ERO: 025-1077 Consultation…

ERO: 025-1077
Consultation on Proposed Special Economic Zones Criteria: Comments submitted by the Prince Edward County Field Naturalists (PECFN)
The Prince Edward County Field Naturalists (PECFN) do not support the proposed framework for Special Economic Zones (SEZs). Based on our review of the proposal and global precedents, we believe this initiative represents a bridge too far — one that sacrifices environmental protection, democratic accountability, and Indigenous rights in Ontario.
Key Reasons for Opposition:
1. Unprecedented Deregulation and Loss of Environmental Safeguards
SEZs would allow the provincial cabinet to exempt designated projects and proponents from environmental laws, including those protecting species at risk, wetlands and woodlands. This has the potential to undermine decades of progress in environmental stewardship and opens the door to irreversible ecological harm — particularly in sensitive areas like Prince Edward County’s rare alvar ecosystems, migratory bird habitats, coastal wetlands and Natural Core Areas.
2. Threat to Climate Resilience and Landscape Connectivity
Ontario’s natural heritage — including woodlands, wetlands, grasslands, and the ecological linkages between them — is a foundation for climate resilience. These ecosystems regulate water, store carbon, buffer extreme weather, and support biodiversity. Fast-tracking development in SEZs without proper environmental assessment or public oversight threatens to weaken Ontario’s ability to adapt to climate change. There are no apparent limitations on where SEZs could be located, which suggests that Provincially Significant Woodlands and Provincially Significant Woodlands could be located within SEVs.
3. Lack of Transparency and Public Accountability
The SEZ framework concentrates power in the hands of the Minister and Cabinet, with no requirement for public consultation or independent review of exemptions granted. This removes critical checks and balances and reduces communities, municipalities, and conservation organizations to passive observers of decisions that could dramatically alter their local environments.
4. Disregard for Indigenous Rights and Treaty Obligations
SEZs can be imposed on lands without free, prior, and informed consent of Indigenous Nations, violating constitutional and international obligations. In regions like the Ring of Fire, this could lead to large-scale industrial development without meaningful engagement or protection of Indigenous stewardship and cultural practices.
5. Global Evidence of Harm
International experience with SEZs — from Mexico to China to India — shows that these zones often result in pollution, habitat destruction, labour exploitation, and weakened governance. Ontario should not repeat these mistakes under the guise of economic growth.
Conclusion
Ontario’s biodiversity is not an obstacle to development — it’s an asset that supports long-term prosperity, public health, and climate resilience. The proposed SEZ framework is a dangerous overreach that prioritizes short-term economic interests over environmental responsibility and democratic process.
We urge the Province to:
Withdraw the SEZ proposal in its current form.
Reinstate strong environmental protections and public oversight.
Respect Indigenous rights and uphold the duty to consult.
Invest in sustainable development models that work with, not against, nature.