The inclusion of "Such other…

The inclusion of "Such other factors as the Minister considers appropriate." under the prescribed criteria for designated projects is concerning for at least two reasons:

1. It reduces transparency for trusted proponents and the public by enabling the minister to make decisions based on factors that are unknowable in advance.

2. It potentially allows the minister to override the known factors given that the regulation does not speak to how the minister must weight the factors. Put another way, it potentially allows the minister to rely upon unknown factors when a project is deficient in the known factors.

The minister should be required to publicly state all factors taken into consideration when designating a project.