The Town of Collingwood…

The Town of Collingwood appreciates the opportunity to provide feedback on the proposed regulatory framework for Special Economic Zones (SEZs) under the Special Economic Zones Act, 2025. We recognize the potential of SEZs to accelerate strategic economic development and investment across Ontario. However, we offer the following comments and questions to support clarity, transparency, and responsible implementation.

1. Definition and Scope of SEZs
The Act currently lacks a clear definition of what constitutes a Special Economic Zone. While the draft regulation suggests SEZs will be designated based on their “critical or strategic importance to Ontario’s economy,” this language remains broad and open to interpretation. We recommend:
• Including a formal definition of SEZs within the regulation.
• Clarifying whether “critical” and “strategic” importance are defined elsewhere in provincial policy or legislation.
• Considering the inclusion of historically significant sites or economically important reuse/restoration projects as eligible under SEZ criteria.

2. Criteria for Designated Projects
The first proposed criterion, “Significant and Long-Term Economic Benefit to Ontario”, appears to expand the scope of the Act. This shift from “significant” to “significant and long-term” economic impact should be explicitly defined to guide applicants and ensure consistent interpretation. We suggest:
• Providing examples or thresholds for what constitutes “long-term economic benefit.”
• Including community-level economic benefits, not just provincial-scale impacts.

3. Purpose and Use of SEZs
The establishment of SEZs is a powerful tool intended to support economic growth and development by building faster and more strategically to protect Ontario industries, unlocking new opportunities for long-term investment, driving economic growth, diversifying trade, and strengthening supply chains in the short and long term.

In providing modifications or exemptions to important provincial laws, regulations, permits or approvals, the tool should be used judiciously and only in meritorious circumstances with clear economic benefits that cannot be achieved under the typical systems, with the appropriate risk mitigation methods in place.

The proposed regulatory criteria are broad in nature and may cause concern in the lack of specificity such that the tool may be used more routinely than intended or that significant negative consequences may result (i.e. social or environmental).

Under the Planning Act, a similar tool exists and is intended for extenuating cases to expedite land use planning approvals to deliver on provincial priorities – the Minister’s Zoning Order (MZO). While the Planning Act provisions governing MZOs are general in nature, the Province published a complementary framework, providing additional guidance on:
• Intake thresholds
• Downstream approvals
• Submission expectations
• Ministry assessment
• Consultation and communication
• Grounds for refusals

It is recommended that either the proposed SEZ regulations be enhanced to address these matters or a companion framework be developed to provide similar clarity and structure, including municipal consent as articulated further below.

4. Municipal Consent and Indigenous Consultation
Given the potential local community benefits and possible disruption that an SEZ could cause, municipal consent through a council resolution should be sought in any jurisdiction where an SEZ is proposed prior to enactment.

Additionally, we request clarification on:
• What level of consultation and accommodation with Indigenous communities is required prior to SEZ designation?
• What specific permits, approvals, or exemptions may be granted within an SEZ?
• Will provincial funding be available to support SEZ development or implementation?

The Town of Collingwood is committed to sustainable economic growth, innovation, and resilience. Special Economic Zones, if implemented, should be done with transparency and with clear parameters. To that end, we respectfully urge the Province to incorporate additional clarity and safeguards within the regulatory framework to ensure balanced development that respects local communities, upholds environmental and social responsibilities, and includes meaningful municipal and Indigenous engagement. We thank you for the opportunity to provide input and look forward to ongoing dialogue and collaboration as the SEZ initiative progresses.