HomeMy WebLinkAboutCOR-2025-041 - Short-term Rental By-lawStaff Report
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Corporate Services Department www.kitchener.ca
REPORT TO: Finance and Corporate Services Committee
DATE OF MEETING: June 2, 2025
SUBMITTED BY: Amanda Fusco, Director, Legislated Services, 519-904-1402
PREPARED BY: Kristin VanDerGeld, Manager of Licensing, 519-904-5605
WARD(S) INVOLVED: All
DATE OF REPORT: April 17, 2025
REPORT NO.: COR -2025-041
SUBJECT: Short-term Rental By-law
RECOMMENDATION:
That the Short-term Rental By-law be approved in the form shown attached to staff report
COR -2025-041 as Appendix "A" to COR -2025-041,
That the fees set out in Appendix "B" of staff report COR -2025-041 be approved; and
That the request for one (1) Full Time Equivalents (FTE) to support the administration,
inspection, and enforcement of the Short -Term Rental By-law be approved.
REPORT HIGHLIGHTS:
• The purpose of this report is to provide follow-up as requested by Council at the June 24,
2024, meeting.
• Staff have separated the short-term rental provisions from the Shared Accommodation
By-law as proposed in staff report COR -2024-233 and COR -2024-288 to create a stand-
alone Short-term Rental By-law.
• Additional community engagement with potential stakeholders was conducted in the form
of in-person sessions and an online Engage Kitchener survey.
• This report supports Building a Connected City Together: Focuses on neighbourhoods;
housing and ensuring secure, affordable homes; getting around easily, sustainably and
safely to the places and spaces that matter.
BACKGROUND:
On June 24, 2024, Council considered report COR -2024-288 (Supplemental Shared
Accommodation By-law) and report DSD -2024-249 (City-wide Lodging House Review) which
sought approval to allow lodging houses city-wide in conjunction with a proposed licensing
framework that would regulate both lodging houses and short-term rentals in the form of a
Shared Accommodation By-law. While the amendments to the City's Official Plan and Zoning
By -Law to permit lodging houses city-wide in all residential zones were approved, staff were
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directed to separate the proposed licensing regulations for Lodging Houses into a stand-alone
by-law and that the proposed Short -Term Rental provisions be deferred to allow additional time
to further review requirements and conduct further engagement with potential stakeholders. On
August 12, 2024, the Finance and Corporate Services Committee considered report COR -2024-
344 (Lodging House By-law) which sought approval of licensing framework to regulate lodging
houses in the form of a Lodging House By-law. The Lodging House By-law was approved and
came into effect on January 1, 2025. 1 n the final quarter of 2024, staff explored options for short-
term rental licensing, making a deliberate effort to engage with the community further as well as
examine the approaches taken by other municipalities. As a result, a proposed Short-term Rental
By-law was developed. This report is seeking Council's approval of the Short-term Rental By-
law, associated licensing fees and additional staffing resources.
REPORT:
Regulating short-term rentals (STRs) through licensing is becoming increasingly important as
the market for platforms like Airbnb, Vrbo, Expedia, and Booking.com has grown rapidly in recent
years. These platforms allow property owners to rent out their homes or rooms for short stays,
offering significant benefits, such as increased income for hosts and more affordable, unique
accommodation options for travelers. However, as STRs proliferate, concerns have emerged
that necessitate formal regulation. Some key reasons why licensing STRs is crucial:
• Public Safety
• Consumer Protection
• Nuisance Control
• Enabling Data Collection
Engagement:
Staff explored options for Short -Term Rental Licensing by conducting thorough community
engagement, meeting with interested stakeholders, and examining the strategies employed by
neighboring municipalities. Further engagement sessions were conducted in collaboration with
the City of Waterloo, who was also reviewing short-term rental regulations.
To ensure the greatest amount of qualitative feedback from the community, staff collaborated
with the city's Community Engagement Consultant to develop thorough, objective, and non -
biased survey questions to inform Council regarding impacts, licensing regimes and
neighborhood integration of short-term rentals. An online Engage Kitchener survey was posted
between November 5th, 2024, and December 6th, 2024, and the survey was advertised on social
media, the City's website, and within City facilities. Survey links were also shared with student
associations like CSI and with individuals who had previously engaged with staff. The survey on
short-term rentals had 581 contributors, with 18% of survey respondents identifying as short-
term rental owner/operators and the remaining 82% identifying as citizens who reside in a
neighbourhood where a STR is operating and other interested parties. Key highlights from the
short-term rental survey results include the following:
• 65% of respondents felt that short-term rentals should be regulated through licensing
• 51% of respondents described their experience having a short-term rental property in
their neighbourhood as negative or very negative.
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• 53% of respondents felt that operating a short-term rental was a business.
• 59% of respondents felt a short-term rental should be restricted to an owner's principal
residence.
• 61 % of respondents felt the maximum number of days for a short-term rental should be
30 days or less.
The survey also provided respondents the opportunity to offer free -form suggestions, ideas, and
feedback. Key takeaways from those comments include:
• Some respondents suggested that a complete ban on short-term rentals should be
considered.
• Many respondents feel that short-term rentals worsen the housing crisis by decreasing
the availability of long-term rental options, increasing housing prices, and creating
competition for affordable housing.
• Some respondents pointed out the positive impacts of STRs, including well-maintained
properties, boosted tourism, and the provision of flexible housing options for temporary
needs.
• Negative perceptions of STRs include issues like noise, nuisance, parking, lack of
accountability from absentee owners, and a decline in community cohesion.
• Supporters of STRs highlighted that short-term rentals boost the local economy by
encouraging tourism and generating job opportunities for cleaners, maintenance workers,
and other service providers.
• Some respondents believed a tiered licensing approach would be useful to differentiate
between commercial operators and hosts who rent out their principal residence.
In addition to the survey, staff also held two joint in-person engagement sessions with the City
of Waterloo on November 18th and 27th, 2024. These sessions were attended by approximately
40 people combined, primarily comprised of short-term rental operators. At these sessions, staff
presented regulatory options being used by other area municipalities, potential insurance
implications, and had a presentation by a representative from Airbnb to discuss the company's
position on licensing. The key take-aways from these sessions were:
• Some participants supported licensing frameworks for better safety and accountability,
while others opposed them, citing potential challenges for small operators, higher costs,
and decreased flexibility.
