Many many members of the…

Many many members of the public urge you to include provisions that would reduce bird collisions with buildings, based on the Canadian Standards Association A460:19 Bird-friendly building design standard. By mandating bird-friendly building construction measures in the Building Code, Ontario could significantly reduce the vast number of birds that die needlessly each year. There are people who have to go around the GTA and pick up the bodies of dead birds, if we continue to build at the rate we do and do not compensate for the destruction we cause our road will be littered with the dead bodies of birds just trying to migrate. Who is going to want to live in a city where they have to step around the rotting bodies of birds, trying to walk dogs in a graveyard of bodies, having to hire more staff to keep the street clean when it is 100% preventable.

It is estimated that every year, about 25 million birds are killed by colliding with windows in Canada.1 FLAP Canada has documented birds from 173 species – including 24 species at risk – colliding with buildings in the Greater Toronto Area alone, yet the risk to birds extends throughout the Province of Ontario. FLAP keeps every single body they find and create an exhibit to showcase how much death these windows cause. The issue is impossible to ignore I strongly urge you to look into all of the past years of FLAPs annual bird collision layouts, that FLAP puts on annually to put this issue into perspective. I think its important visual that needs to go hand in hand with this decision. You need to be able to look at that photo and understand that you are only going to double the amount of death and contribute to the reduction of biodiversity with one simple decision.

There are proven, affordable solutions to this problem. In 2019, the Ministry of Environment, Conservation and Parks funded the development of the Canadian Standards Association A460:19 Bird-friendly building design standard, which was later endorsed by the Ontario Association of Architects.2 However, the standard remains voluntary in Ontario.

The Building Code should be revised to incorporate 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. Implementing bird friendly design in new buildings typically represents a negligible (< 1%) increase in overall construction cost and does not impede development. By mandating bird-friendly building construction measures, Ontario could significantly reduce this leading source of bird mortality. In so doing, it could make meaningful progress on its stated goal of protecting species and supporting conservation efforts to preserve Ontario’s rich biodiversity (Made-in-Ontario Environment Plan).

The Ontario government is proposing changes to the City of Toronto Act and Planning Act through Bill 23 “More Homes Built Faster Act” 2022 that would remove the authority of municipal governments to enforce green building standards. This will result in the discontinuation of bird friendly building design guidelines that have been adopted and enforced through site plan control by numerous municipalities across Ontario, including: Ajax, Aurora, Brampton, Burlington, East Gwillimbury, Fort Erie, Guelph, King, London, Markham, Mississauga, Newmarket, Ottawa, Pickering, Richmond Hill, Toronto, Vaughan and others. The latest update to Ontario’s Building Code should include a harmonized approach to bird friendly building design under the A460:19 standard.

We trust that you will seriously consider the benefits of incorporating strategies from the CSA A460:19 standard into the next edition of Ontario’s Building Code.