I am writing to comment on…

I am writing to comment on ERO-1077, Consultation on Proposed Special Economic Zones Criteria. To begin, I support responsible supply management and sustainable development of aggregate resources in Ontario, however, many Ontarians are negatively impacted by gravel mining because of a weak regulatory framework and companies failing to follow regulations as noted in the Auditor General’s 2023 report on aggregate mining.

In addition to very poor enforcement of existing aggregate regulations, the proposed regulatory criteria for Special Economic Zones (SEZ) lacks an objective transparent process for assessing health, environmental, social, and economic consequences of implementing a project proposal. Using only the Minister’s opinion and trusted proponents to decide on projects is weak and insufficient governance.

Specifically, in section 4, the identification and assessment of potential impacts and mitigation strategies is lacking. It is essential to employ experts to identify effects that proposed SEZ projects may cause. An independent assessment of risks is an essential step in effective decision making for any business or government. Further, mitigation strategies are needed that avoid or reduce adverse risks to health, nature, land, water, and air quality. Without this critical step, the government may face unintended consequences which irreparably harm people and biodiversity and incur legal and financial consequences.

The ERO notice highlights that numerous submissions regarding Bill 5 point out the government's history of making decisions favouring associates of Ministers and the Premier. A lack of transparency and accountability in deciding upon projects and ‘trusted proponents’ risks corrupting the political decision-making process further. An independent third-party vetting and science-based assessment process is essential. Without a thorough independent, transparent process the Minister leaves himself open for speculation about corruption and the province vulnerable to unscrupulous actors.

In closing, I urge the government to repeal the Special Economic Zones Act and not pass the proposed regulation. If the province moves forward with the SEZ regulation, I call on the government to amend the regulations so that all communities are kept informed and given the opportunity to share their views on matters that impact their health, safety, and wellbeing. Economic development should not “trump” our collective personal and environmental health.

Sincerely,