Decisions at all levels of government can have lasting impacts on our communities. We advocate for better policies and funding mechanisms to help Ontario build healthy, resilient communities.

Since 2009, the GIO coalition and its members have been successfully promoting green infrastructure across Ontario. A great deal of policy progress has been made in that time period — but there is still much to do!

VOLUNTARY CARBON OFFSET PROGRAM (draft): MOECC is developing a voluntary carbon offsets program (separate from the cap and trade program) with the aim to provide a quality, branded class of offsets that the Ontario government, the private sector and others can use to reduce both their carbon and ecological footprints. The November 2017 discussion paper emphasized potential offsetting projects that could provide co-benefits, including green infrastructure projects that would align with other sustainable development goals.

MODERNIZING ONTARIO’S MUNICIPAL LEGISLATION ACT: The MMA updated Ontario’s Municipal Act and the City of Toronto Act to give municipalities more responsibility and power to grow and protect green infrastructure. Updates included: requiring that municipalities have policy pertaining to protection and enhancement of their tree canopy and natural vegetation; allowing municipalities to pass green roof by-laws; and empowering municipalities to act in the economic, social and environmental well-being of the municipality, including respecting climate change.

Thank you for the opportunity to provide feedback on the Low Impact Development (LID) Stormwater Management
Guidance Manual. The Green Infrastructure Ontario Coalition (GIO) applauds the efforts of the Ontario Government to
take feedback from different stakeholders into consideration in the development of this document.
GIO is an alliance of organizations that share a common vision for a healthy, green Ontario where the economic, social,
environmental, and health benefits of green infrastructure are fully realized. We see low impact development as a key
green infrastructure solution, and as crucial to a resilient, low-carbon future (for more details about our definition of
green infrastructure, see Appendix A). As such, we are pleased to provide the following feedback to ensure that the LID
Stormwater Guidance Manual is as useful a resource as possible.
Green infrastructure/LID principles
GIO heartily endorses the underlying principles in this guidance document, including the stated objectives, benefits,
and co-benefits, and the need for green infrastructure/LID to play a leading role in the context of rapid urbanization
and climate change. Helpfully, green infrastructure is used as an inclusive term that includes natural features and
vegetation as well as “human made or engineered” features, including low impact development technologies.1 Benefits
of green infrastructure/LID include flood and erosion control, improved water quality, enhanced groundwater
recharge, maintenance of stream baseflows, reduced thermal pollution, and cost savings from avoided damage and
conventional end of pipe solutions.2 The guidance manual does not create a new requirement, but rather provides
information and advice on how to achieve volume reductions, reduced peaking, filtration, and other goals of longestablished provincial policy. (For more on GIO’s support for the principles of ecological stormwater management, see
our EBR submission, July 14, 2017). We thank the Ministry staff, consultants, and reviewers who have devoted
countless hours to the development of a large, detailed, thorough, and complex document over a period of more than
half a decade. Thank you.

Chapter overviews are needed
Succinct summaries (about a half page or more vs. the one paragraph introductory paragraphs now provided) are
needed at the beginning of each chapter, again carefully crafted for all audiences (incorporating the language found in
the recommended summary). In particular, the chapter on the “Environmental Planning Process” in Ontario as
currently written is a complex review of all the myriad acts, policies, and agencies that come into play. Readers would
be helped by a structured chapter introduction that shows how the parts work together.
Further, an edit of the entire document by a seasoned professional would make it more accessible and digestible by all
readers, clearer, and possibly more succinct. To the extent possible, technical details and concepts should be explained
for non-technical readers. Sections that are intended only for “practitioners” should be identified as such.
RECOMMENDATION: GIO recommends the addition of expanded summaries at the beginning of each chapter, and
consideration of a full document edit.
Support is needed for implementation
The manual is not a cookbook with a prescribed recipe for integrating green infrastructure/LID into stormwater
management; instead, it outlines the goals, a hierarchy of strategies, options, advice, and resources for achieving the
desired outcomes. This approach provides flexibility. It will also require considerable resources, skill, and judgement to
implement. A steep learning curve and culture change will often be required to transition from conventional
conveyance measures to LID/green infrastructure.
RECOMMENDATION: GIO recommends that an appropriate partnership host a community of practice for practitioners
responsible for implementing this guidance. We support a strong or leading role for the Conservation Authorities in a
community of practice.
RECOMMENDATION: GIO recommends that support be provided for public outreach and education to be conducted by
an organization such as Green Infrastructure Ontario and its membership.

Continuous evaluation and improvement needed
Chapter 3 of the guidance manual powerfully articulates the rationale for a target to capture and treat runoff up to the
90th percentile of precipitation events in order to prevent aquatic habitat degradation and other damaging impacts of