21 November 2025 The…

21 November 2025

The Honourable Doug Ford
Premier of Ontario

The Honourable Rob Flack
Minister of Municipal Affairs and Housing

The Honourable Todd McCarthy
Minister of the Environment, Conservation and Parks

Re: ERO 025-1101: Enhanced Development Standards at the lot level (outside of buildings)

Dear Premier Ford and Ministers Flack and McCarthy,

I am writing on behalf of LiveRoof Ontario Inc, a London area based green roof supplier and employer within the Ontario green roof industry, to express our concerns regarding to the potential regulatory changes expressed in ERO 025-1101 regarding enhanced development standards at the lot level as part of Bill 17 and Bill 60.

As green roof suppliers we have significant expertise in the design, utilisation and installation of low impact development based, lot level stormwater control strategies, specifically green roofs.

Our firm understands and supports the push behind Bill 17 and 60 to make the regulatory requirements across municipalities simpler, and consistent, by having the same development standards across the province. We agree that uniformity of development standards across all municipalities are important to help developers and their consultants, as well as planners and building officials develop plans easier and faster and obtain and issue approvals faster. This is bound to have a positive effect on the, currently, very lengthy site plan approval and building permit process across Ontario.

Our concerns flow from the language in ERO 025-1101, that states that all mandatory lot level stormwater control standards will be removed as a planning tool from municipalities across the province. In the document no hint is given about the replacement for those lot level standards. Moving forward in the direction that ERO 025-1101 states will have negative consequences. It will:
- Reduce livability and impact the health and safety of Ontario’s residents, especially in densely populated areas
- increase long term costs to municipalities, the province and developers
- reduce the employment within the green roof and broader natural infrastructure industry
- interfere with effective planning, which will negatively impact all parties involved in development as well as the broader public.
- reduce Ontario’s status as a leader in low impact development.

Uniformity in building standards is a good thing to have, however if the standards set are too low, the problems outlined will arise both short term and long term. Stormwater control is one of the best examples of the need for lot level controls, especially in dense urban environments. Lot level controls help prevent combined sewage overflows, and help reduce damage to the aging underground stormwater infrastructure. Green roofs, as an example of a lot level stormwater control technique, reduce the overall flow and the peak flow into the underground stormwater infrastructure by significant volumes. Recent studies at the UofT GRIT Lab put the reduction at 70% of all the rain falling on green roofs never reaching the underground stormwater control infrastructure and 90% never entering the infrastructure at times of peak flow. The City of Toronto, through the now defunct green roof bylaw, has over 1200 green roofs that collectively prevent over 500 million litres of water entering the sewer system in Toronto annually.

The ongoing findings of the National Research Council of Canada (NRC), through its Climate Resilient Built Environment (CRBE) Initiative, have provided clear evidence that rainfall intensity, storm frequency, and unpredictability are expected to rise sharply in the coming years and decades. And the recently released report by the Institute for Catastrophic Loss Reduction highlights a rapidly escalating threat of catastrophic losses throughout Canada at a rate of almost 10% per year. The report not only highlights the escalating problem with catastrophic losses, it also hints at the coming crisis in insurability against these losses in certain geographic locations. Ontario cannot afford to ignore these findings.

Flooding is one of the most pressing climate risks facing our communities. To reduce this threat under escalating storm pressures, the Province must incorporate every available tool to mitigate future flooding. This requires decisive action now.

We therefore recommend the following measures:
- Update the Ontario Stormwater Management Planning and Design Manual to reflect the National Research Council of Canada (NRC)’s latest scientific findings along with the Sustainable Technologies Evaluation Program (STEP) initiated by Ontario’s Conservation Authorities to protect water resources and reduce or prevent flooding.
- Adopt province-wide lot-level minimum water balance requirements with clear, predictable performance standards.
- Introduce incentives for developers who exceed the minimum performance standards
- Introduce incentives and allocate capital funding for lot-level stormwater infrastructure on projects not in the hands of developers, thereby reducing the frequency and cost of underground stormwater system replacements.
- Recognize and include all acceptable lot-level stormwater control methods—such as green roofs—as source controls to reduce runoff and relieve pressure on municipal systems.
- Recognise standardised test methods as they become available, to evaluate individual lot level stormwater control techniques for effectiveness
- Inspect lot level stormwater controls periodically to ensure they are in compliance with the minimum requirements set across the province. Require remediation of those that are not.
- Integrate Toronto’s Green Roof Construction Standard into the Ontario Building Code to ensure consistency of installation of green roofs across the province.
- Integrate construction standards for all LID systems, as they become available, into the Ontario Building Code.

With Bill 17 and Bill 60 providing the opportunity to provide uniform development standards across the province, Ontario has a unique opportunity to lead by example. By embedding resilience and sustainability into our development requirements, the Province can build not only faster, but smarter—creating communities that are prepared for the climate realities of the future.

We urge the Province to act swiftly and decisively. The cost of inaction will be measured in flooded homes, damaged infrastructure, and disrupted communities. The benefits of action, by contrast, will be measured in resilience, economic stability, and public confidence.

Thank you for your leadership in advancing this initiative. We stand ready to support the Province in implementing these recommendations and ensuring Ontario’s development standards reflect both the urgency of climate change and the promise of sustainable growth.

Sincerely,

On behalf of LiveRoof Ontario Inc

Kees Govers, BSc(Agr), GRP
Technical Sales Manager