I strongly urge you to…

I strongly urge you to include the CSA A460:19 Bird-friendly building design standard as a mandatory part of the Ontario Building Code. This CSA standard is a made-in-Ontario document that would effectively require bird friendly design in all new building construction across the province. It would prevent thousands of bird-building collisions, helping to keep these wonderful creatures alive, preserve biodiversity and the ecosystem services that wild birds provide to Ontario’s economy.

Birds are wonderful creatures. Seeing a dead bird after it has hit a building or window is heartbreaking. But each day during migration season, volunteers in Toronto collect dozens or hundreds of dead birds. FLAP Canada has documented birds from 173 species – including 24 species at risk – colliding with buildings in the Greater Toronto Area alone. And the risk to birds extends throughout the Province of Ontario. They quote a study estimating 25 million birds die of collisions with buildings in Canada annually. Since a large share of Canada’s buildings (including tall ones) is in Ontario, we are responsible for millions of needlessly dead birds.

There are proven, affordable solutions to this problem. FLAP points out that In 2019, the Ontario Ministry of Environment, Conservation and Parks funded the development of the Canadian Standards Association A460:19 Bird-friendly building design standard. This standard was later endorsed by the Ontario Association of Architects. Unfortunately, this standard is currently only voluntary in Ontario.

Implementing this as a uniform, mandatory standard for all new buildings would help to save millions of birds in the province over the next few decades. It would help to stem the dangerous decline in the populations of many bird species. In addition to maintaining biodiversity, it would allow the birds to keep performing critical ecosystem services like insect control, helping farming and forestry. Other bird ecosystem services include helping to maintain people’s and other animals’ physical health (by reducing insect disease vectors), mental health (by helping people to reconnect with nature) and education (by helping to interest children in STEM through watching and studying birds). As a result of all of these benefits, the Building Code improvement would help the Ontario economy by raising productivity and reducing costs.

A uniform, mandatory standard would also help the building industry by increasing certainty, making training easier, and reducing the cost of bird-friendly building materials via greater economies of scale in production.

Please amend the Building Code to incorporate mandatory use of the Bird Collision Mitigation Strategies from CSA A460:19, including the appropriate use of visual markers, specifications for window glazing and glass railings, and building-integrated structures. FLAP states that Implementing bird friendly design in new buildings typically represents a negligible (< 1%) increase in overall construction cost and does not impede development.

Implementing this standard in the Building Code is even more important now, after Bill 23 removed the power of cities to require bird-friendly design for new buildings. Many Ontario cities, including Toronto, had implemented such standards. MPP Stephen Crawford’s office stated in an email to a constituent that Ontario could include Green Standards such as bird-friendly buildings, in revising the Building Code. This must be done as soon as possible.

MPP Crawford’s message suggested that these measures would be optional for municipalities to adopt, despite being in the Building Code. That would increase uncertainty for developers, builders and the public, and leave gaps in bird protection. Birds do not know about municipal boundaries. They migrate all over the province and the Western Hemisphere. We should ensure uniform protection for birds in Ontario, and provide an example for all other jurisdictions, which would save even more millions of birds.

For all of these economic, health and biodiversity reasons, I urge you to add mandatory compliance with CSA A460:19 Bird-friendly building design standard for all new buildings to the Ontario Building Code.

Thank you in advance.