Re: ERO #025-1077 – Consultation on Proposed Special Economic Zones Criteria

November 6, 2025

Ministry of Economic Development, Job Creation and Trade

18th Floor, 777 Bay Street

Toronto, ON

M5G 2N4

 

Re: ERO #025-1077 – Consultation on Proposed Special Economic Zones Criteria

 

We, the 87 undersigned organizations, continue to have significant concerns with the Special Economic Zones Act, 2025. These concerns are not addressed by the proposed criteria for the creation of Special Economic Zones (SEZs) under the Act, as proposed in ERO #025-1077.

Regarding the Draft Policy Intent for SEZ criteria, we note that the criteria for projects focuses on economic benefits, to the detriment of equally important outcomes such as environmental protections, Indigenous rights and labour standards. Ontario’s economic competitive advantage rests on the maintenance of strong environmental and social regulatory standards, not reducing standards under opaque processes.

Regarding Indigenous Communities consultation feedback, we are deeply alarmed by the explicit exclusion of free, prior and informed consent (FPIC) in the section titled “Feedback Not Reflected in the Current Draft Proposed Regulations”:

“feedback from Indigenous communities emphasized the importance of explicitly including references to Indigenous Peoples’ rights, including Aboriginal and Treaty rights, as well as references to the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) and Free, Prior, and Informed Consent (FPIC) in the Regulations… these references have not been included” [emphasis added].

FPIC is recognized as a foundational principle in the United Nations Declaration on the Rights of Indigenous Peoples, which was ratified by the Government of Canada in 2021.

Regarding the draft SEZ Regulation, the disproportionate reliance on the “opinion of the Minister” to make key determinations fundamentally undermines the purpose of developing criteria in the first instance. It is imperative that criteria for designating SEZs is clear, transparent and evidence-based, not the subjectivity of the Minister. The draft SEZ Regulation should be revised to clearly identify:

• how trusted proponents will be evaluated, including metrics for assessing compliance records, and criteria to avoid conflict of interest;
• how the designated project will not significantly impact ecosystem health, water quality, or undermine Ontario’s climate objectives; and,
• a more transparent decision-making process that is not solely subject to the “opinion of the Minister.”

Beyond these specific concerns, we would like to reiterate our opposition to exempting any entities from environmental, labour and other provincial standards, whether via SEZs or any other mechanism. These standards are decades in the making and reflect the values of Ontarians. Specifically, at a minimum, the zone criteria should be updated to specifically state that no SEZ shall impact lands regulated under the Provincial Parks and Conservation Reserves Act, provincial plans such as the Greenbelt, Niagara Escarpment, Oak Ridges Moraine, or other provincially significant designations such as provincially significant wetlands.

Based on global experiences with SEZs, the many instances of short term gains for companies or developers came at the expense of long term public well-being, often resulting in polluted waters, land dispossession and poor working conditions. Responsible development requires clear standards, meaningful community input, and public trust. For these reasons, we urge the Government of Ontario to repeal the Special Economic Zones Act or significantly amend the Act and the proposed regulations to ensure Indigenous rights are respected, social and environmental standards are upheld, and evidence-based transparent decision-making is followed.

Sincerely,

 

Tony Morris

Conservation Policy and Campaigns Director

Ontario Nature

 

Mary Lou Gerow

Secretary

Bancroft Field Naturalists’

 

Bruce R. Allen

Sole Proprietor

Bruce R. Allen Paralegal

 

Robert Roszell

Chair

10,000 Trees for the Rouge

 

Anne Mills

Director

Bert Miller Nature Club

 

Amy Schnurr

Executive Director

BurlingtonGreen Environmental Association

 

Jessica Lax

Executive Director

Algonquin to Adirondacks Collaborative

 

Tom Sitak

President

Brant For Nature

 

Sean Southey

Chief Executive Officer

Canadian Wildlife Federation

 

Yvon Duchesne

Board Chairperson

Citizens for Marshland Conservation

 

Dr. Paul Berger

Lead Organizer

CUSP – Citizens United for a Sustainable Planet

 

Alyssa Wright

Interim Chair

Engage Barrie Organization

 

Lesley Lavender

CEO

Federation of Ontario Cottagers’ Associations

 

Susan Moore

President

Friends of Salmon River

 

Lorraine Green

Co-chair

Grandmothers Act to Save the Planet (GASP)

 

Hart Jansson

Co-Founder and Chair

Halton Action for Climate Emergency Now

 

Sharon Lovett

Co-Chair

High Park Nature

 

Sheila Fleming

Co-President

Ingersoll District Nature Club

 

Janis Grant

President

Kingston Field Naturalists

 

James Bruce Craig

Chair

Concerned Citizens of King Township

 

Darlene Salter

Co-chair

Eagle Lake Farabout Peninsula Coalition

 

Jarvis Strong

Executive Director

Escarpment Corridor Alliance

 