• Participants emphasized the economic benefits of short-term rentals, including
generating local revenue and supporting tourism.
• Some expressed concerns about the cost and necessity of commercial insurance for
hosts.
• Participants discussed principal residence requirements, with a preference for a tiered
licensing approach.
• There were discussions about the differences between short-term and long-term rentals,
along with concerns regarding how the Residential Tenancies Act regulations might
apply.
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Municiaal Scan:
A thorough review of municipalities with existing short-term rental by-laws was conducted, and
staff met with representatives to gather feedback on their licensing programs. Additionally, staff
engaged with Explore Waterloo Region and received insights into how other provinces, such
as Nova Scotia, are handling licensing. Staff also reviewed the City of Cincinnati's Short -Term
Rental By-law, as it was highlighted as a point of interest during our engagement sessions.
Overall, municipalities are adopting a licensing framework from STR's, and many are limiting
operators to a single STR unit within their principal residence and prohibiting commercial or
multi -listing operators with the objective of protecting the long-term rental housing market.
Research into other jurisdictions that have implemented the principal residence restriction have
expressed challenges from an enforcement perspective because it is resource -intensive and
requires significant investigation. During our engagement sessions many operators expressed
a clear preference for maintaining their properties as short-term rental units and confirmed they
would not transition into the long-term rental market, should such a restriction be imposed.
Additionally, many municipalities have opted to license short-term rental platforms like Airbnb,
rather than just the hosts, for several key reasons such a better enforcement and compliance,
transparency and data access, and mitigating negative impacts.
Application requirements vary by municipality, but the majority are renewed annually and have
minimum requirements such as an associated licensing fee, proof of ownership, proof of
principal residence (where applicable), and insurance. Some municipalities have chosen more
robust requirements that include electrical and HVAC inspections, property maintenance plans,
and a criminal record check.
During stakeholder engagement sessions staff presented the benefits and challenges of
STR's, policy options, what other are municipalities are doing, and potential application
requirements. City of Cambridge currently does not have any short-term licensing regulations
in place and the City of Waterloo has amended their Residential Rental Licensing By-law to
allow for the operation of a short-term rental in an owner's principal residence in low-rise rental
properties. This was implemented as interim measure until a broader rental licensing review is
completed. During these sessions staff heard that many STR operators rely on this as their
primary source of income and are not opposed to licensing but expressed that an overly
complex application or inspection process could create barriers for small business owners.
Proposed By-law Components
The proposed By-law aims to regulate short-term rentals through a tiered licensing system that
establishes rules for both principal and non -principal residence STRs, as well as for hosting
platforms such as Airbnb and Vrbo.
A Short -Term Rental is defined as a Dwelling Unit or part thereof used to provide transient
sleeping accommodations for a period of thirty (30) consecutive days or less, typically
facilitated through a Short-term Rental Company, and may include a traditional bed and
breakfast, but does not include a rental arrangement exceeding thirty (30) consecutive days.
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Residential rental properties that are operating as long-term rentals (more that 30 consecutive
days) will not be captured under this By-law.
The licence categories include the following:
Short -Term Rental Com
Would capture any online service, website, mobile application, or other digital platform that
markets and brokers the booking, reservation, or rental, of a Short -Term Rental for
compensation (such as Airbnb and Vrbo).
Short -Term Rental Princiaal Residence:
Includes any person who operates or permits the operation of a Short-term Rental in their
Principal Residence.
Short -Term Rental Commercial:
Incorporates any person who operates or permits the operation of a Short-term Rental in a
dwelling unit that is not their Principal Residence.
Application Requirements:
Application requirements include detailed floor plans that indicate the locations of all smoke
and carbon monoxide alarms, a fire checklist, confirmation of insurance, proof of ownership
and principal residence where applicable, and a Dedicated Responsible Person that will
adhere to requisite response times in relation to the STR. A Guest Handbook will be
developed by staff and completed by the licensee, and it will contain contact information for the
Dedicated Responsible Person, emergency and non -emergency services, and reference
materials associated with relevant city by-laws such as noise, nuisance, and parking.
What Staff Heard:
Staff conducted significant engagement and are recommending modifications to what was
originally proposed in Shared Accommodation staff report COR -2024-233. This is what we
heard:
What We Heard
Proposed Modification
• Bedroom limits would decrease
• Removed bedroom limits but all
income potential and flexibility.
rooms used for guest accommodation
must meet applicable building
standards.
• A requirement to keep a guest registry
• Requirement removed for STR hosts.
would be cumbersome and all guest
STR Company's (platforms) will be
information is not always provided to
required to keep a record of each
the STR hosts by the platforms.
concluded transaction in relation to a
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The proposed modifications will offer a structured, low -barrier way to bring STR activity into
compliance with licensing requirements while improving oversight and accountability,
supporting public safety, while providing useful data collection that can help to track trends
such as the impact on long-term housing, neighbourhood concerns, and can inform future
policy decisions.
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Short-term Rental listed or advertised
on its platform.
• Limiting the number of days that an
• Removed the cap on number of days
STR can operate per year would
an STR can operate per year.
reduce host income and would involve
undo administrative complexity.
• Booking length of a maximum of 90
• STR definition updated to reflect
consecutive days was not conducive
accommodations for a period of thirty
to those that may need a STR for a
(30) consecutive days or less. Any
longer stay due to family medical,
stay longer than 30 days would not be
renovations, or insurance claims.
considered a STR.
• Limit the number of inspections
A fire safety checklist and basic floor
required upon application and
plans will be required to confirm
reconsider floor plans. Guest reviews
compliance with minimum fire safety
and ratings act as informal quality
and building standards. Inspections
control.
may be conducted in response to
complaints or if an application
package is deemed incomplete or
unsatisfactory.
• A tiered licensing approach allows for
• The proposed by-law incorporates a
flexibility and may reduce licensing
tiered licensing approach for principal
costs.
residence operators, commercial
operators, and platforms.
• The proposed licensing fees are too
• Fees have been reduced while
high for small business owners.
supporting a cost recovery model and
include licensing STR Companies.
• Meeting insurance requirements will
• Staff continue to recommend
significantly increase premiums.
insurance requirement based on
advice provided by the Waterloo
Region Municipal Insurance Pool. If
the STR is already adequately insured
as contractually required to do so
under their insurance policy, there
should be no additional cost/premiums
charged.
