As a Landscape Architect…

As a Landscape Architect actively involved in community planning, environmental design, and climate‑resilient development, I am concerned that the legislative changes proposed under ERO 026‑0300 prioritize procedural streamlining and development acceleration at the expense of environmental performance, landscape systems, and long-term community resilience. While addressing Ontario’s housing supply is critical, the proposed amendments risk undermining place‑based planning, landscape-led infrastructure, and municipal tools that support sustainable growth.

Landscape architecture plays a central role in delivering stormwater management, urban heat mitigation, tree canopy protection, biodiversity enhancement, and public realm quality. The proposed changes under Bill 98 would significantly restrict municipal authority to require enhanced development standards, including green infrastructure and landscape performance measures, beyond the base Ontario Building Code.
From a landscape perspective, this raises concerns that:

Low‑impact development (LID) strategies such as bioswales, rain gardens, soil volume minimums, and permeable surfaces may no longer be enforceable.
Municipal climate adaptation strategies that rely on landscape systems could be overridden by standardized provincial requirements.
Communities will face increased flood risk, urban heat island effects, and loss of tree canopy over time.

Landscape elements are not decorative amenities; they are functional infrastructure that reduces long‑term public costs associated with flooding, heat‑related illness, and infrastructure failure.

The broader Bill 98 framework, of which ERO 026‑0300 forms a part, proposes limiting site plan control, an essential mechanism through which landscape performance is secured.
From a landscape architecture standpoint:

Site plan control is often the only stage where tree preservation, grading, soil health, and pedestrian‑scaled public realm design can be meaningfully reviewed.
Removing or weakening this tool increases the likelihood of token landscaping, reduced tree survival, and hardscaped, heat‑intensive environments.
Landscape coordination between buildings, utilities, and public space will suffer, leading to higher retrofit costs for municipalities.

Ontario municipalities are already experiencing the impacts of climate change through extreme rainfall, drought, and heat events. Landscape-based solutions are among the most cost‑effective responses.
By constraining municipal leadership on landscape and green development standards, ERO 026‑0300 may:

Shift short‑term cost savings onto long‑term public liabilities.
Reduce community access to shaded streets, high‑quality parks, and functional public space.
Conflict with municipal climate action plans that depend on landscape interventions rather than building‑only solutions.

Landscape Architects are regulated professionals responsible for protecting the public interest through responsible land planning and environmental design. Reducing the scope of landscape‑related review and requirements diminishes the role of qualified professionals in delivering safe, healthy, and climate‑resilient communities.
This also risks:

Lower design quality in new communities.
Reduced innovation in landscape construction practices.
Missed opportunities for integrated infrastructure that supports both housing delivery and environmental stewardship.

In conclusion, while the objectives of ERO 026‑0300 to increase housing supply and efficiency are understood, the proposed approach places speed and uniformity ahead of environmental performance and landscape resilience.

I respectfully urge the Province to:

Retain municipal authority to require enhanced landscape and green infrastructure standards.
Ensure standardized Official Plan structures allow for robust, locally responsive landscape policies.
Preserve site plan control mechanisms that secure landscape performance.
Recognize landscape architecture as essential infrastructure supporting housing, health, and climate adaptation.

A truly housing enabling framework must also be landscape enabling, ensuring Ontario’s communities are not only built quickly, but built well, safely, and sustainably.