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HomeMy WebLinkAboutDSD-2025-248 - Evictions Due to RenovationsStaff Report J IKgc.;i' r� R Development Services Department www.kitchener.ca REPORT TO: Planning and Strategic Initiatives Committee DATE OF MEETING: June 16, 2025 SUBMITTED BY: Rosa Bustamante, Director of Planning and Housing Policy/City Planner, 519-783-8929 PREPARED BY: Katie Anderl, Project Manager - Planning, 519-783-8926 Natalie Goss, Manager of Policy and Research, 519-783-8933 Mike Balch, Planner (Policy), 519-783-8928 WARD(S) INVOLVED: All Wards DATE OF REPORT: June 4, 2025 REPORT NO.: DSD -2025-248 SUBJECT: Evictions due to Renovations RECOMMENDATION: That staff be directed to refer Path 2 initiatives to the Housing for All update for consideration and implementation; and, That staff be directed to apply for relevant new Federal and Provincial funding and support community partners to access, programs and funding sources that support the creation and maintenance of affordable rental housing; and further, That advocacy to the Province of Ontario include the proclamation and enactment of all regulations pertaining to bad faith evictions due to renovations in Bill 97, Helping Homebuyers, Protecting Tenants Act, 2023. REPORT HIGHLIGHTS: • The purpose of this report is to provide an update on `renoviction' by-laws in Ontario and to outline ways that the City may further support tenants experiencing evictions. • The key finding of this report is that while there are opportunities and challenges for the City within the space of evictions as a lower -tier municipality, the City can implement new initiatives to support tenants at risk of or experiencing bad faith evictions outside of a rental renovation license by-law through new actions incorporated into Housing for All 2.0. New initiatives should be referred to the Housing for All update. • Community engagement included an online evictions survey, and conversations with tenant support organizations, the City's Lived Expertise Working Group, and landlords. • This report supports the delivery of core services. *** This information is available in accessible formats upon request. *** Please call 519-741-2345 or TTY 1-866-969-9994 for assistance. Page 216 of 316 EXECUTIVE SUMMARY: Evictions due to renovations are one symptom of the housing crisis that is being experienced in Kitchener and across Canada. An eviction is the forced removal of a person from their home. In researching this report, lived experiences of evictions were shared that provided an understanding of the magnitude of the matter in Kitchener. Evictions are traumatizing to tenants, even when the rules are followed, and even when there is a successful outcome at the Landlord Tenant Board. Solutions to the housing crisis, including preventing unlawful evictions, require coordinated multi -jurisdictional planning, meaningful legislation, and funding and supports from other orders of government. The City of Kitchener is a leader in using tools and resources available to a local municipality to make meaningful interventions, and intentionally prioritized housing with its first housing strategy, Housing for All (HFA). HFA contains seven key priority areas and 44 actions, all of which have either been accomplished or significantly advanced as described in DSD 2025-103. A full overview of the tremendous number of housing related initiatives that have been approved, are in progress and are planned are provided in Figure 1 - Housing Related Studies and Initiatives (below). Through the Federal Housing Accelerator fund and the Provincial Building Faster Fund the City of Kitchener has seen the creation of over 9,450 new housing units since 2022, brought the purpose-built rental vacancy rate to a healthy 3-5 per cent range in October 2024 and supported the creation of over 1,000 new affordable units. Housing for All 2.0 is the next phase of Kitchener's housing strategy. Work has already begun on Housing for All 2.0 through a Housing Needs Assessment and an early draft of updated housing policies in progress through Kitchener 2051 — Official Plan. Staff recommends that the Path 2 actions emerging from this report be incorporated into Housing for All 2.0. These are new actions and initiatives that build on the work from HFA focused on continued support for tenants at risk of evictions and represent action in this area within Kitchener's jurisdiction and existing resource capacity. By incorporating Path 2 into Housing for All 2.0, staff can resource and prioritize these actions without impacting the delivery of the plans and initiatives that Council has previously directed. Path 2 does not require new staff or specialized expertise, and rather seeks to leverage partnerships and relationships with the Region of Waterloo and local tenant support organizations who have existing expertise in the space of evictions prevention. Staff recommend the following Path 2 initiatives: • support the relationship between landlords and tenants, together with community partners, the Region and other area municipalities by establishing and supporting a Landlord -Tenant Forum (including Regional and local area municipalities, the development industry, small and large landlords, service providers and tenant advocates). • create and promote robust and proactive educational resources for tenants and landlords such as in person information events, direct outreach such as delivery of information postcards to tenants residing in multiple dwellings where development is proposed or building permits have been issued and sharing information through community newsletters and neighbourhood associations. Page 217 of 316 • actively participating with the Region of Waterloo, other area municipalities, service providers and tenant advocates to collaborate on actions identified in Building Better Futures and the Plan to End Chronic Homelessness. Path 2 initiatives can be considered and scoped as part of the Housing for All updated strategy and implementation. Page 218 of 316 Cf) 4- 0 CD N 0) 0) m 0- CL 2 E (D 0 c Eo c00 0 0 0 r,4 u 'Z, = , m < 0 OL -cE E 'a -0 > Q, c Ln 0 -E o— CL cL E o X E C: cu 5 'M 0 0 Q).c0 E m' m 000 .CL m cu z CL t -C c o OD < r ' < ;� C: (V w -8 cr c) E a) UO) w 0 > c Ln 0 z 0r.4 GO N 0 a) E .0 CL C: > C) Z; QJ Q) 0 M c c 0 w j_ - u N4 W MO M 6.7 M U a on can :3 v.2 t 0 1= 0 - - J= ,, E 0 0 -C y -(u -C C) CL (V OD < 0 u w C m cr 3: C7 m E w CL 0 0 r Q cc ci m 4 2 rtF w c E 0 0 0 cc c w O ro =5 3: u C: c N —M z m o -C 0 0 -01 c E W =0 A? m C'n 0 -0 .— ID > ;-- CL c -M M CL �c '5 >W Q0, o (" W, m F= c -2 IJ Q - D- m o cc U to E W W 0 i� iZ - 0 o to v O o ci p w 0 N E a) CL < E !2rs '-E LF- 3 — 'cy 0 0 0 w a) < c o Fp C o v CLH o x to ct Ci C: 0 r_ co cc w 'a > 2 0 0 Cf) 4- 0 CD N 0) 0) m 0- REPORT: As part of Council's approval of Kitchener's Rental Replacement By-law on June 24, 2024, Council passed the following resolution related to `renoviction' By-laws: "...that staff be directed to report back in June 2025... to provide a further update on any other "renovictions" By-laws within Ontario" Renoviction is a term that combines "renovation" and "eviction", describing a situation where a landlord evicts a tenant under the pretext of renovations to the property. Such evictions can and have been used in bad faith to displace existing tenants paying a lower rent with new tenants paying a higher rent under the guise of a needed repair or renovation to illegally evict tenants. It is important to distinguish a bad faith `renoviction' from landlords who are undertaking renovations or repairs which may require a vacant unit and who follow the rules and regulations laid out on the Residential Tenancies Act (RTA). There are valid reasons for substantial renovations to a property including bringing building systems to current standards, repairing unsafe buildings, and updating units after years or decades of use. Throughout this report staff will use the term evictions due to renovation to describe the act of displacing tenants, and the eviction will be characterised as lawful or unlawful according to compliance with