The proposed modifications will offer a structured, low -barrier way to bring STR activity into
compliance with licensing requirements while improving oversight and accountability,
supporting public safety, while providing useful data collection that can help to track trends
such as the impact on long-term housing, neighbourhood concerns, and can inform future
policy decisions.
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Implementation Plan:
As with the introduction of any new by-law, there will be an initial period of preparation to allow
for system modifications, administrative organization, recruitments/training of staff, and
process improvements. Followed by a public awareness campaign that will focus on
regulations. Staff will work Communications to establish a presence on the City of Kitchener
website to provide information and application requirements. Application intake will begin on
January 1, 2026, for those seeking an opportunity to voluntarily comply with the new licensing
regulations.
Fnfnrcement-
As a result of the proactive planning and strengthened enforcement measures introduced
through the Lodging House Program, Council approved the addition of two full-time equivalent
(FTE) positions—a Licensing Inspector and a Property Standards Officer. These roles are
expected to have the capacity to absorb inspection and enforcement responsibilities related to
short-term rentals. Enforcement will be carried out primarily by Licensing Inspectors through
field inspections, monitoring of online platforms, and information sharing with both internal
departments and external partners. Reactive enforcement will be conducted based on
response to public complaints and will be investigated based on urgency and public safety.
Licensing and Property Standards enforcement will be conducted using a progressive
approach which may include but is not limited to fines and or charges under the Provincial
Offences Act/Administrative Monetary Penalty System. The Manager of Licensing may apply
conditions on a licence or refuse/revoke a licence (subject to a hearing before the Licensing
Appeal Committee).
Administration:
Staff project that there are approximately 600-800 STR's operating in Kitchener. There is
currently no capacity for existing staff to intake, review, analyze and process the expected
volume of STR applications in addition to the approximately 3,000 business license
applications that are processed annually. Staff are requesting the addition of one (1) new
Licensing Administrator to assist with customer service, application processing and issuance.
It is expected that the expenses related to the FTE will be off set by the collection of licensing
fees (Appendix B).
Zoning By-law Compliance:
Staff have identified that at such time as Short Term Rental By-law comes into effect, Zoning
By-law regulations for `tourist home' and `bed and breakfast' as home business uses are no
longer required. As such, staff anticipate advancing a Zoning By-law amendment during the
implementation period to remove these uses from the Zoning By-law. This will eliminate
duplication and potentially contradictory regulations.
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STRATEGIC PLAN ALIGNMENT:
This report supports Building a Connected City Together: Focuses on neighbourhoods; housing
and ensuring secure, affordable homes; getting around easily, sustainably and safely to the
places and spaces that matter.
FINANCIAL IMPLICATIONS:
If supported, the Short -Term Rental Program would have operating budget financial implications
associated with the cost of 1 full-time employee (salary and fringe benefits). Staffing includes a
Licensing Administrator $93,871.56. The recruitment of 1 full-time equivalent (FTE) to oversee
the administration of the Short -Term Rental By-law is a minimum requirement for ensuring the
success of the program.
COMMUNITY ENGAGEMENT:
INFORM — This report has been posted to the City's website with the agenda in advance of the
council / committee meeting.
CONSULT — Staff used the Engage WR platform to solicit public feedback on STR's and
potential licensing regulations which solicited engagement from over 500 respondents. In
addition, staff reached out to groups such as Conestoga Students Inc., and members of K -W
Airbnb.
COLLABORATE — In collaboration with the City of Waterloo staff hosted two joint in-person
engagement sessions on November 18th and 27th, 2024. These sessions were attended by
approximately 40 people combined, primarily comprised of short-term rental operators. At these
sessions, staff presented regulatory options being used by other area municipalities, potential
insurance implications, and had a presentation by a representative from Airbnb. .
PREVIOUS REPORTS/AUTHORITIES:
• COR -2024-288 Supplemental Report Shared Accommodation By-law
• COR -2024-233 — Shared Accommodation By-law
• DSD -2024-249 - City-wide Loding House Review
• DSD -2021-11 — Lower Droon Land Use Study Recommendations Report
• DSD -20-214- Housing for All — City of Kitchener Housing Strategy
• Municipal Act, 2001
• Planning Act
APPROVED BY: Victoria Raab, General Manager, Corporate Services
ATTACHMENTS:
Attachment A — Short -Term Rental By-law
Attachment B - Licensing Fees
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BY-LAW OF THE
CORPORATION OF THE CITY OF KITCHENER
BY-LAW NO. 2025 -XXX
BY-LAW TO PROVIDE FOR THE LICENSING AND REGULATION OF SHORT-TERM
RENTALS IN THE CITY OF KITCHENER.
WHEREAS it is deemed expedient to exercise the powers conferred on Council by the
Municipal Act, 2001, S.O. 2001, c.25 (the "Municipal Act"), as amended;
AND WHEREAS Section 8 of the Municipal Act, provides that a municipality has the
capacity, rights, powers, and privileges of a natural person for the purpose of exercising
the authority under the Act;
AND WHEREAS Section 8(3) of the Municipal Act, authorizes a municipality to provide
for a system of licences;
AND WHEREAS Section 11 of the Municipal Act authorizes a Municipality to pass bylaws
responding to health, safety and well-being of person, parking on property, structures
include fences and signs;
AND WHEREAS Section 151 (1) of the Municipal Act authorizes a municipality to provide
for a system of licences with respect to a business and to prohibit carrying on or engaging
in the business without a licence and to take other actions with respect to such licences;
AND WHEREAS Section 151 (1) of the Municipal Act authorizes a municipality to license,
regulate, or govern real and personal property used for the business and the persons
carrying it on or engaged in it;
AND WHEREAS Section 425 of the Municipal Act authorizes a Municipality to create
offences;
AND WHEREAS Section 429 of the Municipal Act authorizes a Municipality to establish
a system of fines or offences under a by-law of Municipality passed under the Act;
AND WHEREAS section 434.1 of the Municipal Act, 2001 authorizes the City to require
a Person, subject to such conditions as the municipality considers appropriate, to pay an
Administrative Penalty if the municipality is satisfied that the Person has failed to comply
with a by-law of the City;
NOW THEREFORE the Council of The Corporation of Kitchener enacts the following:
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1. Definitions
"Administrative Penalty By-law" means the Administrative Penalty System for
Violations of Non -Parking By-laws, By-law Number 2024-001 of the City, as amended
from time to time, or any successor thereof.
