Ministry of Municipal…

Ministry of Municipal Affairs and Housing
Planning and Housing Policy Branch
777 Bay St
Toronto, Ontario
M7A 2J3

13 May 2026

I am writing today with my feedback regarding Environmental Registry of Ontario (ERO) 026-0300, “… on proposed legislative changes to the Planning Act, City of Toronto Act, 2006, Building Code Act, 1992 and Municipal Act, 2001 through Bill 98, the proposed Building Homes and Improving Transportation Infrastructure Act, 2026.”

First of all, I would like to acknowledge the Indigenous Peoples who have lived on this land for millennia. I greatly respect and honour their integrity and contributions to the land, environment, and their culture.

I am a resident of Ottawa Ontario.

I support the feedback to ERO 026-0300 from The Atmospheric Fund (TAF) stating
“TAF is concerned that Bill 98’s proposed removal of municipal authority to set Green
Development Standards (GDS) will have significant and lasting consequences for housing affordability, building performance, municipal infrastructure, and climate outcomes. Restricting municipal discretion disconnects planning decisions from local conditions, infrastructure capacity, and community needs, without delivering material improvements in housing supply or approval timelines.” (1)

We need all “tools in the toolbox” to address the climate emergency. The tools exist now, municipalities are able to – and need continued authority to – advance low-carbon, energy efficient, resilient planning and development. We need all “hands on deck” to progress the efforts to minimize each and every speck of GHG emissions to minimize global temperature increases now – this decade, to enable a livable planet for future generations of life – humans and otherwise.

Green Development Standards are an incredible tool (also known by the City of Ottawa as the High-Performance Development Standard) – “Sustainable and resilient design in new development supports public health and safety, environmental protection and responds to climate change, all of which are priorities within Ottawa’s new Official Plan” . (2)

For new housing, and retrofits, green development is smart, comfortable, healthy – for living now and planning for the future. We need to reduce embodied carbon and operational carbon emissions. "Studies on embodied carbon or “material carbon emissions” (MCE) indicate that the emissions associated with building materials are quite substantial. The total additional annual average of 56.33 million m2 of new low-rise built-in Canada each year, the MCE of Canadian homes would be 14.1 Mt CO2e/year. This is equivalent to the annual emissions from 3.1 million Canadian vehicles, or 3.6 coal-fired power plants. The housing sector does not account for or address these emissions." (3)

Personal example of green retrofits and new build: My partner and I are grateful to have a 1958 single-family home in Ottawa, and a seasonal residence (cottage) in Ontario. For a quick context on our situation:
• Home: Over the past 25 years, we have completed projects to make our home very energy efficient following energy audit guidance: with insulation (2002, 2022); triple-paned windows (2015); electrification including a cold-climate air-source heat pump (2022); a battery electric vehicle (2026); and by year-end 2026 we expect to be net-zero using net-metering with solar power generation and battery storage, and last step to be disconnected from the fossil-gas line.
• Cottage: We contracted the design and build in 2021-2022 of an energy efficient structure, with almost entirely plant-based materials, and fully electric. The reduction in embodied carbon using plant-based materials was very intentional to limit our environmental impact during the material and construction processes; along with the reduction in operational carbon during the remaining lifecycle of our cottage.

Retrofitting and new builds can be completed without Green Development Standards in place. However, due to the urgency of the climate crisis, we need the province to support the municipalities in their climate focused endeavours – including implementing Green Development Standards – in this decade and beyond.

I appreciate the opportunity to submit my feedback regarding Bill 98.
---------------- References ------------
(1) https://taf.ca/custom/uploads/2026/05/ERO-026-0300-TAF-Response.pdf
(2) https://ottawa.ca/en/planning-development-and-construction/residential-…
(3) https://www.buildersforclimateaction.org/uploads/1/5/9/3/15931000/bfca-…