Commentaire
To: Government of Ontario, Housing Minister Honourable Rob Flack
Re: Removal of Green Roof By-Law in New Building Construction
Dear Minister,
On behalf of Hugh Garner Housing Co-operative’s Roof Top Committee, I submit strong concern regarding the recent Order-In-Council decision to remove the requirement of green roofs on new building construction.
Hugh Garner Co-op replaced its first 1982 standard roof with an 8000 sq. ft. south green roof in 2010. At that time Toronto had 444 green roofs. Today there are over 1200. Toronto is a North American standard in green roof construction. The organization “Green Roofs for Healthy Cities” started by our architect Monica Kuhn, is based in Toronto. There is demand, and the economic, environmental and community benefits numerous:
o Savings in heating and cooling costs
o Noise reduction
o Savings on roof lifespan
o Creates employment
o Cooler Cities
o Better air quality
o Water savings
o Habitat creation
o Nature access
Such an impactful decision requires public consultation and debate at Queen’s Park, not made out of the public eye. If, as the government claims, such a decision is beneficial to the public, the reasoning will be evident if presented in the appropriate democratic manner.
Inserting the decision into an omnibus bill does not advance climate goals in an urban setting-a setback with economic disadvantages and harms a growing industry much of which is established in non-urban settings.
Hugh Garner Co-operative is a residence of 380 members benefitting from a forward-looking decision in 2005. We’ve been encouraged to see the expansion of this intelligent design in both new and retrofitted residential, commercial and industrial construction. Weakening the green roof building requirement would be a large step backwards economically and environmentally. It is also evident that this proposed change overrides municipal authority.
Please rescind the Order-in-Council, consult widely in public and debate in the Legislature.
On behalf of Hugh Garner Housing Co-operative Roof Top Committee.
Wade Potts (Chair)
550 Ontario St. 11
Toronto M4X 1X3
Further details in attachment used in community and student education tours
Points of Interest for Green Roof Tours
Information about Hugh Garner Housing Co-op
The co-op was opened in 1982. It has 181 units, with a total of about 380 residents. Units range in size from one to four-bedroom units. It is a mixed community with children and adults and accessible for members who have mobility issues. Our members come from countries all over the world making Hugh Garner co-op a vibrant and diverse community.
1. What is a Green Roof?
A green roof is a living roof of a building that is partially or completely covered with vegetation and a growing medium, planted over a waterproof membrane.
It can include various layers; at minimum a waterproof and root repellent membrane, a drainage system and engineered, light weight soil and plants that grow well with green roof conditions.
(eg: exposure to more sun, heat, wind and frost than ground gardens, in contained beds and soil made of 60% earth, 40% non water absorbing material).
The Hugh Garner - South Roof - is an INTENSIVE roof.
“Intensive” green roofs contain deeper soil. This allows for more vegetation choices such as trees and perennial garden flowers. At Hugh Garner, soil depths range from 6-8 inches in shallow areas to 4 feet in depth for trees.
The Hugh Garner - North Roof - is an EXTENSIVE green roof system.
Extensive green roofs have much more shallow soil (from 1 to 6 inches) with plants that typically include sedums and grasses.
2. Benefits of a Green Roof
o Savings in heating and cooling costs from added insulation layer and plants. Insulation also reduces noise, making for quieter building and cities.
o Savings on roof lifespan- a doubling membrane’s lifespan – saving costs for owners and garbage from landfill with more often conventional construction. Creates employment in alternative energy sector.
o Cooler Cities – plants help reduce the urban heat island effect.
o Better air quality - plants and growing medium absorb polluting air particles, capture carbon dioxide, reduce smog and produce oxygen
o Water savings –roofs divert water and saves both building’s water cost and use of City water, reduces flooding and stress on City’s sewage in overflow events
o Habitat creation – provides habitat space and food for a diverse variety of plants, butterflies, insects, birds and other wildlife
o Nature access– a green roof offers shade from trees, bushes and aesthetic structures, giving tenants use of a natural setting and social space year round
o Healthier people – studies show significant improvements in mental, emotional and physical health for those with access to nature and beauty.
o Gardening opportunities and education – learning about plant varieties, wildlife and ecosystems for tenants and visitors
o Education – a community learning tool for environmental responsibility and green roof technology for those who want to build green roofs on their homes, buildings.
3. Special Features of Hugh Garner Green Roof
Hugh Garner’s green roof is 22,000 square feet in total.
