Comment
This is one of the worst proposals related to housing and urban development that this government has proposed.
I strongly disagree that a regulation that prohibits municipalities' ability to require shadow, wind, urban design and lighting studies has a "neutral" impact on the environment. A community that is built without consideration for wind, light, cultural heritage values and human health and safety is not a sustainable or desirable human environment. Building a healthy and enjoyable human environments should be the objective of MMAH as well as Ontario's municipalities. It should not be seen as a burden/cost imposed on developers.
Consider the ways that these studies support the building of healthy, desirable communities:
Light pollution - excessive lighting can have negative impacts on humans (nuisance; disrupts circadian rhythms), migrating birds (disorienting, causes collisions) and nocturnal species that depend on darkness for hunting, breeding, and other essential life functions.
Sun/shadow and wind studies - urban spaces that do not consider micro-climatic elements like sun, shadows and wind can deter people from spending time in outdoor spaces because the environment is inhospitable. This is unhealthy on many levels: it discourages human interactions, which in turn may lead increased crime and other undesirable activities due to the lack of human activity. Shadows that block passive solar heating increase heating costs and therefore carbon emissions in the winter. Wind studies are also a necessary part of engineering tall buildings for structural/safety reasons as well as for ensuring pedestrian comfort.
Urban Design - urban design is the discipline that takes all of the above factors into consideration, and also looks to ensure a new building contributes to (or at least doesn't have a negative impact on) a community's built heritage and community character. Communities are built for people with social, cultural and environmental requirements that are best addressed through the studies that the government seems to think are unnecessary.
Proceeding with this regulation would be a step back in time and a rejection of good urban planning. Overall I do not believe it will save time or result in more housing. It is removing from the planning process the ability to shape communities that are environmentally safe and desirable for humans and non-humans alike.
Instead of trying to reduce costs for developers by reducing the amount of studies they have to do, the government should focus on standardizing what is required in these types of studies. The quality and livability of communities needs to be upheld through detailed studies.
The government should instead turn its focus to providing surplus land, innovative financing tools, or reviving cooperative housing projects as a means of increasing the affordable housing supply. Relying on market forces (i.e., making development more profitable for developers) is not a sustainable solution for the housing crisis.
Submitted May 14, 2025 3:09 PM
Comment on
Proposed Regulations– Complete Application
ERO number
025-0462
Comment ID
142640
Commenting on behalf of
Comment status