To whom it may concern, I…

To whom it may concern,

I recognize the Province’s goal of streamlining approvals and removing barriers to housing development across Ontario. However, limiting the use of site‑level performance measures may increase long‑term costs for municipalities, property owners, and taxpayers. Infrastructure decisions made at the development stage strongly influence lifecycle costs, system capacity, and long‑term municipal financial pressures.

Site‑level measures such as stormwater source controls and green infrastructure reduce peak flows, extend asset life, and delay or avoid the need for costly system upgrades. When these measures cannot be required upfront, municipalities are often forced to address infrastructure limitations reactively, at significantly higher cost.

Ontario municipalities already face substantial infrastructure funding challenges. A policy approach that prioritizes short‑term approval speed over long‑term infrastructure performance risks shifting costs into the future rather than delivering true efficiency.

In addition, Ontario’s green infrastructure sector supports a wide range of skilled jobs across planning, design, manufacturing, construction, installation, and long-term maintenance. Many of these jobs are directly tied to site‑level performance measures that improve stormwater management, climate resilience, and infrastructure efficiency.

By shifting sustainable and performance‑based design measures from regulated requirements to voluntary considerations, Bill 98 introduces market uncertainty that may reduce demand for these skills and services. This could weaken an established sector that supports local employment, particularly at a time when demand for skilled construction and environmental professionals is already acute.

At a time of labour shortages across construction and infrastructure industries, policies that maintain stable demand for skilled, evidence‑based solutions are critical. Recognizing green infrastructure as essential infrastructure and not as an optional enhancement would better align Bill 98 with workforce and economic resilience objectives.

As Bill 98 moves forward, I encourage a balanced approach that supports housing delivery while preserving tools that demonstrably reduce long‑term infrastructure costs and financial risk as well as considering the employment implications to my industry.