Ministry of Housing and…

Ministry of Housing and Municipal Affairs
PlanningConsultation@ontario.ca

Comments re the Proposed Planning Act, City of Toronto Act, 2006, Building Code Act, 1992 and Municipal Act, 2001 Changes (Schedules 1, 2 and 7 of Bill 98, the Building Homes and Improving Transportation Infrastructure Act, 2026)
ERO number 026-0300

May 14, 2026

Thank you for the opportunity to comment on the proposed changes to the Proposed Planning Act, City of Toronto Act, 2006, Building Code Act, 1992 and Municipal Act, 2001

My comments relate to the proposal to “Prohibit Mandatory Municipal Enhanced Development Standards and Green Building Standards”.

The government of Ontario is proposing these changes as it believes they will reduce costs for housing development and better address the housing needs of the province.

At the same time the government of Ontario is also planning for decarbonizing energy supply as is evidenced by a number of government reports such as:
• Energy for Generations. The first chapter of this report is “Energy Efficiency” and describes how the government is supporting efficiency for homes and businesses.
• Ontario’s Clean Energy Opportunity: Report of the Electrification and Energy Transition Panel supports the development of innovative solutions and strengthening local and community strategies.
• Cost Effective Energy Pathways Study for Ontario. The consultants ESMIA and Dunsky outline electrification and retrofits of the building sector as key pathways to decarbonization.
These and many other reports describe some of the numerous strategies that can be implemented to achieve the green transition and decarbonization.

If the government restricts municipalities from adopting green development standards it would put up barriers to one of the best ways for municipalities to contribute the Ontario’s decarbonization goals.

One might imagine that the province would applaud municipalities that adopt green development standards as it assists the government. The municipalities that have chosen green development standards are undertaking the administrative efforts involved in improving the energy efficiency of new construction and development. There will be long-term savings on operating costs and reductions in carbon emissions. Building with more energy efficiency in mind at the time of construction is far superior to making costly retrofits in the future which may require government rebates or other incentives. There may be better use of community infrastructure. Green development standards also support businesses that are aligned with the efficiency and innovation goals of the government.
Other provinces are generally much more supportive of municipalities taking similar initiatives and modernizing their future building stock. They do not try to restrict municipalities from taking the steps that local councils view as beneficial for the future of their communities.

The government is rightly concerned about the need to address housing shortages quickly. Upfront building costs have increased for many reasons. While it may seem like preventing municipalities from adopting green building standards is a good strategy, it would likely only have a limited and short-term impact on building costs. As mentioned above implementing green development standards reduces costs in the longer term. The adoption of green development standards may even facilitate, rather than hinder, new housing developments. These important advantages suggest that the adoption of green development standards should be welcomed by the government.

Many organizations have outlined various other strategies for addressing the increased costs of building and to ensure housing needs are addressed.

It is to the provincial government’s advantage to permit municipalities to adopt green development standards. I strongly support allowing municipalities the option of doing so.