The Township of Southgate…

The Township of Southgate wishes to thank the province for this opportunity to comment on the proposed omnibus Bill 5 “The Protect Ontario by Unleashing our Economy Act, 2025”. The Township has several concerns related to the proposed amendments, which are as follows:

Establishing Special Economic Zones:
There is no clear process whereby Special Economic Zones are established. The potential that any development in these zones would be exempted from any Provincial Legislation and Municipal By-laws provides little accountability and assurance that a project would be subject to due diligence, proper review and oversight. The ability to exempt a project in these zones from any environmental due diligence or review, possess significant long-term risk to municipalities as the loss of wetlands and other sensitive areas or species cannot be easily remedied.
What means will the province provide to assure municipalities that they can be a part of the decision-making process and would be engaged prior to any decisions by the Province on these zones or projects within the zones?

Engaging with local municipal staff and Council can provide unique, location specific information that provincial staff and decision makers may be unaware of and have implications for projects going forward. Economic uncertainty can come and go – but these projects (and their impacts) will last for decades or longer.

Species at Risk/Heritage Act changes (loss of Archeological assessments):
The potential changes to Species at Risk and reduction of protections to habitat do not align with the Provincial Interest in Planning. The removal of Environmental Assessments also does not align with the Provincial Interest in Planning. Specifically, 2 (a), 2 (c), and most significantly 2 (d) of the Planning Act – which would be dramatically impacted by the proposed changes to the Heritage Act. The removal of archeological impact assessments may pose challenges given the Provincial Duty to Consult to our indigenous communities – how will the province ensure that burial grounds or indigenous history will be maintained and not lost? The proposed changes also do not seem to align with the Provinces own Duty to Consult guidelines.

Ontario Place Redevelopment:
While the Ontario Place Redevelopment does not impact Southgate – it is concerning when amendments are made that specifically seek to remove the public opportunities for engagement on the development. Meaningful consultation is expected of planning applications, yet the province is seeking to remove this requirement.

General comments:
The Township encourages the province to put in place a decision-making process and oversight process on where economic zones are established prior to adoption of any changes. We encourage the province to also include engagement with local municipalities (council, residents and their staff) before making decisions on establishing these zones and uses. These are projects that will remain in these communities for decades and have far reaching impacts.

We also encourage the province not to remove environmental protections for species at risk and natural heritage features. Climate Change is accelerating and affecting the residents of Ontario and restoring destroyed habitat is challenging and often does not occur. Once a species is lost, it generally cannot be brought back.

The removal of environmental impact assessments on two projects (The Proposed Eagle’s Nest Mine and Proposed Dresden Landfill) is concerning – as this could lead to more projects being exempt from proper environmental due diligence.

Southgate hopes that the province will take this opportunity to see the significant public concerns on the proposed Bill 5 and make significant changes to restore proper environmental due diligence, public trust and engagement before moving forward.