To whom it may concern,…

To whom it may concern,

Thank you for providing the opportunity to comment on this proposal.

The purpose of this bill, as I understand it, is to allow cabinet to designate specific areas where trusted proponents (as designated by cabinet through regulation) are exempt from typical processes and laws in order to speed up development. While I am in agreement with the government when they say it is important to advance strategic economic projects, I do not think the SEZA is a useful tool in this regard, primarily for two reasons. First, the SEZA is limited to as-of-yet ill-defined projects and proponents, and not applied equally throughout the province. Second, the exemptions from other provincial laws leaves me concerned that due process will not be followed and that the public interest will not be upheld.

The concept of Special Economic Zones is, at the moment, quite nebulous. The definition in Schedule 10, Section 2 (2) merely states that cabinet will make a regulation defining it sometime in the future. Therefore, it is hard to say what impact this will have on our economy, positive or negative, as the definition is literally TBD. With that said, I will have to engage in a bit of speculation. The government seems to want to cut through a bureaucratic morass of red tape in order to fast-track mines, pipelines, and highways. With the caveat that plenty of “red tape” are actually regulations designed to protect us (and that this government has a poor track record of distinguishing actual red tape from laws that protect the public interest [1]), I think that any regulatory reform should be looked at through a whole-of-province lens. If a rule truly does not serve the public interest and only serves to slow down the process, then it should be removed entirely—not just within SEZs. If the government thinks that businesses would benefit from faster approvals and a more straightforward regulatory environment, then table a bill to remove the red tape and have the legislature vote on it, as has been done many times by this government.

Instead, what the SEZA enables is for cabinet to give special privileges to certain companies who are close to the premier and his ministers. My concern about abuse potential comes from a long history of this government providing privileged access to a handful of well-connected donors. From the Greenbelt scandal, where developers literally handed USB sticks to the minister’s chief of staff with requests for removals [2], to MZOs handed out without any consultation with municipalities [3][4], to selling off provincial assets behind closed doors for pennies on the dollar [5][6], this government has shown time and time again that it cannot be trusted to wield its executive powers in a manner befitting of the highest office in the province. This bill is just the latest in a series of bills that centralizes power within cabinet and the minister’s office. We are watching in real-time the effect of too much executive power; I have no desire to replicate the American experience in Ontario.

I value policy that is built on evidence, is informed by experts, and upholds the public interest. Unfortunately, I do not see much of that in this proposal. The bill seeks to empower ministers to make vibes-based decisions that will bring windfall profits to some business owners while not doing the tough work to truly weed out red tape from helpful regulations. I want to reiterate that I am fully supportive of building up our economy, but it has to be done in a responsible and equitable way, not based on impulsive, ad-hoc decisions. I want the government to take this bill back to the drawing board and come up with a real plan for economic resilience—a plan that builds a clean economy, that ensures a just transition, that protects our environment, and leaves a better future for the next generation—a plan that creates real wealth for Ontario.

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[1] https://thenarwhal.ca/ontario-environment-ford-explainer/
[2] https://www.cbc.ca/news/canada/toronto/auditor-general-greenbelt-lobbyi…
[3] https://www.cbc.ca/news/canada/toronto/mississauga-lakeview-village-mzo…
[4] https://thepointer.com/article/2023-05-16/this-is-insanity-pcs-toss-out…
[5] https://www.cbc.ca/news/canada/toronto/ndp-calls-for-review-of-hearn-pl…
[6] https://www.cbc.ca/news/canada/toronto/ontario-dominion-foundries-agree…