I support the Province’s…

I support the Province’s objective to accelerate housing development and improve consistency and certainty in planning and building standards across Ontario. I am 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 as the result of flooding and poor stormwater management.

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

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 reducing community resilience.
What is also needed is a funding mechanism to incentivize the adoption of enhanced lot level building standards that are improving the long term performance and resilience of buildings and municipal assets beyond the base line standards that are required in the Ontario Building Code. Asset performance and systems resilience are both necessary goals to strive for during the approval of construction. They are far more difficult and expensive to achieve after the building, subdivision or neighbourhood have already been built. In light of the ever increasing environmental pressures that buildings will endure in our lifetime alone, there is a need to build to the highest possible standard, even if not required by the building code.

In addition, the woefully out of date, Provincial Stormwater Design Manual and Guidelines publication needs to be updated to provide municipalities, design professionals and developers with all the modern tools of stormwater control right across the province, not just in the select number of municipalities that have made the effort to improve their own standards beyond those of the 2003 publication date of the design guide. Our health and safety depends on all modern tools being recognized and available for municipalities, designers, and developers to implement.

As the Province advances Bill 98, I encourage clear recognition that stormwater source control and related green infrastructure are essential health and safety measures that should remain available through the planning process. Thank you for the opportunity to provide comments on this important matter.