unfortunately there has been a huge volume of extra H&C cases because most who are refused asylum file H&C cases and there are many others trying for H&C RO try and stay in Canada for a variety of reasons. There does seem to be some changes going on but if you were already in the system before changes were implemented your case will likely take longer. Many people don’t actually complain if they have a work permit and prefer for their cases to drag out as long as possible.That’s a lot of time! Have you already requested the GCMS notes or speak with an agent?
35 months and they haven’t started processing your application? What does your lawyer tell you?