Thank you for the…

Thank you for the opportunity to comment on the proposed legislation.

I 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.

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. 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. 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).