"Adult" means an individual eighteen years of age or older.
"Agent" means a Person authorized in writing by an Owner to act on the Owner's or
group of Owner's behalf.
"Applicant" means the Person applying for a Licence or renewal of a Licence under this
by-law.
"Application" shall include any Application for a Licence or renewal of a Licence on the
form provided by the Manager of Licensing, or their designate, and such application being
to the satisfaction of the Manager of Licensing and in accordance with the requirements
set out in this By-law.
"Application Licence Fee" means a pre -determined fee approved by Council through
the User Fee Schedule as part of the budget that is paid by a Person as part of the
Application for a Licence.
"Bedroom" means a room or area used, separated from the common living area(s) which
is equipped with a sleeping type bed and a closable, latching door for privacy. A Bedroom
shall further meet the requirements for natural light as set out in the Building Code Act,
and if located in a basement, must provide the for adequate means of egress, as
approved by the City's Fire Department.
"Building Code Act" means the Building Code Act, 1992, S.O. 1992. c.23, as amended,
including any regulations enacted thereunder.
"Business" except where inconsistent with the context means any Business wholly or
partly carried on within the City of Kitchener even if the Business is being carried on from
a location outside of the City of Kitchener and includes without limitation:
a) trades and occupations;
b) the operation of a Short -Term Rental;
c) exhibitions, concerts, festivals, and other organized public amusement held for
profit or otherwise;
d) the sale or hire of goods or services on an intermittent or one-time basis and the
activities of a transient trader; and
e) the display of samples, patterns, or specimens of goods for the purpose of sale or
hire.
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"Chapter" shall refer to a by-law of the City which has been incorporated in The City of
Kitchener Municipal Code and assigned a Chapter number.
"Chief Building Official" means the Chief Building Official of the City or their designate.
"Chief Fire Official" means the Chief Fire Official of the City or their designate.
"Chief of Police" means the Police Chief for the Waterloo Regional Police Services or
their designate.
"City" means The Corporation of the City of Kitchener.
"City Solicitor" means the City Solicitor of the City or their designate.
"Corporation" means a body incorporated pursuant to the Business Corporations Act,
R.S.O. 1990 c. B.16, or the Corporations Act, R.S.O. 1990, c. C.38, the Not -for -Profit
Corporations Act, 201, S.O. 2010, c.15, or other applicable Federal or Provincial Act, as
the case may be.
"Council" means the elected officials comprising the municipal council of the City.
"Dedicated Responsible Person" means a Person who is either the Owner/Licensee
or an agent, representative, or property maintenance company who is authorized to act
on behalf of the Owner/Licensee and who is responsible for managing and addressing
issues in relation to the Licensed Premises.
"Designated Provision" means any section of this By-law designated in accordance
with section 12.4 of this By-law.
"Director" means the Director of Legislated Services of the City, their successor in title,
or their designate.
"Dwelling Unit" means a building or part thereof used or intended to be used as a
residential unit that contains cooking, eating, living, sleeping and sanitary facilities.
"Floor Plan" means a scale diagram of the arrangement of rooms in one story of a
building.
"Government -Issued Identification" means an official document issued by a
government authority that serves as proof of a person's identity and includes, but is not
limited to, a driver's licence and passport.
"Guest" means a Person renting a Short -Term Rental by way of concession, permit,
lease, rental agreement or similar contractual arrangement.
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"Guest Handbook" means a document that has been prepared and approved by the
Manager of Licensing and completed by the Licensee which, among other things,
prescribes the roles and responsibilities of the Guest and Owner/Licensee, including but
not limited to expectations as they relate to non -disturbance of neighbours; compliance
with applicable City by-laws, and adherence to the provisions of this by-law.
"Human Rights Code" means the Human Rights Code, R.S.O. 1990, c. H.19, as
amended.
"Incomplete Application" means where required information is missing on the
Application form; information or documentation required by the Manager of Licensing as
part of the Application has not been provided; or the full Application Licence Fee is unpaid
including any late fee and/or penalty fee.
"Licence" means a licence to operate a Short -Term Rental issued under this
By-law and the termed "licensed" shall have a corresponding meaning.
"Licensed Premises" means the Dwelling Unit referred to on a Licence issued pursuant
to this By-law.
"Licensee" means a Person who has been issued a Licence under this By-law.
"Licensing Appeal Tribunal" means a committee designated by Council for the purpose
of hearing any appeal under this By-law.
"Manager of Licensing" means the City's Manager of Licensing, their successor in title,
or their designate.
"Medical Officer of Health" means the Medical Officer of Health for the Region of
Waterloo Public Health or their designate.
"Municipal Act" means the Municipal Act, 2001, S.O. 2001, c. 25, as amended.
"Officer" means an employee or agent of the City or a member of the Waterloo Regional
Police Services and shall include, without limitation, the Manager of Licensing, a
municipal law enforcement officer, by-law enforcement officer, or Business Licensing
Inspector, the Director, the Chief Fire Official, the Chief Building Official, the City's
Director of By-law Enforcement, or any person or inspector duly authorized on their behalf
or otherwise authorized by Council.
"Ontario Fire Code" means the Ontario Regulation 213/07: Fire Code, under the Fire
Protection and Prevention Act, 1997, S.O. 1997, c. 4.
"Owner" means the registered owner of the Property, or a Person who has leased the
Property.
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"Person" includes an individual, sole proprietorship, partnership, unincorporated
association, unincorporated syndicate, unincorporated organization, trust, body
corporate, and a natural person in their capacity as heir, trustee, executor, administrator,
or other legal representative.
"Premises" means land, Property or any part thereof including all buildings or other parts
thereon.
"Principal Residence" means the primary and permanent place of residence where an
owner(s) or a lessee of a Property predominantly reside and has designated it as their
principal residence on their income tax filing, property bills, and in other government
records.
"Property" means any lot, block, or other area in which land is held or into which it is
subdivided, including the building and structures, and pools thereon.
"Regulations of this By-law" means the provisions of this By-law including the
applicable schedules.
"Short -Term Rental" means a Dwelling Unit or part thereof used to provide transient
sleeping accommodations for a period of thirty (30) consecutive days or less, typically
facilitated through a Short-term Rental Company, and may include a traditional bed and
breakfast, but does not include a rental arrangement exceeding thirty (30) consecutive
days.
