Removing Barriers for…

Removing Barriers for Additional Residential Units

1. Length of Permit Review: Unlike single detached dwellings, which are to be reviewed within 10 days of submission, ARU permits are allotted 15 days for review. We suggest that permit review period for the ARU be reduced to 10 days.

Permit submission for an ARU must be quick and simple. We would suggest an easy-to-follow checklist.
2. Glazing Requirements: Ambiguous language within the OBC regarding the determination of “living space” has resulted in unnecessarily large, aesthetic glazing requirements. This adds unnecessary cost to the construction of ARU’s and can impact the structural stability of foundation walls.

3. Determination of ARU’s under the OBC: In feedback from our builders, they have experienced three different scenarios which influence the standards of the OBC that are applied. Clarity is needed to remove these inconsistencies.
a. New construction primary dwelling and concurrent new construct ARU – treated one way when the permit for the primary dwelling has not been “signed-off”. The current “solution” is to submit the ARU permit as a “finished basement” and convert prior to sign-off. This is complicated, and has unnecessary implications.
b. Completed new construction primary dwelling with a “closed” permit – ARU can be submitted as normal under the current OBC
i. 2025 Changes to the OBC (effective January 1, 2025) will require a separate HVAC system for the secondary suite. The associated cost of the additional system is +/- $6,000. It also has space/layout implications/costs for the units – as space is required to locate the secondary HVAC system.
c. If the primary dwelling is 5 years or older – flexibility is provided under Part 11 of the OBC. This flexibility is relatively pointless, as the code has not substantially changed in the last 5 years.

4. Tarion Requirements: we have recently learned that detached/backyard ARU’s (majority of which are modular) will require Tarion licensing. The cost and time implications of this are substantial, as Tarion licensing has a variety of associated administrative requirements including security which is held for years.

5. Concerns with the LTB – wait times associated with the Landlord Tenant Board (LTB) can deter the development of ARU’s. The Province should consider a streamlined process specifically to address issues associated with ARU’s.

The London Home Builders’ Association respectfully submits the above comments and suggestions regarding Bill 185 and reducing barriers to build more additional residential units. We encourage the Minister of Municipal Affairs and Housing to take them into consideration as the government deliberates any changes that may be needed prior to royal assent.

Thank you,

Jared Zaifman

CEO – London Home Builders’ Association