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Re: Report no. 14-29, Rental housing licensing recommended approach

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May 2, 2014

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VIA Email           

Mayor Karen Farbridge
Members of Council
City of Guelph
Planning and Building, Engineering
and Environment Committee
Guelph City Hall, 1 Carden Street
Guelph, Ontario  N1H 3A1

Your Worship and Members of Council,

I am writing in support of the steps that are recommended in Report no. 14-29 – that instead of putting a licensing system in place for rental housing, the City of Guelph use existing bylaws to deal with property concerns.

Licensing can be a good tool if its focus is on Building Code, Fire Code and health and safety standards, but it is not an appropriate option for dealing with the actions of the people who may live in the housing. This is why we concur with the report’s recommendation to expand existing programs to target the actual problem areas, without adding an extra cost to tenants across the City.

We are pleased to hear that the City’s recent bylaw enforcement enhancements are having a positive effect in addressing some of the central community concerns relating to rental housing. And we support extending these efforts to better target areas and behaviours of concern, instead of imposing additional requirements that will affect all tenants.

The potential costs of licensing could reduce or limit the availability of affordable rental housing, which is a critical need for many people who identify with grounds of Ontario’s Human Rights Code (for example, age, receipt of public assistance, disability, or country of origin). Provincial guidelines also call on municipalities to maintain the stock of affordable housing.

In our guide, Room for Everyone: human rights and rental housing licensing, we included a series of promising practices we saw in our work with municipalities across Ontario. We are pleased to see that the proposed approach in Guelph follows some of these practices.

For example, staff looked closely at human rights considerations before arriving at the recommendations. Also, we were pleased to see staff efforts to reach out to a wide variety of groups that would be affected by any proposed licensing.

Continuing to review bylaw options through a human rights lens can help you make sure your communities are inclusive and meet the needs of all residents.

I hope this information is helpful to you. If you would like more information on human rights and rental housing licensing, please contact Jacquelin Pegg at 416-326-9863, or via email at

Yours truly,

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