Comment
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.
As Bill 98 moves forward, I encourage a balanced approach that supports housing delivery while preserving measures that demonstrably reduce long‑term infrastructure costs and financial risk.
Submitted May 12, 2026 1:15 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
185558
Commenting on behalf of
Comment status