Comment
Thank you for the opportunity to comment on Bill 98 and the Province’s broader direction regarding green development standards.
I am writing to express serious concern about recent provincial actions that weaken or override municipal green development standards. These standards are essential tools that municipalities use to reduce emissions, improve climate resilience, and ensure that new growth aligns with Ontario’s long-term environmental and economic interests.
Green development standards—such as requirements for energy efficiency, sustainable materials, tree canopy preservation, and stormwater management—are not arbitrary barriers to development. They are evidence-based measures that reduce lifecycle costs, limit environmental degradation, and support healthier, more resilient communities. Weakening these standards shifts costs onto municipalities, residents, and future generations in the form of increased infrastructure strain, higher energy demand, and greater exposure to climate-related risks.
Bill 98 raises particular concerns in this context by further centralizing decision-making authority and limiting the ability of municipalities to respond to local environmental conditions. Ontario’s municipalities are on the front lines of climate impacts, including flooding, extreme heat, and infrastructure stress. Restricting their ability to implement forward-looking development standards undermines their capacity to protect residents and manage growth responsibly.
From an environmental perspective, this direction is inconsistent with Ontario’s stated climate commitments. Reducing emissions from the built environment is one of the most effective and necessary strategies available. Green development standards directly contribute to this goal, and removing them creates a regulatory gap at a time when stronger action—not weaker—is required.
From an economic perspective, the argument that green standards significantly impede housing development is overstated. Many jurisdictions have successfully integrated higher performance standards without halting growth. In fact, consistent and predictable standards can drive innovation, support local green industries, and reduce long-term costs for homeowners and municipalities alike.
I urge the Province to reconsider provisions within Bill 98 that limit municipal authority over development standards, and to instead support a coordinated approach that:
Enables municipalities to implement locally appropriate green development standards.
Provides clear, province-wide minimum standards that align with climate targets.
Encourages innovation in low-carbon and climate-resilient construction.
Supports builders and municipalities with the tools and resources needed to meet higher performance requirements.
Ontario is at a critical juncture. Decisions made today about how we build our communities will shape environmental and economic outcomes for decades. Weakening green development standards is a step backward that risks locking in higher emissions and greater climate vulnerability.
I respectfully request that the Province take a more balanced and forward-looking approach that recognizes the importance of municipal leadership in sustainable development.
Thank you for considering these comments.
Submitted May 14, 2026 11:21 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
186101
Commenting on behalf of
Comment status