This is an addendum to my…

This is an addendum to my previous comment, but again, I'm in the construction industry, have been for 20 years, and instead of focusing on this act, which is not going to be particularly helpful, and also result in massive private sector job loss, the focus should be on:

1. Stop the constant creep of the OBC. Engineers have been allowed to just run wild with it, trying to eliminate every single potential hazard, and life just does not work that way. This needs to stop and be dialed back where appropriate. As one recent example, they're now thinking of mandating extra tornado reinforcement on all homes, just because of what happened in Barrie. Ridiculous. This kind of standards/code creep is constant. It needs to stop. What we have now, is adequate, and also there are areas of overkill.

2. Stop the ever-expanding requirements for infrastructure that utilities set forth. Eg. Ever more elaborate manhole standards being requested - massive underground chambers built in stainless steel, and if I recall correctly - air conditioned - just absolutely ridiculous. Nothing was wrong with our old standards. This kind of thing is significantly more expensive than an environmental impact assessment and mitigation plan.

3. Stop the massive road width requirements, setbacks, sight triangles, which cause not only additional capital cost to developers, but also increased maintenance costs and an increase in our property taxes down the road. They also remove valuable land from being able to be developed and sold. We do not need intersections that look like an asphalt desert, with 10-25m setbacks on either side. Who thought that was a good idea? This is killing us. Go back to the old standards we had 80-100 years ago. Those are the most valuable neighbourhoods for a reason, and trucks and emergency services still get around those just fine. Fire and ambulance departments have been erroneously allowed to dictate way too much of how things get built, in the interest of "safety". This is wrong, old neighbourhoods with narrower roads are still functional. This standards creep has only eaten up valuable land and contributes to developer costs both in terms of capital and lost opportunity cost. It has to stop. It is so easy to do, and it results in zero job loss.

4. Avoid creating a situation that will have development mired in constitutional court challenges, as we have seen with pipelines. This is significantly more expensive and uncertain than the long-standing endangered species act where the process is clear.

5. Basically, it is infinitely easier, protects jobs, and clearer for everyone, to provincially mandate that new development will only need to follow the more cost efficient, tried and true infrastructure standards and codes that have worked for over half a century. No more standards and code creep. This is both for underground and surface level utilities including roads and setbacks. We already have these designs, we know they function, it's such an easy change that has positive impacts.

In summary, please do not go forward with these proposed changes to this particular act. The impacts are going to be very harmful to our economy. There are many areas that should be targeted instead, that will make development of housing and resource extraction easier, more profitable, and that would also have significantly less negative impact, both in terms of jobs and endangered species. The proposed changes are not at all going to be helpful, they are going to cause more uncertainty in terms of court challenges, more uncertainty in terms of requirements, which we see now with the excess soil amendments - everyone is confused and it has only added more red tape and more cost, utterly needlessly. No idea why these soil standards were allowed to come into effect under the PC purview anyway, and no idea why there are now confusing amendments being issued instead of just a targeted elimination of the new requirements. Now you want to create more confusion in another regulation. It's not helpful at all.

Target the right things. Please listen to the entire industry. Not just the CEOs of industry and developers. They are often removed from the nitty gritty of the actual issues. It's not only "environmentalists" who are concerned here. Many intelligent Ontarians, involved in development and related industries, are very concerned with this being the focus. There are other areas that should immediately be targeted instead, and will have an immediate positive impact without affecting any jobs, without creating any uncertainty or more red tape. Clear up the confusion with the excess soil regulation amendments, my god is it a mess, and for no good reason. Just go back to what it was before. Huge impact.

Finally, work in tandem with the Feds to establish development corridors - but there is no way to get around consulting with indigenous stakeholders. That's where the court challenges will come in and create chaos. That needs to be dealt with from the outset in order to have risk to investment mitigated.

There needs to be some rationality and consensus to the way things operate in the province, between industry, development, and environment. Nothing is separate, we are all in this together. Development depends on the environment. We have values and goals that are equally worthy and which can be worked out without a confusing and drastic proposal such as this. We seem to be ping-ponging between extremes here, and it is so unhelpful. There are so many straight forward easy actions this government could be doing to make development easier and more profitable and less costly for Ontarians. The focus has been placed on the wrong piece of legislation.

I'm tired of the red tape, but this is not at all the way to eliminate it. Please consult with the wider job sectors involved in this. It's far from a group of environmentalists.