Letter on Ontario's Bills 5 and 17

June 26, 2025

 

RE: Open Letter on Ontario Bill 5 and Bill 17

The Toronto Society of Architects (TSA) has long played an advocacy role in Toronto and the surrounding region, speaking up on issues as they relate to the built environment and their impact on the life of Ontarians. It is in this role that we feel compelled to share our concerns over the recently passed Bill 5, Protect Ontario by Unleashing our Economy Act, 2005, and Bill 17: Protecting Ontario by Building Faster and Smarter Act, 2005. 

The need to build more, better, and more affordable housing—and the infrastructure to support it—is undeniable. So too is the urgency to do this task as quickly and effectively as possible. Across the province, and particularly in the Greater Toronto region, millions of Ontarians are facing a housing crisis larger than any we have ever seen before, made even more challenging by skyrocketing housing costs that have far outpaced wages.

While we support the premise of faster and more efficient construction, we are deeply concerned with the manner with which the Province has approached these two broad-reaching pieces of legislation and their likely consequences on our built and natural environments. We echo the concerns raised by a number of groups over the environmental, archeological, and heritage impacts of these two bills and question the expedited legislative process used to pass them with minimal input from Ontarians. 

To deal with the housing crisis we face today, we will need to build at a scale never before seen in our province. The sheer number of buildings that need to be constructed, along with associated infrastructure such as mass transit, schools, parks, and hospitals, will not only reshape our region now, but will have consequences far into the future. The government is right in looking for opportunities for efficiency and speed in this transformative moment, but Bill 5 and Bill 17 do so at the expense of good planning and environmental stewardship. The consequence of this could be a building stock that is inefficient to operate, expensive to maintain, and difficult or impossible to upgrade, not to mention irreparable damage to the environment—a heavy burden for future generations of Ontarians and a step backwards in our duty to take care of the land.

There is no question that Ontario’s legislative and policy framework surrounding the design and construction of the built environment has room for improvement. Yet to make a real difference, speed up construction, and avoid unintended consequences, changes need to be agreed upon with the participation of all those involved: design professionals, developers, municipal authorities, and, of course, the provincial government. We need to be working together, not around one another, to find real efficiencies, and legislative changes must provide sufficient time for meaningful input not only from professionals but the wider public and First Nations with whom we have a duty to consult. Not doing so not only leaves millions of Ontarians out of the conversation, but results in legislation that is at times unclear, without an agreed upon execution plan, and open to challenges—all things that will result in an even more confusing policy environment for design professionals and their clients to navigate. Clarity in the rules is key for the speed of construction, and the way Bill 5 and Bill 17 have been passed has resulted in the opposite environment.

At the TSA we remain committed to assisting our members in building a more sustainable, affordable, and enduring built environment—a treasured gift for future generations rather than a liability generated by the burden of an unsustainable asset. While legislative and regulatory standards might change, we will continue to produce educational and professional resources that encourage our members and the industry at large to exceed code minimums and target best practices because we believe that is what Ontarians deserve. We also remain steadfast in our call for more meaningful and robust conversations between government, industry and the public, believing that doing so is the only way to create a shared vision for our built environment–one where thoughtful, purposeful and responsible design can enhance lives and deliver long lasting impact. 

The Greater Toronto Area, and Ontario as a whole, is at an inflection point in our history. How we decide to shape our built environment now, will have ramifications for many generations to come. Let’s make sure we don’t only do this fast, but we do it right.

As always, we make ourselves available to work together for a better Toronto and Ontario.

 

—The 2025 Toronto Society of Architects Executive