City of Cambridge Submission on Ontario's Proposed Data Centre Playbook

On behalf of the City of Cambridge, I want to thank the Province of Ontario for inviting municipalities, residents, utilities, businesses and other interested parties to provide input into the development of Ontario's Data Centre Playbook. 

The City strongly supports the Province's decision to establish a clear, coordinated and province-wide approach to data centre development. This is the right approach for Ontario. It recognizes that data centres are critical infrastructure while also acknowledging that their scale and demands require clear rules, careful planning and meaningful local benefits. 

A consistent provincial framework will provide municipalities, residents, utilities, investors and operators with greater certainty. It will also help avoid a patchwork of separate municipal responses. Without clear provincial direction, municipalities may feel compelled to address these proposals independently through different planning tools or temporary measures, including interim control by-laws. A strong Playbook can reduce that need by creating reliable province-wide expectations while preserving the important role of municipalities in land use planning, servicing, local infrastructure coordination, development review and community engagement. 

Data centres are essential infrastructure 

Data centres are no longer simply large buildings containing computer equipment. They are part of the essential infrastructure that supports modern life and Ontario's future prosperity. 

They enable financial transactions, health care systems, emergency services, municipal operations, education, advanced manufacturing, cloud computing, cybersecurity, artificial intelligence, research and the everyday digital services used by residents and businesses. Communities seeking to attract advanced manufacturing, technology companies, research institutions and knowledge-based industries will increasingly require secure, reliable and locally accessible digital infrastructure. 

Data centres can also strengthen domestic supply chains, support innovation, increase municipal assessment and tax revenues, create skilled employment and improve Canada's economic and digital resilience. Their importance will continue to grow as artificial intelligence, quantum computing, automation and digital public services become more deeply embedded in our economy. 

The question, therefore, should not be whether Ontario needs data centres. The question is how Ontario ensures that the right data centres are built in the right locations, using the right technologies, with appropriate protections, clear municipal participation, and meaningful benefits for the communities that host them. 

Cambridge believes every data centre must earn the privilege of locating in an Ontario community. 

Cambridge's recommended requirements for the Playbook: 

Protect Canadian data sovereignty: 

Residents have raised understandable concerns about where Canadian data is stored, who controls it, what laws apply to it and whether critical Canadian information could become subject to foreign access or influence. 

The Playbook should establish Canadian data sovereignty as a mandatory consideration in the approval of new large-scale data centres. Ontario should prioritize Canadian-based companies and projects governed by Canadian law, with meaningful Canadian ownership, operational control and accountability. 

Applicants should be required to demonstrate that sensitive and critical Canadian data will remain in Canada and be protected by Canadian privacy, cybersecurity and security requirements. They should disclose ownership, investors, operators, controlling interests, applicable legal jurisdictions and any anticipated cross-border data transfers. 

Where full Canadian ownership is not possible, an applicant should be required to demonstrate meaningful Canadian governance, operational control, domestic data residency, cybersecurity oversight and legal accountability. The Province should undertake a formal sovereignty assessment examining ownership, operational control, data residency, cybersecurity, foreign access risks and the nature of the information expected to be stored or processed. 

The objective should be clear: critical Canadian data must remain protected by Canadian laws, Canadian standards and meaningful Canadian oversight. This is especially important for health care, financial services, education, energy, public safety, defence and other critical infrastructure. 

Require modern closed-loop cooling and protect water supplies: 

Water use is one of the most significant concerns being raised by residents, particularly in communities where water capacity is constrained or where municipalities rely heavily on groundwater. 

Ontario should make modern, water-efficient cooling technology a condition of approval. New data centres should be required to use closed-loop, dry-cooling or equivalent systems that recirculate coolant and require little or virtually no ongoing municipal water during normal operations. Traditional systems that depend on continuous withdrawals of treated municipal water for cooling should not be accepted for new facilities where modern alternatives are technically available. 

Every applicant should disclose projected water demand during construction, the initial filling of the cooling system, normal operations, maintenance, system top-ups, emergency conditions and extreme temperatures. The submission should also identify the source of all water, expected wastewater discharges, drought contingencies and the response to municipal water restrictions. 