"Short -Term Rental — Principal Residence" means any Person who operates or
permits the operation of a Short -Term Rental in their Principal Residence.
"Short -Term Rental — Commercial" means any Person who operates or permits the
operation of a Short -Term Rental in a Dwelling Unit that is not their Principal Residence.
"Short -Term Rental - Company" means any online service, website, mobile application,
or other digital platform that markets and brokers the booking, reservation, or rental, of a
Short -Term Rental for compensation.
"Zoning By-law" means all applicable by-laws in effect and enacted in accordance
section 34 of the Planning Act, R.S.O. 1990, c. P.13, as amended, that restrict the use of
land in the City.
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2. Regulated Short -Term Rentals
2.1 The Short -Term Rentals as set out in Schedule 1 are subject to the requirements
of this By-law and to the requirements of the applicable schedules as shown
therein.
2.2 The applicable requirements of a schedule to this By-law shall prevail over the
general requirements of this By-law to the extent of any conflict.
3. Prohibitions
3.1 This By-law shall not apply to the following, where not defined herein shall be
defined in section 3 of the City of Kitchener Zoning By-law:
a) Hotel;
b) Motel;
c) Inns;
d) Lodging House; or
e) any rental unit to which any of the following Acts, or their regulations apply:
i) Homes for Special Care Act, R.S.O. 1990, c.H12, as amended;
ii) Long -Term Care Homes Act, R.S.O. 1990, c.17, as amended;
iii) Retirement Homes Act, 2010 S. 0. 2010, c. 11, as amended,
iv) Social Housing Reform Act, 2000, S. 0. 2000, c.27, as amended,
v) Hotel Registration of Guests Act, R.S.O. 1990, Chapter H.17, as amended;
vi) Accommodation Sector Registration of Guests Act, 2021, R.S.O. 2021,
chapter 21, Schedule 1, as amended; and/or,
vii) Residential Tenancies Act, 2006, S. 0. 2006, c. 17.
3.2 No Person shall:
a) own, operate, permit to be operated, or act in the capacity of a Short -Term
Rental set out in Schedule 1 without a Licence issued in accordance with
this By-law;
b) own, operate, permit to be operated, or act in the capacity of a Short -Term
Rental as set out in Schedule 1 without complying with the Regulations of
this By-law;
c) operate a Short -Term Rental licensed under this By-law:
i. at a location other than the Licensed Premises where applicable;
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ii. under any other name than the name(s) identified on the Licence;
iii. except in accordance with the Regulations of this this By-law; or
iv. without complying with any and all conditions or restrictions placed on
the Licence by the Manager of Licensing;
d) transfer or assign a Licence to any other Person or to any other location
other than the Licenced Premises;
e) provide false or misleading information to the City when applying for a
Licence under this By-law, renewing a Licence or at any other time;
f) hold themselves out as Licensed under this By-law without holding the
appropriate Licence;
g) advertise or permit the advertisement or operation of a Short -Term Rental
without a Licence; or
h) advertise a Short -Term Rental without including the current Licence number
in every advertisement.
4. Licensing Requirements
4.1 An Applicant applying for a Licence shall submit the following to the Manager of
Licensing:
a) a complete Application in the form prescribed by the Manager of Licensing;
b) the applicable Application Licence Fee;
c) any other documents as required by the Regulations of this By-law; and
d) any documentation that may be required by the Manager of Licensing with
respect to investigations required pursuant to this By-law.
4.2 If not prescribed by the By-law, upon receipt of an Application, the Manager of
Licensing shall make or cause to be made all investigations which they deem
necessary.
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4.3The Manager of Licensing may require the Applicant to have investigations
conducted and obtain documentation from and provide to the Manager of
Licensing, or to have documentation provided by any of the following or their
designates: the Chief Fire Prevention Officer, Chief Building Official, Regional
Medical Officer of Health, Waterloo Regional Police Services, and Director of
By-law Enforcement.
4.4 For a renewal of a Licence, an Applicant shall submit the following to the Manager
of Licensing:
a) a renewal Application in the form prescribed by the Manager of Licensing;
b) the applicable Application Licence Fee; and
c) documents as required by the Regulations of this By-law; and
d) any documentation that may be required by the Manager of Licensing with
respect to investigations required pursuant to this By-law.
4.5 Every Licensee shall:
a) notify the Manager of Licensing within fourteen (14) days of any changes in
the ownership of the Licensed Premises;
b) shall comply with all applicable federal, provincial or municipal legislation,
including, but not limited to, the Building Code Act, as amended, the Fire
Code, as amended, and all applicable municipal by-laws, including Noise,
Zoning, Parking, and Property Standards, and other applicable law, code or
Act, such as the Human Rights Code and Criminal Code of Canada;
c) All municipal taxes, licenses, fines, or charges, and building permits for the
Licensed Premises must be current and not outstanding before a Licence
will be issued; and
d) comply with the conditions and restrictions placed on the Licence by the
Manager of Licensing or the Licensing Appeal Tribunal.
5. Issuance of Licence and Grounds for Refusal
5.1 The Manager of Licensing shall receive and process all complete Applications for
a Licence.
5.2 Upon receipt of a complete Application, the Manager of Licensing shall either
issue, renew, or issue with conditions a Licence.
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5.3 Except where otherwise provided herein, every Licence issued or renewed
pursuant to this By-law shall be issued in the name of Council by the Manager of
Licensing.
5.4 Where the Manager of Licensing receives an Incomplete Application, the Manager
of Licensing shall, notify the Applicant that the Application is incomplete and, where
applicable, any steps required to complete the Application.
5.5 The Manager of Licensing will deem an Application to be incomplete where:
a) required information has not been provided on the Application form;
b) information or documentation required by the Manager of Licensing as part of
the Application has not been provided; or
c) the full Application Licence Fee is unpaid including any late fee and/or penalty
fee.
5.6 Where no action has been made to remedy an Incomplete Application by the
Applicant in the time specified by the Manager of Licensing the Application shall
be deemed abandoned. The Application will be cancelled, and any associated
Application Licence Fee will be deemed non-refundable.
5.7 The Manager of Licensing shall, where an address or other contact information
has been provided, notify the Applicant of the intention to refuse an Application
and shall advise the Applicant of their right to appeal.
