February 17, 2021

February 13, 2021 letter from Toronto’s Medical Officer of Health Dr. Eileen de Villa and Peel’s Medical Officer of Health Dr. Lawrence C. Loh to Dr. David Willams, Ontario’s Chief Medical Officer of Health. 


February 13, 2021

Dr. David Williams
Chief Medical Officer of Health, Public Health
Ministry of Health
393 University Avenue, 21st Floor
Toronto, ON M5G 2M2

Re: Return to the Provincial Framework for Peel and Toronto on February 22, 2021

Dear Dr. Williams:

We are writing to request that the Province delay assessing our regions’ readiness to move into the COVID-19 Response Framework until March 9th, 2021 at the earliest, based on regional indicators.

In our judgement, the decision for Toronto and Peel to re-enter the COVID-19 Response Framework on February 22nd constitutes a serious risk for the residents of Peel and Toronto. While we are encouraged by the downward trend of many key indicators, we believe there are many reasons to proceed with caution as we look to re-open:

  • Weekly incidence rates are declining but hover at approximately 100 per 100,000 population in both Peel and Toronto.
  • Both Peel and Toronto have not seen a consistent downward trend in hospitalizations.
  • Both regions continue to see pressures on acute care bed capacity and staffing.
  • VOC incidence is continuing to increase and are now present in most congregate settings in Toronto. Peel has also had variant strains in congregate settings and workplaces, and is currently investigating transmission of the B.1.351 strain in a multi-unit dwelling.

The recent decline in cases can be attributed to the success of public health measures imposed after the holidays. The restrictions put in place December 26th are clearly working and they need to continue. Any relaxation of measures, like that proposed for February 22nd, is expected to give rise to increased COVID-19 and VOC transmission over and above what is already occurring. This, in turn, can be expected to result in increased COVID-19 related illnesses, outbreaks, hospitalizations and deaths.

Percentage of Population Vaccinated:

While we have been able to vaccinate many long-term care and high risk retirement home residents, staff and essential caregivers, we currently have a largely unvaccinated population. With uncertainty related to supply, it is unclear when we will be able to continue to vaccinate large portions of the population.

Experiences of Other Jurisdictions with VOCs:

Learning from other jurisdictions shows VOC growth can be exponential without significant public health measures in place. A loosening of public health measures runs the significant risk of leading to another potential lockdown. As we have seen in other jurisdictions, additional measures and strong lockdowns have been required to curb the increase of VOC transmission (e.g., United Kingdom, Ireland).

Reopening Schools Safely:

Keeping the current measures in place for a sufficient period after the reopening of schools allows local public health to mitigate the risk to students and staff as they return to in-person learning.

Public Perception:

In reviewing recent mobility data, it is clear that only when the Province-wide Shutdown began on December 26th, followed by the Provincial Stay-at-Home Order and Emergency Declaration on January 14th did we see a significant decline in mobility. Even in the absence of changes to public health measures, data has recently started to show an increase in mobility that could result in more contacts which, in turn, increases risk of transmission. Reopening in any degree influences public perception of risk and may give a false sense of security that the risk is no longer present.

With this as background, we are requesting that the Province delay assessing our regions’ readiness to move into the Framework until March 9th at the earliest. Until that time, we recommend both Peel and Toronto remain in the ‘Shutdown Zone’ under O. Reg. 363/20 and that the region-specific Stay-at-Home Orders (O. Reg. 73/21 and O. Reg. 89/21) remain in place. This delay will allow Peel and Toronto to monitor VOC growth and support the safe re-opening of schools.

We recognize the importance of balancing economic recovery with protecting the health of the population. We also acknowledge that the Province has instituted an “emergency brake” provision that allows the local Medical Officer of Health to reinstate maximum restrictions if their jurisdiction experiences rapid acceleration in COVID-19 transmission or if its health care system risks becoming overwhelmed. However, it is important to recognize the weariness the public is experiencing, particularly those who have been most impacted by COVID-19. We believe that the public will be far less accepting of a return to a third lockdown than the gradual and progressive lifting of the existing one.

We request the Province alter its current course, towards a more gradual and progressive approach that would ease restrictions more slowly, allowing time to monitor the trends, respond and adjust accordingly to keep transmission rates low. This cautious approach would also allow for the development of clear public messaging that reinforces the continuing risk of the pandemic while also instilling optimism as vaccines are on the horizon. We believe this prudent approach also recognizes the importance of economic recovery and creates momentum towards it while also balancing the importance of protecting the health of the population.

To that end, given the urgency of the situation, we are requesting to meet with you within the next day on Sunday, February 14th, 2021 to discuss this matter. We will make ourselves available for a time at your convenience.


Dr. Eileen de Villa, MD, MBA, MSc, CCFP, FRCPC
Medical Officer of Health, City of Toronto

Dr. Lawrence C. Loh, MD, MPH, FCFP, FRCPC, FACPM
Medical Officer of Health, Peel Public Health

Cc: Chair of the Ministry of Health Public Health Measures Table, Dr. David McKeown


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