ERO 025-1077 – Consultation…

ERO 025-1077 – Consultation on the Proposed Regulation under the Special Economic Zones Act, 2025
Submitted by: Concerned Citizens of Ramara (CCR)
Date: October 27, 2025

Contact: CCORamara@gmail.com

1. Introduction
Concerned Citizens of Ramara (CCR) appreciates the opportunity to comment on the proposed regulation under the Special Economic Zones Act, 2025 (SEZA), posted as ERO 025-1077. CCR supports responsible economic development that benefits Ontario residents while protecting water, the environment, and Indigenous and municipal rights.
Ontario’s current consultation on SEZ criteria coincides with growing federal and provincial investment in critical minerals development—a sector poised to shape Ontario’s industrial, environmental, and social landscape for decades. CCR believes this alignment warrants particular attention to ensure SEZ designations serve the public interest without weakening environmental safeguards or democratic oversight.

2. Context: SEZs and Critical Minerals
Both the Government of Canada and the Province of Ontario have identified nickel, cobalt, lithium, graphite, and rare earth elements as strategic resources essential for clean-energy technologies, electric vehicles, and national supply-chain security.
Ontario’s Critical Minerals Strategy (2022-2027) and the federal Critical Minerals Strategy (2024 update) aim to accelerate exploration, processing, and manufacturing. The proposed SEZ regulation could become a primary instrument for fast-tracking permitting and exemptions in this sector.
While CCR recognizes the value of efficient project delivery, we emphasize that efficiency cannot come at the cost of environmental, social, or Indigenous rights protections.
3. Main Concerns and Potential Impacts
a) Environmental and Health Safeguards
• The SEZA allows for modifications or exemptions to named Acts and municipal by-laws. Without clearly identified non-waivable protections, SEZs could bypass essential safeguards such as those in the Clean Water Act, Environmental Protection Act, and Endangered Species Act.

• Critical-mineral refining and processing involve intensive water, chemical, and waste management. These activities require full environmental oversight and cumulative-effects assessment—not case-by-case exemptions.

b) Indigenous Rights and Participation
• The SEZ criteria require Indigenous engagement plans but do not codify Free, Prior and Informed Consent (FPIC) or create mechanisms for Indigenous-led projects, co-governance, or revenue-sharing agreements.

• Ontario’s duty to consult under Section 35 must be accompanied by clear, funded pathways for early engagement and Indigenous-led monitoring.

c) Municipal and Community Oversight
• SEZ designations may override municipal by-laws and local planning instruments. Municipalities and residents must retain a meaningful role in approving SEZ projects that affect local services, infrastructure, or emergency response.

• Communities located on vulnerable aquifers—such as Ramara Township—require assurance that water resources, well systems, and local infrastructure will be protected.

d) Transparency and Accountability
• The Ministry notes that SEZ regulations are not required to be posted to the Environmental Registry. This undermines transparency.

• Every SEZ designation or exemption should be publicly posted with full rationale, impact analysis, mitigation commitments, and expiry or renewal provisions.

4. Recommendations
CCR respectfully recommends that the Ministry of Economic Development, Job Creation and Trade amend the draft SEZ regulation to include the following:
1. Non-waivable protections: Explicitly list the Clean Water Act, Environmental Protection Act, Ontario Water Resources Act, and Endangered Species Act as statutes that cannot be modified or exempted within SEZs.

2. Cumulative-effects assessment: Require cumulative environmental and health impact analysis for SEZs involving multiple mineral-processing or refining projects.

3. Indigenous-led participation: Define “Indigenous-led projects” and create clear avenues for Indigenous co-governance, benefit-sharing, and oversight.

4. Municipal concurrence: Require municipal consent before any SEZ designation alters local by-laws or servicing responsibilities.

5. Public registry and monitoring: Mandate publication of all SEZ designations, exemptions, and related performance data on the Environmental Registry.

6. Closure and assurance: Require fully funded closure bonds and post-closure monitoring for all SEZ projects that handle hazardous materials.

7. Net-zero and climate alignment: Ensure SEZ-approved projects demonstrate credible plans for emission reduction and energy efficiency consistent with Ontario’s and Canada’s climate goals.

5. Conclusion
The Special Economic Zones framework could help Ontario attract high-value investment and strengthen its critical-minerals value chain. However, without transparent guardrails, cumulative-effects oversight, and genuine Indigenous and municipal participation, SEZs risk eroding public trust and environmental security.
CCR urges the Ministry to embed non-waivable protections, cumulative-effects requirements, Indigenous partnership provisions, and transparent reporting into the final SEZ regulation to ensure that Ontario’s economic future is both prosperous and sustainable.
Respectfully submitted,
Concerned Citizens of Ramara (CCR)
Ramara, Ontario