Thank you for the…

Thank you for the opportunity to provide comments on the Special Economic Zones Act. Halton Hills Town staff understand that due to current economic challenges, including those pertaining to international trade, it is important that the Province of Ontario strives toward continuing to be a center of innovation, economic growth and activity within Canada. Town staff offer the following comments for the proposed Act:

General Comments:

Municipal Official Plan policies and Zoning By-law requirements are based on local conditions, serving as both a guide for development, while providing protections for, and/or mitigating impacts on surrounding land uses. The Town has robust Natural Heritage System policies to ensure the long-term protection of the environment. The Town has prepared a number of local scoped subwatershed studies for specific secondary plan areas which identify key natural heritage features, natural hazards such as floodplains and environmental constraints and opportunities. The Special Economic Zones Act, as proposed, would restrict a municipality’s ability to implement such policies within a designated Special Economic Zone. Criteria for designating Special Economic Zones, Trusted Proponents and Vetted Projects should continue to comply with local planning, policies and requirements in areas where this status is sought.

It is unclear what, if any, public consultation would be required under this Act. If designated Special Economic Zones, Trusted Proponents and Vetted Projects are exempt from certain provisions of applicable legislation, including consultation requirements, the proposed Act should identify which provisions are exempt, along with criteria for such exemptions. This information would help local planning officials better inform their Councils and the public on how Special Economic Zones, Trusted Proponents and Vetted Projects are identified, and what legislative requirements are imposed.

To better assist municipalities in understanding and commenting on the Special Economic Zones Act, draft regulations which identify the criteria used to determine Special Economic Zones, Trusted Proponents and Vetted Projects should be circulated by way of a separate ERO posting. This would help municipalities prepare for and anticipate the impacts of the forthcoming legislation.

Due to the limited timelines provided to review the proposed legislative changes, the comments provided are to be considered preliminary. Further comments may be provided once staff has an opportunity to complete their review and report to Council. In the future, providing a longer comment period would be helpful for municipalities to provide meaningful comments on ERO postings of this nature. For instance, a 60-day period would be beneficial where the ERO posting review requires coordination between multiple departments. Longer comment periods also allow for municipal staff to bring the proposals to their Councils for review and consideration before comments are due. This also gives municipal staff the opportunity to provide comments which are endorsed by Council, and considered final.

Special Economic Zones

Town staff request more information as to what criteria are going to be used by the Province to determine what will be defined as a Special Economic Zone. There is the potential for a wide variety of

land uses which, based on the current ERO posting, could be considered as such depending on what the established criteria will be. As the Town is currently undergoing its’ Official Plan Review process; it would be beneficial for the Town to understand what, if any, lands within the Town could be constituted as being of “critical or strategic importance” to the provincial government. Town staff also request more information on what the public process is proposed to look like with establishing Special Economic Zones. Town staff encourage the provincial government to require that the process to designate a Special Economic Zone be done in collaboration/consultation with the local municipality in which the proposed Zone would be located.

The Town does not support the designation of Special Economic Zones in environmentally sensitive areas such as the Niagara Escarpment Area, Greenbelt Plan Area and rural prime agricultural area. If lands located within the Town were to be designated as a Special Economic Zone, Town staff would recommend that the Zone be used to attract industries such as advanced manufacturing, food & beverage processing, agribusiness and clean technology/renewables which would align with the industries the Town has targeted for economic growth and which could also help with the growth of the Ontario economy as a whole. Town staff would point to the Premier Gateway Employment Area in the Town as being an area that could see benefit to a Special Economic Zone designation to help attract new investment to the Province, particularly in advanced manufacturing. It is important to note, however, that the Town has completed the required Secondary Plan for the area including detailed scoped Subwatershed Studies. Protection for key environmental features as per the recommendation of these studies should be maintained.

Vetted Projects

Town staff request more information as to what criteria are going to be used by the Province to determine what will be defined as a Vetted Project. It is difficult to provide comments or feedback on such projects until that information is provided.

Trusted Proponents

Town staff request more information as to what criteria are going to be used by the Province to determine what will be defined as a Trusted Proponent. Town staff would also find it beneficial to understand if there are any proposed proponents that will be located within the Town.

One-Window Services

Town staff request more information as to the proposed One-Window Services that are mentioned in the ERO posting. The wording of the posting indicates that there may be a tiered system with regards to the One-Window Services and Town staff would like to know to what extent these services are going to be used under the planning legislation umbrella of the Province.