To Whom It May Concern, I am…

To Whom It May Concern,

I am writing to formally submit my comments regarding the proposed Minister's regulation (ERO 026-0309) that seeks to remove municipal authority to require mandatory Enhanced Development Standards (EDS) and sustainability measures as a condition of land division approvals.

As a registered landscape architect (OALA) actively engaged in the review of development applications at the municipal level in Ontario, I strongly urge the Ministry to reconsider this shift from a mandatory to a voluntary approach. Restricting a municipality's ability to enforce local sustainability conditions will directly undermine long-term environmental functionality, increase long-term infrastructure burdens on municipalities, and degrade the resilience of our communities.

The Necessity of Sustainable Requirements at the Local Level
While the proposal suggests that elements not strictly tied to basic health and safety should become voluntary, this creates a false dichotomy. "Sustainability measures" such as comprehensive tree preservation policies, woodlot compensation, ecological offsetting, and advanced stormwater Best Management Practices (BMPs) are not mere aesthetic enhancements. They are critical site engineering components that mitigate the localized impacts of development.

A province-wide, voluntary approach fails to recognize that environmental constraints and infrastructure capacities vary drastically between municipalities. Local governments require the regulatory tools to enforce EDS in order to meet specific municipal targets, such as preserving tree canopy cover and managing complex drainage systems, which directly impact local climate resilience and stormwater management efficiency. Shifting the burden of these measures from the development sector to the municipality—as acknowledged in the proposal's Regulatory Impact Analysis—is financially unsustainable for local governments.

The Critical Role of the Landscape Architect in the Development Process
The successful implementation of these standards relies heavily on the technical expertise of landscape architects. Our involvement is critical in translating broad municipal sustainability targets into highly specific, functional site plans.

During the development review process, landscape architects provide essential oversight on site engineering interfaces, including intricate grading, subsurface infiltration design, and ensuring that proposed vegetation can survive within constrained urban environments. We ensure that tree preservation fencing requirements are not just lines on a drawing, but functional barriers that protect existing natural assets during construction. Limiting municipal authority to mandate these standards will devalue this critical technical oversight, leading to an increase in unintended environmental impacts and subsequent remediation costs for the municipality.

Standardizing development approvals should not come at the expense of necessary, site-specific environmental protections. I strongly recommend that the province maintains the authority of local municipalities to require mandatory Enhanced Development Standards.

Thank you for the opportunity to provide feedback on this crucial matter.

Sincerely,
Jiaqi Yi, OALA, CSLA