ERO 025-1077 – Proposed…

ERO 025-1077 – Proposed Regulation under the Special Economic Zones Act, 2025

Date: October 27, 2025

I am writing as a resident of Ramara Township who is deeply concerned about the proposed regulation under the Special Economic Zones Act, 2025 (ERO 025-1077).

This proposal would give Cabinet and the Minister authority to create “Special Economic Zones” where normal environmental and municipal laws could be modified or set aside. While I understand the goal of strengthening Ontario’s economy and supporting critical mineral development, the approach must not undermine Indigenous rights, farmland preservation, wetlands, or water protection — the very resources that sustain our communities.

The government’s proposal does not provide clear details about how Indigenous consultation will be carried out or respected. Consultation cannot be symbolic or limited to information sessions; it must reflect genuine dialogue, collaboration, and consent.

Ontario has a constitutional duty to consult and, where appropriate, accommodate Indigenous communities whenever their rights, lands, or waters may be affected. A transparent and well-documented process must be in place before any zone, project, or proponent is approved.
True partnership means including Indigenous voices at the earliest stages, not after decisions are made.

We farm in Simcoe County, Ontario and we have entered into a Conservation Easement Agreement to protect the farm in perpetuity, as farmland. Food and shelter are the basic foundations of any society. Ontario contains over half of all of Canada’s prime agricultural soils, despite farmland making up less than 5% of the province’s land base. Ontario is losing 319 acres of farmland every day, as per the most recent agricultural census. At this rate, Ontario’s farmland in production today could be lost within 100 years. Each year, Ontario's agriculture sector generates nearly $51 billion in gross domestic product and agri-food exports have increased by 65% since 2018, yet the agricultural sector in Ontario is constantly being undermined every day.

Ontario’s agricultural lands are irreplaceable. Once converted to industrial use, they are lost forever.

Special Economic Zones could make it easier for developers to seek exemptions that pave over even more farmland in the name of “strategic development.” That would run directly counter to Ontario’s own agricultural policy goals and food security needs.

Ontario must ensure that SEZ designations cannot be applied to all agricultural lands and that agri-food operations are protected from underhanded rezoning tactics favouring incompatible development.

Wetlands and groundwater systems are nature’s infrastructure — they store water, absorb floods, and filter contaminants.

Many Ontario communities, including Ramara, depend on shallow and highly vulnerable aquifers. The SEZ framework must not allow exemptions to the Clean Water Act, Environmental Protection Act, or Ontario Water Resources Act.

Any development affecting wetlands, recharge zones, or surface water must include independent environmental assessment and long-term monitoring.

If these protections are weakened, the consequences will be irreversible — for both people and ecosystems.

Recent polling shows that half of Ontario residents are concerned about bypassing environmental safeguards. Ontario residents expect progress to go hand in hand with protecting the nature we all depend on. Nature is not an obstacle to progress. It is a prerequisite for long-term stability, food security, and economic resilience. It cleans our water and air, regulates our climate, provides food, and protects communities from floods and extreme weather. These services reduce economic and financial risks, health risks, and lower future government spending while strengthening our national security.

I respectfully urge the Ministry of Economic Development, Job Creation and Trade to:

1. Guarantee that no SEZ may proceed without formal, documented Indigenous consultation consistent with Section 35 of the Constitution and the principles of Free, Prior and Informed Consent (FPIC).

2. Exclude all agricultural lands and designated wetlands from eligibility for SEZ designation.

3. Identify and enforce non-waivable protections under the Clean Water Act, Environmental Protection Act, and Endangered Species Act.

4. Require public posting and review of all SEZ designations, including environmental and social impact reports.

Economic development must not come at the expense of the natural systems and rights that sustain us. The proposed SEZ regulation risks creating a parallel process where fundamental protections are treated as optional.

Ontario’s prosperity depends not only on investment, but on the health of our land, water, and relationships with Indigenous Nations.

Please ensure this regulation upholds those values in both spirit and law.