the RTA. There are multiple reasons for evictions, some lawful and others unlawful. One of the main forces driving unlawful evictions is economic. Over the last decade, the income potential of the housing market has become more lucrative for landlords and investors and the value of real estate and the income possible through rent has increased substantially. For dwelling units constructed before 2018, landlords are only permitted to raise rents for current tenants in accordance with provincial guideline increases (2.5% in 2023 — 2025), or for other legislated reasons such as additional services being offered, or by mutual agreement. Provincial guideline rent increases have not kept pace with market rent increases. Over time, the difference between the Provincially permitted guideline rent increase and average market rents grows, so that a tenant living in a unit for 10+ years (since 2015) may pay $600 a month ($7,500 annually) less than what could be realized by a landlord with a new tenant in the same unit (see Attachment C: Data Analysis). For landlords, evictions by lawful or unlawful means, may become a tempting proposition so that they may increase rent. For tenants with a low or moderate income, losing a rent -controlled unit can be devastating as they may not be able to find a similar unit at the same rent in the rental market. This causes a significant financial burden as the renter must now dedicate more income to secure adequate housing. The RTA permits evictions due to renovations where a building permit is secured and the extent of the renovations so extensive that vacant possession is required. The RTA outlines protections and compensation afforded to the tenant including financial compensation or an alternative unit, and permitting the tenant to return to the unit following renovations at the same rent as would have been permitted prior to renovations. Page 220 of 316 Unlawful or bad -faith evictions due to renovations can include different breaches of law and results in the displacement of tenants and causes the permanent loss of affordable market rental housing. Bad faith evictions include: • issuing eviction notices without securing proper permits or for work not extensive enough to warrant vacant possession • not allowing a tenant who has exercised their right of first refusal to return post - renovation (often by allowing a new tenant to move into the unit without providing the original tenant with notice that the unit ready for re -occupancy) • unlawfully raising the rent on a returning tenant • not undertaking or significantly delaying the renovations or repair after evicting renters. This report includes four parts. Part 1: Current Regulatory Landscape and Funding Sources Housing and affordable housing, tenancies, and evictions are governed by legislation, policies, plans and funding at all orders of government. This section discusses these regulations and funding sources. A more comprehensive jurisdictional scan of legislation and plans/funding is contained in Attachment A. Part 2: Overview of Rental Renovation License By-laws Rental renovation license by-laws are one tool that are currently being implemented and explored by municipalities in an attempt to prevent unlawful evictions due to renovation. A summary review of rental renovation license by-laws approved in Ontario is provided in this section, and a more detailed overview is contained in Attachment B. Part 3: What we Heard and Data Analysis This report includes a review of available data to start to understand the magnitude of the problem and provides a summary of qualitative data gleaned from conversations with tenants, landlords and tenant support organizations and advocates. An overview of data from the Landlord Tenant Board (LTB) and a Market Rent Analysis is included in Attachment C, and a summary of conversations with community-based tenant support organizations and landlords is included in Attachment D. Part 4: A Path Forward Ideas for action are further discussed in Part 4 of this report together with other matters for consideration depending on the path chosen for further work in the space of preventing unlawful evictions. This report contemplates several paths that will help to support and maintain affordable housing and support tenants experiencing or at risk of evictions, including unlawful evictions due to renovations. Throughout this report staff have identified actions and initiatives that are related to specific learnings. These are presented as being Path 1, Path 2 and Path 3 initiatives as follows: Path 1 initiatives represent our current path and the ambitious scope of work that supports tenants through the provision and retention of affordable housing, and supporting tenants experiencing evictions, advocating to the Province, and leveraging new funding sources. Page 221 of 316 Path 2 increases the City's focus on tenant support and preventing unlawful evictions and allows the City to efficiently direct resources in this space by leveraging relationships with the Region of Waterloo and local tenant support organizations. Path 3 is a path towards rental renovation license by-law, which seeks to support tenants experiencing unlawful evictions due to renovations by requiring the property owner/landlord to obtain a license. These paths are not mutually exclusive. The City's journey along Path 1 will continue regardless of direction to initiate work on paths 2 or 3. Staff recommend that Path 2 initiatives be incorporated into Housing for All 2.0 so that they can be prioritized within the overall work plan and do not delay delivery of other corporate priority projects. Staff do not recommend proceeding with Path 3. Part 1: Current Regulatory Landscape and Funding Sources Concerns with housing affordability, tenant rights, and evictions are felt across Canada. All orders of government are involved in addressing these issues, and there are a complex range of legislation, plans, and funding sources to support construction and retention of affordable housing and to support tenants at the Federal, Provincial, and municipal levels. A scan of relevant legislation, plans, programs and funding is included in Attachment A. The federal role in housing is to develop programs/tools to support the creation of affordable housing, provide financing tools, and to monitor housing affordability. The majority of funding for affordable housing and tenant supports is provided by the Federal government through the Canadian Mortgage and Housing Corporation (CMHC). Some of these funds are distributed by the CMHC directly to housing providers through loans and grants. Funds are also administered and distributed by other orders of government on the Federal government's behalf through provincial programs, by provincially designated service managers and by area municipalities (e.g. Housing Accelerator Fund). There are a broad range of programs and funding related to the provision and maintenance of affordable housing and affordable market housing, rent supports and tenant supports that may be available. These exist in a complex funding system for housing providers, landlords and tenants to navigate. Of note, there are currently three new programs in early stages of implementation or under development at the Federal level which directly respond to maintaining the affordability of existing units and supporting tenants. These include the: • Canada Rental Protection Fund which will help the community housing sector acquire rental apartment buildings and preserve affordability of rents over the long- term • Renter's Bill of Rights provide direction for fair and well-functioning renting and home buying systems, promoting practices such as access to home inspections and price transparency as well as addressing unfair evictions • Tenant Protection Fund provide funding to legal services and tenants' rights advocacy organizations to better protect tenants against unfairly rising rent payments, renovictions, or bad landlords Page 222 of 316 Path 1 initiative: monitor for new programs and funding sources at the Federal and Provincial levels which the