Comment to the Environmental…

Comment to the Environmental Registry of Ontario on Bill 17
I am a resident of the City of Toronto and have for some time been active in efforts to encourage home retrofits to achieve greater energy efficiency, reduced carbon pollution and greater resilience to extreme weather. As the 2022 Neighbourhood Climate Action Champion for Ward 11, I began the Home Retrofit Forum. Subsequently, I joined the Toronto Home Energy Network, and am now Chair of its Communities Working Group. I feel strongly that Bill 17, as it is now written, runs counter to the work I have been doing and that it will be detrimental to the health, safety and financial interests of the people of Toronto.
Bill 17 proposes to streamline and accelerate housing development, make housing more affordable, and advance transit-oriented communities. While these are admirable goals, I strongly object to the route the province is taking to achieve them. With Bill 17, the Provincial Government makes clear its position that any controls over development are bad and that they should be removed. It strips municipalities of their authority to safeguard urban design elements like flood protection, air quality, and energy efficiency, and eliminates critical checks and balances by mandating automatic approval of development submissions from prescribed professionals.
Perhaps most critically for Toronto, Bill 17 threatens to prevent the City from enacting and enforcing its Green Standard which aims to reduce carbon pollution, make buildings more energy efficient to reduce stress on our grid, consider stormwater retention to reduce flood risk during heavy rainfall, provide minimum tree canopy coverage to combat extreme heat, and provide bicycle parking and pedestrian walkways to encourage active transportation and healthy lifestyles. The climate and energy efficiency provisions in Ontario’s Building Code have not been updated since 2017, which makes local rules even more critical.
It has been estimated that 80% of buildings that will exist in 2050 have already been built. Retrofitting them all is a massive but essential undertaking. The last thing we need is for new buildings to add to the scope of the problem. Building energy inefficient homes reliant on fossil fuels will create huge costs down the road as retrofitting buildings to get off gas or enable electric vehicle charging is many times more expensive than building them right in the first place. Green buildings are more affordable to operate, healthier to live in, and more protected from extreme weather events like flooding and heat. Eliminating or even loosening local green building standards will make tenants and homeowners worse off and may lead to the need for expensive repairs in the future.
This is no evidence that Toronto’s stronger building requirements have discouraged development in the city. Toronto has managed to exceed its provincial housing targets with green building standards already in place since 2010 and has had more development in recent years than any other city in North America. While green standards add minimal upfront costs, they enhance long-term affordability and reduce municipal infrastructure expenses. Without them, future homeowners will certainly face higher utility costs, and city budgets will be further strained.
For all the reasons enumerated above, I respectfully request that Bill 17 be significantly revised to remove its ability to override municipal controls over development within their jurisdictions without taking away from the Bill’s worthy intention of streamlining, accelerating and reducing the cost of the housing approval processes.