5.8 The Manager of Licensing may refuse an Application where:
a) an unsatisfactory report regarding an investigation carried out pursuant to this
By-law or any other applicable by-law of the City and any condition causing the
report to be unsatisfactory has not been remedied; or
b) the past conduct of the Applicant affords the Manager of Licensing reasonable
grounds to believe that the Applicant has not or will not carry on their Business
in accordance with applicable law or by-laws, or with integrity and honesty; or
c) the Property or Dwelling Unit specified on the Application are subject to any
Order that has not been complied with made pursuant to the Building Code
Act, or the Fire Protection and Prevention Act 1997, S.O. 1997, c.4, or by the
Medical Officer of Health; or
d) the Licence has been suspended or revoked by the Manager of Licensing or
the Licensing Appeal Tribunal.
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6.Terms of Licence
6.1 A Licence issued pursuant to the provisions of this By-law shall expire one year
from the date it was issued or on the expiry date listed on the licence unless it is
revoked in accordance with any provisions of this By-law.
6.2 Where a Person sells or transfers ownership of a Short -Term Rental to another
Person, the Licence issued shall be void upon transfer.
7. Revocation and Suspension
7.1 The Manager of Licensing shall, where an address or other contact information
has been provided, notify the Licensee of the intention to revoke or suspend a
Licence and shall advise the Licensee of their right to appeal.
7.2 The Manager of Licensing may revoke or suspend a Licence where:
a) the Manager of Licensing is of the opinion that the Licensed Premises poses
a threat to the health and safety of the public or Guests;
b) the Licence was issued in error;
c) the Licensee has violated any of the provisions of this By-law or any other
applicable laws;
d) any conditions placed on the Licence have been violated;
e) the Licence was issued upon provision or receipt of false or misleading
information.
7.3 If appealed, Guests residing in the Licensed Premises may continue to reside in
the premises until a final decision has been rendered by the Licensing Appeal
Tribunal, unless an order or other directive is issued under any other legislation or
by a court of competent jurisdiction which orders or directs the removal or
departure of the Guests prior to the Licencing Appeal Tribunal issuing a decision.
8. Appeal
8.1 All appeals shall be submitted in writing to the Manager of Licensing within 14
days from the notification issued by the Manager of Licensing.
8.2 The Licensing Appeal Tribunal is adjudicated by a committee designated by
Council.
8.3 The decision of the Licensing Appeal Tribunal is final and binding.
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8.4 If the Manager of Licensing refuses a Licence, the Applicant shall have the right
to appeal the decision to the Licensing Appeal Tribunal.
8.5 The Manager of Licensing may refer an Application or a Licence to the Licensing
Appeal Tribunal where:
a) the Applicant or Licensee does not meet the requirements of this By-law or
any other applicable law or by-law;
b) there are reasonable grounds for belief that an Application or other
documents provided to the Manager of Licensing by or on behalf of an
Applicant or Licensee contains a false statement or provides false
information;
c) the past or present conduct of any person, including the officers, directors,
employees or agents of a corporation, affords reasonable cause to believe
the Person will not carry on or engage their Short -Term Rental in
accordance with the law, or with honesty and integrity;
d) any Licensee has contravened this By-law or any other by-law or federal or
provincial statue or regulations while engaged in operating a Short -Term
Rental;
e) any special conditions placed by the Manager of Licensing or Licensing
Appeal Tribunal on a former or current Licence of the Applicant or Licensee
under this By-law have not been met; or
f) the provisions of this By-law provide grounds not to issue or renew.
8.6 When any matter has been referred or appealed to the Licensing Appeal Tribunal
the Applicant or Licensee shall be given reasonable notice of the time and place
of the hearing and shall be invited to make a submission either in writing or
verbally.
8.7 When any matter has been referred or appealed to the Licensing Appeal Tribunal,
after due consideration of the Application or Licence and after the Licensing Appeal
Tribunal has heard such representations as the Applicant or Licensee and staff
may care to make, may direct that the Licence be issued or renewed, or may
refuse, suspend, revoke, or add conditions to a Licence where:
a) the Applicant or Licensee does not meet the requirements of this By-law or
any other applicable law or by-law;
b) information or documentation required by the Manager of Licensing as part
of the application process has not been provided;
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c) the Application is incomplete or the Application Licence Fee is unpaid
including any late and/or penalty fee;
d) the Manager of Licensing received an unfavourable report regarding an
investigation carried out pursuant this By-law or any other by-law of the City;
e) there are reasonable grounds for belief that an Application or other
document provided to the Manager of Licensing by or on behalf of an
Applicant or Licensee contain a false statement or provides false
information;
f) the past or present conduct of any Person, including the officers, directors,
employees or agents of a corporation, affords reasonable cause to believe
the Person will not carry on or engage in the operation of a Short -Term
Rental in accordance with the law or with honesty and integrity;
g) without limiting the generality of section 8.5 (f), any Person, including the
officers, directors, employees or agent of a corporation, has contravened
this By-law or any other by-law of the City or federal or provincial statue or
regulation while engaged in the operation of a Short -Term Rental;
h) any special conditions placed by the Manager of Licensing, on a former or
current Licence of the Applicant or Licensee under this By-law have not
been met;
i) the provisions of this By-law provide grounds not to issue or renew in the
circumstances; or
j) the Applicant or Licensee has consented to the refusal, suspension,
revocation, or adding of conditions to the Licence.
8.8 No Person shall violate any conditions that the Manager of Licensing or the
Licensing Appeal Tribunal has placed on a Licence issued under this By-law.
8.9 For the purpose of section 8.6, the Person's last known address and email address
shall be deemed to be those provided pursuant to section 4.1 of this By-law unless
notice in writing has been given to the Manager of Licensing providing new
information in which case the most recently provided information shall be deemed
correct for the purpose of providing notice hereunder.
9. Inspections
9.1 Any Officer authorized by the Manager of Licensing may enter onto Premises at
all reasonable times and in accordance with any applicable requirements in the
Municipal Act to inspect any Premises used for the carrying on of any Business in
respect of which a person is required to be licensed under this By-law.
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9.2 No person shall obstruct or hinder or cause to be obstructed or hindered any
Officer or Officers designated under this By-law to perform their duties.
