REFERENCE: ERO 025-1140:…

REFERENCE:

ERO 025-1140: Bill 60 - Fighting Delays, Building Faster Act, 2025 – Supporting the Harmonization of Municipal Road Construction Standards

Please accept the following as Oxford County’s Submission of Comments in response to the proposed changes posted for public consultation on the Environmental Registry of Ontario (ERO 025-1140).

Background

The County of Oxford appreciates the opportunity to provide feedback on the proposed regulatory changes under Bill 60 – Fighting Delays, Building Faster Act, 2025. In general, the County supports the Province’s efforts to streamline infrastructure delivery and improve consistency across Ontario’s municipalities.

Currently, most municipalities, including the County of Oxford, maintain their own road design and construction standards that reflect local conditions, development patterns, and operational practices. The County has numerous capital construction projects that could be directly impacted by the proposed amendments. This includes our annual paving program and the various road reconstruction projects undertaken each year. The County invests a significant amount of funding into maintaining and upgrading our road assets, and any changes to standards could have a direct impact on how these projects are planned and delivered.

Comments

If implemented, the standardization of municipal road construction practices could offer several benefits to municipalities, including the County of Oxford. Consistent provincial standards could simplify project delivery, enhance clarity for consultants and contractors operating across multiple jurisdictions, and lead to efficiencies in design, procurement, and construction processes. Standardization could also benefit smaller and rural municipalities by encouraging the use of proven materials and design methods, while providing access to relevant standards that may otherwise be beyond the technical or financial capacity of smaller organizations to develop independently.

However, the County feels that it is essential that any harmonized standard consider the wide range of differences among Ontario’s municipalities, from large urban centres to smaller rural communities, with flexibility to accommodate local conditions, asset management priorities, and available municipal budgets. A “one-shoe-fits-all” approach could be counterproductive to the intent of harmonization if it doesn’t account for varying conditions like: climate, geography, growth patterns, or infrastructure needs. The County of Oxford recommends that the Province provide clarity on the following key points:

- What is the process for requesting an exemption from a standard, and will there be clear guidance on acceptable alternative solutions?

- Will detailed technical specifications be made publicly available in advance for municipal and industry review?

- What is the expected timeline for municipalities to comply with the new standards once regulations are enacted?

- How will compliance be monitored and reported, and what are the potential consequences for noncompliance?

- Will there be periodic reviews or updates of standards to reflect evolving industry practices and technologies?

- Have cost impacts been assessed for municipalities of different sizes and capacities?

- Will the Province provide guidance, tools, or funding to support municipalities; particularly smaller or resource limited ones, in implementing the new standards?

Conclusion

Overall, the County of Oxford supports the Province’s efforts to harmonize municipal road construction standards as an important step toward improving consistency, efficiency, and project delivery across Ontario. However, we feel that continued municipal consultation will be key to successfully implementing these standards.

Sincerely,

Reuben Davis, P.Eng.
Senior Manager of Engineering Services
Oxford County Public Works