Comment
I/we support the Province’s effort to establish consistent development standards across Ontario. Uniform standards allow developers, builders, and consultants to design and construct projects anywhere in the province with clarity and confidence.
These standards must align with the scientific findings of the National Research Council of Canada (NRC) outlined in the Climate Resilient Built Environment (CRBE) Initiative. The NRC’s research shows that rainfall intensity, storm frequency, and weather unpredictability will increase significantly in the coming years and decades.
To reduce the growing risk of flooding driven by more severe storms, the province must use every available tool to strengthen stormwater resilience.
To achieve this, we recommend the following actions:
• Update the Stormwater Management Planning and Design Manual to reflect the latest NRC climate research.
• Adopt province wide lot level water balance requirements with clear, predictable performance standards.
• Recognize all effective lot level stormwater controls, including green roofs, as approved source control measures to reduce runoff and lessen pressure on municipal systems.
• Integrate Toronto’s Green Roof Construction Standard into the Ontario Building Code to ensure consistent and reliable installation practices.
• Introduce incentives and allocate capital funding to support lot level stormwater infrastructure, reducing reliance on costly underground system replacements.
Supporting documents
Submitted November 22, 2025 7:36 PM
Comment on
Consultation on Enhanced Development Standards – Lot Level (outside of buildings)
ERO number
025-1101
Comment ID
173191
Commenting on behalf of
Comment status