9.3 An inspection may be conducted by an Officer to determine whether or not the
following are being complied with:
a) any by-law of the city under the Municipal Act including this By-law;
b) a direction or order of the City made under the Municipal Actor made under
a by-law of the municipality passed under the Municipal Act;
c) a condition of a Licence issued under a by-law of the municipality passed
under the Municipal Act; or
d) an order made under the Municipal Act.
9.4 For the purpose of an inspection of any Premises to which any provision of this
By-law applies, an Officer may:
a) require the production for inspection of documents or items relevant to the
inspection in a timeframe prescribed by the Manager of Licensing;
b) inspect documents or items relevant to the inspection;
c) require information from any person concerning a matter related to the
inspection; and
d) alone or in conjunction with a person possessing special or expert
knowledge, make examination or take tests, samples, or photographs
necessary for the purpose of the inspection.
10. Orders
10.1 Where the Manager of Licensing has reasonable grounds to believe that a
contravention of this By-law has occurred, the Manager of Licensing may make an
Order requiring the Person who contravened this By-law, or who caused or
permitted the contravention, or the Owner or Licensee, of the land on which the
contravention occurred, to do work to correct the contravention.
10.2 An Order under section 10.1. of this By-law shall set out:
a) reasonable particulars of the contravention adequate to identify the
contravention and the location of the land on which the contravention
occurred; and
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b) the work to be done and the date by which the work must be done, or that
the activity deemed to discontinue has ceased.
10.3 An Order under section 10.1. of this By-law may require work to be done even
though the facts which constitute the contravention of this By-law were present
before this By-law came into force.
10.4 No Person shall fail to comply with an Order under section 10.1 of this By-law.
10.5 Any Order pursuant to this By-law shall be given in writing and is effective:
a) on the date on which it is delivered to the Person to whom it is addressed;
b) on the fifth day after it is sent by registered mail to the Person's last known
address; or
c) upon the sending by email transmission to the Person's last known email
address.
10.6 For the purpose of section 10.5, the Person's last known address and email
address shall be deemed to be those provided pursuant to section 4.1 of this By-
law unless notice in writing has been given to the Manager of Licensing providing
new information in which case the most recently provided information shall be
deemed correct for the purpose of providing notice hereunder.
11. Enforcement
11.1 Council hereby authorizes the Waterloo Regional Police Services or any Officer
thereof to act as agent for the City, as necessary, for the purpose of enforcing this
By-law.
11.2 The Manager of Licensing is hereby charged with the responsibility for the
enforcement of this By-law and the City Solicitor, City Clerk/Director of Legislated
Services, Director of By-law Enforcement, and any other municipal official are
hereby required to render the Manager of Licensing any reasonable assistance in
that regard.
12. Offences and Penalties
12.1 Every Person, excluding a corporation, who contravenes any provision of this
By-law or an Order made under this By-law and every director or officer of a
corporation who concurs in a contravention by the corporation is guilty of an
offence and is liable, upon conviction, to a fine not exceeding Twenty -Five
Thousand Dollars ($25,000).
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12.2 Every corporation that contravenes any provision of this By-law or an order
made under this By-law is guilty of an offence and is liable, upon conviction, to
a fine not exceeding Fifty Thousand Dollars ($50,000).
12.3 Sections 3.2, 4.5, 8.8, 9.2 10.4, and Schedules 4, 5, 6 inclusive of all
subsections thereunder, of this By-law are hereby designated as parts of this
by-law to which the Administrative Penalty By-law applies.
12.4 Any person who contravenes any Designated Provision of this By-law shall,
upon issuance of a penalty notice in accordance with the Administrative
Penalty By-law, be liable to pay an administrative penalty and any
administrative fees.
13.Collection of unpaid fines
13.1 Pursuant to section 441 of the Municipal Act, if any part of a fine for a
contravention of this By-law remains unpaid after the fine becomes due and
payable under section 66 of the Provincial Offences Act including any extension of
time for payment ordered under that section, the Manager of Licensing may give
the Person against who the fine was imposed a written notice specifying the
amount of the fine payable and the final date on which it is payable which shall be
not less than twenty one (21) days after the date of the notice.
13.2 If the fine remains unpaid after the final date specified in the notice, the fine shall
be deemed to be unpaid taxes for the purpose of Section 351 of the Municipal Act.
14. Schedules
14.1 The schedules attached to this By-law shall form part of this By-law.
15. Short Title
15.1 This By-law shall be known as the "Short -Term Rental By-law".
16. Severability
16.1 If a Court of competent jurisdiction should declare any section or part of a section
of this By-law to be invalid, such section or part of a section shall not be construed
as having persuaded or influenced Council to pass the remainder of this By-law
and it is hereby declared that the remainder of this By-law shall be valid and shall
remain in full force and effect.
17. Coming into force
17.1 This By-law shall come into force and effect on January 1, 2026.
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18. Municipal Code
18.1 The Clerk of the City is hereby directed to make this By-law a part of The City of
Kitchener Municipal Code by adding it to the concordance and arranging and
numbering it as a chapter so as to fit within the scheme of the Code.
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SCHEDULE 1
SHORT-TERM RENTAL LICENCE CATEGORIES
LICENCE CATEGORY
REGULATIONS
Short -Term Rental - Company
Schedule 4
Short -Term Rental - Principal Residence
Schedule 5
Short -Term Rental - Commercial
Schedule 6
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SCHEDULE 2
INSURANCE
1. This schedule shall apply to any Applicant that is required to submit proof of insurance.
2. Upon submitting an Application, the Applicant shall execute the following indemnity to
the satisfaction of the City:
The Licensee both during and after the term of the Licence or renewed Licence,
shall at all times, and at its own cost, expense, and risk, defend, indemnify and
hold harmless the City, its elected officials, officers, employees, volunteers,
agents, and all respective heirs, administrators, executors, successors, and
assigns from any and all losses, damages (including, but not limited to, incidental,
indirect, special and consequential damages, or any loss of use, revenue or profit
by any Person or Business), fines, penalties and surcharges, liabilities,
judgements, claims, demands, causes of action, contracts, suits, actions or other
proceedings of any kind and expenses which the indemnified City may suffer or
incur, howsoever caused, provided such losses, damages, fines, penalties and
surcharges, liabilities, judgments, claims, demands, cause of action, contracts,
suits, actions or other proceedings of any kind and expenses as defined above are
due or claimed to be due to the negligence, breach of contract, and/or breach of
law of the Licensee.
