My comment concerns Bill 5,…

My comment concerns Bill 5, short title Protect Ontario by Unleashing our Economy Act, 2025, henceforth referred to as the “Bill”. Specifically, I am concerned about section 2 to Schedule 3, hereafter referred to as the “Amendment”. To summarize, this Amendment will exempt a proposed landfill on the immediate periphery of the town of Dresden from an existing environmental assessment issued under the Environmental Assessment Act, or EAA. It is imperative that the Amendment be struck for three reasons:

1. The proposed landfill’s location presents an existential risk to Dresden and its community;

2. The Amendment’s insertion into Bill 5 undermines the government’s credibility in its approach to the present crisis in Canada-U.S. relations; and

3. The Amendment’s inclusion in the Bill may embroil our government in a corrupt quid-pro-quo.

For context, Dresden is a small community situated between Sarnia and Chatham, populated by a little more than 2 000 people. My family’s roots in the Dresden area predate Confederation, and many others in the area can say the same. The proposed landfill will operate on a lot totalling 35 hectares. The proponents of this project appear to have attempted to exploit pre-existing EAA approvals which permit a small landfill on the site. Intending to radically expand the operation to handle hundreds of thousands of tons of waste each year, the proponents believed that this expansion will not require a new review under EAA Part II.3 as would be required of significant new landfill operations.

This conduct did not go unnoticed: Dresden residents and communities in Chatham-Kent and Lambton counties rallied to oppose the project, demanding that a massive landfill situated near the heart of the community’s watershed be subject to a standard review under Part II.3 of the EAA. Local councils provided significant political, financial, and legal support to these efforts. As a result of these efforts, the previous Minister of the Environment, Conservation and Parks announced in March, 2024 that a comprehensive review of the project under the EAA would be required, as would be required of “any other landfill”. To this effect, a regulation was later issued on June 28, 2024 under the EAA designating the site as requiring a Part II.3 assessment before proceeding.

This requirement is eminently reasonable; the project has not been halted and may proceed if its proponents can demonstrate that all obligations required for projects designated for review under EAA Part II.3 have been met. This review is particularly necessary before this project can proceed for two reasons:

1. The proponents’ apparent reasoning in selecting this specific site for this specific project; and

2. The scale of proposed operations and disproportionate impact of the landfill’s operations due to its proximity to the community and to its watershed.

On the first point, the site for the proposed landfill is unusual. It has been noted that it is bizarre to locate a large landfill designed to process distant metro areas’ waste so far from primary highway arteries, namely the 401. As a result, an estimated average of 700 trucks per day are expected to egress to the landfill via local Dresden and county roads. These roads are not designed to handle such heavy truck traffic; local taxpayers will be responsible for road upgrades and maintenance, effectively subsidizing the landfill’s owners. In part because of this unusual siting decision, one may suspect that the proponents selected this site for the landfill in an attempt to, as mentioned, exploit existing, limited EAA approvals. Until the Minister’s intervention in 2024, this course of action may have succeeded. One may wonder why the proponents attempted to subvert the environmental assessment process required of all new landfill projects in attempting to claim that this massive landfill is a simple expansion of a small, long defunct waste processing operation. It seems reasonable for one to assume that the proponents feared that the proposed operation would not satisfy EAA standards required for new landfills, especially given the site’s proximity to the town and its watershed.

This leads to the second concern, that being the location of the landfill immediately next to Dresden and at the core of the community’s watershed via Molly’s Creek and the Sydenham River. In addition, a number of homes are situated directly adjacent to the proposed site, each drawing their own well water. The presence of such a large landfill immediately adjacent to these homes risks contaminating the watershed and, by extension, residents’ drinking water. I ask: on its face, is it reasonable to locate a 35-hectare landfill site on the immediate periphery of a town of just more than 2 000 people? On its face, is it sensible to locate such an enormous landfill deep within a key watershed from which residents draw their drinking water? If so, I suppose one can anticipate the province’s imminent establishment of a new, 2 000-acre landfill operation on the banks of Lake Ontario in the heart of Etobicoke. In all seriousness, should this landfill proceed as planned without a standard EAA review, Dresden may be virtually destroyed. If the town is not destroyed by landfill runoff contaminating the watershed, then it will be destroyed by the imposition of brutal tax increases to finance road infrastructure upgrades required to handle heavy truck traffic to and from the site. A historic, quaint community risks becoming little more than a vestigial conduit for a private operation which, as thanks for the community’s fiscal contribution, will reward the community by threatening to poison its water.

