City of Toronto, Engineering…

City of Toronto, Engineering & Construction Services (ECS) has significant concerns about the proposal to implement mandatory common municipal road construction standards. We appreciate the opportunity to outline the challenges and explain why we do not support this proposal.

Toronto currently uses a combination of provincial standards, adapted versions of those standards, and our own standards. This flexibility enables adaptability, innovation, quality assurance, and the ability to address performance and lifecycle issues, while also providing clarity and consistency for industry.

While harmonization may offer limited efficiencies, these are outweighed by significant risks. Larger municipalities would lose the innovation and responsiveness embedded in their current specifications, which are tailored to their unique needs and local expertise. Conversely, smaller municipalities might be burdened with excessively complex or onerous standards that exceed their technical capacity and budgets and do not address local needs.

Suggesting that harmonization alone will resolve delivery challenges may overlook underlying issues and fail to address root causes. Construction specifications often reflect a municipality’s direct response to local issues, particularly those arising from the need to increase housing density in heavily urbanized areas, build and operate public transit, reduce congestion, meet climate targets, and achieve the required performance to meet local traffic levels, geography, climate, contractor performance challenges, and material availability and quality.

Specific concerns:
• Financial and administrative impacts depending on the direction of provincial harmonization efforts, including the replacement of current standards, updating of design and inspection standards and procedures, updating of procurement practices, tender templates, and legal agreements, retraining of staff across all areas of construction delivery, and potential contractual penalties if in-flight development, piloting, and implementation of new local standards must be halted.

• Inability to develop and maintain standards that reflect a municipality’s infrastructure, policy objectives, and operational needs, or the ability to address local issues such as geography, population, traffic, public transit, market availability of materials, municipal policies, and internal expertise.

• Elimination of the incentive for innovation at the municipal level, which may lead to stagnation in construction methods, materials, and climate resiliency. Research and development would have to be absorbed by the Province, at significant cost and extended timelines, since each change would require broad consultation and testing to ensure applicability across the entire province.

• The above would be exacerbated if the harmonization extends beyond road standards to also encompass roadside design and other municipal infrastructure elements.

• The proposal is championed by private industry whose priorities may differ from those of municipalities and the Province. Industry may provide feedback, but if the Province includes them in the decision-making process, the outcomes may not be in the public interest.

Recommendations:
• The Province should not harmonize road construction standards for the reasons cited above.

If the Province proceeds with exploring harmonizing road standards:
• The City of Toronto – ECS should be invited to play a leadership role in shaping the process, as we do currently with the review and development of provincial construction standards under existing processes.

• The Province consider a tiered approach to reflect the varying populations, geographies, capacities, and needs of municipalities across the province and ensure equitable implementation expectations, rather than a single mandatory set of specifications.

• Clarify whether piloting new approaches and materials would be permitted under a harmonized framework and ensure clarity in the updated legislation.

• Clarify whether harmonization is intended to be applied province-wide or differentiated by MTO regions or other classifications.

• To safeguard the public interest, decision-making should rest solely with municipalities and the province. Industry can be consulted, but must be excluded from any formal decision-making roles, including voting.