Thank you for the…

Thank you for the opportunity to provide feedback on proposed regulatory changes as relates to Bill 98, the Building Homes and Improving Transportation Infrastructure Act, 2026.

As an environmental public health professional, these comments reflect my expertise and understanding of the social, ecological and structural determinants of health – including healthy and affordable housing, healthy built and natural environments, and climate-resilient communities.

Given the climate-related health impacts that individuals and communities in Ontario are already experiencing, including heat and air pollution-related illness and death, I am very concerned with the proposals outlined in Bill 98 to remove the requirement for municipalities to have climate change policies including in their official plan, to prohibit enhanced development standards (e.g., sustainable design) as a condition of land division approvals, and to changes to parkland dedication that risk reducing the quality and quantity of accessible green space.

With the Planning Act identifying matters of provincial interest as including: “the orderly development of safe and healthy communities” and “the protection of public health and safety”, it is imperative that the above-mentioned determinants of health be prioritized in land-use planning and development policies, including proposed changes to the Planning Act and other legislation. Consideration of the impacts of a changing climate goes hand-in-hand with creating compact, complete communities, providing more affordable housing options, and ensuring the protection of, and access to, healthy and sustainable natural environments. These measures help protect public health and reduce health inequities, for example by ensuring energy affordability and climate resiliency.

With the aim of creating healthy, equitable and climate-resilient communities, I urge the Government of Ontario to reconsider legislative changes as proposed in Bill 98, and specifically to:

1. Retain the requirement stated in section 16 (14) of the current Planning Act for municipalities to have climate change policies in their official plans. This policy states: “Climate change policies: An official plan shall contain policies that identify goals, objectives and actions to mitigate greenhouse gas emissions and to provide for adaptation to a changing climate, including through increasing resiliency. 2017, c. 23, Sched. 3, s. 5 (2).” Contrary to what the ERO description suggests, these are not redundant requirements. Removing this requirement will increase climate risks by increasing inconsistencies in how or whether municipalities account for a changing climate in all aspects of community development including housing, transportation, and other infrastructure such as sewage, water and stormwater services. It also weakens progress on reducing greenhouse gas emissions and moving towards a more sustainable, net-zero economy.

2. Reconsider changes that would prohibit municipalities from requiring mandatory Enhanced Development Standards (e.g., Green Development Standards) and that would remove references to “sustainable design” from site plan control. Green Development Standards have been shown to support faster development approvals and the timely delivery of much needed housing. As noted in a submission to the Government of Ontario from the Ontario Public Health Association on Bill 23, More Homes Built Faster Act, 2022, “Green Development Standards that incorporate higher tiers of energy efficiency for new buildings and other sustainability and climate-resiliency features benefit health and the planet. These features can help to reduce energy poverty by increasing building energy efficiency and reducing energy cost for tenants and owners. Green building standards can also achieve improved air quality and thermal comfort to protect occupants from indoor air pollutants, extreme heat, and extreme cold. Several public health agencies across Ontario have provided input into green building standards presenting the health and equity evidence to support improved energy efficiency and climate-resiliency.”

3. Reconsider changes to Parkland Dedication provisions that would risk the ability of municipalities to secure accessible, quality green space by allowing encumbered lands or privately owned public spaces to count towards municipal parkland dedication requirements. As noted in a submission to the Government of Ontario from the Ontario Public Health Association on Bill 23, More Homes Built Faster Act, 2022, “Reduction of parkland requirements and parkland dedication fees will significantly reduce access to local greenspace. This will have negative impacts from a climate resiliency and health perspective, increasing health risks by impacting people’s access to cool outdoor spaces during heat events and disproportionately impacting equity-deserving groups, especially people most vulnerable, who have limited access to parkland and with the least resources to adapt.”

In closing, I urge the government to act on the recommendations in the Ontario Provincial Climate Change Impact Assessment (PCCIA) to use the key findings to “inform policies, programs, research and investment decisions moving forward” including land-use and climate adaptation policies, and specifically, given the PCCIA findings that: “climate risks are highest among Ontario’s most vulnerable populations and will continue to amplify existing disparities and inequities”, to prioritize equity-deserving groups in implementing climate adaptation measures. This requires using an equity and climate change lens in all land-use planning and housing policy decisions. To again quote the PCCIA Technical Report: “Mainstreaming climate change adaptation into existing frameworks and processes will ease the seeming burden and more fully engrain climate considerations which serve to protect the environment, public health and safety, infrastructure, economies and communities.”

Thank you for considering these comments.

References:

Ontario Public Health Association submission to the Standing Committee on Heritage, Infrastructure and Cultural Policy. https://opha.on.ca/wp-content/uploads/2022/11/Ontario-Public-Health-Ass…

Government of Ontario. 2023. Ontario Provincial Climate Change Impact Assessment. Technical Report. https://www.ontario.ca/files/2023-11/mecp-ontario-provincial-climate-ch…