RE: Environmental Posting…

RE: Environmental Posting Registry of Ontario posting 019-2566: Bill 222 – Ontario Rebuilding and Recovery Act, 2020

To whom this may concern:

The Ontario General Contractors Association (OGCA) represents over 70% of Ontario's institutional, commercial and industrial (ICI) construction. Together we deliver more than $12 billion of construction each year in Ontario, focusing on supplying the infrastructure needed to support our growing communities.

The OGCA welcomes this opportunity to provide its comments and perspectives on Bill 222 – Ontario Rebuilding and Recovery Act, 2020. When taken together, the proposed legislation will reduce barriers to the planning, design, and construction of major infrastructure projects not just in the GTA but in the entire province.

The majority of our members support legislation that reduces the regulatory burden to the planning, approval and design process in delivering transit and all infrastructure projects. As such, we support the sections of the Bill addressing the coordination of projects to remove delays and steps to remove obstructions efficiently.

Despite this support, we still have concerns related to risk allocation as Bill 222 will provide the Minister of Infrastructure and Minister of Transportation with new development related powers that, when passed along to an organization, will dramatically change how risk is allocated for general contractors and other constructors. As constructors, general contractors must always be aware of and make every effort to mitigate risk. For this reason, general contractors may find it difficult to bid on projects where more risk is allocated to constructors.

OGCA is encouraged at the ongoing commitment to investing in Ontario's infrastructure. However, over regulation is only one issue slowing down the delivery of infrastructure. We propose that the government and delivery organizations, including Infrastructure Ontario and Metrolinx, invest further in design to reduce risk and address delivery challenges. Taking this step will ultimately lead to better project outcomes that are on-budget and on-time. Although this Bill will make the design and construction process faster, a comprehensive and thorough design process is the only way to produce the quality and on-time delivery of transportation projects.

OGCA welcomes this opportunity to provide its perspective and thoughts on Bill 222: Ontario Rebuilding and Recovery Act, 2020. If you have any questions, please contact Erich Schmidt, Government and Stakeholder Relations Associate, at erich@ogca.ca.

Sincerely,

OGCA