I am pleased to see, in the…

I am pleased to see, in the draft regulations on criteria for designating Special Economic Zones, requirements that the Minister consider the extent to which designated projects will benefit communities within and outside the Special Economic Zone, particularly Indigenous communities. Similarly, I am pleased to see that items to be considered when assessing the potential economic benefits of a project go beyond merely the size of the Ontario economy (which can appear artificially inflated by profit growth of specific large companies) to also include diversification of the economy, job creation, development of a skilled workforce, tax revenue, security and supply chains, and adoption of innovation.

Nevertheless, there are some amendments that I would like to propose to how 'economic benefits' are considered and characterized. Notably, I would like to propose that, for an area to be designated as a Special Economic Zone, more stringent and specific considerations be required than whether activities will be "economically significant or strategically important to the Ontario economy". I believe that this existing language is too vague to ensure that economic benefits actually transfer down to Ontario communities; therefore, I would propose to instead use language to the effect that activities must be considered "significant AND strategic to the economic RESILIENCE, SUSTAINABILITY, and wellbeing of the Ontario COMMUNITY". In the same vein, I would like to propose that language be nuanced to ensure that the Minister considers 'net benefits' rather than simple benefits to the community, thereby adding a requirement that costs, in addition to benefits, must be evaluated. As well, while I recognize and appreciate the inclusion of a requirement to consider the extent to which Ontario-based goods and services will be used by a designated project, I would like to also see a similar requirement to consider the extent to which more broadly Canadian-based goods and services will be used (e.g. in a model where Ontario-based goods and services would be a first rank priority but Canadian-based goods and services from elsewhere in Canada would still be prioritized over foreign entities).

Less specific to the consideration of economic factors, I would also like to recommend amendments to the proposed regulations that enable Indigenous governments to be designated as trusted proponents (similarly to municipalities and profit or not-for-profit entities). I would also like to see criteria added outlining that no designation as a Special Economic Zone may be granted where there are ongoing land claims. Additionally, I would recommend to add time limits on the duration of time that designation as a Special Economic Zone lasts before it has to be reviewed for continued appropriateness and the designation renewed.

Finally, it is recognized that some elements of the overall policy to implement Special Economic Zones will be outside the scope of the regulations on criteria for their designation specifically. Nevertheless, I would like to endorse calls that have already been communicated to the Government to ensure that a public registry be developed for Special Economic Zones and designated projects, as well as that an appeal process is in place for both types of designation.