To Whom it May Concern: As…

To Whom it May Concern:

As Bill 98 moves forward, our small Ontario business Next Level Stormwater Management:

- stresses the importance of a balanced approach that supports housing delivery while preserving tools that demonstrably reduce long‑term infrastructure costs and financial risk;

- stresses the need for clear recognition that stormwater source control and related green infrastructure are essential health and safety measures that should remain available through the planning process

- encourages the Province to ensure that Bill 98 maintains sufficient municipal authority to responsibly manage growth, protect infrastructure, and deliver complete communities in alignment with provincial housing objectives.

- stresses for the Province to consider the employment implications of Bill 98 alongside housing delivery goals.

Municipalities are responsible for ensuring that new development can be safely serviced, integrated into existing infrastructure, and supported over the long term. A coordinated, province‑wide framework that clearly defines acceptable performance‑based standards would better support housing delivery while preserving municipal accountability. Eliminating established planning tools altogether risks shifting infrastructure challenges to future stages, where issues are more costly and difficult to address.

Our small Ontario business Next Level Stormwater Management supports the Province’s objective to accelerate housing development and improve consistency and certainty in planning and building standards across Ontario. However, we are concerned that aspects of Bill 98, particularly those limiting municipal authority to require sustainable design and performance-based measures through site plan control, may have unintended consequences for public health, flooding and stormwater management.

Ontario municipalities are already experiencing increased rainfall intensity and storm unpredictability. Lot‑level stormwater controls such as vegetated roofs and other source control measures are proven, cost‑effective tools used across the province to manage runoff, reduce peak flows, and protect municipal infrastructure. These measures directly contribute to public safety by reducing localized flooding, mitigating urban heat, limiting damage to public and private property, and avoiding emergency repairs.

While Bill 98 allows for health‑ and safety‑related standards, greater clarity is needed to ensure that stormwater source control continues to fall clearly within this category. Removing municipalities’ ability to require these measures at the development stage shifts risk downstream to municipal systems and existing communities, increasing long‑term costs and vulnerability.

Our small Ontario business Next Level Stormwater Management recognizes the Province’s goal of streamlining approvals and removing barriers to housing development across Ontario. However, limiting the use of site‑level performance measures may increase long‑term costs for municipalities, property owners, and taxpayers. Infrastructure decisions made at the development stage strongly influence lifecycle costs, system capacity, and long‑term municipal financial pressures.

Site‑level measures such as stormwater source controls and green infrastructure reduce peak flows, extend asset life, and delay or avoid the need for costly system upgrades. When these measures cannot be required upfront, municipalities are often forced to address infrastructure limitations reactively, at significantly higher cost.

Ontario municipalities already face substantial infrastructure funding challenges. A policy approach that prioritizes short‑term approval speed over long‑term infrastructure performance risks shifting costs into the future rather than delivering true efficiency.

Thank you for the opportunity for our small business to comment on this important matter.