Submission to the…

Submission to the Environmental Registry of Ontario
Re: ERO #025-0391 – Special Economic Zones Act, 2025
Submitted by: Dr. Alexandra Pedersen, Queen’s University

I am submitting this comment in my capacity as a faculty member at Queen’s University, where I teach and research in the interdisciplinary Earth and Energy Resources Leadership program. My work focuses on governance in the extractive industries, environmental justice, and community engagement. I also serve on the Board of Directors for MiningWatch Canada, a national organization that advocates for responsible mining practices. Through this work and my teaching, I am actively engaged with critical discussions about mining and environmental governance in Ontario. Internationally, I have worked alongside Indigenous communities affected by Canadian mining abroad, experiences that inform my understanding of the structural issues facing Indigenous peoples in resource development globally and in Canada.

I am deeply concerned by the proposed Special Economic Zones Act, 2025, part of Bill 5: Protect Ontario by Unleashing Our Economy Act. The Act would grant sweeping powers to the provincial cabinet to establish and regulate Special Economic Zones (SEZs), particularly for mining and infrastructure projects, bypassing key environmental protections and removing already-limited requirements for public or Indigenous consultation. As proposed, these are not specialized economic zones, but rather "sacrifice zones" (Pollon 2023). SEZs often function as sacrifice zones; geographic areas where social, environmental, and Indigenous rights protections are deliberately weakened or suspended to prioritize industrial or economic activity. This is exactly what this bill proposes to do.
The bill’s language referring to “proponents” without clearly identifying who they are or how they are selected creates a troubling lack of transparency, setting a dangerous precedent for backroom deals and increasing the risk of regulatory capture and corruption.

This is especially alarming in the context of the Ring of Fire, an ecologically sensitive region that is home to wetlands critical to carbon storage, and traditional territories of numerous Indigenous Nations who have already affirmed they are not in favour of this type of development. By enabling the designation of SEZs without transparent public oversight and without the consent of the affected Indigenous governments, the Act disregards the constitutional duty to consult and accommodate, and the commitments made under the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP), including the principle of Free, Prior, and Informed Consent (FPIC). It also disregards Ontario’s obligations under Treaty 9, where the Crown agreed to share the land and its resources, not unilaterally authorize development without the consent of signatory First Nations. The absence of these safeguards in a context of accelerated development risks exacerbating conflict, undermining Indigenous rights, and creating long-term social and environmental harm.

This bill is the wrong reaction to the United States' tariffs because it addresses external trade pressures by dismantling environmental protections, democratic safeguards, and Indigenous rights rather than investing in long-term economic resilience. Fast-tracking extraction without proper oversight or value-added strategies will primarily benefit companies looking to export raw materials, often to international firms, thereby reinforcing our dependency on the very markets imposing trade barriers. Instead of building a diversified, sustainable economy, the bill risks deepening structural vulnerabilities and weakening Ontario’s ability to respond to future geopolitical and economic disruptions

This legislation does not address the actual barriers to sustainable development in northern Ontario: namely, the lack of long-term partnerships with Indigenous Nations, the absence of baseline environmental assessments, and the failure to create governance structures that respect Indigenous law and jurisdiction. Instead, the bill risks fast-tracking extractive projects while sidelining the very communities who are most impacted, communities who have repeatedly called for genuine engagement, long-term planning, and protection of their lands and ways of life.

This bill is not a meaningful solution for job creation because it prioritizes rapid extraction and deregulation over long-term, sustainable economic planning. Jobs generated through Special Economic Zones are often short-term, low-regulation positions tied to boom-and-bust cycles in resource extraction; offering little stability, training, or community investment. Without requirements for local hiring, environmental responsibility, or Indigenous co-governance, these projects risk outsourcing profits, importing labour, and leaving communities behind once resources are depleted or markets shift. Real job creation requires durable investment in education, infrastructure, value-added industries, and equitable partnerships, not bypassing protections to benefit a few developers.

I urge the Government of Ontario to:

- Halt or significantly revise this legislation to ensure that no SEZs are designated without full public transparency, independent environmental review, and Indigenous co-governance;
- Work collaboratively with Indigenous Nations to design any future regional development frameworks in a way that respects Indigenous jurisdiction, legal orders, and self-determination;
- Commit to reconciliation not in words but in law and policy by embedding UNDRIP and FPIC into all legislation related to land and resource use.

This Act does not build prosperity; it undermines democratic process, environmental resilience, and the principles of reconciliation. I would welcome the opportunity to contribute further to this conversation, including through consultation processes or engagement with decision-makers on building just and sustainable governance in Ontario’s mining regions.

Dr. Alexandra Pedersen
Assistant Professor (Adjunct), Earth and Energy Resources Leadership
Queen’s University
alexandra.pedersen@queensu.ca