The following comments are…

The following comments are provided on n the ERO posting of subjects that could not be required to be addressed by municipalities as part of a complete planning application (quotes below around the ERO wording for the proposed changes).

I note that under Ontario’s definition of "Environment" includes human life, namely “a) air, land or water, b) plant and animal life, including human life.”

From the posting description, I believer the proposed changes would reduce the safety, comfort and wellness for human life from the deregulation of wind, shadowing and lighting impacts as follows:

1. “Sun/Shadow: information and material related to the impact of shadows cast by a proposed development on the subject land and on surrounding lands including streets.”
• Shadow impacts are included to allow regulators to assess if the users and residents of properties adjacent to as proposed development will receive adequate sunlight for their enjoyment and health requirements.
• These shadow studies are routinely done by existing consultants with existing software and do not constitute hold up to the development application process.

2. “Wind: information and material related to the potential impacts of a proposed development on wind conditions in surrounding areas.”
• Wind velocities are currently assessed to determine comfort and safety issues for pedestrians at street level. Unfortunately they do not require studies of wind affects on units, balconies or patios on higher building storeys than above ground level. Removal of this regulation requirement would present potentially significant safety and comfort concerns for pedestrians. Rather than remove them they should be revised to include wind effect impacts at higher building elevations than at ground level.
• These wind studies are routinely done by existing consultants with existing software and do not constitute hold up to the development application process.

3. “Urban Design: information and material concerning the urban design of a proposed development, including how a proposed development aligns with municipal urban design guidelines or policies.”
• If there are no requirements for aligning with municipal urban design policies, then how would the quality of the development application and its contribution to the quality of a community and its infrastructure be assessed?
• This proposed change would seem likely to lead to a reduction in the quality of development applications and a reduction in standards that would ensure developments make a positive contribution to complete communities.

4. “Lighting: information and material related to lighting and lighting levels on the site, including the location and type of lighting fixtures proposed on the exterior of the building and on the site.”
• If there are no regulations on the level of light required for a site, then how will the Province ensure that lighting levels are suitable for the comfort and safety of those occupying or visiting a site?
• This portion of the proposed changes seems to go against common sense so there must an error in how it is presented. Further clarification is needed. If the proposal is simply to remove lighting requirements at all then it will likely lead to less than reasonable comfortable lighting levels and increase the potential for criminal activities under the cover of reduced lighting.