I am writing to express…

I am writing to express Clean Air Partnership's deep concerns regarding Bill 17 – Protect Ontario by Building Faster and Smarter Act, 2025. While we support efforts to improve housing affordability and streamline development processes, we are very concerned by provisions in the Bill that could threaten the ability of municipalities to implement and enforce Green Development Standards (GDS) — a critical tool for energy efficiency, local climate action and market capability and resilience planning.

Green development standards are a key policy lever for reducing emissions from new developments, supporting long-term energy efficiency, reducing stranded asset risks, improving public health, reducing future retrofit costs, and ensuring that growth aligns with affordability, sustainability and equity goals. If green standard authorities are taken away from Ontario municipalities then they must be replaced with alignment with the National Model Energy Code and an Ontario Step Code structure should be advanced that ensures that the development market is building capacity to advance lower carbon new buildings.

Concerns with Bill 17 are as follows:

Undermining Municipal Authority: The proposed amendments could limit municipalities’ ability to mandate energy and emissions performance or other sustainability requirements through site plan control. This erodes the tools municipalities rely on to implement council-endorsed climate targets at the local and provincial level. In addition, municipalities should retain the authority to identify the reports they require as part of a complete development application including reports required to secure green standard metric compliance. Municipalities should retain the authority to identify which Plans they will require as part of a complete development application including, but not limited to energy modelling reports.

Green Standards Do Not Delay Planning Approvals: There is no evidence that municipalities with green standards in place are slower on approving development applications than municipalities without green standards in place. In fact, there is some evidence that green standards can streamline the development application process by providing clarity right from the start of the planning application process to proponents on the requirements for a complete application for that municipality.

Climate Commitments Jeopardized: Municipalities are on the front lines of climate change. Bill 17 directly conflicts with provincially mandated obligations under the Planning Act that requires municipalities to include climate change as a consideration in managing growth, transportation planning, energy conservation, resilient communities, and promoting compact, transit supportive development.

Loss of Market Transformation Momentum: Over a dozen municipalities across the GTHA are advancing GDS aligned with emissions reduction pathways. The loss of these coordinated efforts risks disrupting market certainty for developers, limiting innovation and market capability, reversing gains in advancing energy efficient new building stock. Green standards have supported significant increases in energy efficiency and low carbon market capability and has been a critical policy for driving uptake to new and innovative utility business models that address the upfront capital costs burden and advance energy efficiency and beneficial electrification at the most cost effective time to do so - at the time of construction.

Cost-Effective Climate Action: GDS are among the most cost-effective ways for municipalities to reduce future retrofit costs, lower utility costs for residents, reduce stranded asset risks and prevent lock-in of inefficient and high-emissions developments. Removing this progress shifts long-term burdens onto future homeowners, municipalities, and the province.

Clean Air Partnership respectfully urges the Province to:

Not enact any restrictive provisions in Bill 17 that would prevent municipalities from implementing a mandatory green development standard. Municipalities should retain the authority to identify which Plans they will require as part of a complete development application including, but not limited to energy modelling reports.

Work collaboratively with municipalities to develop a harmonized approach that supports local innovation while enabling Ontario to meet its broader energy efficiency, market transformation and climate obligations. If consistency is a provincial goal then it is recommended that the Province align with the National Model Energy Code at a step that increases provincial energy efficiency requirements (which have not been increased via the Ontario Building Code since 2017) and adopt a tiered structure that enables municipalities to work with their development community to build market capacity to meet the higher tiers and thereby build market capability, thereby enabling the market to prepare for upcoming tiers.

Recognize that enabling municipalities to act on climate is not an obstacle to building faster — it is essential to building smarter and more sustainably.

Thank you for considering our concerns.