As a Registered Professional…

As a Registered Professional Planner with a graduate degree in environmental studies and a decade of professional expertise in building housing and infrastructure and assessing climate change risk, I strongly disagree with the proposed legislative and regulatory changes under the Fighting Delays, Building Faster Act, 2025. This act means the end of Toronto’s green roof by-law and Toronto Green Standard, Mississauga’s and Guelph’s stormwater charges, and Thunder Bay’s solar roofs, among so many other important municipal development improvements for the health and safety of their communities and our planet. At a time when flooding alone caused $1 billion in insured damages in ON in 2024.

Municipalities have every right to direct development in their jurisdiction as they see fit, as they are closest to the best interests of the communities they serve and the geographies they live in. This act is not only an overstep of the Province's jurisdiction that undermines the very role of municipal governments in Ontario, it is also based on no scientific evidence. Evidence tells us green roofs cost on average 0.05% of a downtown building's total cost and create $75M worth of economic activity, including 1600 jobs in ON. In addition to their water quality, flood mitigation, biodiversity and human health benefits.

Climate change is here, we are living through heat waves, floods, wildfire smoke, and extreme weather of all kinds that our infrastructure was not built and still is not being built to standards adequate to withstand. MMAH you have the ultimate power to change this fact by updating the climate parameters in the Ontario Building Code, so we build to current and near future weather and not outdated historic weather trends. 1/100 year storms are now 1/5 year storms. We are already experiencing 10%+ plus increases in 15 min rainfall events and that is set to increase to 30% by 2050. Coupled with fewer natural landscapes to absorb larger rain events. In addition to extreme heat and humidity that will require exponentially more building energy consumption to maintain indoor climate controls. What is the point of building faster, if its not to an adequate standard to serve its purpose?

Enhanced development standards are efficient mechanisms to manage stormwater, heat, humidity and wind in our built environments for the benefit of those who live in them. As someone who advises on built environment specifications, I often referenced the Toronto Green Standard, because it is a best in-class standard available to those of us doing this work on the ground. Enhanced development standards are not being implemented carelessly by municipalities they are developed with the utmost scientific rigor, based on local context and professional expertise. Weather is becoming hyper-localised and our weather monitoring stations are too far between to accurately measure the weather we are experiencing, which makes local lived experience extremely important to inform how we build.

Local enhanced development standards are not the same across Ontario, because population and development pressures are not the same across Ontario. Larger municipalities and regions experiencing those pressures are better placed to respond to them by requiring a higher standard of development, because they will experience greater impacts when sub-standard developments not adapted to current climate fail us - fail to keep us cool, dry and safe. They are the areas with so much rapid and inadequately planned development due to years of Provincial overruling that has created unsustainable housing sprawl in our suburbs and towns, and unsustainable density in our cities.

The Province’s Ontario Municipal Board overruled municipalities time and time again and allowed Southern Ontario’s grade-A farmland and wetlands to be paved over, so that water has nowhere left to go but into the streets, people’s homes and businesses, and overwhelming local sewer and water body capacity to handle them safely. In 2024, flooding caused $1 billion dollars in insured, let alone uninsured damages, in Ontario according to the Insurance Bureau of Canada. “Ontarians have been hit hard by flooding this year, and the damage we’ve seen is unprecedented,” said the IBC’s Amanda Dean, vice-president in Ontario and Atlantic Canada. “The emotional distress that this summer’s floods have caused thousands of Ontario residents cannot be overlooked.”

The Province of Ontario has a long history of downloading civil service responsibilities to municipalities without providing the equivalent tax revenue streams to pay for them. It is not municipal mismanagement that got us here. Providing frontline services - emergency response, drinking water, wastewater, stormwater, transit, power, roads - this is the health and safety of our communities. Municipalities should be commended by the Province for continuing to provide these services despite provincial under-funding and ever-growing climate and population change. Municipalities have created enhanced development standards to do more with less. They've served to make our communities better, just as they are getting worse, by building better.

Scientific evidence shows that construction practices have not largely changed in the last century, yet we have so many new building science advancements and smart compassionate community development techniques to draw upon now. Taking away municipal authority to drive positive change in development is all the proposed legislative and regulatory changes under the Fighting Delays, Building Faster Act, 2025 is poised to do. It will not make anything faster. Development delays are now being caused by the Provincial Government changing all the rules that all the actors in the development industry know and rely upon. Adequate consultation practices would have told you that.

MMAH it is your duty to serve all the citizens of Ontario equitably, using real consultation practices, and evidence-based decision-making. Please do not proceed with this legislation that will make the built environment a more dangerous and unhappy place to live for Ontarians.