To the Ministry of Municipal…

To the Ministry of Municipal Affairs and Housing,

I am an Ontario resident and taxpayer residing in Barrie, Ontario, submitting this comment as a private citizen. I am writing as a resident of Barrie, Ontario to submit comments on ERO #026-0300, regarding proposed amendments to the Planning Act, City of Toronto Act, 2006, Building Code Act, 1992, and Municipal Act, 2001 under Bill 98, the Building Homes and Improving Transportation Infrastructure Act, 2026.

I wish to register my strong opposition to several provisions in this proposal. While the stated goal of building more homes faster is legitimate, the following changes sacrifice environmental protection, democratic accountability, and the long-term resilience of Ontario communities in ways that are not justified by housing supply outcomes.

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1. BANNING MANDATORY GREEN BUILDING AND SUSTAINABLE DESIGN STANDARDS

This proposal would remove municipal authority to require Enhanced Development Standards (EDS), sustainable design elements, or green building standards through site plan control or zoning. This is a serious and irreversible mistake.

Municipalities are closest to their communities and best understand local environmental conditions — flood risk, heat islands, water stress, and soil conditions. The ability to set higher standards for how buildings perform is not a barrier to housing construction. It determines the long-term livability, energy cost, and climate resilience of the homes being built. Stripping municipalities of this authority will produce cheaper homes in the short term at enormous public cost over the long term.

The province should be enabling municipalities to set higher standards — not prohibiting them from doing so.

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2. REMOVING CLIMATE CHANGE POLICY FROM OFFICIAL PLANS

The proposal removes the explicit legislative requirement for municipalities to include climate change policies in their official plans, characterizing it as "redundant" because the Provincial Planning Statement (PPS) still requires climate resilience planning.

This framing is misleading. Legislative requirements and PPS policy carry different legal weight and send different signals to municipalities, planners, developers, and courts. Removing this requirement weakens the overall planning framework and signals that climate is a secondary concern. At a time when climate adaptation costs in Ontario are accelerating, this is the wrong direction.

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3. WATER RESOURCES AND THE CONNECTION TO BILL 98'S WATER PROVISIONS

The standardized official plan framework proposed here includes a required "C2 Water Resources" schedule and a "Natural Environment and Water Resource Areas" land use designation. These are welcome on paper — but they must be read alongside Bill 98's companion proposal (ERO 026-0301), which amends the Water and Wastewater Public Corporations Act, 2025 to enable arm's-length corporate delivery of water services across Ontario.

Taken together, these proposals create a troubling picture: official plans will be required to map and protect water resources, while the governance of the water and wastewater systems that depend on those resources is being restructured into corporate entities removed from direct democratic control. Protecting water on paper while financializing its delivery in practice is not protection at all.

I urge the ministry to ensure that any water resource protections built into the official plan framework are backed by governance structures that remain fully under public and democratic control.

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4. REMOVING NOTICE REQUIREMENTS FOR MINISTER'S ZONING ORDERS (MZOs)

The proposal removes the legislative requirement for the Minister to provide notice before amending or revoking a Minister's Zoning Order. MZOs are already one of the most powerful and least transparent planning tools available to the provincial government. Their use has expanded dramatically in recent years, often overriding local planning decisions with limited public input.

Removing even the basic notice requirement is not a streamlining measure — it is a further erosion of public accountability. This change should not proceed.

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5. SIMCOE COUNTY UPPER-TIER PLANNING RESPONSIBILITIES

As a Barrie resident, I am directly affected by the proposed phased removal of Simcoe County's upper-tier planning responsibilities. Upper-tier planning exists to ensure that land use decisions reflect regional infrastructure systems, watershed boundaries, agricultural land, and environmental features that cross municipal lines.

Fragmenting these responsibilities across lower-tier municipalities without demonstrated benefit to communities creates real risks: inconsistency in environmental standards, gaps in watershed-level protection, and duplication of planning infrastructure. The province has not made a compelling case for why this change will produce better outcomes for residents of Simcoe County. Meaningful community consultation — not just municipal expressions of interest — should be required before any phased removal proceeds.

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In summary, I am asking the ministry to:

- Restore municipal authority to require mandatory green building and sustainable design standards;
- Retain the legislative requirement for climate change policies in official plans;
- Ensure that water resource protections in official plans are matched by democratic governance of water delivery systems — not corporate arm's-length structures;
- Restore notice requirements for MZO amendments and revocations;
- Pause the removal of Simcoe County's upper-tier planning responsibilities pending genuine public consultation.

Housing affordability and environmental resilience are not competing goals. The provisions in this proposal treat them as if they are — and Ontario residents will pay the price.

Thank you for accepting this comment.

Sincerely,

Marc
Barrie, Ontario
ERO Reference: #026-0300