re: Proposed MZO to Protect…

ERO number

025-1108

Comment ID

159068

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Individual

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Comment

re: Proposed MZO to Protect a Biomanufacturing Campus in Toronto

Through my company, Juno Risk Solutions Inc., I have acted as a security risk advisor to Tenblock Management Inc. since 2022. Tenblock is the development entity of Microbjo Properties Inc., the owner of the private property and existing apartment building at 1875 Steeles Avenue West in the City of Toronto. I am writing to provide my professional opinion that if the review of the proposed MZO includes consideration of national, industrial or business security matters, then such concerns are neither created nor worsened by the proposed development and any claims in regard to national, industrial or business security should not be given any weight in your evaluation.

I have attached a more detailed letter outlining the results of my analysis which includes discussion of a number of other comparator properties to provide you context as you consider this file.

Without question, Sanofi has security concerns related to the protection of its business interests. This is not unique to Sanofi. Indeed, Public Safety Canada, CSIS and CSE have been persistent in their public and private warnings to a broad range of Canadian industries, including 11 strategic technology areas of which bio-manufacturing represents a sub-set of only one of these areas. The Federal security services have been clear that these industries face realistic threats from corporate and state-sponsored espionage. I have direct personal experience evaluating threats and advising clients in a variety of industries on approaches to protect their interests.

However, simply increasing the height of a building on a neighbouring site where existing surrounding buildings and public spaces are already sufficient to gain effective view into the buildings and open spaces within the facility will not increase that risk. I draw your attention to a similar residential development product underway in Gloucester that will create commanding views of the National Research Council campus on Montreal Road, CSIS Headquarters and the Communications Security Establishment (CSE) complex. Unlike this present case, there is no mention in the public documents related to that case that any of these three well-known targets of foreign espionage raised any security concerns about the introduction of a 25-story condominium complex immediately adjacent to their facilities.

Again, I direct you to my attached letter for a more fulsome discussion of the issue.

Andrew Chester
CEO
Juno Risk Solutions