I am responding on behalf of…

ERO number

025-1101

Comment ID

172578

Commenting on behalf of

Individual

Comment status

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Comment

I am responding on behalf of a company that supplies green roof systems across Ontario. Our work directly supports municipalities, developers, and design professionals in implementing resilient, low-impact development solutions at the lot level. We have extensive experience with stormwater management practices and the integration of green roofs as part of broader municipal green development standards. Because enhanced development standards directly influence the use of green infrastructure, and therefore directly affect our business and the communities we serve, we have a strong interest in ensuring these standards are consistent, effective, and focused on the future.

Municipalities should continue to be empowered to apply evidence based, performance-focused standards outside of buildings, including:

-Lot-level stormwater management requirements, including water balance targets and peak flow reduction.

-Acceptance and clear guidance for green roofs as a recognized stormwater management solution.

When municipalities lack the ability to require these standards, downstream risks and costs to public infrastructure increase.

Our organization has seen that the short-term costs of enhanced development standards (including green infrastructure installations) are modest relative to overall project budgets and are outweighed by:

-Reduced long-term stormwater infrastructure costs

-Lower flood-related damages

-Reduced heat-related impacts

-Increased property value and long-term site performance.

Green roofs, for example, provide long-term operational savings through roof membrane protection, extended roof lifespan, improved energy performance, and measurable stormwater benefits. The return on investment exceeds initial cost premiums.

Ontario would benefit from province-wide recognition of green roofs as accepted stormwater controls in alignment with the Toronto Green Roof Construction Standard. Consistency across municipalities will reduce administrative burden, create clarity for builders, and allow industry to scale innovation.

Climate change is already increasing flood risk and storm intensity. Municipalities must have the authority to use every available tool to protect communities. Limiting local standards would weaken resilience efforts and shift long-term costs to taxpayers.