The following are proposed…

The following are proposed responses to discussion questions included in the provincial ERO
posting:
1. Should ‘moon shot’ projects with potentially enormous impact but low likelihood of
success be considered?
If considered, criteria on how potential for success is determined should be clear.
Securities/guarantees could be required to address responsibility for mitigating
impacts/risks, especially for local communities. We further request that a Special Economic
Zone / project only be established where there is a confirmed supporting host municipality
(as the Association of Municipalities of Ontario (AMO) has requested).

2. What criteria should be used to assess long-term economic and community benefits?
The following could be considered as criteria:
• Local area and in-province Investment
• Job Creation potential (sustained and construction)
• Development of a community benefit agreement
• Diversification of a community's business and industry mix
• Economic Multiplier Effect – spending and tax revenues
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• Concentration of domestic supply chain
• Alignment with local priorities
The Method for calculating economic benefits could be calculated based on the application
of the SEZ vs standard regulatory requirements/processes – as in, evaluating what is the
specific economic benefit of using the SEZ

3. How should the government ensure transparency and accountability in SEZ
designations?
Transparency and accountability could be addressed through issuing Notification letters to
municipalities, First Nations, and affected agencies when a SEZ is being considered.
A requirement for a municipal support resolution would provide for consideration of such
designations through published local municipal agendas.
Transparency would be further supported by publishing clear and complete records of
information and analysis provided to support designations and providing a clear conflict of
interest declaration and recusal process.

4. What safeguards are needed to protect environmental and cultural heritage within
SEZs?
We would encourage the application of a mitigation hierarchy for natural heritage resources,
with priority given to avoiding natural heritage features.
It is difficult to see where would be appropriate for the province to waive requirements
related to the cultural heritage of indigenous communities.
The province could choose to waive application of provincial standards relative to nonindigenous cultural heritage resources, where these are distinct from indigenous cultural
heritage. We recommend a consistent approach with the proposed Ontario Heritage Act
exemption criteria if implemented and encourage continued engagement with affected
indigenous and non-indigenous communities on the development and application of these
tools.