City can leverage, or can assist housing providers to leverage, that support tenants experiencing evictions, or support the creation and maintenance of affordable rental housing. While the Federal government provides the majority of funding and has high-level jurisdiction over housing programs and policies, the Province has jurisdiction over rents, rent control and landlord -tenant matters through the Residential Tenancies Act, 2006 (RTA). The most effective tools to protect tenants and deter unlawful evictions that occur due to renovations reside at the Provincial level. Residential Tenancies Act, 2006 The RTA, is the Provincial legislation which establishes the rules and regulations governing the relationship between landlords and tenants in Ontario, including matters related to evictions. The RTA outlines rules for tenancy agreements and other matters such as requiring that landlords maintain their properties in a good state of repair and comply with health, safety, housing, and maintenance standards. Generally, when a tenant is evicted from their home, the tenant must be provided with a notice from the landlord which provides the landlord's reason for the eviction. A tenancy can also be terminated by mutual agreement. The LTB provides many types of forms that must be used by landlords and tenants to serve notices or to apply to the LTB for adjudication. This report and data obtained from the LTB primarily references two types of Notices: • N12 — Notice to End your Tenancy Because the Landlord, a Purchaser or a Family Member Requires the Rental Unit • N13 — Notice to End your Tenancy Because the Landlord Wants to Demolish the Rental Unit, Repair it or Convert it to Another Use There is also reference to a T5 — Landlord gave a Notice of Termination in Bad Faith. This form is used by tenants to apply to the LTB to determine if the landlord gave a N12 or N13 Notice of Termination in bad faith. Once notice has been served to the tenant, the landlord may apply to the LTB for an eviction order. The LTB adjudicates conflicts between tenants and landlords and can order evictions. A tenant does not need to vacate a unit until ordered to do so by the LTB. Tenants may request a hearing at the LTB if they feel a landlord has given a notice of termination in bad faith. A detailed review of LTB hearing processes is available from the LTB website, and a copy of the N13 and Instruction Guide are provided in Attachment E. Section 50 of the RTA specifically allows evictions when vacancy is required to complete renovations that are so extensive that they require a building permit and vacant possession. In such cases the landlord is required to: • Provide a termination date at least 120 days after the date the notice is given. • Provide financial compensation or another acceptable unit. • Advise the tenant of their right of first refusal to re -occupy the unit once renovations are completed and allow the tenant to return at the same rent as could have been lawfully charged if there had been no interruption in tenancy. Page 223 of 316 Bill 97, Helping Homebuyers, Protecting Tenants Act, 2023 Through Bill 97, Helping Homebuyers, Protecting Tenants Act, 2023 the Province has introduced additional requirements and penalties for notices to end tenancy due to repairs or renovations. These include: • Confirmation from a qualified professional stating that the repairs or renovations are so extensive that they require vacant possession of the rental unit • Providing the tenant with notification of the estimated completion date of any renovations/repairs should they indicate that they wish to exercise their right -of -first - refusal, and provide updates should this date change • Providing the tenant with notice when the unit is ready for re -occupancy and providing a minimum of 60 days for the tenant to exercise their right -of -first refusal. • Fines for unlawful eviction under an N13 have doubled from $50,000 to $100,000 for individuals, and from $250,000 to $500,000 for corporations. Bill 97 has achieved Royal Assent but certain provisions have not yet been proclaimed into force. Once in force, these changes will further support tenants experiencing evictions and are emulated in rental renovation license by-laws in other municipalities. Municipal Act, 2001 S.O. 2001, c. 25 The Municipal Act, 2001 establishes the framework for how municipalities (excluding the City of Toronto) are governed and operated, setting out their duties, roles, and responsibilities. The Municipal Act gives municipalities broad powers to pass by-laws and govern within their jurisdiction, assigning a "tier' category to each municipality. The City of Kitchener exists in a two-tier system with the Regional Municipality of Waterloo being the upper tier municipality, and the City of Kitchener being the lower tier municipality. The Municipal Act gives the City authority to pass licensing by-laws and require business licenses. In the space of housing these include the Lodging House Licensing By-law and Rental Replacement By-law which help to regulate rentals and ensure they are safe. Housing Services Act, 2011, S.O. 2011, c. 6, Sched. 1 The Housing Services Act (HSA) sets the framework for community housing in Ontario, including the roles and responsibilities of municipalities (service managers) in providing affordable and social housing. It outlines how municipalities should plan for affordable housing, social housing, and housing for people with disabilities, as well as requires planning to prevent homelessness. The HSA also establishes the criteria for service managers to provide assistance to eligible households, including rent -geared -to -income (RGI) assistance and other forms of housing assistance. The Region of Waterloo is the provincially designated service manager for the City of Kitchener and other local area municipalities. In this role, they are responsible to plan for affordable housing and ways to end chronic homelessness, by putting measures in place to house people and keep them housed; funding and providing housing and housing support services; managing wait lists for affordable housing; and overseeing affordable housing providers. The Region is funded to provide the above noted services and housing programs. These supports are complementary to any eviction prevention by-laws and provide wraparound supports to tenants experiencing or at risk of evictions. Page 224 of 316 Path 2 initiative: actively participate with the Region of Waterloo, other area municipalities, service providers and tenant advocates to collaborate on solutions identified in Building Better Futures and the Plan to End Chronic Homelessness. Building Code Act, 1992, S.O. 1992, c. 23 The Building Code Act governs building construction, renovation, demolition and change - of -use in the Province of Ontario. It sets the legal basis for the Ontario Building Code which outlines the technical and administrative requirements for building construction. The Building Code Act outlines when and under what conditions a Building Permit is required. One of the primary conditions identified in the RTA to allow an eviction due to a renovation is that the work must be so extensive that a building permit is required. The Building Code Act also provides the authority to pass Municipal Property Standards By-laws which provide a legal mechanism to ensure that all dwellings and properties are maintained in accordance with minimum health and safety standards. This suite of tools includes requirements for maintenance of heat in rented dwellings, interior and exterior minimum maintenance property standards, and lot maintenance standards. Planning Act R.S.O. 1990, c. P.13 The Planning Act, sets out the rules for land use planning. The Planning Act provides some authority to the municipality to protect and provide additional housing including establishing demolition control area by-laws, enacting Inclusionary Zoning By-laws in Protected Major Transit Station Areas, and permitting up to 3 dwelling units on most residential lots. The City has enacted zoning regulations and passed by-laws enacting and