On behalf of the London Home…

On behalf of the London Home Builders' Association I wanted to provide comments supporting the suggested delay for the implementation of the Phase 2 requirements, the planning and reporting documents, and the tracking requirements detailed 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.

While we support the requirement to engage qualified persons to assist in development plans to assess and characterize soil conditions, the Regulation has 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 delays and undue burden to project costs, which, in the case of residential construction projects ultimately gets passed along to homeowners and taxpayers. This is counter to the government’s direction for making housing and the cost of living more affordable, and bringing housing to the marketplace in a more timely manner.

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, hinders this process, instead of improving it.