3. The Applicant shall maintain liability insurance acceptable to the Manager of Licensing
throughout the term of the Licence if the Licence has been granted.
4. The liability insurance shall consist of a comprehensive policy of public liability and
property damage insurance in an amount of not less than $2,000,000.00 per
occurrence.
5. The liability insurance shall name The Corporation of the City of Kitchener as
additional insured with a cross -liability endorsement and severability of interest
provision.
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SCHEDULE
FLOOR PLANS
1. This schedule shall apply to any Applicant that is required to submit Floor Plans.
2. The Floor Plans accepted by the Manager of Licensing shall be drawn to scale on
graph paper or digital format and include identifying the following:
a) all rooms, spaces or common areas of the Short -Term Rental;
b) how each room, space or common area shall be used, which means specifically
indicating where all Bedrooms will be located on the Floor Plan;
c) the dimensions (in meters) of all rooms, spaces or common areas;
d) dimensions of all windows;
e) location of all entrances and exits; and
f) location of all smoke and carbon monoxide alarms.
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SCHEDULE 4
SHORT TERM RENTAL - COMPANY
1. In addition to the licensing requirements set out in section 4 of the By-law; an Applicant
for a Short -Term Rental - Company Licence shall supply the following:
a) The company's registered Business address in Canada;
b) The name, title or position, telephone number, and email address of a person
responsible for responding to all communications from the City;
c) The website or app through which the applicant brokers or facilitates reservations
for Short -Term Rentals; and
d) Any other information or documents as required by the Manager of Licensing.
3. Every Short -Term Rental - Company Licensee shall:
a) Provide in a conspicuous place a field on the platform/website to allow a Licensee
to input their Licence number;
b) Provide on a quarterly basis or upon request, a list of Short -Term Rentals active
on their platform(s), including the operator ID, listing URL, and corresponding
Business Licence number;
c) Upon request remove listings that the City has deemed to be not in compliance
with by-law regulations; and
d) Keep a record of each concluded transaction in relation to a Short -Term Rental
listed or advertised on its platform for three (3) years following the last day of the
rental period. A transaction is concluded on the last day of the rental period. The
records retained shall include the following:
i) the name, address, and Licence number of the Short -Term Rental;
ii) the number of nights the Short -Term Rental was rented;
iii) the nightly and total price charged for the Short -Term Rental;
iv) Whether the rental was an entire -unit rental or room rental; and
v) Any other information required by the Manager of Licensing.
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SCHEDULE 5
SHORT-TERM RENTAL - PRINCIPAL RESIDENCE
1. In addition to the licensing requirements set out in section 4 of the By-law; an
Applicant for a Short -Term Rental — Principal Residence Licence shall supply the
following:
a) Proof of ownership;
b) If the Applicant is the lessee of the Property or if the Property is a condominium
unit, written consent from the Property owner and/or the condo board;
c) Proof of Principal Residence in the form of at least 2 of the following:
i) a copy of the Applicant's driver's licence or government -issued photo
identification card;
ii) a copy of the Applicant's most recent tax return;
iii) a copy of the Applicant's most recent property tax bill; or
iv) a copy of the Applicant's lease agreement.
d) Proof of Insurance;
e) Floor Plans;
f) The number of Bedrooms available for rent;
g) Guest Handbook; and
h) a current list of all platforms in which the Short -Term Rental is listed, advertised,
solicited, other otherwise held out for rent.
2. The Application for a Short -Term Rental - Principal Residence are subject to the
following approvals:
a) Fire Approval; and
b) Planning Approval.
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3. Every Short -Term Rental - Principal Residence Licensee shall:
a) post the Licence in a conspicuous place at the Licensed Premises;
b) have a Dedicated Responsible Person who is responsible for managing or
addressing issues in relation to the Licensed Premises and is available to attend
at all times within a period no greater than one hour for emergency issues, and
within three hours of non -emergency issues, and shall be responsible for the
day-to-day operations of the Short -Term Rental;
c) create and display at the Licensed Premises a Guest Handbook;
d) ensure the number of cars parked on the property do not exceed the number of
parking spaces which can be legally provided in accordance with the Zoning By-
law;
e) ensure that each bedroom complies with the Building Code Act and any
regulations thereto with regards to access to natural light and window
requirements;
f) ensure that each Bedroom has no more than 2 Adult occupants;
g) not hold more than one Short -Term Rental - Principal Residence Licence.
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SCHEDULE 6
SHORT-TERM RENTAL - COMMERCIAL
1. In addition to the licensing requirements set out in section 4 of the By-law; an Applicant
for a Short -Term Rental - Commercial Licence shall supply the following:
a) Proof of ownership;
b) If the Applicant is not an owner of the property or if the property is a
condominium unit, written consent from the property owner and/or the condo
board;
c) Proof of Insurance;
d) Floor Plans;
e) The number of Bedrooms available for rent;
f) Guest Handbook; and
g) a current list of all platforms in which the Short -Term Rental is listed,
advertised, solicited, other otherwise held out for rent.
2. The Application for a Short-term Rental - Commercial are subject to the following
approvals:
a) Fire Approval; and
b) Planning Approval.
3. Every Short -Term Rental - Commercial Licensee shall:
a) post the Licence in a conspicuous place at the Licensed Premises;
b) have a Dedicated Responsible Person who is responsible for managing or
addressing issues in relation to the Licensed Premises and is available to attend
at all times within a period no greater than one hour for emergency issues, and
within three hours of non -emergency issues, and shall be responsible for the day-
to-day operations of the Short -Term Rental;
c) create and display at the Licensed Premises a Guest Handbook;
d) ensure the number of cars parked on the property do not exceed the number of
parking spaces which can be legally provided in accordance with the Zoning By-
law;
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e) ensure that each bedroom complies with the Building Code Act and any
regulations thereto with regards to access to natural light and window
requirements;
f) ensure that each Bedroom has no more than 2 Adult occupants;
g) hold a separate Licence for each Short -Term Rental.
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`APPENDIX B'
SHORT-TERM RENTAL LICENSING FEES:
LICENCE TYPE:
ANNUAL FEE:
SHORT-TERM RENTAL - COMPANY
$5,000
SHORT-TERM RENTAL — PRINCIPAL RESIDENCE
$300
SHORT-TERM RENTAL - COMMERCIAL
$500
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