ORBA Submission on ERO 025…

Numéro du REO

025-1071

Identifiant (ID) du commentaire

173133

Commentaire fait au nom

Ontario Road Builders Association

Statut du commentaire

Commentaire approuvé More about comment statuses

Commentaire

ORBA Submission on ERO 025-1140: Bill 60 – Fighting Delays, Building Faster Act, 2025 – Supporting the Harmonization of Municipal Road Construction Standards
Date: November 18, 2025
Submitted to:
Ministry of Transportation (MTO) – Transportation Policy Branch & Standards and Contract Branch
ERO Number: 025-1140
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Introduction
The Ontario Road Builders Association (ORBA) welcomes the opportunity to comment on the proposed legislative amendments under the Fighting Delays, Building Faster Act, 2025, which will support the harmonization of municipal road construction standards across Ontario.
As the voice of the province’s road-building industry—representing contractors, suppliers, engineering partners, and firms responsible for delivering the majority of Ontario’s transportation infrastructure—ORBA strongly supports the government’s direction.
Harmonizing municipal road construction standards is not simply a technical exercise; it is a foundational economic competitiveness initiative that will:
• Reduce construction costs;
• Accelerate project delivery;
• Improve quality, safety, and lifecycle performance;
• And support job creation across Ontario’s construction and materials sectors.

ORBA commends the Ministry for its leadership, its extensive consultations with stakeholders, and its commitment to modernizing how Ontario builds infrastructure.
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Summary of ORBA’s Position
ORBA strongly supports legislative amendments that:
1. Enable the Minister to set mandatory, province-wide road construction standards;
2. Establish a structured governance framework rooted in evidence-based decision-making;
3. Allow exemptions only through a transparent, data-driven process;
4. And modernize municipal procurement and contracting practices.

These changes are essential to reducing fragmentation, eliminating duplicative standards across 444 municipalities, and ensuring Ontario builds to one consistent, high-quality standard.
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1. Mandate Province-Wide Adoption of OPSS.MUNI
Ontario’s current system—where hundreds of local municipal standards coexist—results in:
• Inefficiencies;
• Higher project costs;
• Increased risk for contractors;
• Barriers to competitive tendering;
• And inconsistent outcomes for the traveling public.
ORBA supports the Ministry’s intent to move to mandatory, province-wide adoption of OPSS.MUNI. A clear transition path, communicated well in advance, will allow both municipalities and industry to prepare budgets, align procurement documents, train staff, and plan capital projects accordingly.
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2. Protect Projects Already in Design, Procurement, or Construction
To maintain certainty and prevent disruption, ORBA recommends that:
Projects already tendered, awarded, under construction, or in advanced design stages should continue under the specifications and contract documents used when they were initiated.
This approach avoids:
• Costly redesigns;
• Delays;
• Disputes between owners and contractors;
• And unnecessary burden on municipalities with commitments already in place.
Grandfathering provisions are a best practice in standards implementation and will support a stable transition.
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3. Prioritize High-Impact Areas First (Asphalt, Aggregates, General Conditions)
Certain areas create the highest variability, risk, and cost in municipal road construction—particularly:
1. Asphalt mix specifications
2. Aggregate standards
3. General conditions of contract

Early alignment in these areas will deliver the most immediate and measurable benefits.
Independent analysis, including work by CANCEA, shows that harmonizing asphalt standards within the Greater Toronto Area alone could unlock nearly $1 billion in value over 10 years, and more than $11 billion province-wide.
These components also represent the areas where municipalities have introduced the most divergent requirements, creating significant inefficiencies for contractors working across jurisdictions.
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4. Undertake a Comprehensive Review of OPSS.MUNI
A full technical review of OPSS.MUNI should occur before mandatory implementation to ensure that:
• Specifications are current;
• Outdated sections are refreshed;
• Gaps or inconsistencies are addressed;
• Climate resiliency and sustainability practices are incorporated;
• And quality assurance frameworks are strengthened.
• This process instills confidence and reduces the risk of implementation challenges.
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5. Develop Standardized Contract Templates to Support OPSS.MUNI
To fully realize the benefits of harmonized technical standards, ORBA strongly recommends the development of a suite of standardized municipal contract documents, including:
• Tender templates
• General and supplementary conditions
• Instructions to bidders
• Change management templates
• Payment and reporting forms
• Inspection and test reporting templates
Jurisdictions like British Columbia (through the Master Municipal Construction Documents) demonstrate how standardized documents reduce administrative burden, improve consistency, and support transparent procurement.
Ontario can achieve similar benefits through coordinated development of supporting contract documents with municipalities, industry, and engineering partners.
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Governance Framework Recommendations
To ensure the long-term integrity and success of OPSS.MUNI, ORBA recommends the following governance measures:
A. Strengthen the OPS Advisory Governance Model
The OPS Advisory Committee should be the central authority for approval of changes, supported by specialty technical committees that include representation from:
1. MTO
2. Municipalities (large, medium, small)
3. ORBA
4. Engineering consultants
5. Testing & QA professionals
B. Establish a Predictable Review Cycle
A recurring review schedule (e.g., every 3–5 years) will maintain transparency, stability, and responsiveness to emerging challenges.
D. Implement a Formal, Evidence-Based Exemption Process
Municipalities seeking local variations must demonstrate:
• Clear engineering justification;
• Lifecycle analysis;
• And alignment with OPS governance.
• This ensures innovation is captured, evaluated, and potentially scaled province-wide.
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Why Harmonization Matters
Lower Costs
Consistent standards reduce unnecessary contractor risk, material variability, and administrative overhead—leading to more competitive bids and better value for taxpayers.
Faster Project Delivery
Common specifications eliminate repetitive review processes and reduce time spent reconciling technical differences across municipalities.
Higher Quality and Safety
Uniform technical requirements improve consistency, reduce premature failures, and enhance public safety.
Environmental Benefits
OPSS.MUNI supports the adoption of:
• Recycled aggregates
• Lower-carbon asphalt technologies
• More efficient material use
• Reduced waste across the supply chain
• Economic Competitiveness & Job Creation
A harmonized system strengthens Ontario’s competitive position, enables the road-building industry to scale effectively, and supports thousands of skilled trades and engineering jobs province-wide.
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Conclusion
ORBA supports the government’s commitment to mandatory, harmonized municipal road construction standards and commends the Ministry for its leadership on this file.
Harmonization will reduce red tape, strengthen Ontario’s economic competitiveness, improve the quality and sustainability of municipal infrastructure, and enhance the value delivered to taxpayers.
ORBA and its members stand ready to work with the Ministry as it advances regulatory development, implementation planning, and governance modernization.
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Submitted by:
Ontario Road Builders Association (ORBA)
Steven Crombie
Senior Director, Public Affairs
steven@orba.org