Please find attached…

Comment

Please find attached correspondence from TMA Law, on behalf of our Client, Build Urban Inc., in support of Bill 98's proposed prohibition on mandatory enhanced development standards ("EDS").

Mandatory EDS add an unnecessary level of complexity to the development approval process, largely without a clear corresponding sustainability benefit, thereby leading to increased costs and delays to homebuilders and homeowners alike.

EDS and green development standards are redundant and duplicative of existing regulations imposed by the Building Code, the Ministry of Environment, Conservation, and Parks, and of industry best practices, all of which already regulate matters of energy efficiency and environmental sustainability.

The OBC already requires certain development standards, which our Client and its members are pleased to meet, and our Client will often exceed the OBC standards where economic viability and market conditions dictate. However, Enhanced Development Standards must not be permitted to be mandated by municipalities.

As such, our Client welcomes and applauds the Province’s proposed changes to the Planning Act which make it abundantly clear that municipalities do not have the authority to require mandatory Enhanced Development Standards and green development standards.

Thank you,
Mark A. de Jong