RE: ERO #026-0300 – Proposed…

RE: ERO #026-0300 – 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)

I am writing as an individual and as a municipal employee to express my strong opposition to the proposal to streamline and standardize official plans and to prohibit mandatory municipal enhanced development standards and green building standards.

Ontario is greatly experiencing the effects of climate change such as more floods, ice storms, extreme heat events, and wildfires. In response to this, municipalities across Ontario have declared climate emergencies and have developed plans and targets to reduce their greenhouse gas emissions and to increase the resiliency of their communities to protect the health and safety of their residents.

Over the past decade, Ontario has experienced a rise in health issues directly and indirectly related to climate change, including extreme heat illnesses, respiratory problems from wildfire smoke, and an increase in vector-borne diseases. Flooding in Ontario, particularly in 2024, has caused over $1 billion in insured damages. The July 2024, Toronto flood resulted in an estimated $940 million in insured losses, followed by over $100 million in damages from August storms. These costs will continue to rise due to increased extreme weather events and if we do not start building more resilient communities.

Removing the requirement for municipalities to include climate change policies in their official plans would be a step backward and would deliberately put the health and safety of Ontario residents at risk. By including climate change policies in official plans, municipalities have the ability to proactively plan for and reduce the impacts of future climate disasters. Climate change policies in official plans creates a roadmap for a more resilient, cost-effective, and liveable community that protects the health and safety of Ontario residents.

Prohibiting mandatory municipal enhanced development standards and green building standards takes away a critical tool communities use to manage stormwater, reduce urban heat islands, and lower long-term operating costs for residents. Buildings are the source of 24% of Ontario’s emissions, mainly from the use of fossil fuels like natural gas for heating. These emissions are likely to increase if energy efficiency measures are not allowed to be in place. Additionally, if homes and buildings are not built to be more resilient to extreme weather events, homeowners and taxpayers will bare the brunt of retrofitting and repairing their homes and buildings, which is significantly more expensive than building sustainably from the get-go.

Framing the proposal to prohibit mandatory green building standards as “removing red tape” ignores the downstream costs taxpayers will bear in flood damage, heat emergencies, and aging infrastructure.

No government can credibly claim to be “building strong communities” while stripping the very tools municipalities use to plan for climate resilience which actually builds strong communities.