requiring such measures in Kitchener. The City has gone further to permit a broad range of housing including rental housing of all types by enabling 4 units as -of -right on most residential lots, and approving Growing Together East and West which enable more housing in major transit station areas. The Planning Act also permits the creation of a Community Improvement Project Area for housing and affordable housing — which the City is seeking to implement later in 2025. Council Approved Housing Initiatives: The City has previously approved or is currently developing and implementing numerous housing related initiatives that support the provision and retention of rental and affordable rental housing, where legislation, jurisdiction and funding exist. The City has numerous by- laws, plans, policies, incentives, and advocacy efforts that support the provision and retention of affordable housing, and support tenants that are outlined in Attachment A. These by-laws and initiatives ensure that: • rental housing is safe (through Property Standards By-laws, and Lodging House Licensing By-law) • demolitions and conversion of rental dwellings are comprehensively evaluated (through Demolition Control and Condominium Conversion policies), • in buildings with 6 or more rental units, where units are demolished they are replaced and tenants compensated (Rental Replacement By-law), • new housing of all types is enabled, including additional dwelling units on residential lots, proactively zoning to allow for more density and a greater variety of housing Page 225 of 316 and to require affordable housing in Protected Major Transit Station Areas (Enabling 4 Units, Growing Together and Inclusionary Zoning), • the City and residents benefit from opportunities afforded through funding opportunities (such as the Housing Accelerator Fund and Building Faster Fund) • Council approved incentives such as the application fee waiver for non -for-profit affordable housing providers, the property tax exemption program for affordable housing providers, and the not-for-profit affordable housing grant support the creation of new affordable forms of housing • the Province and other orders of government are aware of the challenges that are faced by our community, and the requested actions and reforms that will lead to change. Staff is of the opinion that these efforts are making a meaningful difference in creating and protecting rental and affordable housing and supporting tenants. These efforts have been bolstered by Provincial policies and incentives aimed at increasing housing supply, such as the Building Faster Fund and the Municipal Housing Pledge. Federal programs like the Rapid Housing Initiative and the Housing Accelerator Fund have further supported these efforts by prioritizing the growth of affordable and supportive housing. Through the Federal Housing Accelerator fund and the Provincial Building Faster Fund the City of Kitchener has seen the creation of over 9,450 new housing units since 2022, brought the purpose-built rental vacancy to a healthy 3-5 per cent range in October 2024 and over 1,000 new affordable units. Path 1 Initiatives: • support and incentivise the development of new supportive and affordable housing through existing planning initiatives, funding sources, Housing Accelerator Fund projects, and building on the successes of Housing for All with Housing for All 2.0. • continue to deliver the full scope of previously directed and approved housing related projects and initiatives Council Approved Motions and Actions: Council has consistently been advocating for stronger legislation regarding affordable housing and eviction protections and has taken meaningful action wherever legislation and authority exists. Council has passed the following motions and taken the following actions related to housing and affordability since 2020: • On October 5, 2020, Council requested that the Province reinstate the Planning Act provisions enabling a municipality to apply Inclusionary Zoning provisions within its entire jurisdiction, or at minimum, enable Inclusionary Zoning along Major Transit bus routes throughout the City, rather than only in Major Transit Station Areas (MTSAs). In March 2024, Council approved an inclusionary zoning framework for Kitchener within its MTSAs as is currently permitted under Provincial law. • On October 18, 2021, Council passed a resolution to take additional and meaningful steps to address the ever increasing problem of "Renovictions" and that the motion be sent to the Association of Municipalities of Ontario, the Premier of Page 226 of 316 Ontario, the Minister of Municipal Affairs and Housing, the Region of Waterloo and other Municipalities in Ontario for their consideration and possible endorsement. On September 25, 2023, Council called on the Province to double social assistance rates for ODSP and OW recipients, tie these new rates to inflation, and support Feed Canada's recommendation to stop the clawbacks. This means OW and ODSP recipients would be allowed to earn their first $1000 without penalty, and benefits such as CPP, WSIB, EI, and the upcoming Canada Disability Benefit (CDB) would be exempt from clawbacks. On January 30, 2023, Council directed staff to provide recommendations on how the City can support the transitioning of displaced residents including the review of rental replacement by-laws in Ontario. In June 2024 Council approved a Rental Replacement By-law for the City which has been successfully implemented. On October 16, 2023, Council directed staff to propose a zoning by-law amendment that would permit "as -of -right" permissions for up to four (4) residential units on a property wherever zoning permits single detached, semi-detached or street townhouse dwelling units on sufficient lot sizes and report back to Council in Q1 2024. In March 2024 Council approved Official Plan and Zoning By-law amendments to enable 4 residential units as -of -right across the City. On August 26, 2024, Council resolved that the Province amend the Residential Tenancies Act on matters related to vacancy control and rent control and strengthening process requirements for evictions. • On February 7, 2025 Ontario's Big City Manors passed a motion, tabled by Mayor Vrbanovic, calling on the Province of Ontario to proclaim and bring into force all regulations pertaining to bad faith renovictions in Bill 97, Helping Homebuyers, Protecting Tenants Act, 2023. (Bill 97 was passed in June 2023, however, regulation pertaining to bad faith renovictions have yet to be proclaimed). Path 1 initiative: that advocacy to the Province of Ontario includes the proclamation and enactment of all regulations pertaining to bad faith evictions due to renovations in Bill 97, Helping Homebuyers, Protecting Tenants Act, 2023. Part 2: Overview of Rental Renovation License By-laws: In 2019, in response to numerous complaints regarding renovictions, the City of New Westminster in British Columbia (BC) created a business license aimed to deter renovictions and to provide protection to tenants being displaced by large scale renovation work. This by-law was enacted under the BC version of the Municipal Act (the Local Government Act and the Community Charter) which authorizes municipalities to make by- laws relating to rental housing/residential tenancies and makes specific reference to the BC Residential Tenancies Act. The City of New Westminster saw a decrease in the number of reported renovictions and inquiries of concern during the time that the by-law was in effect. The By-law was repealed in 2021 as changes to the BC Residential Tenancy Act were strengthened and amended so that the license by-law became inoperative and redundant. Page 227 of 316 The City of New Westminster by-law has inspired municipalities in Ontario including Hamilton, London and Toronto, where tenants are experiencing unlawful evictions due to renovations, to explore whether similar approaches maybe possible in the context of Ontario laws and regulations. This includes measures such as Rental Renovation Licensing and By-laws that aim to prevent illegal evictions and