The Right to Know: Hubbert’s Emissions Proposal and the Fight for Environmental Transparency in Animal Agriculture

On March 11, 2025, the Ministry of the Environment, Conservation and Parks posted a proposal on the Environmental Registry of Ontario ("ERO") for a new air emissions approval for Hubbert's Processing and Sales Inc., a meat processing facility in Brampton, Ontario. If approved, the Environmental Compliance Approval (Air) with Limited Operational Flexibility ("ECA") would replace all existing air approvals for the facility and authorize both current and future equipment to emit air pollutants—including nitrogen oxides—into the surrounding environment, within specified production limits.

Nitrogen oxides are a class of harmful emissions that pose well-established risks to human health and the environment. According to the Government of Canada, these pollutants can have “adverse effects on the respiratory system of humans and animals… can cause damage to vegetation, buildings and materials, and contribute to acidification of aquatic and terrestrial ecosystems.” 

In light of these risks, AEL Advocacy has submitted comments on Hubbert’s proposal. But our ability—and the public’s ability—to meaningfully review and respond has been severely limited by a troubling lack of transparency.

Hubbert’s Processing & Sales Inc., 109 East Drive, Brampton, ON (Source: Google Maps)

Barriers to Public Participation

Ontarians have a legal right to participate in environmental decision-making granted under the Environmental Bill of Rights ("EBR"). Enacted in 1994, the EBR was designed to empower the public, ensuring that decisions affecting our environment and health are not made behind closed doors. The EBR gives everyone the right to know about proposals that may impact the environment, to provide feedback, and to have that feedback meaningfully considered by government decision-makers.

But that right only matters if people can access the information they need to understand what’s being proposed.

In this case, the public comment period for Hubbert’s emissions proposal is open until April 25, 2025. Yet, when AEL Advocacy attempted to access the proposal’s supporting documents—including information about emissions levels, sources, and environmental risks—we hit a wall.

The ERO posting indicated that the application documents could only be viewed in person. When AEL Advocacy contacted the listed official, we were told access was restricted and that the materials were deemed “confidential.” Instead, we were advised to submit a Freedom of Information request—a process that can take several months, far beyond the April 25 deadline.

This situation presents a fundamental access to justice issue. Without access to the proposal’s supporting documentation—including environmental assessments, mitigation strategies, and technical justifications—the public cannot evaluate the risks, ask informed questions, or offer meaningful feedback. Denying or delaying access to these materials undermines the purpose of public consultation under the EBR, effectively excluding the public from the decision-making process.

A Broader Pattern of Regulatory Gaps in Animal Agriculture

This lack of transparency is especially concerning given the broader context. The animal agriculture sector already benefits from minimal environmental oversight compared to other polluting industries. In Ontario, large-scale meat processing and livestock operations are often subject to weaker enforcement mechanisms and enjoy regulatory exemptions that limit public scrutiny.

Restricting access to emissions information in this case only deepens the lack of transparency and accountability in the industry. If the government is serious about protecting environmental and public health, it must hold all industries—especially high-polluting ones—to consistent and rigorous standards of disclosure and public consultation.

The Ministry’s Responsibility to Uphold Public Participation

The Ministry of the Environment, Conservation and Parks has specific responsibilities under the EBR when reviewing proposals like Hubbert’s. Because this is a Class II Instrument under Ontario Regulation 681/94 (Classification of Proposals for Instruments), the Ministry is obligated to take additional steps to ensure public participation is meaningful.

This includes considering whether to extend the public comment period beyond 30 days and exploring enhanced consultation processes such as oral hearings, public meetings, or mediation—particularly when access to written materials is restricted. Failing to do so not only weakens public trust in environmental governance but also risks violating statutory obligations under the EBR.

Moving Forward

AEL Advocacy continues to push for full access to the information surrounding Hubbert’s emissions proposal and is calling on the Ministry to extend the public comment period until all relevant documents are available to the public. The EBR mandates more than just the appearance of consultation—it requires transparency, accessibility, and genuine opportunities for public engagement.

We strongly encourage members of the public to submit comments through the Environmental Registry of Ontario by the April 25, 2025 deadline. To support public participation, AEL Advocacy has prepared an Action Brief that includes background information, key talking points, and a sample letter that you can personalize and submit.

This is a critical opportunity to speak out against the lack of transparency and demand a say in how emissions from the animal agriculture sector are regulated. Public consultation only works when the public can participate—so let’s make our voices heard.