Please stop including self…

Please stop including self-congratulatory messaging on the Environment Registry. There is no evidence that the act will support economic growth and development, unlock new opportunities for long term investment, diversify trade, or strengthen supply chains.

Also please proof read your proposals. The amount of typographical errors is unacceptable.

I do not believe you should move forward with implementing the Act. This Act is fundamentally undemocratic, as it undermines our elected legislators, and transfers legislative power to the unelected Lieutenant Governor in Council and Minister of Economic Development, Job Creation and Trade. I'm asking you to repeal the Special Economic Zones Act, 2025. I have a feeling you're not going to do that, so I will add feedback, that will minimize the damage done by this proposal. Hopefully, it will be moot, because hopefully you will decide to move forward with repealing the act.

First, this proposal does not seem to align with the Ministry's Statement of Environmental Values. This proposal, especially the draft regulation shows no regard for the inherent value of the natural environment. That value will play no role in the creation of any zone or designation of any so-called trusted proponent or the designation of any projects. Neither is the right of the people of Ontario to a healthful environment. Also nothing in this proposal will ensure that this act is used to further, "common goal the protection, conservation and restoration of the natural environment for the benefit of present and future generations." The proposal also does not include "The prevention, reduction and elimination of the use, generation and release of pollutants that are an unreasonable threat to the integrity of the environment." Nor does it include, "The protection and conservation of biological, ecological and genetic diversity." Also omitted is clear consideration for, "The protection and conservation of natural resources, including plant life, animal life and ecological systems." Nor will it promote the "The identification, protection and conservation of ecologically sensitive areas or processes." This also does not support the Climate Change Action Plan. This proposal also does not explain how the Ministry considered it Statement of Environmental Values. All of this, is contrary to the Ministry's Statement of Environmental Values. What you should do to remedy this is not move forward with the proposal. I do not think you will do that. If you will push through this here's how you can fix it to align with you Statement of Environmental Values:
Require all designated projects and trusted proponents to recognize the inherent value of the environment.
Require all designated projects to be consistent with or promote a healthful environment. Set the goal of Special Economic Zones, designated projects, and so-called trusted proponents, to be, "the protection, conservation and restoration of the natural environment for the benefit of present and future generations."
Require designated projects and so-called trusted proponents to prevent, reduce and eliminate of the use, generation and release of pollutants that are an unreasonable threat to the integrity of the environment in Special Economic Zones and outside of them.
Require designated projects and so-called trusted proponents to protect and conserve the biological, ecological and genetic diversity of Special Economic Zones and outside of them.
Require designated projects and so-called trusted proponents to protect and conserve natural resources, including plant life, animal life and ecological systems in Special Economic Zones and outside of them.
Require designated projects and so-called trusted proponents to encourage of the wise management of our natural resources, including plant life, animal life and ecological systems in Special Economic Zones and outside of them.
Identify ecologically sensitive areas or processes and protect them by excluding them from any Special Economic Zone.
Update this proposal to explain how your Statement of Environmental Values was considered in the development of this proposal, and when you publish a decision for this proposal, explain how your Statement of Environmental Values was considered in that decision.
Designate the Special Economic Zones Act, 2025 under Part II of the Environmental Bill of Rights to fulfill the duty to consult the public under your Statement of Environmental Values.
Prohibit designated projects and so-called trusted proponents from using the designation to increase greenhouse gas emissions. Designations of designated projects, so-called trusted proponents, and Special Economic Zones should promote the goal of a resilient and low greenhouse gas economy and society.

I will address concerns with indigenous consultation later on.

