Action Required Before Sept 12th: Feedback on Data Centre Playb

[Sangeeta Chopra-Charron]

Following is a letter that several of us in the community have prepared in response to the Ontario Government’s proposed Data Centre Playbook.

Many of you may already be aware of this initiative, but I wanted to take a moment to amplify it and encourage you to share it with your networks across Ontario. Broad circulation and submitting comments through the Environmental Registry of Ontario (ERO) will help ensure the Ford government hears our concerns. There is strength in numbers.

The comment period is open until September 12, 2026.

How to submit a comment:

1. Log in to your ERO account
2. Open the notice:
   https://ero.ontario.ca/notice/026-0853
3. Click Submit a comment

If you submit without signing in, your comment will be anonymous and won’t appear in your account. Log in first if you want to track it.

Prefer email? Send your comment to data.centre.consultation@ontario.ca and reference ERO #026‑0853.

I appreciate the opportunity to provide input on the Government of Ontario’s proposed approach to the development of the Data Centre Playbook. Public consultation is essential, but the current draft framework requires significant strengthening to meaningfully protect community health, environment stability and municipal decision-making authority.

After reviewing the proposed approach, I am concerned that the Playbook is shaped almost entirely around economic development, cybersecurity, and investment attraction, with little indication that feedback outside of industry priorities will meaningfully influence the final framework. As noted in my submission, “the scope of the playbook is dangerously narrow” and “the complete absence of a pillar addressing health impacts…is a critical gap” .

To be considered a responsible and comprehensive framework, the Playbook must integrate the following mandatory protections.

1. Mandatory Health Impact Assessments and Residential Exclusion Zones

Data centres generate persistent infrasound and low‑frequency noise (ILFN) from HVAC systems, transformers, and backup generators. As stated in the document, “persistent low‑frequency noise and disrupted sleep patterns are medically recognized contributors to chronic physiological stress” . Diesel generators also emit harmful PM2.5, a known contributor to chronic respiratory and cardiovascular illness.

To protect public health:

• A full Health Impact Assessment must be mandatory for any proposed facility.
• Data centres must be prohibited from locating near homes, schools, and hospitals — or anywhere their noise or emissions would reach these zones.
• Assessments must use frequency‑specific acoustic modelling, not misleading overall decibel averages.

This is the minimum standard required to safeguard community well‑being.

2. Legally Binding Environmental Standards

Environmental protections must be enforceable, numeric, and backed by real‑time monitoring. Voluntary standards are insufficient.

The Playbook must require:

• Numeric limits for noise, ILFN, vibration, water consumption, and air emissions.
• Strict restrictions on fossil‑fuel backup generation and on‑site gas turbines.
• Public, real‑time monitoring with automatic penalties and grid‑connection suspension for violations.
• Full disclosure of cooling‑system chemicals, water use, leak‑prevention measures, and disposal plans.

As the document notes, “closed‑loop cooling should not automatically be treated as zero water use” and must be transparently assessed .

3. Mandatory Transparency and Independent Review

Before any approval:

• Developers must disclose full site plans, electrical demand, generator specifications, cooling systems, battery storage, fire‑protection systems, and predicted noise and air emissions.
• All studies must undergo independent third‑party review selected by the municipality or Province, at the developer’s expense.
• A public portal must maintain all operational data throughout the facility’s lifecycle.

Transparency is essential for public trust and democratic oversight.

4. Enforceable Economic Commitments

Economic benefits must be binding, not aspirational.

The Playbook must require:

• Specific commitments for local job creation, wage tiers, compute access for Ontario businesses, and domestic supply‑chain participation.
• Automatic penalties and clawbacks for unmet commitments.
• Public reporting on economic outcomes.

Without enforceability, economic promises are meaningless.

5. Protection of Municipal Planning Authority

Municipalities must retain full authority over land‑use decisions.

The Playbook must:

• Prohibit the use of Minister’s Zoning Orders (MZOs) and Ontario Land Tribunal (OLT) overrides for data centre siting.
• Require project‑specific land‑use compatibility assessments.
• Guarantee that stricter municipal standards prevail over provincial guidelines.
• Support creation of a Heavy Industry Data Centre zoning class to eliminate “by‑right” approvals on employment lands.

As the document states, “a more suitable location can and must be found” when a project threatens nearby homes or schools .

6. Responsible Siting to Uphold Canadian Data Sovereignty

Data sovereignty requires legal jurisdictional control — not harmful siting decisions.

The Playbook must require:

• Full compliance with Canadian privacy, security, and data‑residency laws.
• Mandatory assessment of foreign ownership and CLOUD Act exposure.
• Regulation of cross‑border data transfers.
• Siting exclusively within heavy industrial zones, not residential neighbourhoods.
• Conform to Canadian Consent Standards (link https://dgc-cgn.org/public-review-opens-for-proposed-national-standard-on-user-centric-data-consent-management-to-enhance-privacy-and-empower-individuals/

As noted, “physical location alone does not guarantee data sovereignty” .

