There are several compelling…

There are several compelling arguments for the withdrawal of Schedule 3 of the proposed Protect Ontario by Unleashing Our Economy Act, 2025 (Bill 5). Schedule 3 proposes to exempt significant projects, including the York1 Dresden Landfill, from the rigorous requirements of the Environmental Assessment Act (EAA). I urge the Province to consider the following points which underscore the necessity of maintaining the integrity of the EAA.

1. Lack of Justification for Exemption: Firstly, the Ontario government has not provided a credible justification for exempting the York1 Dresden Landfill from environmental assessments. The EAA already contains provisions for exemptions when warranted in the public interest. The absence of compelling environmental rationale or persuasive evidence to support the exemption raises serious concerns about the motivations behind this legislative action.

2. Speculative Basis for Exemption: The technical briefing suggests that the exemption is necessary due to “continued threats of border interruptions and tariffs.” However, the possibility of border closures affecting waste exports has been a longstanding concern, and mere speculation does not constitute a valid basis for bypassing established environmental review processes. This precedent could potentially open the floodgates for other landfill proponents to seek similar exemptions, undermining the EAA’s foundational purpose.

3. Public Interest and Environmental Protection: Exempting the York1 Dresden Landfill contradicts the public interest objectives of the EAA, which aims to protect and conserve the environment for all Ontarians. Allowing such exemptions in sensitive areas undermines the societal goals of the EAA and poses risks to water, wildlife, and human health—issues that require thorough investigation and consideration.

4. The EAA as a Robust Process: It is essential to recognise that the EAA is not mere “red tape.” It is a robust, participatory, and evidence-based process designed to identify, evaluate, and mitigate environmental risks associated with significant projects. The substantive requirements of the EAA, including the examination of project need, alternatives, and impacts on various environments, are not replicated in other environmental approvals, rendering the EAA indispensable for comprehensive environmental planning.

5. Absence of Federal Oversight: Furthermore, it is critical to note that the York1 Dresden Landfill is not subject to the federal Impact Assessment Act (IAA). By exempting this project from the EAA, we risk leaving it without any environmental assessment oversight, which is unacceptable.

Conclusion: In light of these points, I respectfully submit that the Ontario government must withdraw Schedule 3 of Bill 5 to ensure that the EAA remains fully applicable to the York1 Dresden Landfill. The integrity of our environmental assessment processes must be upheld to protect the health and well-being of Ontarians and the environment we all share.