Now I want to specifically focus on how this proposal fails to advance the Climate Change Action Plan, which the Ministry is responsible for supporting. Even though it has been more than 5 years since the plan is issued, the Ministry is still required to support the Plan based on its Statement of Environmental Values. This proposal does not outline a clear process for identifying climate actions that are appropriate to each community that will be affected by a Special Economic Zone, designated project, or so-called trusted proponent. The proposal also fails to explain and take full advantage of the potential for the Special Economic Zones Act, 2025 to be utilized:
To create a transportation system with fewer greenhouse gas emissions;
To make "Ontario one of the easiest and most affordable jurisdictions in North America for homeowners and businesses to install or retrofit clean-energy systems like solar, battery storage, advanced insulation and heat pumps;"
To work "in partnership with First Nations and Métis communities to address climate change, with actions guided by Traditional Ecological Knowledge, and helping to build capacity in these communities to participate in the economic opportunities that may arise from the actions;"
To lead by example and act on opportunities to make government operations carbon neutral;
To ensure natural, agricultural, and forested lands are used in ways that are efficient and sustainable;
To transition to low carbon economy and build the clean-tech sector;
To support walking and cycling, including a better safer cycling network;
To improve the competitiveness of short-line railways;
To "Support the Accelerated Construction of GO Regional Express Rail;"
To support low carbon communities, including through support for mixed-use and pedestrian-focused urban design;
To support climate action by municipalities and other stakeholders; and
To help industries transition to a low-carbon approach.

The government could support the Climate Change Action Plan by not moving forward with this proposal and repealing the Special Economic Zones Act, 2025. If you choose not do that, here's how the proposal could be amended to better support the plan:
Establish classes for designate projects of the following: green transit (transportation projects predicted to reduce greenhouse gas emissions), clean energy (projects which increase the energy efficiency of existing buildings and structures), First Nations and Métis lead climate projects, government-lead carbon reduction projects, walking and cycling projects, short-line railway projects, GO transit expansions, low carbon community, and municipal climate action.
Prohibit designating projects that are expected to increase transportation emissions.
Exclude carbon storing ecosystems from being included in Special Economic Zones.
To consider if proposed designated projects would support a low-carbon economy and society.
Require designated projects to be consistent with green agriculture practices.
To consider how designated projects would support Ontarians ability to walk and bike. Prohibit projects from restricting Ontarians ability to walk and bike.
To consider if the proposed designated project and applying proponent support clean tech.

I will now address some concerns I have about Indigenous Communities Consultation. I worry that the government's response to Indigenous Communities Consultation is not entirely fair and accurate. The paper states, "Inclusion of analysis of potential environmental and health impacts and risk mitigation under project criteria." However, the regulation under project criteria only requires that the Minister consider if, "work has been done to identify potential impacts on health and the environment," and only how this impacts the project's chance of success. This means that if work has been done, but is inconclusive, or risks have been identified, but they won't impact the projects chance of success then the project can still proceed despite these impacts. I suggest the regulation be amended to include consideration for environmental and health impacts, on their own, and to prohibit the Minister from designating projects that will have a probable negative effect on health or the environment.

I also want to discuss how this proposal relates or could related to "A Made-in-Ontario Environment Plan" by the Ministry of Environment, Conservation and Parks. I do want to note that this plan could be subject to change if Bill 68, Plan to Protect Ontario Act (Budget Measures, 2025 (No. 2) passes; I cannot predict how this could change, so these comments are about how the Plan as exists at the time of me submitting this comment. The first change I suggest related to A Made-in-Ontario Environment Plan is to require designated projects to be consistent with and not interfere with A Made-in-Ontario Environment Plan and related plans like the Strategy for a Waste-Free Ontario. Also, ensure that designated projects will not add more organic waste to landfills. I also suggest ensuring that these designations are not used to circumvent Environmental Assessment Requires, as they are an important part of the Plan. The plan is also clear that the Clean Water Act plays an important role in protecting our waters, so I think the proposal should rule out using designations to exempt from the requirements of that Act and its regulations. Another key suggestion I have is to ensure that designated projects do not increase the levels of lead in any water source. Also to assist in the plan, the Minister should be required to consider the role anyone seeking to be a so-called trusted proponent in creating or advancing the circular economy, how a proposed designated project will affect the creation of a circular economy, and reject any applications that the Minister believes will be counter to creation of a circular economy.

