Re: ERO 026 0300 and ERO 026…

Re: ERO 026 0300 and ERO 026 0309 — Bill 98, Building Homes and Improving Transportation Infrastructure Act, 2026

Thank you for the opportunity to provide my comments.

I am a professional landscape architect and the only landscape architect in the Planning Department at the City of Windsor. Because of this, many of the landscape architectural, urban design, and environmental decisions made through Site Plan Control come directly through my review. These decisions shape the safety, sustainability, and long term appearance of our city — and they directly affect families like my own. As both a municipal professional and a parent with a young family and a home in Windsor, I feel a personal responsibility to comment on the proposed changes under ERO 026 0300 and 026 0309.
I fully support the Province’s goal of accelerating housing delivery and reducing unnecessary delays. My work is directly tied to that objective. However, the proposed removal of mandatory Municipal Enhanced Development Standards (EDS), the elimination of “sustainable design” from site plan control, and the prohibition of EDS as conditions of land division approvals will undermine the very outcomes we are all trying to achieve.

Sustainable design and lot level EDS are not optional enhancements. They are the tools that allow municipalities to ensure safe stormwater management, reduce extreme heat risks, maintain tree canopy, support mobility, and build climate resilient neighbourhoods. These are core public interest functions — not aesthetic preferences.

Windsor’s Air Quality Context Makes EDS Even More Critical
Windsor faces air quality challenges that are not experienced to the same degree in many other Ontario municipalities. Our proximity to Detroit — a major industrial and transportation corridor — contributes to elevated levels of transboundary pollution. As someone raising a young family here, I see firsthand how important it is that we use every available tool to improve local air quality.
Trees, permeable surfaces, and green spaces are among the most effective municipal scale interventions for filtering particulates, reducing ground level ozone, and mitigating heat island effects. Removing the ability to require these features at the lot level directly limits our capacity to combat pollution and protect public health in a region already disproportionately affected by poor air quality.

Impacts of the Proposed Changes
Based on both established evidence and my experience reviewing development applications in Windsor, the proposed changes could:

• Increase long term costs for developers, municipalities, and homeowners.
• Reduce public health and safety, particularly in communities like Windsor that already face elevated air quality and heat island risks.
• Fragment and slow the planning process, creating downstream inefficiencies and costly retrofits.
• Weaken Ontario’s competitiveness by misaligning provincial planning tools with federal funding requirements for sustainability and climate resilience.

Request for Inclusion in Site Plan Control Reform
Include the Ontario Association of Landscape Architects (OALA) as a formal stakeholder in ongoing site plan control reform consultations (ERO 026 0310). Landscape architects bear primary professional responsibility for the site level elements covered by site plan control and lot level EDS, yet were not identified as a consulting party in the Province’s technical briefing materials. We respectfully request that this be corrected as the reform process moves forward.

I am committed — both as a municipal professional and as a parent raising a family in Windsor — to helping Ontario build more homes faster without compromising safety, resilience, or long term affordability.

Kind regards,

Ryan Gardiner Upton, OALA