Sharon Boddy

Director

Friends of Carlington Woods/Hampton Park

 

Wioletta Walancik

Administrative & Programs Director

Friends of Second Marsh

 

Richard Witham

Chair

Greater Sudbury Watershed Alliance

 

Margaret Beaudette

President

Halton North Peel Naturalist Club

 

Richard Heron

President

Huntsville Nature Club

 

Miranda Virtanen

Executive Director

Junction Creek Stewardship Committee

 

Pat Morden

Chair

Lakeshore Eco-Network

 

Michael Douglas

Chair

Concerned Citizens of Ramara

 

Barbara Steinhoff

Executive Director

Earthroots

 

Jennifer Nantais

Chairperson

Essex County Field Naturalists Club

 

Rob Potter

President

Friends of Nancy Island and Wasaga Beach Park

 

Janet Stavinga

President and Co-Founder

Friends of Stittsville Wetlands

 

Susan Rietschin

Chair

Guelph Urban Forest Friends

 

Robin Harmer

Chair

Headwaters Nature

 

Christine Roberts

President

Huron Bruce Nature

 

Eric Davis

President

Kawartha Field Naturalists

 

Alexis Whalen

Chair

Land Over Landings

 

Kerrie Blaise

Founder & Legal Counsel

Legal Advocates for Nature’s Defence (LAND)

 

Robert Codd

President

Midland-Penetanguishene Field Naturalists

 

Max Hansgen

President

National Farmers Union – Ontario

 

Jennifer Evans

President

Nature London

 

James Kamstra

President

North Durham Nature

 

Linda Heron

Chair

Ontario Rivers Alliance

 

Laura Reinsborough

Riverkeeper and CEO

Ottawa Riverkeeper

 

Susan Paradisis

President

Peterborough Field Naturalists

 

Dr. Elizabeth Churcher

Corresponding Secretary

Quinte Field Naturalists

 

Tylene Appel

Co-Chair

Seniors for Climate Action Now!

 

Marilyn Murray

Chair

Lennox and Addington Stewardship Council

 

Jamie Kneen

National Program Co-Lead

MiningWatch Canada

 

Darren MacTavish

President

Nature Barrie

 

Joyce Sankey

Conservation Director

Niagara Falls Nature Club

 

Rhonda Kirby

President

North Shore Environmental Resource Advocates

 

Dr. Erica Shelley

Executive Director

Organic Council of Ontario

 

Kenneth Westcar

Secretary/Treasurer

Oxford County Trails Council

 

Gerry Jenkison

President

Prince Edward County Field Naturalists (PECFN)

 

James Smith

Chair – Stewardship Committee

Ruthven Park National Historic Site Inc.

 

Lidija Biro

Founding member

Seniors for Climate in Niagara

 

Phyllis Cacciotti

President

Manitoulin Nature Club

 

Paul Frigon

First Vice-President

Mississippi Valley Field Naturalists

 

Judy Brisson

President

Nature Guelph

 

Dorothy Wilson

Communications Working Group

Nith Valley EcoBoosters

 

Ron McKee

Captain

Oakville Climate Hub, Climate Reality Canada

 

Denis Paccagnella

President

Orillia Naturalists’ Club

 

Glenda Clayton

President

Parry Sound Nature

 

Lenka Holubec

member

ProtectNatureTO

 

Ron Prickett

President

Sault Ste. Marie Naturalists of Ontario and Michigan

 

Terry Coffin

President

Seniors for Nature Outdoor Club

 

Wendy Nicholson

President

South Bracebridge Environmental Protection Group Inc.

 

Michael Appleby

President

Stephens Bay Association

 

Barbara Yurkoski

Advocacy Committee Lead

Thunder Bay Field Naturalists

 

Paul Harpley

President

South Lake Simcoe Naturalists

 

Ron Corkum

President

South Peel Naturalists’ Club

 

Amelia Rose Khan

Volunteer

Toronto350

 

Helen Brenner

Co-Lead

Stop Sprawl Durham

 

Hilda Postenka

Vice President

Thunder Bay Hiking Association

 

Susan Best

President

Trumpeter Swan Conservation Ontario

 

Rebecca Koroll

President

Waterloo Region Nature

 

Peter Beckett

President

Sudbury Naturalists Club

 

Lynn Miller

President

Toronto Field Naturalists

 

Tara Bauer

Director

Turtles Kingston

 

Dani Lindamood

Campaigns & Communications Director

Water Watchers

 

Karen Saunders

Vice President, Wildlife & Industry

WWF – Canada

 

Richard Skevington

Rambles Director

Woodstock Field Naturalists

 

Gloria Marsh

Executive Director

York Region Environmental Alliance

 

Sylvia Bowman

Conservation Director

York Simcoe Nature Club

 

Re: ERO #025-1077 – Consultation on Proposed Special Economic Zones Criteria