I am submitting these…

I am submitting these comments noting that I have been working in the field of climate risk and resilience for over 30 years, my subject matter expertise in climate change is widely recognized, and my historical experience includes being a member of the first expert panel on climate change adaptation in Ontario from 2007-2009. While I recognize the importance of building housing and infrastructure, the urgency to do so more quickly, and accept to some degree the need to streamline the regulatory process, the latter should not be done at the expense of compromising the design, construction, or capital improvement of legacy or new infrastructure assets to be climate resilient to acute and chronic changes in climate projected with climate change. Unfortunately the existing Provincial and National Building Codes are lagging in their consideration of increased design requirements in response to a changing climate and municipal efforts to promote green building standards have played a significant role in building resiliency and reducing vulnerability and risk from climate change hazards. Given the outcome of COP30, and the inevitability of even more severe and extreme weather in the foreseeable future (e.g., by 2050 and beyond), it would be counter productive to limit or otherwise compromise our ability to reduce the level of vulnerability and exposure to future climate-related risks, especially those involving heavy rains and flooding. I note at least 3 events greater than a 1-100 year storm occurring in the Toronto area over the past 20 years (August 19 2005, July 8 2023, and July 16 2024). While the evidence of extreme rainfall events, flood impacts, and role of green building standards to reduce the costly impacts, it seems counterproductive from an economic basis to streamline development at the expense of taking action via proven methods to reduce impacts. I also note beyond the Provincial Policy Statement, through O. Reg. 588/17 Asset Management Planning for Municipal Infrastructure, Ontario has become a leader in Canada in highlighting the importance of taking action to reduce the impacts of climate change and enhance resilience and adaptive capacity. The great work done by the Financial Accountability Office of Ontario on the costs of climate change and adaptation in buildings and transportation infrastructure provides more evidence towards the financial benefits of taking such action. Green building standards should be expanded and enhanced, rather than restricted and minimized. Doing so would be short sighted, and in the long term is contrary to any economic rationale, and may in fact raise questions regarding liability in the event of property damages and harm to human health.