential for entire cities or regions to be designated as such zones means that basic rights-such as the right to refuse unsafe work, minimum wage protections, and even meal breaks-could be eliminated at the stroke of a pen.

Bill 5 represents a sweeping rollback of environmental, social, and democratic protections in Ontario. It prioritizes concerning development and deregulation at the expense of the province’s natural heritage, Indigenous rights, public health, and the rule of law.

I urge the government to withdraw Bill 5 in its entirety and to engage in meaningful consultation with Indigenous Nations, environmental experts, and the public to ensure that Ontario’s future is sustainable, just, and democratic.

Thank you.