I want to express my strong…

I want to express my strong support for the Province’s initiative to establish uniform
development standards across Ontario. Consistency in standards is not merely a matter
of efficiency—it is a cornerstone of sustainable growth. Developers and consultants
must be able to design and build anywhere in the province with confidence that the same requirements apply, ensuring predictability, quality, and fairness across
jurisdictions.

However, uniformity alone is not enough. These standards must be firmly rooted in
science. The National Research Council of Canada (NRC), through its Climate Resilient
Built Environment (CRBE) Initiative, has provided clear evidence that rainfall intensity,
storm frequency, and unpredictability are expected to rise sharply in the coming years
and decades. Ontario cannot afford to ignore these findings.

Flooding is one of the most pressing climate risks facing our communities. To reduce
this threat under escalating storm pressures, the Province must incorporate every
available tool to mitigate future flooding. This requires decisive action now.

I therefore support the recommendation of the following measures:
- Update the stormwater management planning and design manual to reflect the
National Research Council of Canada (NRC)’s latest scientific findings.
- Adopt province-wide lot-level water balance requirements with clear, predictable
performance standards.
- Recognize and include all acceptable lot-level stormwater control methods—such as
green roofs—as source controls to reduce runoff and relieve pressure on municipal
systems.
- Integrate Toronto’s Green Roof Construction Standard into the Ontario Building Code
to ensure consistency of installation across the province.
- Introduce incentives and allocate capital funding for lot-level stormwater infrastructure,
reducing the frequency and cost of underground stormwater system replacements.

Ontario has a unique opportunity to lead by example. By embedding resilience and
sustainability into its development requirements, the Province can build not only faster,
but smarter—creating communities that are prepared for the climate realities of
tomorrow.

We urge the Province to act swiftly and decisively. The cost of inaction will be measured
in flooded homes, damaged infrastructure, and disrupted communities. The benefits of

action, by contrast, will be measured in resilience, economic stability, and public
confidence.

Thank you for your leadership in advancing this initiative. We stand ready to support the
Province in implementing these recommendations and ensuring Ontario’s development
standards reflect both the urgency of climate change and the promise of sustainable
growth.

Respectfully,
Joanna Vilcius
Project Manager, Green Roofs
Ginkgo Sustainability