7. Cumulative Impact Assessments

Evaluating data centres individually creates dangerous blind spots. The Playbook must require regional cumulative assessments for areas with multiple proposals, ensuring combined impacts on air quality, water tables, infrastructure, and grid capacity are fully understood.

8. Decommissioning Bonds and Long‑Term Financial Assurances

Developers must post irrevocable decommissioning bonds to cover:

• site cleanup
• industrial remediation
• disposal of lithium batteries and cooling fluids

This prevents taxpayers from inheriting long‑term liabilities.

9. Enhanced Protections for Natural Heritage and Wetlands

For sites near natural heritage features or Provincially Significant Wetlands:

• Mandatory 100–200 metre setbacks
• Engineered stormwater retention ponds
• Strict runoff and drainage protections

These measures reflect established Ontario environmental practice.

10. Genuine, Funded Community Consultation

Consultation must occur before approvals and must be capable of altering project outcomes — including site rejection. The Playbook must also mandate robust consultation with affected First Nations communities, consistent with the Crown’s constitutional duty to consult and accommodate.

Conclusion

Ontario should not expand artificial intelligence infrastructure without enforceable environmental and health standards, transparent oversight, municipal authority, and strong public‑interest conditions. As stated in the document, “Ontario must refuse to expand its digital footprint without enforceable health standards, transparent public oversight, mandatory local consultation, and rigid public‑interest conditions” .

Integrating these protections will ensure that Ontario’s AI Industrial Strategy strengthens the province’s digital future without compromising community health, environmental sustainability, or democratic decision‑making.

[Debra Turnbull]

@Sangeeta-Chopra-Charron

This is brilliant Sangeeta - well thought out.

I did want to mention that as part of Data Sovereignty, conformance, in theory, should be to all Canadian Standards. I tossed in Consent because nobody thinks of it, and it is currently under development.

Might as well tap them on the shoulder and "Hey guys - pay attention"... then, they'll get hit with the 2-by-4 later...

[Debra Turnbull]

@Sangeeta-Chopra-Charron @Alies-Maybee

Huh... wonder if this is the 2-by-4...:

Data Centres in Canada - Federal Rules

[Sangeeta Chopra-Charron]

@Debra-Turnbull Thanks for your thoughtful input - it made the message clearer and more comprehensive.

[Sangeeta Chopra-Charron]

@Debra-Turnbull @Alies-Maybee - Unfortunately, there are key concerns with the Federal Principles for Data Centre Development. They are as follows:

1. Lack of enforcement mechanisms — The proposed federal principles contain no penalties, compliance requirements, or enforcement tools for companies that violate them. Without consequences, the principles function as voluntary guidelines rather than meaningful regulation.

2. Download of responsibility to provinces and municipalities — By shifting regulatory authority to individual provinces and municipalities, the federal government avoids establishing mandatory national standards. This leaves smaller communities without the federal leverage they need to negotiate with large multinational data‑centre operators.

3. Vague and non‑quantifiable language — Phrases such as “minimize water use and environmental impacts” lack measurable thresholds. Without defined metrics, timelines, or evaluation criteria, companies can claim compliance without demonstrating meaningful reductions.

4. No accountability or legal repercussions — The principles do not outline any monitoring, reporting, or legal consequences for non‑compliance. This undermines public trust and leaves communities vulnerable to unchecked industrial expansion.

5. No requirement for renewable energy investment — Data centres impose massive electrical loads, yet the principles do not require operators to build, fund, or contribute to renewable energy infrastructure to offset their consumption. This omission contradicts Canada’s climate commitments.

6. Risk of upward pressure on electricity rates — Even if companies do not directly pass costs to residents, the dramatic increase in demand can strain supply, trigger new infrastructure spending, and ultimately raise electricity prices. Basic supply‑and‑demand economics suggests residents may bear indirect financial impacts.

We will need to develop a letter to submit feedback to the federal government and to our local MPs

Peter Wall
Deputy Chief of Staff and Director of Communications
Office of the Minister of Artificial Intelligence and Digital Innovation and Minister responsible for the Federal Economic Development Agency for Southern Ontario
peter.wall@ised-isde.gc.ca
343-543-5391

Media Relations
Innovation, Science and Economic Development Canada
media@ised-isde.gc.ca

[Debra Turnbull]

@Sangeeta-Chopra-Charron

Yeah, just found the Federal Government's webpage:

• 1. Data centres must create lasting local benefits.
• 2. Data centres must not shift electricity costs to Canadians.
• 3. Data centres must minimize water use and environmental impacts.
• 4. Data centres must be transparent about local impacts.
• 5. Data centres must bring strategic value to Canada.