mitigate harms to tenants. Such by-laws include new requirements for landlords, and dedicated investigation, compliance and enforcement frameworks. Staff have connected with municipalities across Ontario who have implemented or are exploring these by-laws to learn from their experiences. Staff have reviewed the approved by-laws and license requirements of Hamilton, Toronto and London, and have had conversations with staff from these municipalities to understand the current status of the by-laws, how they are being implemented and enforced, and what opportunities and challenges they are finding. Further details can be found in Attachment B. Of these, only Hamilton and London have by-laws which are in effect, however Toronto's has been approved. Municipalities including Ottawa, Mississauga and Waterloo are also either exploring such by-laws and license requirements or have been directed by their Councils to prepare by-laws for consideration. Each of Hamilton, London and Toronto have developed a slightly different approach to their rental renovation licensing by-law which responds to unique local context and challenges, and the existing and proposed complementary programs. It is important to note that these municipalities are all single tier and therefore, while the license may be managed and implemented separately from housing and tenant support programs, these municipalities are also the Provincially designated service manager, which differs from Kitchener's context. As service manager, the single tier municipality is already staffed and funded to plan for housing and homelessness, to deliver community and affordable housing programs and supports, to offer tenant supports such as tenant defense funds or rent banks and provide educational resources to tenants, which offer important wrap around services to tenants experiencing or at risk of eviction. The City of Kitchener does not have the mandate, funding, staff, expertise or other resources to provide these complementary components of an effective evictions prevention and tenant support system. Further, City staff are not trained social workers or tenant advocates, do not have specialized legal expertise in this area, and cannot advise tenants on their decisions pertaining to the evictions process. One key component and purpose of rental renovation license by-laws is that they provide municipal oversight where N13 eviction notices have been issued to tenants and provide municipal regulation to confirm that the eviction is lawful. This includes that: • an N13 notice has been issued to the tenant • the tenant is aware of their rights including right of first refusal to return to the unit • the tenant receives financial compensation (and in some cases additional rent top - ups) or is offered alternative accommodation • a building permit has been issued. Rental renovation license by-laws also go beyond confirming that the current minimum requirements of the RTA are complied with and include measures proposed by Bill 97 such as requiring that a qualified professional confirm that the proposed repair or Page 228 of 316 renovation not only requires a building permit but is so extensive that vacant possession is required. Staff have reviewed and compared by-laws as described below. Application Fees and Fines: License application fees are typically in the $600 to $700 range, and do not represent a cost recovery model. Fees are deliberately set low to avoid unintended consequences for tenants such as having landlords choosing to delay renovations, sell rather than renovate, or causing landlords to apply for above guideline rent increases. These lower application fees are contrasted with fines that are set intentionally high to disincentivize non- compliance and which can be up to $100,000. Compensation/Rent-top up: Toronto and Hamilton include provisions that require landlords to provide additional rent top -up to the average market rent for the duration of time a tenant is displaced. Toronto's by-law requires the landlord to provide for three months' rent top -up if the tenant elects not to return (this is in addition rent compensation payments required by the RTA). London's by-law does not provide for a rent top -up or alternative accommodations and instead relies on compliance with the RTA. Time and Costs: Rental renovation by-laws in these municipalities typically took anywhere from 5 to 12 months to prepare and be approved. An additional 5 to 9 months was needed to prepare for implementation before coming into effect. This allowed time for staff to draft and consult on by-laws with stakeholders, and provided for an implementation period to hire/train staff, develop processes, prepare application forms and educational materials, etc. By-law and license development and annual costs vary depending on the complexity and scope of the License By-law. Initial projections include multiple FTE's and vehicle purchases, as well as program start up costs. Hamilton and London have both taken an incremental approach to hiring and will increase staff as applications demand, and as complementary programs are implemented (such as Hamilton's Safe Apartment Building's By-law and Tenant Support Program). Toronto has approved the highest program budget of approximately $2 million (in 2026) including 14 staff, $300,000 annually for tenant education and communications, and an additional $200,000 for development of initial communication and educational materials (to be produced in multiple languages). London has allocated a lower budget of $330,000 in 2025 including 3 FTEs, and an initial communications budget. Complementary By-laws and Programs: Hamilton, London and Toronto have approved their respective rental renovation license programs together with other important and related tenant and rental support programs including safe apartment buildings by-laws and landlord/rental licenses. The City of New Westminster, BC also has complimentary tenant support programs, and social planning and by-law staff with expertise in tenant support and evictions supported preparation and implementation of the license program. These complementary programs work to provide wrap-around tenant supports and education, fund tenant defense, and create more comprehensive rental licensing programs community wide, and are listed and briefly described in Attachment B. In Kitchener, much of the planning and funding for these supports and programs rests with the Region and are implemented together with Page 229 of 316 community partners. Any investments and interventions by Kitchener should be coordinated with the Region and community partners, to ensure that works and supports are being provided efficiently and without duplication. I imitntinnc- Each municipality has been clear that the license does not prevent an N13 from being issued, a Building Permit being issued for renovation or repair work and cannot prevent LTB hearings or evictions being ordered. Licensing by-laws provide an avenue for municipal oversight of Provincial regulations and allow the issuance of licenses which permit a tenant to be displaced when criteria are met. They rely on by-law enforcement and the application of fines and additional compensation payments as a financial and bureaucratic disincentive to landlords to evict tenants. Where the rules of the RTA and any additional rules of rental replacement by-laws are followed evictions may occur. Path 3 initiative: direct the preparation and implementation of a rental renovation licensing by-law, in accordance with the considerations outlined in Part 4 of this report. Part 3: What We Heard & Data Analysis What We Heard from Tenant Support Organizations In the process of preparing this report staff had the opportunity to have conversations with a range of community-based tenant support and advocacy organizations in April and early May including: the Region of Waterloo's Plan to End Chronic Homelessness Co -Creators group, the Waterloo Region Social Development Center (WRSDC), Association of Community Organizations for Reform Now (ACORN) Canada and, Waterloo Region Community Legal Services. These