Thank you for the…

Thank you for the opportunity to comment on this proposal. I am submitting this response on behalf of the Carleton Place Environmental Advisory Committee (CPEAC).

• The Carleton Place Environmental Advisory Committee strongly opposes the MMHA proposal to introduce extensive restrictions on municipalities’ ability to have Green Development Standards that affect anything outside the building envelope.
• While the CPEAC supports improved efficiencies and acknowledges the benefits of consistent standards, we are concerned that the current Provincial Planning Statement and Planning Act do not provide adequate, specific, evidence-based metrics to minimize the carbon footprint of development and ensure community health and safety in the context of increasing climate risks.
• A truly conservative Provincial Planning Act would include Green Development Standards, since they are essential for healthy, safe, livable communities: they ensure that new housing developments are built in a way that ensures long-term economic and environmental sustainability, conserves Ontario’s natural heritage and air and water quality, and provides protection from increasingly severe storms, floods, and heat waves.
• GDS also provide simplicity and clarity for developers by providing clear, specific metrics in advance, streamlining the approval process.
• Building more houses won’t help our communities in the long term if they are not built in a way that takes long-term community and environmental health into consideration. Municipal Green Development Standards are intended to fill a serious gap in provincial regulation. Provincial land use planning standards should take realistic consideration of the future sustainability constraints that Ontario will encounter as part of a changing world. Failing that, the Province should allow individual communities, especially those in rapidly growing metropolitan fringes where vast new infrastructure is being built, to maintain higher standards.
• The CPEAC also recognizes that municipalities may require site-specific tools and benefits to address unique conditions and goals. It is not appropriate to completely standardize GDS requirements across a province the size of Ontario: municipalities differ widely in their geographies, priorities, resources, and the climate risks they face, and need to be able to set Green Development Standards that meet local needs. 
• As an advisory committee to a small rural-suburban town, the CPEAC would certainly appreciate more guidance and support from provincial and regional governments to help us better support our town’s efforts to manage growth and build housing density while meeting its sustainability and climate adaptation goals.
• But we also see the benefit what our Town has done, which is to use successful models from other municipalities and adapt them to our local situation, establishing metrics in line with those of other municipalities in the region (to provide consistency for developers) but responsive to our town’s particular geographical and economic situation. Our GDS provides clarity on minimum requirements while offering flexibility for additional sustainability features to be considered on a voluntary basis.
• The CPEAC recommends a balanced approach that reduces administrative burden while preserving and enhancing Green Development Standards across the province. A cost benefit analysis would help identify which sustainability features will pay for themselves over the long term by helping reduce energy costs as well as the growing cost of dealing with climate-related disasters. We consider this to be a truly conservative approach, since it ensures that communities grow in a way that ensures environmental and economic stability for years to come.