Good morning; We support the…

Good morning;

We support the suggested delay for the implementation of the Phase 2 requirements, those namely being the planning and reporting documents, and the tracking requirements which are spelled out in the Regulation. Further we would encourage the Ministry to use the time that the implementation delay provides, to undertake further consultation with industry stakeholders, who are directly impacted by the implementation of the Regulation. As a General Contractor, while we support the requirement to engage qualified persons (QP's) to assist in development plans to assess and characterize soil conditions, we find that the Regulation is heavy-handed in its approach. Outlining rigid reporting requirements, sampling and testing frequencies and prescribed minimum test parameters which have limited regard for the actual site conditions or site history. These can also lead to significant costs and affect construction schedules, adding undue burden to project costs, which, in the case of residential construction projects and infrastructure construction projects, ultimately gets passed along to homeowners and taxpayers.

This seems contraindicative to the government’s current direction for making housing and the cost of living more affordable, and addressing the largest housing shortage among G8 countries. Based on the News Release issued by the Provincial Government made on March 30, 2022, it is understood that the Province commits to a housing supply action plan every year over four years, starting in 2022-23, with policies and tools that support implementing the recommendations from the housing affordability Task Force’s report. The Excess Soils Regulation in its current form would hinder rather than assist this process; thereby increasing pressure on an already strained system.