Shift in Government Strategy
Bill 5 discontinued provincial funding and policy support for energy efficiency retrofits in public-sector buildings, including schools, hospitals, and social housing. These programs were previously delivered through the Save on Energy framework in collaboration with the Independent Electricity System Operator (IESO) and sectoral partners. The changes reflect a shift in government strategy toward centralized infrastructure investment, with a reduced emphasis on demand-side energy conservation measures.
Scope of change
- As of June 2025, more than 450 planned or ongoing retrofit projects have been paused or canceled, according to data from the Ontario Public School Boards’ Association and the Ontario Hospital Association.
- Capital planning assumptions in multiple districts have been revised to account for the loss of provincial co-funding, which previously covered 30-50% of eligible project costs. Facility managers report adjustments to maintenance schedules, project scoping, and long-term utility planning in response to the change.
Emissions and energy use
- Municipal infrastructure offices and the IESO’s final conservation dataset indicate that public building emissions rose by 11.3% year-over-year between Q1 2024 and Q1 2025.
- This increase has been linked to higher baseline energy consumption from aging equipment, deferred retrofits, and the absence of projected energy savings, previously estimated at 41,000 tonnes CO₂e annually from efficiency upgrades.
Operational and budgetary effects
- Reports from school boards and hospital administrators in cities including Toronto, Ottawa, Thunder Bay, and Windsor indicate utility bill increases in the range of 8-14%, with associated impacts on operational budgeting and infrastructure lifecycle planning.
- No replacement efficiency program has been introduced as of June 2025. The Ministry of Energy has stated that broader infrastructure investment strategies are under development but has not provided details regarding future support for public-sector energy conservation.
Equity Considerations in Rural and Indigenous Communities
Bill 5 concluded several targeted programs previously supporting energy affordability and sustainability in low-income, remote, and Indigenous communities. The changes reflect a broader restructuring of provincial energy planning priorities and funding streams.
Programs concluded
- Energy Affordability Program (EAP): Provided home energy assessments, insulation, appliance upgrades, and bill relief to income-qualified households.
- Indigenous Community Energy Planning (ICEP): Supported community-led development of energy strategies in First Nations communities.
- Fuel-switching incentives: Offered capital support for heating system conversions in off-grid, northern, or high-cost energy environments.
Scale of change
- Based on 2022-2024 participation rates, approximately 120,000 households no longer have access to these initiatives.
- In some northern and remote communities, these programs comprised 50-60% of total annual retrofit activity, including systems important for health, safety, and energy reliability.
Community feedback
- In May 2025, the Ontario Native Women’s Association (ONWA) issued a public statement expressing concern about the energy security of Indigenous women, children, and elders following program termination.
- The Chiefs of Ontario and Nishnawbe Aski Nation called for enhanced coordination with federal programs, noting that existing mechanisms (such as Natural Resources Canada's Indigenous Off-Diesel Initiative) may not fully compensate for the removal of province-specific offerings.
Transition planning
- As of June 2025, no formal transitional framework, replacement program, or consultation plan has been released by the Ministry of Energy. Stakeholder engagement on future design alternatives has not yet been initiated.
Land Use and Biodiversity Changes
Bill 5 includes provisions aimed at expediting energy infrastructure development, including modifications to permitting thresholds and environmental review processes for designated projects. These changes have implications for conservation zoning, habitat connectivity, and land classification across multiple regions.
Wetland and conservation land reclassification
- A June 2025 review by Conservation Ontario estimates that more than 1,200 hectares of previously protected wetlands have been reclassified or made eligible for development under project-specific exemptions.
- Affected sites are primarily located in the Greater Toronto Area, Niagara, and southwestern Ontario, and include regions previously designated as floodplains or groundwater recharge zones.
- According to local conservation authorities, approximately 17% of wetlands classified as “provincially significant” in the impacted areas are now subject to potential land use change.
Greenbelt buffer and habitat connectivity
- Greenbelt buffer regulations are currently under formal review. Proposed amendments would increase flexibility for siting of transmission and other energy-related infrastructure within or near previously restricted zones.
- Several environmental and planning organizations have identified potential risks to habitat continuity, species movement corridors, and watershed hydrology if buffer widths are reduced.
- Internal correspondence from the Ministry of Natural Resources and Forestry (leaked in May 2025) referenced scenarios of increased localized flood risk and long-term ecosystem service loss, though no official cumulative impact statement has been published.
Environmental oversight and review
- The Office of the Environmental Commissioner, operating under revised mandate and reduced staffing levels, has raised concerns that project-by-project mitigation measures may not fully account for cumulative ecological impacts across the province.
- Projects located within designated Special Economic Zones (SEZs) established under Bill 5 are eligible for exemptions from certain environmental assessments and planning regulations. These exemptions vary case-by-case and are subject to cabinet discretion.
Broader Environmental and Social Considerations
System equity and resilience
- The conclusion of targeted energy affordability and efficiency programs affects access to low-cost energy upgrades, particularly for households in older buildings or off-grid communities.
- The absence of retrofit support may limit resilience to temperature extremes and seasonal demand spikes, which are expected to become more frequent due to climate variability.
Ecosystem services and climate adaptation capacity
- Adjustments to land use protections have broader implications beyond biodiversity, including impacts on flood mitigation, local temperature regulation, and natural water filtration (ecosystem services often provided by wetlands and forest buffers).
- Municipalities may face higher infrastructure costs if natural systems are degraded, especially in areas reliant on stormwater control and passive cooling during heatwaves.
Regional variation
- Urban areas report increases in emissions and energy costs associated with deferred efficiency investments in large public buildings.
- Rural and Indigenous regions face more direct impacts on household energy burden and clean energy access due to the withdrawal of geographically targeted programs.
- Regions with high ecological value (such as Niagara, Simcoe, Muskoka, and Durham) are identified by conservation authorities as having increased exposure to land use and habitat changes under the revised development framework.
Regulatory integration and planning coherence
- The absence of cumulative environmental assessments and integrated planning tools under Bill 5 has raised concerns about regulatory coordination across land use, energy, and environmental portfolios.
- Without a province-wide mechanism for tracking trade-offs between emissions, infrastructure development, and biodiversity objectives, stakeholders have flagged the potential for policy misalignment with federal climate targets and biodiversity commitments, including those under Canada's 2030 Nature Strategy.