Comment
As a taxpayer from Alcona, Innisfil, I am writing to express serious concerns regarding Bill 98, particularly the proposed removal of municipal authority to require green building and sustainability standards as part of development approvals. While I recognize the urgent need to build housing and improve transportation infrastructure, this legislation risks creating long term financial, environmental, and public safety costs for Ontarians—especially as urban flooding and stormwater management failures continue to worsen across the province.
As a taxpayer, I am deeply concerned that Bill 98 prioritizes short term development speed over long term resilience, local accountability, and environmental protection.
1. Erosion of Municipal Autonomy Over Green Standards (Climate & Environmental Rollback)
Removing the ability for municipalities to mandate green building and sustainability standards represents a significant rollback of locally driven climate action. Municipalities such as Toronto have spent years developing evidence based green standards—covering energy efficiency, green roofs, permeable surfaces, tree canopy protection, and stormwater retention—to address local environmental risks.
These tools are not symbolic; they are practical responses to real and growing challenges:
• Urban flooding
• Overburdened stormwater systems
• Extreme rainfall events
• Heat island effects
• Rising infrastructure repair costs paid by taxpayers
By making green standards entirely voluntary, Bill 98 effectively removes municipalities’ capacity to prevent future climate related damages upfront, shifting the burden instead to residents and provincial emergency response and infrastructure budgets. This undermines local governance and ignores the reality that climate impacts are experienced locally, not uniformly across the province.
2. Stormwater Management Risks While Flooding Remains a Major Urban Concern
Ontario municipalities are already struggling with the cost and consequences of flooding—from basement backups to road washouts and overwhelmed sewer systems. Green development standards play a vital role in mitigating these risks through:
• On site stormwater retention
• Reduced impervious surfaces
• Low impact development techniques
• Naturalized landscapes that absorb rainfall
Bill 98’s approach increases the likelihood that new developments will externalize stormwater impacts onto surrounding neighbourhoods and public infrastructure. When flooding occurs, taxpayers—not developers—pay the price through:
• Emergency services
• Infrastructure repairs
• Insurance claims and rising premiums
• Long term system upgrades
Removing mandatory green standards while climate driven rainfall intensifies is fiscally irresponsible and places unnecessary strain on public systems.
3. One Size Fits All Planning Ignores Local and Regional Reality
The proposed standardization of official plans across all municipalities—using a single provincial template—fails to recognize the diversity of Ontario’s communities. Urban centres face density, flood risk, and aging infrastructure challenges; rural and northern municipalities face entirely different geographic, environmental, and servicing realities.
Uniform planning tools cannot adequately respond to:
• Local watershed conditions
• Flood prone areas
• Existing infrastructure capacity
• Community specific environmental risks
Local planning flexibility exists for a reason. Eliminating it weakens outcomes rather than improving efficiency.
4. Speed vs. Oversight: A Costly Tradeoff for Ontarians
While Bill 98 emphasizes accelerated housing construction, it does so by reducing environmental safeguards, limiting public transparency, and weakening local oversight. Faster approvals should not come at the expense of:
• Environmental protection
• Climate resilience
• Community input
• Long term infrastructure sustainability
Developments built without appropriate green standards today can create decades of downstream costs tomorrow. Speed that sacrifices oversight ultimately transfers risk from private developers to the public.
Conclusion
Ontario needs housing—but it also needs resilient, fiscally responsible, and climate adaptive communities. Bill 98, as currently proposed, risks locking the province into higher long term costs, increased flood damage, and diminished local governance.
I urge the Province to:
• Restore municipal authority to mandate green building and stormwater management standards
• Recognize the critical role of local planning in addressing climate impacts
• Avoid a one size fits all approach to growth
• Ensure that housing speed does not come at the expense of environmental protection and public accountability
Protecting municipalities’ ability to plan responsibly is not an obstacle to growth—it is essential to building safe, sustainable, and affordable communities for the long term. Let's work together with Ontario municipalities and towns!
Submitted March 31, 2026 12:33 PM
Comment on
Proposed Planning Act, City of Toronto Act, 2006, Building Code Act, 1992 and Municipal Act, 2001 Changes (Schedules 1, 2 and 7 of Bill 98, the Building Homes and Improving Transportation Infrastructure Act, 2026)
ERO number
026-0300
Comment ID
183855
Commenting on behalf of
Comment status