Comment
If the change to the Building Code is intended to mean municipalities cannot adopt Green Development Standards (GDSs) or other similar standards that have the effect of implementing construction requirements beyond those of the Building Code, this must be made clear to municipalities and reflected through the implementation of municipal complete application requirements. If this is the intent, the requirements for a complete application must clearly exclude the need to submit any GDS or related document / report(s) being required as part of a complete application (similar to the wind study, design guidelines and lighting plan exclusions). This can include many documents identified in municipal OPs such as: Mandatory target documents, Embodied Carbon Reports, performance metrics, community energy plans, sustainability guidelines, etc. See example at link provided of a current municipal GDS initiative and the additional information that would be required in support of an application. Similar (but inconsistent & vary in each municipality) complete application requirements can be found in all municipal official plans where GDS and other similar guidelines have been adopted.
Bill 17 must be clear on complete application requirements as it relates to permitting municipalities to implement any requirements beyond the Building Code and accordingly, what documents/reports can be requested as part of a complete application. There cannot be any ambiguity or interpretation on this matter.
Supporting links
Submitted May 21, 2025 12:46 PM
Comment on
Proposed Regulations– Complete Application
ERO number
025-0462
Comment ID
149328
Commenting on behalf of
Comment status