I strongly urge the…

I strongly urge the provincial government to withdraw the portion of Bill 60 that revokes the City of Toronto Green Roof By-Law. I am a licensed landscape architect with 15 years of experience working with green roofs.

Revoking the Green Roof By-Law would be devastating to Ontario’s Green Roof Industry, effectively eliminating its largest market and causing a loss of more than 1,600 jobs across the province. These job losses would impact a wide variety of small businesses in both rural and urban areas, including engineers, designers, landscape contractors, maintenance professionals, truckers, crane operators, and manufacturers of components like edging, membranes, plastic injection molds, irrigation systems, soil blenders, and agricultural producers of green roof plants.

Contrary to what some may believe, green roofs have no impact on single-family housing and a negligible impact on the cost of multi-residential developments. An analysis of dozens of multi-unit residential projects found that green roofs cost between 60 cents and $1 dollar per square foot in buildings where condominium units sell for $900 to $1,200 per square foot. This represents as little as 0.006 percent of the selling price.

The 12.5 million square feet of green roofs currently installed on more than 1,200 buildings across Toronto are essential to the ongoing management of stormwater and the prevention of flooding. Existing green roofs in Toronto alone capture more than half a billion litres of stormwater from flooding buildings and entering the sewer system each year. Roughly equivalent to the daily flow of the Ashbridges Bay Treatment Plant, this frees up capacity needed to allow new developments in the city. This is also critical infrastructure, as flooding in Ontario cost more than $1 billion in 2024 alone, impacting insurers and increasing insurance rates for taxpayers. Green roofs are an essential tool for addressing stormwater management regulations and can be implemented more rapidly than traditional grey infrastructure. Capturing and storing stormwater in green roof soil, drainage layers, and plants is more cost-effective for urban developers than storing it in expensive cisterns, which also consume valuable space.

Green roofs installed under the By-law provide half a million square feet of valuable, accessible green space. This not only supports greater human health and wellbeing but also provides an opportunity for developers to market themselves, selling and leasing their units faster and at a premium, thereby recovering their initial investment. Furthermore, building owners benefit directly from lower heating and cooling energy costs, higher property values, and a doubling of the life expectancy of their waterproofing membranes.

Green roofs also contribute significantly to energy savings. They eliminate the extreme heat from black roof membranes and, through the process of evapotranspiration, cool buildings and the intake air for air conditioning units lowering costs. The evapotranspiration process reduces the artificially high temperatures in cities, known as the urban heat island effect, which is a growing health and safety issue in Ontario’s communities. The urban heat island effect drives greater energy consumption, places added stress on the energy grid during heat waves, and contributes to poorer air quality and heat-related mortality.

Ontario’s Green Roof Industry, working with researchers and standard-setting bodies, has created world-class standards in areas like wind uplift, which benefit the development community by further reducing costs and supporting innovation. Given their multiple benefits, green roof mandates exist in world-class cities such as Chicago, New York, San Francisco, Paris, Tokyo, Berlin, and London, to name a few. Emerging technologies now being developed and applied include blue-green roofs to manage more stormwater; biodiverse green roofs to support pollinators; food-producing green roofs to generate employment; and solar green roof integration, which has been proven to improve solar panel energy efficiency.

Given these important considerations and the government's stated objectives to build homes and secure jobs, we request that the proposal to revoke Toronto’s Green Roof By-Law be withdrawn from Bill 60. This will save 1,600 jobs across Ontario and would allow the industry to continue to deliver products and services that serve developers, building owners, and build healthier and more resilient Ontario communities.