The Province should require independent verification of water-use estimates, ongoing monitoring and public reporting. If actual water consumption materially exceeds the approved amount, the operator should be required to undertake corrective action. 

In groundwater-dependent communities such as Waterloo Region, municipal drinking water must not become an inexpensive industrial cooling resource. Water required for residents, housing, employment growth, agriculture and essential public services must remain the priority. 

Protect electricity reliability and existing ratepayers: 

Data centres can place significant and sustained demand on the electricity system. Residents and businesses need assurance that approving a large new electricity user will not compromise reliability, delay other economic development, increase electricity costs or force existing customers to subsidize infrastructure required for a private development. 

The Playbook should require every proposed data centre to work directly with the applicable local hydro distribution company before provincial approval is granted.  Each project should submit a comprehensive energy and grid-impact plan identifying total electricity demand at full build-out, phasing, required distribution and transmission upgrades, ownership and maintenance responsibilities, capital and lifecycle costs, impacts on reliability, impacts on capacity required for housing and employment growth, backup generation, emissions, energy storage, demand response, emergency curtailment and financial security. 

Data centre owners should pay the complete cost of connecting to and affecting the electricity system. Those costs and risks should not be transferred to existing residential, commercial or industrial ratepayers. Large operators should also provide adequate financial guarantees or security to protect utilities, municipalities and ratepayers from non-payment, stranded infrastructure or a project that does not proceed as proposed. 

Ontario should encourage or require large data centres to contribute to grid resiliency through on-site or nearby generation, battery storage, demand management and the ability to reduce load during defined system emergencies. Local distribution companies must retain a meaningful role in evaluating, planning and safely operating the systems affected by these major loads. 

Require a complete employment and economic benefit plan: 

Residents have also questioned whether the substantial land, electricity and infrastructure requirements of data centres are justified by the number of permanent jobs created at an individual facility. 

The Province should directly address this concern by requiring every applicant to provide a complete and independently supportable employment and economic benefit plan. Job claims should clearly distinguish between construction jobs, permanent on-site employment, indirect employment and broader economic spin-offs. 

The plan should identify construction employment and duration, local contracting and procurement opportunities, permanent full-time and part-time positions, anticipated occupations and qualifications, salary ranges, apprenticeships, co-op placements, internships, workforce training, partnerships with colleges and universities, and opportunities for Ontario and Canadian suppliers. 

Applicants should also explain how the project will support cybersecurity, information technology, engineering, research, commercialization and local innovation. Commitments should be measurable and subject to monitoring after approval. 

Ontario should give preference to projects connected to a wider innovation, research or industrial strategy rather than stand-alone facilities with limited interaction with the host economy. A successful project should strengthen local technology companies, advanced manufacturing, start-ups, institutions and strategically important Canadian industries. 

Plan appropriate locations and prioritize brownfield redevelopment: 

Data centres are specialized employment uses with distinct land, electricity, fibre, cooling, noise, security and infrastructure requirements. They should not be placed in locations simply because land happens to be available. 

The Playbook should direct municipalities to incorporate appropriate data centre policies into their official plans and zoning frameworks. Provincial guidance should identify common matters to be considered while preserving the authority of local councils to determine appropriate locations based on local conditions. 

Location criteria should address compatibility with surrounding uses, separation from sensitive residential and institutional uses, proximity to suitable electricity and fibre infrastructure, road access, servicing capacity, noise, low frequency sound and vibration, emergency access, fire protection, stormwater, natural heritage, visual screening, security and opportunities for waste heat recovery. 

Brownfield and previously developed employment lands should be prioritized where servicing, compatibility and environmental conditions are allowed. Redeveloping an underused industrial site can return land to productive use, support remediation, limit unnecessary greenfield expansion and take advantage of existing infrastructure. However, brownfield status should not create automatic approval. Every site must still demonstrate compatibility, capacity, environmental suitability and alignment with the municipality's economic objectives. 

