I support the Province’s…

I support the Province’s objective to accelerate housing development and improve consistency and certainty in planning and building standards across Ontario. However, I am concerned that aspects of Bill 98, particularly those limiting municipal authority to require sustainable design and performance-based measures through site plan control, may have unintended consequences for public health, flooding and stormwater management.
Ontario municipalities are already experiencing increased rainfall intensity and storm unpredictability. Lot‑level stormwater controls such as vegetated roofs and other source control measures are proven, cost‑effective tools used across the province to manage runoff, reduce peak flows, and protect municipal infrastructure. These measures directly contribute to public safety by reducing localized flooding, mitigating urban heat, limiting damage to public and private property, and avoiding emergency repairs.
While Bill 98 allows for health‑ and safety‑related standards, greater clarity is needed to ensure that stormwater source control continues to fall clearly within this category. Removing municipalities’ ability to require these measures at the development stage shifts risk downstream to municipal systems and existing communities, increasing long‑term costs and vulnerability.
As the Province advances Bill 98, I encourage clear recognition that stormwater source control and related green infrastructure are essential health and safety measures that should remain available through the planning process. Thank you for the opportunity to provide comments on this important matter.

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 tools that demonstrably reduce long‑term infrastructure costs and financial risk.

Lastly, 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.
I encourage the Province to consider the employment implications of Bill 98 alongside housing delivery goals.