Kelly Denty

Halifax Regional Municipality P.O. Box 1749,

Halifax, N.S. B3J 3A5

March 30, 2021

Via email: dentyk@halifax.ca

Re: Proposed Amendments to the HRM Noise Bylaw (N-200)

Dear Kelly,

The undersigned write to express our concerns with current discussions within HRM around the Noise Bylaw. Staff has been tasked to do yet another report. This issue has arisen every few years over the past several, During the past discussions it has been resolved with the status quo being upheld. That is exactly where Industry, as represented by the signees below, would like it to stay. As has been confirmed by staff in past iterations as well as current efforts our standards in HRM are completely in line with other Canadian jurisdictions, i.e. the status quo we are asking for is the norm not an exception. Everyone seems to want to promote growth within HRM, but do not want to acknowledge that growth requires some noise to occur,

Our primary concern is around possible reduction in working hours allowed. As you are wellaware, we have a very short construction season and any reduction in working hours will be very detrimental. For example, road building activities will increase the cost to HRM by en estimated minimum 10% for every hour of reduction. This same percentage applies as well to rock breaking which is also part of this review. HRM taxpayers will get less work completed per year and pay noticeably more for it. Another very serious outcome of reduced hours is how it will exacerbate HRM citizen complaints, not reduce them There will still be noise and inconveniences around issues such as traffic delays, but now they will last longer as it will take longer to complete the projects. Reducing hours is a lose/lose for HRM citizens.

We are all working to provide high-quality, affordable housing, development and projects for all. The implementation of any by-law, which would reduce the number of working hours, and extend the timeline for a project, will increase cost for no added benefit.

We have asked numerous times for data as to how big a problem this really is and have not been provided with any concrete results. Is this many complaints or very few? Our understanding is the latter has been the norm.

On the plus side we understand there are discussions around improving the exemption process. An example we often mention is concrete pours which by their nature must continue until completed, regardless of whether they go over allowed working hours. These should be handled by staff, not council, and in a very time sensitive manner. This would do away with unnecessary interaction with HRP, By-Law staff, etc.

As always, we are available individually or as a group, to answer any questions you may have, or to address any concerns.

We look forward to your consideration of the above and your response.

Respectfully submitted

Grant FeJtmate, Executive Director

Nova Scotia Road Builders Association

Duncan P. Williams, President/CEO

Construction Association of NS

Crystal Ingram, Executive Assistant

Canadian Home Builders’ Association — Nova Scotia

Stephen Adams, Executive Director

UDI of Nova Scotia