The South Roof, is 8000 sq. feet with public access and gardens.
The North Roof, is 14,000 sq. feet, and is in development to add soil/plants.
Water Recycling:
Rainwater is recycled. It collects under roof structures and the gardens. The rainwater sits in cups and is regularly drawn and pumped through sprinkler pipes in the beds. This feature makes the watering of gardens low maintenance.
The South Roof can hold 1000 cubic feet of water (28 cubic meters).
The North Roof can store 1667 cubic feet of water (47 cubic meters).
This prevents approximately a yearly 33,000 cubic gallons of water runoff into city sewers, saving the cost of cleaning and distribution of Toronto City water.
Wooden Structures
Gazebos and pathways are made of Eastern white cedar, sustainably grown and harvested from outside Kingston, ON. (instead of old growth cedar from B.C.)
Accessibility:
Pathways and seating areas accommodate members and visitors who use mobility devices such as wheelchairs, scooters, etc. Some of the planting areas have been designed to make gardening accessible to all members.
The Hugh Garner Green Roof serves as a teaching tool. It inspires green roof students, professionals, gardeners and people from around the world with regular tours that are hosted by Co-op volunteers.
Community Building and Volunteering:
The roof garden is well used by members. It is a shared space open from 5 am to 11 p.m. Members gather on the roof garden to enjoy the beautiful and spacious views, to socialize, learn about the wildlife and, as well as participate in the upkeep of the garden. A community herb garden provides herbs for all.
A Roof Top Committee ensures that all of the Hugh Garner gardens are cared for. The green roof and gardens at ground level help create community, teach about gardening and are a welcoming space for members and visitors.
4. The Team
Monica Kuhn of Monica Kuhn E. Architect designed the green roof structure design with assistance from Carolyn Moss, architect of Moss Sund Architects.
Monica has been involved in promoting green roofs in Canada for many years and was a forming board member of Green Roofs for Healthy Cities and more recently was on the City’s technical advisory team that informed the creation of the new City of Toronto Green Roof By-law.
Monica assembled a team of professionals to work on the Hugh Garner Green Roof which included Terry McGlade of Gardens in the Sky. Terry, also a long-time promoter of green roofs, has designed and installed many roof gardens in the City of Toronto including the City Hall green. Gardens in the Sky is a division of Flynn Canada, a building envelope contractor, with clients across Canada.
5. The History of The Green Roof and Co-op Volunteer Efforts
In 2002, it became time to redo the building’s roof. A group of Co-op members gathered with the interest of building a green roof instead of a regular roof. Green roofs were a very new concept in Canada in 2002.
An engineering feasibility study confirmed the roof could carry the weight of a green roof. Co-op members agreed on a project proposal and extensive planning for a green roof began in 2004.
The million-dollar Hugh Garner green roof is a member driven project.
With the Co-op members’ support, the newly formed Green Committee of member volunteers researched green roof technology, coordinated with industry experts, fundraised money, oversaw construction and overall planning as well as promoted awareness of the roof project for members, visitors and media.
One of the largest tasks was raising the funds: the cost was $950,000 for a new roof membrane, on both roofs, and an intensive green roof on the south roof.
A total of approx. $600,000 came from the Co-op’s capital reserves.
Green committee volunteers fundraised $341,000, which took 7 years.
Donations and grants came from members, individuals, organizations, corporations and government grants (eg: The Trillium Foundation and the City of Toronto Live Green Program made the biggest contributions. Toshiba representatives from Japan planted our Japanese Maple tree and gave $20,000.)
In 2010 the Hugh Garner green roof project was completed.
Hugh Garner now has one of the largest residential green roofs in Canada. It is a pioneer and continues to inspire green roof building in Canada.
Toronto is the first City in North America to have a bylaw to require and govern the construction of green roofs on new development. The Bylaw applies to new building permit applications for residential, commercial and institutional development made after January 31, 2010 and to new industrial development as of April 30. 2012.
Today, over 1200 green roofs exist in the City of Toronto. Between 2010 and 2015, 260 were created in Toronto, consisting of 196,000 sq m of green roof area.
Soumis le 22 novembre 2025 5:20 PM
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Modifications proposées à la Loi sur l’aménagement du territoire (Annexe 10 du projet de loi 60 - Loi de 2025 visant à lutter contre les retards et à construire plus rapidement
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