The Province should also encourage data centres to form part of master-planned employment developments rather than isolated, stand-alone buildings. This can support shared infrastructure, complementary businesses, district energy, heat recovery and better integration with the surrounding community. 

Incorporate a mandatory, locally determined Community Benefit Framework 

Most importantly, Ontario should require every new or materially expanding data centre to provide a direct, meaningful and lasting benefit to its host community. 

The Province should incorporate a mandatory Community Benefit Framework directly into the Data Centre Playbook. The Playbook should establish the requirement that each qualifying project provide measurable community benefits as a condition of approval. However, the nature, form and local allocation of those benefits must remain at the discretion of the host municipality. 

Every municipality is different. Communities have different infrastructure needs, growth pressures, financial realities, neighbourhood priorities and social challenges. A meaningful benefit in Cambridge may be different from a meaningful benefit in northern, rural, regional or other urban municipalities. A uniform provincial list or one-size-fits-all formula would not adequately reflect those differences. 

The respective roles should therefore be clear: the Province should require community benefits and establish minimum principles for transparency, proportionality, enforceability and reporting; the host municipality should determine what benefits are needed, negotiate the agreement and direct the benefits toward the local priorities that create the greatest public value. 

Municipalities should have the authority to negotiate and approve community benefit agreements that are flexible, transparent and enforceable. Agreements should identify commitments, values, timelines, performance measures, reporting requirements and remedies if commitments are not fulfilled. The municipality should also be able to revisit the agreement when a facility materially expands or its approved electricity, water or land requirements significantly change. 

The scale of a required benefit could be informed by total project investment, electricity demand, building area, land consumed, infrastructure impacts, water and wastewater requirements, permanent employment, expected municipal revenues, expansion potential and operating life. The provincial framework should make clear that these factors are a floor for negotiation, not a substitute for municipal discretion. 

At the municipality's discretion, benefits could support affordable housing, parks, trails, playgrounds, recreation centres, libraries, arts and culture, tourism, festivals, food banks, shelters, service-based organizations, youth programs, scholarships, skilled trades training, transit, active transportation, environmental restoration, downtown revitalization, community energy, public technology access, innovation programs, Indigenous partnerships or other locally identified priorities. 

Municipalities should also be able to negotiate non-financial benefits. These could include local procurement, apprenticeship targets, public access to training, land for municipal purposes, shared infrastructure, waste heat recovery, district energy, environmental improvements, emergency preparedness resources and in-kind professional or technical support. 

Ontario should further enable a municipality, where it chooses, to establish a dedicated Data Centre Community Benefit Fund. Potential contributions could be structured through an upfront payment, annual operating contribution, electricity-use-based contribution, negotiated infrastructure investment, sponsorship program or a combination of methods. Funds generated by a facility should primarily return to its host municipality, with provision for neighbouring or regional benefits where impacts cross municipal boundaries and the affected municipalities agree. 

Community benefits must not be treated as optional donations or short-term promotional initiatives. They should constitute a durable public value proposition that is proportionate to the scale, intensity, and longevity of the development. 

Where a community is being asked to host infrastructure that occupies valuable employment land, places substantial demands on electricity and other municipal systems, and may generate limited growth in the municipal tax base due to relatively low employment levels, that community should receive a visible, measurable, and lasting return. 

The right framework will allow Ontario to say yes to projects that protect Canadian data; use modern, water-efficient technology; pay their complete infrastructure and electricity costs; strengthen rather than compromise the electrical grid; create credible permanent quality employment and economic benefits; locate in appropriate, well-planned areas; minimize impacts on residents and the environment; and provide meaningful and lasting benefits determined by the host municipality. 

Thank you again for the opportunity to provide input. The City of Cambridge welcomes continued dialogue with the Province, municipal associations, local distribution companies, Indigenous communities, industry representatives and Ontario municipalities as the final Data Centre Playbook is developed. 

Ontario has an opportunity to create a national standard for responsible data centre development. With clear rules, strong municipal participation and a mandatory but locally determined Community Benefit Framework, the Province can attract critical digital infrastructure while protecting the interests of the people and communities that make this investment possible. 

Sincerely, 

Jan Liggett