organizations provided valuable insight and perspective into tenant experiences related to the evictions landscape and processes. Key themes identified by community-based tenant support organizations are summarised in Table 1, and a more detailed summary of interviews is provided in Attachment D. Staff also sought to understand what a rental renovation licensing by-law, like those in other municipalities, helped to solved or what benefits were provided. Staff learned that these by-laws fill a perceived gap in Provincial legislation and an absence of reforms to the LTB to enact or enforce regulations that protect tenants. Tenant organizations and advocates are looking to municipalities to provide accountability and oversight of Provincial legislation to ensure regulations are complied with, and that tenants' rights are protected. Further, they are looking to municipal licensing by-laws for additional financial consequences for bad actor landlords, and additional compensation for displaced tenants to ensure vacant possession is a last resort measure. Tenant support and advocacy groups as well as landlords raised concerns with the LTB. These concerns included both perceived lack of accessibility, fairness of decisions, lack of repercussions for bad actors (both bad actor tenants and landlords), and delays resulting in undue hardship (both to tenants and to landlords). With respect to delays, the LTB outlines expected service timelines on their website, and acknowledges that there were significant delays through 2023. They indicate that current service timelines have decreased significantly and most application types are currently scheduled within 5-7 months as compared to 8-10 months in 2023, and decisions are typically issued within 30 Page 230 of 316 days. They expect these timelines to continue to decrease as more files are scheduled and the backlog resolved. Table 1 — Key Themes identified by community based tenant support organizations Theme Comments Financialization of The rapid increase in property values, and coincidentally housing is driving market rents is causing rents to rise at a faster pace than evictions. income. Rent control is tied to a tenant and not a unit, therefore, when there is a change of tenants rent for the unit may be increased, causing a permanent loss of an affordable market unit. Landlords are motivated to drive or evict tenants from units being rented for less than market value in orderto increase rental income. Existing affordable Much of Kitchener's affordable market housing is in older market housing is buildings, many of which are 50+ years old. These buildings deteriorating, both require maintenance and sometimes major repairs where justifying repairs and maintenance has been deferred. Tenants are reluctant to causing poor living complain about units in poor repair as they are fearful of situations. being evicted in order for those repairs to occur. There are also reports that some landlords use the guise of repairs and renovations to evict tenants for work which may not require vacant possession. Power imbalance Several commenting groups reflected on the real or between landlords and perceived imbalance of power between landlords and tenants tenants (whereby landlords have power and tenants have little). This is further exacerbated by tenants who may not have a complete understanding of their rights, or who may have limited financial means, which both limit ability to effectively fight bad faith evictions at the LTB either due to lack of personal knowledge or lack of financial resources to obtain legal representation. While community funded legal resources are available to some low-income tenants, others may exceed the financial threshold to obtain services, or the resources may be at capacity and not able to take on additional clients. Regulations of the RTA Several organizations are critical that the regulations of the are not adequate RTA do not adequately protect tenants, and that Bill 97 needs to be enacted to provide additional protection. Commenting groups feel that there is a lack of governmental oversight and enforcement of the Provincial regulations, and that the local level of government should step in to aid enforcement. Landlord Tenant Board Several community groups commented that the landlord accessibility and fairness tenant board format can be difficult for tenants to participate in fully and meaningfully, potentially impacting outcomes. Hearings are fully virtual which can present barriers for people without access to technology (including limited data or minutes) or limited technological capabilities. Further, there are concerns that decisions are not consistent and that Page 231 of 316 Theme Comments when fines are levied, they are not sufficiently high to be an effective deterrent for a landlord, and that there is limited compensation awarded to tenants. Landlord Tenant Board Staff heard concerns from several groups about LTB backlogs backlogs and failure to provide timely decisions. These delays cause uncertainty and distress for tenants who are experiencing an eviction or who have challenged evictions which are alleged to be in bad faith. Lack of data Several organizations cited a lack of available quantitative data as a gap and noted that it is difficult to accurately describe and understand the scale of the evictions actually occurring vs. those that can be tracked. Data obtained from the LTB does not include decisions and is limited to those notices which have proceeded to the LTB for an eviction hearing. Informal evictions and those that are not challenged by the tenant or proactively referred to the LTB by a landlord, may not proceed to the LTB and are not captured. Bad -faith evictions are Several organizations indicated that while there may be a abundant lack of data, bad faith evictions are prevalent. Anecdotally, there are reports of landlords evicting tenants and not carrying out work, not providing opportunity for the displaced tenant to move back in, etc. In many cases, tenants are evicted by agreement, often using a cash -for -keys model, where the tenant is provided a lump -sum payout to agree to end the tenancy. Tenant advocates comment that while these buyouts are tempting, they are not beneficial to the tenant in the long-term. Any eviction or eviction Several organizations noted that every eviction attempt is attempt is traumatic for traumatic, and many tenants experience multiple eviction tenants attempts. This can occur while residing in the same unit (particularly if a building is sold to a new owner), or in multiple subsequent places of residence. Advocates identify that each eviction or eviction attempt causes stress, uncertainty and trauma for residents. What we Heard from those with Lived Expertise As a part of the supporting work on the rental replacement by-law, an anonymous online eviction survey was launched in February 2024. At the time of drafting this report, there have been over 150 responses. Staff were also provided the results of an evictions survey of Waterloo Region Community Legal Services. These surveys provided valuable insight into the experiences of tenants experiencing evictions and highlighted the emotional and financial cost of rental displacement. The lack of alternate housing, the pressure and coercion experienced, and the destabilization that occurs when one loses a home provided vivid illustration of hardships. The majority of responses to the City's online eviction survey 60% have been from people living in buildings with under 5 rental units and 27% from people living in buildings with 11 Page 232 of 316 or more rental units, and most units have 2+ bedrooms. The cost of rent listed by most survey respondents was $1400 or more and represented 26-50% of their total income. Approximately 30% of respondents shared that the reason they were evicted was because their home was being renovated and another approximately 33% said that they were being evicted because the landlord/owner's family member wanted to move in. Other reasons included the desire to increase rents and/or sell the property. Many