In addition, the Amendment’s implications for the province’s efforts to manage the crisis in Canada-U.S. relations will now be addressed, though some context will first be established. Prior to the government’s commitment to proceed with a full environmental assessment, our Premier was asked about local opposition to this proposal during the Lambton-Kent-Middlesex byelection campaign in May, 2024. The Premier’s response was, “If the people like something, we do it. If they don’t, we don’t do it. It’s about as simple as that”. The Premier appears to have had a sudden change of heart, however. On April 17, 2025, in response to a question regarding the Amendment’s inclusion in the Bill, the Premier stated: “forty percent of waste from companies and people are heading down to the U.S. Just imagine if, tomorrow, President Trump … says ‘we aren’t taking any more of Ontario’s waste’ – [w]hat do we do?”. Apparently, the answer to that question is to dump the province’s garbage on Dresden, regardless of anything the American President may or may not do.

To use the present crisis as a pretext to overrule by legislative cudgel an environmental assessment which has yet to even conclude suggests that the government either does not take the crisis seriously, or that it believes, contrary to its rhetoric, that no such crisis exists. Either conclusion undermines Ontario’s and Canada’s efforts to respond to American threats by undermining our credibility before the United States and by wasting precious legislative time on matters which are, in the scope of the Canada-U.S. relationship, beyond trivial.

I believe that the United States presents enormous risks to our economic and political sovereignty, and that difficult decisions will have to be made in the coming weeks and years. I fail to see, however, how this threat necessitates the development of a domestic strategic garbage reserve. I further fail to see why this strategic reserve must be rammed down the throat of a small community, unless the government believes that Dresden is too small to resist. The government’s rhetoric with respect to the David and Goliath challenge Canada faces vis-à-vis that United States suggests that it believes that a small but determined community can confront, combat, and outlast a larger, predatory foe. It would do well to apply the same principle concerning its own attack on Dresden given the community’s determined will to defeat this proposal.

My final point in opposition to the Amendment is perhaps the most consequential in terms of its consequences for the province as a whole and certainly for its government. Based on recent reports, I am increasingly afraid that the government’s motivation for including the Amendment is based not on the national or provincial interest, but is simply a political favour for wealthy donors to the governing Progressive Conservative Party. To briefly summarize the report, following the government’s commitment to order an EAA review of the proposed landfill, associates of the proponents made thousands of dollars in political contributions to Progressive Conservative Party fundraising initiatives, including purchasing $1 000 tickets to attend at least one party fundraising event at which the Premier himself was present. In addition, the proponents, their employees, and family members are alleged to have contributed approximately $200 000 to the Progressive Conservative Party since the current government came to power in 2018. The proponents have also allegedly engaged lobbyists with professional relationships to the Premier, and in 2021 it is alleged that the proponents and family donated over $50 000 to the Progressive Conservative Party in advance of a $1 000 per ticket event featuring an “intimate and candid discussion” with the Premier.

I draw no conclusions from these events regarding the Premier’s relationship with the proponents or whether any such relationship influenced the government’s decision to include the Amendment in Bill 5. My point is, whether corrupt intent exists or not, the Amendment’s inclusion in Bill 5 in light of such reports contributes to the perception that Ontario is not a democracy governed by its people, but governed instead by the well-resourced and properly connected. Such perceptions are toxic to confidence in our government and in other public institutions.

In conclusion, I ask that section 2 to Schedule 3 be removed from Bill 5. This Amendment unjustly excludes a massive landfill project from standard environmental assessment procedures generally required of proposed landfills. Should this project proceed without the assessment as currently required, a beautiful, historic community faces extinction as a result of contaminated water, unsustainably disruptive truck traffic, and unconscionable tax increases. The Amendment’s inclusion in the Bill also undermines the province’s approach to dealing with the crisis in Canada-U.S. relations by making the absurd suggestion that our very sovereignty is threatened unless a new landfill is given an exclusion from environmental assessment requirements which will otherwise remain unchanged. Finally, section 2 to Schedule 3 must be stripped from the Bill to prevent corruption or perceptions thereof from tarnishing Ontarians’ trust in government. Given global anti-democratic upheaval, I trust that this Bill will not become law with this Amendment intact; the stakes are too high to do otherwise.