A New Regulatory Framework for Multi-Tenant Houses

10th floor, West Tower, City Hall
100 Queen Street West
Toronto, ON M5H 2N2

Attention: Nancy Martins

Re: PH25.10 A New Regulatory Framework for Multi-Tenant Houses

Dear Deputy Mayor Ana Bailao, Chair, and Members, Planning and Housing Committee 

This is to express our support in principle for the above noted report to create a new comprehensive regulatory and compliance framework (zoning bylaw amendments, licensing requirements), for Multi-Tenant Houses across Toronto.

We appreciate that this represents a cross-divisional multi-pronged initiative that has been a long time in development. We also note that City Planning delivered on our request made in connection with the earlier report (November 2020) to ensure that resident associations (including both tenants, homeowners) are given the opportunity to be engaged in the process of public and stakeholder engagement on the proposed zoning standards for city-wide permissions for multi-tenant housing.

We recognize that expanding permission for rooming houses across the city is important to ensure affordable housing options. Experience in the City of Toronto, that has allowed rooming houses for years, shows the need for such housing, but also for licensing and enforcement to both ensure a safe home for residents, as well as to prevent problems in the neighbourhood.  We therefore also support the use of special programs to assist residents as needed.

We also agree with the phasing in of permissions. The report proposes that the first step (Year 2) is to bring existing non-compliant, unlicensed and illegal buildings up to standard, with the delay to November 2022 in the bylaw coming into effect allowing time for the involved Departments to prepare for implementation in Nov. 2022 (Year 2). Then Year 3 will open the opportunity for new applications.

We support the recommendation for enhanced enforcement as this is essential to ensure that multi-tenant housing is safe and healthy for residents, and the surrounding community. This means enforcement of property standards, fire safety as well as community safety. Having a program to help support the needs of residents is an important preventative measure.

The definition of evaluation criteria and key performance indicators is critical to ensure success of this initiative. As such we recommend:

• That PHC request that City Council require that a formal evaluation of Year 2 be undertaken before the introduction of Year 3.

To execute this complex program successfully requires a guaranteed commitment to a major cross-divisional budget increase from 2021 through to Oct 31, 2024.  As such we recommend:

• That PHC request that the City Council ensure that the cross-divisional budget adequately covers the costs for the initiative, including zoning by-law enforcement, property standards, and supportive services.

In that regard we will be submitting a detailed list of budget related questions to staff. Finally, we would comment that given the steep increase in resources that are required (without accompanying revenue offsets) but which are not specifically requested in the current report, it would appear that strong political leadership will be required to ensure adequate resources are made available, and ultimately ensure the success of the program.

Yours truly,

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cc: Mayor John Tory and Councillors 
Chris Murray, City Manager
Giuliana Carbone, Deputy City Manager Community & Social Services
Tracey Cook, Deputy City Manager, Infrastructure & Development Services
Carleton Grant, Municipal Licensing & Standards
Gregg Lintern, Chief Planner and Executive Director, City Planning Division