Toronto’s New Green Standards – Environmental Essential or Affordability Aggravator?

In its meeting on July 14th, Toronto City Council (the “City”) adopted (with amendments) item PH25.17: Toronto Green Standard (TGS) Review and Update. This directs staff to apply version 4 of the TGS standards (the “Standards”) to new development applications starting May 1st, 2022. Buildings are responsible for 59 per cent of Toronto’s carbon emissions, and while the Standards have been hailed by City councillors as helping to combat climate change and biodiversity collapse, some in the development industry question whether the Standards are compounding the cost of housing and Toronto’s affordability crisis.

The Standards are based on three tiers of increasingly sustainable performance. All developments, including those through the City’s Housing Now initiative must conform at least to Tier 1 standards. Builders who construct at higher tiers are eligible for an incentive under the City’s Toronto Green Standard Development Charge Refund Program.

Tier 1 standards will soon require all new developments to accommodate electric vehicles in 25% of parking spaces (up from 20% currently). Some large-scale Tier 2 and 3 developments will require 100% electric vehicle parking. Near-zero greenhouse gas emissions will be required by 2030 for all mid-high rise residential and non-residential buildings. Furthermore, new developments will also be required to better capture and control stormwater runoff. This control will occur through better street design, green roof coverage of at least 80%, and landscaping 25% of the lot area with native flowering/pollinator species.

Tier 2 and 3 standards, in addition to the above, will require developers to conduct a materials emissions assessment of the embodied carbon of structural and envelope components. This means carbon, not just from construction but from any previous buildings on site, will require calculation and potential sequestration through onsite green infrastructure provision and landscape design. This might suggest a shift away from concrete building structures in the long term, as such structures are highly carbon intensive.

One thing the Standards do not address is the prevalence of natural gas within the City’s existing housing stock, which accounts for much of the emissions from residential buildings, primarily to heat space and water.

Lastly, Council passed a motion to study potentially enacting by-laws for all multi-residential buildings, irrespective of tenure, to enable its transition towards a “circular economy”. This would include mandating various waste reduction, reuse and diversion programs beyond compost and recycling, and diverting from landfill as much construction and demolition material as possible during construction, redevelopment, and renovations.

Something Old, Something New

To an extent, the Standards adopted by Council are familiar because the themes addressed have been an ongoing discussion in the City, and across the world. The proposed demolition of the Rogers Centre last year left some questioning whether embedded carbon costs could be adequately captured in the development review process. The expansion of green roofs and pollinator gardens goes hand in hand with last week’s Council decision to re-balance stormwater utility rates to encourage more surface permeability. Various other global cities have adopted circular economy strategies, including Amsterdam, LondonParis, Copenhagen, and more, with the ultimate aim of such strategies to produce no waste and pollution, by design. Lastly, the recent tornado in the City of Barrie, has prompted further calls for climate resistant buildings.

Compounding Costs

Toronto’s Building Industry and Land Development Association (“BILD”) has raised concerns that the Standards could increase costs for the development industry, which would ultimately get pushed onto buyers and renters of new housing. Specific concerns raised by BILD include whether the electrical grid has enough capacity to accommodate an influx of new electric vehicles, and the maintenance costs for green roofs and pollinator gardens. BILD also questioned whether a Province-wide green standard would make more sense, to avoid pushing development outside of Toronto and into other areas in the region. Lastly, BILD questioned whether these new Standards, in addition to new Inclusionary Zoning, would make some developments simply unfeasible.

Next Steps

The Standards will come into effect on May 1st, 2022, giving members of development industry just under a year to make relevant changes to their processes and practices. The Standards are reviewed every four years, which means in 2025 the City will have another opportunity to determine whether the Standards should be improved, or whether those coming into force next year represented an overstep to a complex industry.

In the wake of various climate disasters across the globe, and growing calls for more action on climate change, the question will not be whether the industry changes, but when.