Comment
I support the Province’s initiative to create uniform development standards across the province. Uniformity is important for developers and consultants to be able to design and build anywhere in the province to the same standards.
HOWEVER, these new standards need to reflect the scientific findings of the National Research Council of Canada (NRC) as reported in "Climate Resilient Built Environment (CRBE) Initiative".
Rainfall intensity, along with the frequency and unpredictability of storms, is expected to rise sharply in the coming years and decades. For the province to reduce the threat of flooding under ever increasing storm pressure, we need to incorporate all available tools to mitigate future flooding.
To achieve these goals, we recommend the following actions to be taken:
- Update the stormwater management planning and design manual to reflect the scientific findings of the National Research Council of Canada (NRC)
- Adopt province-wide lot level water balance requirements with predictable performance standards
- Include all acceptable lot-level stormwater control methods, including green roofs, as stormwater source control to reduce runoff and ease pressure on municipal systems
- Adopt Toronto’s Green Roof Construction Standard in the Ontario Building Code to ensure to consistency of installation
- Introduce incentives and allocate capital funding for lot-level stormwater infrastructure to reduce frequency of costly underground stormwater infrastructure replacement
Thank you for reading.
Submitted November 20, 2025 12:19 PM
Comment on
Consultation on Enhanced Development Standards – Lot Level (outside of buildings)
ERO number
025-1101
Comment ID
172276
Commenting on behalf of
Comment status