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Letter to the City of Guelph regarding report No. 13-32 - Rental housing licensing cost-benefit analysis

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July 11, 2013

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City of Guelph
Planning, Building, Engineering and Environment Committee
City Hall, 1 Carden Street
Guelph, Ontario  N1H 3A1

Your Worship and Members of Council,

Over the past several months, City staff have been in contact with the Ontario Human Rights Commission (OHRC) as the City considers its options for licencing rental housing in Guelph. We are pleased to see that some of this discussion is reflected in references to human rights in the Rental Housing Licensing Cost-Benefit Analysis report.

We will continue to follow your progress on licensing, and offer a few suggestions for the next stages.

The current report refers to some sections of Room for everyone, the OHRC’s new guide to human rights and rental housing licensing. We have included hard copies of this book for all Committee members for your reference. This guide contains a number of areas to consider when designing or considering licensing. Examples include:

  • Consult with groups protected under Ontario’s Human Rights Code before drafting the bylaw
  • Work to ensure any bylaw does not limit or reduce the availability of affordable housing
  • Make sure that meetings about the bylaw focus on actual licensing issues, and not on the people who will live in the housing.

While the current cost-benefit analysis report offers some insight into what a licensing bylaw might include, we recommend that decisions on the length of licensing and renewal periods only be made after a final decision to proceed with licensing is made, and after bylaw details are more clearly defined.

We look forward to taking part in the consultation phase, and will continue to comment on ways to ensure the bylaw meets the City’s health and safety needs while also respecting and advancing human rights – a critical connection for a healthy community.

For more information, contact Jacquelin Pegg, Inquiry Analyst, 416-326-9501,

Yours truly,

Barbara Hall, B.A, LL.B, Ph.D (hon.)
Chief Commissioner

Note: Original and copies of Room for everyone being forwarded via courier.