Hon. Victor Fedeli,
Minister of Economic Development, Job Creation and Trade
Re: Consultation on Proposed Special Economic Zones Criteria – ERO #025-1077
Dear Minister Fedeli,
This is to express our comments and concerns on the above noted proposal to implement the part of Bill 5 focusing on Special Economic Zones Criteria. We continue to support respect for the rule of law, particularly with respect to Indigenous sovereignty which requires free, prior, and informed consent, and the critical importance of protecting biodiversity and environmental rights.
Safeguards needed for public health and the environment
The proposed regulatory criteria for Special Economic Zones (SEZ) rely on “Minister’s opinion”, substituting subjectivity for objective evidence, and lacking a transparent process for assessing health, environmental, social, and economic consequences of implementing a project proposal.
Specifically, in Section 4, the identification and assessment of potential impacts and mitigation strategies is lacking. It is essential to employ experts to identify direct and indirect effects that proposed SEZ projects may cause. Further, mitigation strategies that avoid or reduce adverse risks to health, nature, land, water, and air quality need to be employed. Due diligence, an independent assessment of risks, is an essential step in effective decision making for any business or government. Without this critical step, the Ontario Government may face unintended consequences which irreparably harm people and biodiversity, and incur legal and financial consequences.
Transparency in decision-making
The ERO notice highlights that numerous submissions regarding Bill 5 point out the government’s history of making decisions favouring associates of the Premier and
Ministers. A lack of transparency and accountability in deciding upon projects and ‘trusted proponents’ risks corrupting the political decision-making process. An independent third-party vetting and science-based assessment process is essential. Without a thorough, independent, transparent process, the Minister leaves him/herself open for accusations about corruption, and the Province vulnerable to unscrupulous actors.
Public Participation
It is vital for affected communities to have an opportunity to raise concerns about a project’s impact. If the Province moves forward with the SEZ regulation, we call on the Ontario 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. The current approach to closed door decision-making put forward in the proposed regulation will only serve to add to the frustration and lack of trust in your government.
In closing, we are concerned about the lack of safeguards and exemptions from laws meant to protect health, nature, and communities. The proposed regulation as it stands places the burden of health and environmental costs on Ontarians. Economic growth and environmental protection should be balanced, if not mutually beneficial.
We urge the government to repeal the Special Economic Zones Act and not pass the proposed regulation.
Sincerely,
Geoff Kettel
President, Federation of Urban Neighbourhoods
c.c.: Premier, Ministers, MPPs