Dear Special Economic Zones…

Dear Special Economic Zones Team,

I have read the proposed Special Economic Zones Act several times, and I am very concerned about its potential uses.

The proposed Act does not contain any statutory restrictions on what projects, persons, or areas may be designated. The Act relegates these safeguards to Ontario Regulations instead.

If we have a trustworthy government, perhaps this isn’t an issue. But what happens in the future? What happens if a future, corrupt government uses this Act to benefit their friends, family, or business partners? What about blackmailers? There is no limit to what or who the Act can exempt. There is no area the Act could not apply to. There is no sector which the Act cannot empower. There is no statutory obligation to consult with the public about the Act’s use. So, why not use the Act to benefit the Minister’s friends? What would stop this? Please understand that’s not an attack on the current Minister—it’s a comment on how any number of future Ministers might use this Act.

Maybe the government does need the power to override burdensome regulations for justified critical projects. It’s true that some projects are nearly impossible to approve. This is particularly true of resource and infrastructure projects given our deteriorating relationship with our American allies.

But this proposed Act has no guardrails. I could only consider supporting it if statutory requirements in the Act prevented it from exempting projects, proponents, or areas from the Safe Drinking Water Act, the Building Code Act, the Provincial Parks and Conservation Reserves Act, and the several Acts that protect the Greenbelt System. But it’s just not possible for me to support an Act that can suspend all other Acts and regulatory instruments on the basis of “trust us.” Maybe the current government is trustworthy—but what about every future government?

I hope you understand my concern. Thank you for taking the time to review my comment.

Sincerely,