To Whom It May Concern, ERO…

To Whom It May Concern,

ERO Submission: Comments on Bill 17, Protect Ontario by Building Faster and Smarter Act, 2025

To: Environmental Registry of Ontario

Re: Bill 17 – Protect Ontario by Building Faster and Smarter Act, 2025

Date: June 11, 2025

Introduction

Thank you for the opportunity to provide comments on Bill 17, the Protect Ontario by Building Faster and Smarter Act, 2025. We recognize the urgent need to address Ontario’s housing crisis but have considerable concerns about the efforts to streamline development and infrastructure delivery.

We offer the following feedback to Bill 17 so it is better in the interest of municipalities, developers, and the public.

1. Development Charges Act Amendments - No Support for Standardization and Transparency

We do not support efforts to standardize and clarify the calculation and application of development charges (DCs). We need to ensure that development charges are covering the costs of development so that more efficient infill development happens rather than unaffordable Greenfield Development and that local taxpayers aren't forced to subsidize new developments with already unaffordable property taxes.

Concerns Regarding Revenue and Infrastructure Delivery

The requirement for municipalities to spend or allocate at least 60% of DC reserve funds annually for all DC services may constrain municipal flexibility and long-term infrastructure planning. We encourage the province to ensure that this requirement does not inadvertently compromise the delivery of critical infrastructure or municipal financial sustainability.

Exemptions and Deferrals
The permanent exemption of DCs for long-term care homes and the ability to defer payment of DCs for residential development until occupancy is absurd. These measures may reduce municipal revenues needed for growth-related infrastructure. We recommend that this be removed from the Bill.

2. Planning Act Amendments

Limiting Complete Application Requirements

We support the intent to streamline planning approvals and reduce unnecessary delays. However, municipalities need to have the ability to require additional information for complete applications for the greater public good.

We caution that overly prescriptive limits on required studies may hinder municipalities’ ability to address unique local planning and environmental considerations.

Ministerial Zoning Orders (MZOs)

The expanded authority for the Minister to impose conditions on MZOs should not be permitted. Already MZO's have been horrific and have cost the government considerable public trust and accountability. We urge the province to ensure that local input and environmental considerations are not bypassed in the pursuit of expedited approvals and that MZO's be eliminated.

3. Building Code Act Amendments

Uniform Construction Standards Are Not Required.

While ideally the province would bring in progressive provincial building codes in alignment with National building codes, municipalities should still mainain the ability to implement their own Green Development and High Performance Building Standards.

We need to ensure municipal innovation in areas such as green building standards. We recommend that the province continue to allow high performance and sustainable construction standards in all jurisdictions.

Streamlining Approval of Innovative Materials
Eliminating the requirement for secondary provincial approval of construction products already approved by the Canadian Construction Materials Centre is a positive step that will accelerate the adoption of innovative building techniques and materials.

4. Transit and Infrastructure Provisions

We support measures to streamline the delivery of transit-oriented communities and major provincial infrastructure projects, including clarifying the roles of the Minister of Infrastructure and Metrolinx. However, it is important that these powers are exercised with transparency, respect for local planning processes, and meaningful engagement with affected communities and Indigenous partners.

Conclusion and Recommendations
Bill 17 is seriously flawed and will only contribute to the current planning chaos crippling our development industries from too many unnecessary provincial government changes. Most municipalities have yet to even update Official Plans from changes ordered in 2022.

To accelerate housing and infrastructure delivery in Ontario. We recommend ongoing consultation with municipalities, Indigenous communities, and stakeholders to refine regulations and implementation details.

Monitoring and mitigating fiscal impacts on municipalities, especially regarding DC exemptions and spending requirements.

Ensuring that streamlining measures do not compromise environmental protection, public engagement, or local planning needs.

Advancing municipal leadership on sustainability and innovation in the built environment.

Our organization has advocated for better, more resilient and efficient buildings for decades.

It's horrifying to see Bill 17 threatening and reducing Green Development Standards and the actions that our municipalities can be undertaking to build better buildings, be more efficient, be more resilient, and ensure our population is better prepared for the future.

We should not be building 1.5 million new homes to yesterday's outdated standards when we know we have to electrify, get off natural gas and other fossil fuels, implement heat pumps and district heating, build stronger, better with more insulation, more airtightness, more energy efficiency and more innovative solutions- just like the rest of the world is.

Toronto's Green Development Standards were implemented 15 years ago because of a lack of provincial leadership and the need to do better. For a decade and half now Toronto has been building better buildings and GHG emissions are falling - unlike many other parts of the province where no actions have been taken and they continue to rise dramatically - dooming our future and planet.

Toronto's Green Development Standards as well as High Performance Building Standards should be the model for the province - not something to be overridden and dismantled.

Please repeal most of Bill 17, synchronize with the National Building Code and allow municipalities to demand the better buildings and communities that Canadians are going to require for the years ahead - while saving money on operating costs with more efficient, healthier and better buildings.

Thank you for considering these comments. We look forward to further engagement as Bill 17 repealed and corrected to be in the best public interest.