survey respondents had a formal lease and were notified through an N12 notice (25%), or an N13 notice (17%). Nearly 50% of respondents reported not being offered any compensation for their evictions. When asked about their awareness of the rules that apply to landlords/tenants, 55% reported they were informed, 40% reported somewhat informed, and 4% reported having no knowledge. However, when asked about their awareness of community supports, only 28% reported they were aware, 41 % somewhat aware, and 29% reported no awareness. Staff speculate that had tenants been more fully aware of their rights, a greater proportion may have advocated for the required compensation to be provided. Path 2 initiative: create and promote robust and proactive educational resources for tenants and landlords. The survey included an opportunity for respondents to share about their eviction experiences. Many shared that they felt that they were discriminated against or that they felt bullied into paying more rent or face eviction. Others shared a concern over high demand on housing by international students and identified that rising mortgage rates were causing rents to be increased. Many expressed worry and stress over being able to find another similar affordable unit. The information and stories shared through the survey underline the significance and magnitude of eviction and displacement in Kitchener. Staff have also had conversations with the Lived Expertise Working Group (LEWG) about gaps and barriers that exist for tenants experiencing evictions and what they feel is effective about rental renovation license by-laws. The largest barriers identified included the LTB and lack of supports for those defending themselves. The LEWG also expressed concern that landlords were using coercive and intimidating tactics when attempting evictions, and that evictions are often experienced by vulnerable people including seniors and newcomers who may lack resources and knowledge to defend themselves. The LEWG indicated the benefit of these by-laws is that there is municipal oversight, proof that legislative requirements are being met and that the landlord is being held accountable. The LEWG commented that a license allows the municipality to intervene in the relationship between the tenant and landlord and lessen the power imbalance. What we heard from landlords Staff met with a member of the Small Ownership Landlords of Ontario (SOLO) to discuss their perspective on the current conditions and challenges of small-scale rental management (duplex, triplex or other types of additional dwelling units). The member highlighted that the relationship that exists between small scale landlords and their tenants can be more immediate and personal than that experienced with larger rental properties. The representative told staff about challenges experienced by small landlords including non-payment of rent, property damages and LTB backlogs, which threaten financial Page 233 of 316 viability of renting units. Unexpected and additional costs cannot be easily absorbed and have a direct impact on landlords. This risk can cause landlords to discontinue renting existing units and can cause reluctance to become a landlord in the first place. Difficult tenants and long wait times at the LTB were cited as reasons some small landlords seek alternative means of eviction, including cash payouts. The landlord stated that increased non -market, supportive, and cooperative style housing options would likely fill the gap that exists in the housing spectrum and reduce the strain on property owners. It was suggested that licensing and further regulation of renovations, works at cross-purposes to other programs and incentives which seek to increase investment and encourage renovations to increase rental housing stock. Such programs include CMHC sponsored loans for secondary suites, and new regulations that encourage homeowners to add additional dwelling units. Path 2 initiative: explore how the City can support the relationship between landlords and tenants, together with community partners, the Region and other area municipalities by establishing and supporting a Landlord -Tenant Forum (including Regional and local area municipalities, the development industry, small and large landlords, service providers and tenant advocates). Data Analysis In researching this report staff undertook a data analysis exercise in an attempt to understand the number of evictions due to renovations in Kitchener and to determine whether there is any evidence that landlords were evicting tenants illegally or in bad faith (Attachment C). However, after compiling the available information only limited conclusions could be drawn: • data obtained from the LTB is limited to those evictions which have been referred to the LTB for an eviction hearing. Informal evictions and those where a hearing is not requested by the landlord or a tenant are not documented and are not captured in these data sources. Further, N13 notices can be related to evictions due to renovation or repairs, as well as demolition or change in use. While the number of overall N13 notices that were referred to the LTB is listed, the reason is not specified. • The data confirms that despite a few anomalous years, the number of N12s and N1 3s referred to the LTB has generally shown an upward trend between 2017 and 2025. • The data obtained from the LTB shows that of the eviction notices related to units which are likely an additional dwelling unit located in a single detached, semi- detached or street townhouse dwelling, more than 70% are N12s while less than 30% are N1 3s. N1 3s are more closely tied to apartment buildings and multiple dwellings. • LTB data does show that there are certain addresses where a number of N13 notices have been issued impacting several units, and the landlord has applied for an eviction hearing at the same time. In such cases the landlord could be undertaking comprehensive work or could be systematically trying to evict groups of tenants under the guise of renovations. • a comparison of building permits to addresses where N1 3's have been referred to the LTB for an eviction hearing demonstrates that there is inconsistency with the timing of building permit application/issuance and the timing that N1 3's are referred Page 234 of 316 to the LTB. As staff do not have access to decisions of the LTB, there is limited knowledge on whether evictions have been successfully fought by tenants on the basis of a building permit being issued, and whether the presence or absence of a building permit was foundational to the decision. available data does not include information on whether tenants who have requested a right -of -first return have been afforded this right once renovations have been completed. The data that is available is not complete enough to verify the scope of the problem, and conclusions cannot accurately be drawn from this alone. Qualitative data and personal experiences shared by tenants, community organizations, and tenant advocacy groups indicates that evictions due to renovations are a substantial issue. All agree that the lack of available LTB data, and knowledge of informal evictions (for all reasons) is a significant gap. Part 4: A Path Forward Through conversations with tenant advocates and landlords, staff have a better understanding of gaps and perceived gaps in the RTA and the LTB. Through these conversations staff learned that there is a desire for municipalities to use a licensing by- law to provide accountability and oversight of evictions due to renovations, enhance tenant rights and compensation, and implement financial consequences for landlords who do not comply. However, staff also learned that these measures and additional regulation can be a barrier for some landlords. There are several ways that lower -tier municipalities can proactively be in the space of evictions prevention. This section of the report outlines 3 paths forward. Path 1 represents ongoing work that supports provision of supportive and affordable housing, evictions preventions, and ongoing advocacy efforts. This