Comment
I strongly endorse the initiative to establish consistent development standards across Ontario. We must be able to design and build anywhere in the province with confidence that the same standards apply, ensuring efficiency, predictability, and quality.
If Ontario is to reduce the growing threat of flooding under escalating storm pressures, the Province must act decisively. This means incorporating every available tool to mitigate future flooding risks and protect communities.
Development standards must be grounded in science and reflect the findings of the National Research Council of Canada (NRC) as outlined in the Climate Resilient Built Environment (CRBE) Initiative. The evidence is clear: rainfall intensity, storm frequency, and unpredictability are projected to rise sharply in the coming years and decades.
To achieve effective standards that mitigate risk, I recommend the following actions:
• Update the stormwater management planning and design manual to align with the latest scientific findings by the National Research council of Canada (NRC)
• Adopt province-wide lot-level water balance requirements with clear, predictable performance standards
• Recognize and include all acceptable lot-level stormwater control methods — such as green roofs —as source controls to reduce runoff and relieve pressure on municipal systems.
• Integrate Toronto’s Green Roof Construction Standard into the Ontario Building Code to guarantee consistency of installation across the province
• Introduce incentives and allocate capital funding for lot-level stormwater infrastructure, reducing the frequency and cost of underground stormwater system replacements
By embedding resilience and sustainability into its development requirements, Ontario can build not only faster, but smarter—creating communities that are prepared for the climate realities of tomorrow.
Submitted November 18, 2025 10:11 AM
Comment on
Consultation on Enhanced Development Standards – Lot Level (outside of buildings)
ERO number
025-1101
Comment ID
172053
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Comment status