Wellington-Dufferin Guelph …

Wellington-Dufferin Guelph (WDG) Public Health recognizes the intent of the proposed changes for streamlining planning processes and supporting housing delivery across Ontario. From a public health perspective, land use planning plays an important role in shaping exposure to climate-related health risks, including extreme heat and precipitation. As these risks intensify, maintaining a strong and coordinated planning framework is important to help protect population health and reduce long-term system pressures.

1. Removal of Climate Change language in Official Plans

The proposal would remove the requirement for municipalities to include climate change policies in official plans, with the rationale that this is addressed through the Provincial Planning Statement, 2024. While provincial policy direction remains in place, official plans are the mechanism through which that direction is implemented locally, considering valuable local contexts in planning. Removing the explicit requirement may reduce consistency in how municipalities integrate climate considerations into local planning.

Climate change is associated with increasing risks to human health, including extreme heat, flooding, and impacts to air quality. Land use planning decisions influence exposure to these hazards through community design, infrastructure, and the natural environment. Clear policy direction at the official plan level helps ensure these risks are considered proactively and consistently in planning decisions.

Consider retaining a clear requirement for climate change policies within official plans to support consistent local implementation of provincial climate policy, and integration of climate change considerations across land use, infrastructure, and growth planning decisions.

2. Standardization of Official Plans

The proposal would standardize the structure and content of official plans. WDG Public Health supports efforts to improve clarity and consistency across planning documents.

Consider ensuring that standardization maintains sufficient flexibility for municipalities to address local environmental and climate conditions within the framework. Municipalities across Ontario are experiencing climate-related risks differently based on local land use patterns, infrastructure capacity, and environmental conditions. Planning frameworks are most effective when they can respond to these place-based risks and priorities.

A more standardized approach may limit the ability to reflect local climate vulnerabilities and tailor policy responses accordingly. Maintaining flexibility within the standardized framework may help ensure that official plans can effectively address locally relevant climate-related health risks and support resilient community outcomes.

3. Removal of authority to require Enhanced Development Standards

The proposal indicates that municipalities would no longer be permitted to require certain Enhanced Development Standards (EDS) at the lot level where they are not explicitly tied to health or safety and would remove references to “sustainable design” from site plan control provisions.

WDG Public Health has significant concern with the distinction made between “sustainable design” and health and safety. Many elements commonly categorized as sustainable design are directly linked to mitigating environmental conditions that pose established risks to human health. Sustainable site design measures – such as tree canopy, shading, permeable surfaces, and green infrastructure – function as preventative health and safety measures by reducing exposure to climate-related hazards, including:

• Extreme heat: Lack of shade and vegetation and urban greening contributes to higher surface and air temperatures, increasing risk of heat exhaustion, heat stroke, and mortality, particularly among vulnerable populations.

• Flooding and runoff: Impermeable surfaces increase stormwater runoff, contributing to localized flooding, infrastructure strain, and potential exposure to contaminants.

• Air quality and environmental conditions: Vegetation and green infrastructure contribute to improved air quality and more comfortable outdoor conditions, which influence respiratory health and daily activity.

Extreme heat and flooding are key climate-sensitive health hazards in Canada, with increasing frequency and severity expected under climate change. Built environment interventions – many of which fall under “sustainable design” – are recognized as primary strategies to reduce exposure to these risks.

The proposal’s approach, which frames EDS as separate from health and safety unless narrowly defined (e.g., stormwater management), may exclude a range of site-level measures that function as preventative public health protections. While these measures may not always be categorized as immediate life safety infrastructure, they play a critical role in reducing risk over time and across populations.

Removing the ability to require these features may reduce consistency in the provision of shade, cooling, and outdoor environmental protections, increase exposure to heat and hazards associated with flooding, and shift reliance to reactive or retrofit measures rather than preventative design. Consider recognizing that sustainable design measures are intrinsically linked to health and safety outcomes, particularly in the context of building resiliency to climate change. Maintaining municipal authority to require clearly defined site-level features that reduce heat, manage stormwater, and support safe outdoor conditions will help ensure that developments contribute to mitigating, rather than increasing, climate-related health risks.

4. Encumbered Parkland and Privately Owned Public Spaces (POPS)

The proposal indicates that developer-identified lands, such as strata lands and privately owned public spaces (POPS), would count towards municipal parkland dedication requirements. Although these spaces can offer value of open space in areas of high density, enabling these lands to count towards any type of parkland dedication requirement limits municipalities’ abilities to provide a diverse and strategic parkland system that meets current and future community needs.

Parkland provides populations with opportunities for physical activity, mental wellness and social connection through environmental preservation and community programming and amenities. As intensification increases, the need for and use of public parks and open spaces will also increase, particularly among populations residing in multi-unit dwellings. Increased usage places added pressures and maintenance requirements on existing parks, making parkland expansion and recreational amenity optimization key. It is therefore important for municipalities to assess parkland dedication proposals against projected parkland needs.

5. Property Value and Insurance Impacts

Climate-related hazards such as flooding and extreme heat are increasingly influencing property risk, with direct implications for homeowners through rising insurance premiums, reduced coverage availability, and increased out-of-pocket costs. Where preventative, site-level measures are not consistently implemented, properties may be more vulnerable to damage and loss over time.

These pressures intersect with energy inequity, which has direct implications for health. As temperatures increase, households may rely more on energy-intensive cooling to maintain safe indoor conditions. Where homes are not designed with passive cooling features (e.g., shade, tree canopy, building orientation, use of appropriate materials) or planned in a way that considers sustainable design and are built for the future, residents may face:

• Higher energy costs to maintain safe indoor temperatures
• Inability to afford adequate cooling, increasing risk of heat-related illness
• Trade-offs between energy use and other basic needs
• Greater exposure to extreme indoor temperatures

In this context, climate-responsive and energy-efficient site and building design are not only environmental considerations, but also health equity measures that reduce both exposure to climate hazards and the financial burden of adapting to them.
Consider that maintaining the ability to implement preventative, site-level design measures through planning processes may help reduce long-term property risk, support housing stability, and mitigate associated health impacts related to financial burden and environmental exposure.

WDG Public Health supports efforts to streamline planning processes and improve consistency across the planning system with the goal of improving housing access and affordability in Ontario. However, the proposed changes may reduce the ability to systematically integrate climate considerations and site-level design measures that are directly linked to health protection.