I also want to clear statement my concerns about what I perceive to be an integrity problem with the government. This government has a history of preferential treatment and improperly advancing certain people's private interests, and the Special Economic Zones Act, 2025, requires a high level of integrity to prevent catastrophic damage to Ontario. The slow response to concerns that we saw with the Greenbelt Scandal, Official Plan Amendments, Minister's Zoning Orders Controversy and right now, the Skills Development Fund, cannot happen with designations and regulations under the Special Economic Zones Act, 2025. We also cannot afford the secrecy, and sloppy work that the government has handled Ontario Place and Ontario Science Centre with. We could potentially be dealing with people's drinking water, people's air and people's health. The results of subpar work in the process of designating Special Economic Zones, so-called Trusted Proponents, and designated projects could be people's lives and other irreparable damage to the Province. So, I am proposing that you mandate the Ministry establish a program that allows people easily report so-called trusted proponents and designated projects for misconduct or harmful behaviour and mandate the Minister quickly respond to all concerns raised. The Minister should be required to consult the public both here in Ontario and internationally before any designations, so any concerns can be caught before damage is done. The government should also amend the regulation to fully live up to its promises in the after math of the Greenbelt scandal. This means no Special Economic zones in or that effect the Greenbelt Area.

I also suggest that based on the above and the attached list of municipal incidents, that public sector organizations should have to prove they're trustworthy and meet the same requirements as other proponents.

Finally, I think key legislation need to be protected from being minimized by the Act. I think the Ministry should exempt the following Key Environmental legislation from being effected in any Special Economic Zone:
Environmental Bill of Rights, 1993
Aggregate Resources Act
Clean Water Act, 2006
Conservation Authorities Act
Crown Forest Sustainability Act, 1994
Environmental Assessment Act
Environmental Protection Act
Far North Act, 2010
Fish and Wildlife Conservation Act, 1997
Great Lakes Protection Act, 2015
Invasive Species Act, 2015
Lakes and Rivers Improvement Act
Lake Simcoe Protection Act, 2008
Greenbelt Act, 2005
Mining Act
Niagara Escarpment Planning and Development Act
Nutrient Management Act, 2002
Oil, Gas and Salt Resources Act
Ontario Heritage Act
Ontario Water Resources Act
Pesticides Act
Places to Grow Act, 2005
Planning Act
Provincial Parks and Conservation Reserves Act, 2006
Public Lands Act
Resource Recovery and Circular Economy Act, 2016
Safe Drinking Water Act, 2002
Waste Diversion Transition Act, 2016
Cap and Trade Cancellation Act, 2018
Building Code Act, 1992
Endangered Species Act, 2007
Food Safety and Quality Act, 2001
Highway Traffic Act
Oak Ridges Moraine Conservation Act, 2001
Ontario Energy Board Act, 1998
Water Opportunities Act, 2010
Species Conservation Act, 2025
There are also some important non-environmental legislation that I believe should be protected from designations. I believe that the designations should not be used to allow government and other public bodies to evade governance and accountability requirements. I believe that designations should not be used to impede upon the authority of officers of the assembly. Here's a non exhaustive list:
Health Insurance Act
Drug Benefit Act
Freedom of Information and Protection of Privacy Act
Municipal Freedom of Information and Protection of Privacy Act
Public Service of Ontario Act, 2006
Legislative Assembly Act
Members’ Integrity Act, 1994
Adjudicative Tribunals Accountability, Governance and Appointments Act, 2009
Human Rights Code
Archives and Recordkeeping Act, 2006
Regulated Health Professions Act, 1991
Commitment to the Future of Medicare Act, 2004
Excellent Care for All Act, 2010
Courts of Justice Act
Substitute Decisions Act, 1992
Health Care Consent Act, 1996
Personal Health Information Protection Act, 2004
Ontario Works Act, 1997
Ontario Disability Support Program Act, 1997
Anti-Racism Act, 2017
Rights of Labour Act
Labour Relations Act, 1995
Employment Standards Act, 2000
Evidence Act

I hope the above causes your government to not move forward with implementing the Special Economic Zones Act, 2025. If it does not, I hope you will act on the other feedback provided.