To whom it may concern,…

To whom it may concern,

Thank you for the opportunity to comment on this proposal.

As I understand it, the purpose of the proposed regulations is to set standards for what is and isn’t allowed to be considered as part of a planning application. Shadow studies, wind studies, urban design, and lighting are specifically proposed to be exempt from a complete planning application.

I do not support the elimination of shadow studies from planning applications. While I admit that shadow studies sometimes put too much emphasis on maintaining sunlight versus building new housing, I also believe that it is important information to have when considering a development proposal. Access to sunlight is an important part of thermal comfort in the public realm, especially during the winter months.

I am also opposed to the elimination of wind studies from planning applications. Even more so than shadow, wind conditions at grade are a crucial part of maintaining a livable public realm. I invite the housing minister to walk around Toronto’s financial district on a windy day; I think he will find that the drafts coming down from the tall office buildings make it difficult even for able-bodied individuals to stand in one place. Managing wind is not just an arbitrary personal preference; it is a matter of public safety and universal accessibility.

Furthermore, I do not support the elimination of urban design from planning applications. The urban design process helps ensure that our cities have a high-quality public realm for decades into the future. This includes aesthetic considerations such as hiding servicing and loading areas away from the public realm, but also functional considerations such as microclimate and the pedestrian realm. I would like to add that policy 2.9.1(e) of the Provincial Planning Statement (2024) states that “Planning authorities shall… take into consideration any additional approaches that help reduce greenhouse gas emissions and build community resilience to the impacts of a changing climate.” Removing the ability of municipalities to review a project’s urban design characteristics will compromise our ability to adapt to the impacts of a changing climate.

To close out, I would like to say that I would very much like to see more housing built. I am a young person who wishes very much to be able to afford living in the city I grew up in. However, building housing cannot come at any cost. The homes we build today will remain standing for decades to come. It falls upon us to get it right before we build, or risk falling from a housing crisis into a climate crisis of our own making. If this government wants a serious plan to build homes, it should look towards the Green Party’s housing platform: upzoning to four storeys as-of-right and 6-11 storeys on transit corridors; building non-profit homes; Building Code reform; eliminating all parking requirements; and DC waivers targeted at homes within existing urban boundaries [1]. It could also look to its own Housing Affordability Task Force [2], whose recommendations (broad upzoning, DC waivers specifically for infill, Building Code reform, elimination of all parking minimums) have sat largely untouched for over 3 years. In summary, solutions already exist. This government would do well to adopt the experts’ advice, rather than fiddle at the margins with largely ineffectual policies that will harm the public interest.

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[1] https://files.ontariogreens.ca/platform/gpo-platform-en.pdf
[2] https://files.ontario.ca/mmah-housing-affordability-task-force-report-e…