work will continue regardless of new actions contemplated by paths 2 or 3, and within existing resources. These actions represent the City's ongoing efforts to support tenants experiencing evictions and to support the provision of affordable housing. Path 2 requires reprioritization and allocation of resources through Housing for All 2.0. This work can be carried out in partnership with other orders of government and community partners with expertise in tenant support and evictions prevention. These measures are alternative approaches to achieving the benefits of a rental renovation licensing by-law. Path 3 considers a rental renovation license by-law. This scope of work will require additional resources and will take a minimum of one year to develop and implement. Path 1 The City has accomplished a tremendous amount in the housing space over the past few years including reforms to its Official Plan and Zoning by-law to enable more housing across the city in its Protected Major Transit Station Areas, city-wide by enabling 4 units to be built as of right in residential areas and by expanding permissions for lodging homes. The City has facilitated the creation of over 184 supportive homes in Kitchener with an additional 84 currently under development, has waived development and building permit Page 235 of 316 application fees for more than 1000 units, and has partnered with non -profits and developers to maximize the use of City -owned land for affordable housing. Through Kitchener's Housing Accelerator Fund we have created a Not-for-profit Affordable Rental and Co-op Housing Incentive which is set to distribute $5.2 million of the program's lifespan supporting the creation of 520 affordable units, and are in the early stages of enabling incentives for affordable housing through a new Community Improvement Plan. Staff will continue to implement these existing plans, initiatives and incentives which are making a difference in the provision of new rental housing of all types including new affordable and supportive housing in our City. The City is committed to an all orders of government approach to making marked improvements in housing supply and affordable housing. Addressing the housing crisis is a priority for both the Federal and Provincial government, and new programs and funding sources are regularly introduced. Staff recommend monitoring for new programs and funding sources at the Federal and Provincial levels which may further support tenants experiencing evictions and which support the creation and maintenance of affordable rental housing. In particular, staff recommend monitoring the Canada Rental Protection Fund to support local projects and uptake, and the Tenant Protection Fund (currently in development). Staff recommend that Council continue advocacy for legislative changes at the Provincial level to strengthen existing Residential Tenancies Act and Landlord Tenant Board processes, including advocacy for implementation of the changes proposed through Bill 97. Path 1 initiatives can be accomplished within existing resources and do not require further direction: • support and incentivize the development of new supportive and affordable housing through existing funding sources, and building on the successes of Housing for All with Housing for All 2.0 • continue to deliver the full scope of previously directed and approved housing related projects and initiatives • apply for new programs and funding sources at the Federal and Provincial levels and support community partners to access programs and funding sources that support the creation and maintenance of affordable rental housing • that advocacy to the Province of Ontario includes the proclamation and enactment of all regulations pertaining to bad faith evictions due to renovations in Bill 97, Helping Homebuyers, Protecting Tenants Act, 2023. Path 2 Path 2 supports tenants and tenants experiencing evictions of all types, without passing a rental renovation license by-law. The initiatives described in this section can be carried out in partnership with other levels of local government and community partners with expertise in tenant support and evictions prevention. These options do not require new staff expertise, however will need to be prioritized in consideration of other existing workplan priorities, and may require some funding to support actions such as development of educational materials. This work should be incorporated into Housing for All 2.0. Some Page 236 of 316 of these initiatives also work towards achieving the stated goals of a rental renovation by- law as shared by tenant advocates. The goal of these actions is to support tenants and landlords, and prevent unlawful evictions of all types, rather than focussing on evictions due to renovations. Results of the evictions survey and interviews highlighted that while most tenants are at least somewhat informed of the rules that apply through the RTA and LTB, many still feel disempowered, bullied and feel that landlords use coercive techniques to evict tenants. This concern is not limited to evictions for renovation, but for other evictions as well. While tenants can access information from numerous resources, results can be overwhelming and confusing. A key component of rental renovation licenses is provision of clear and accurate information to tenants to inform them of their rights, and to provide information about available community resources to support tenants experiencing an eviction. Dissemination of this type of information to tenants does not have to be tied to a license by-law, and there are alternative approaches to connect with tenants to help support empowered and informed decision making. The regional rental market is highly integrated, and staff suggest that creating and promoting robust and proactive educational resources for tenants and landlords could be effectively implemented by combining efforts with the Region of Waterloo and other area municipalities. This could include coordination of clear online resources, in person information events such as a tenant's fair, direct outreach such as delivery of information postcards to tenants and sharing information through community newsletters and neighbourhood associations. Allocation of staff resources to support the development of educational materials for tenants and landlords will help to support tenants experiencing evictions of all types, rather than being limited to tenants experiencing evictions due to renovations. In researching this report staff also attempted to connect with local landlord organizations. Staff were able to connect with the Small Ownership Landlords of Ontario, however found that several pre-existing local landlord organizations were not currently active. Staff feel that this lack of support and joint leadership for local landlords is a current gap. Other jurisdictions such as London facilitate and support a landlord/tenant roundtable or forum for those involved with rental accommodations. Such a group would bring together landlords, not-for-profit housing providers, developers, service providers, tenant advocates and local government to share information, facilitate connections, and enhance relationships among stakeholders. Staff suggest that resources could be allocated to creating such an association, and that it be modelled on a "Town and Gown". Such a group would be able to provide informed and timely feedback on local challenges, including evictions, and initiatives associated with rented accommodations and other issues of common interest between landlords and tenants. Such a forum also allows the municipality to be better connected to tenants and landlords, to facilitate the exchange of ideas, and find and be part of solutions. Finally, there are opportunities to collaborate with other area municipalities and the Region of Waterloo as well as tenant advocacy groups with existing mandate and expertise. Over the past few months, staff have had the opportunity to participate in the Region of Waterloo's Plan to End Chronic Homelessness Co -Creators group and have had meaningful conversations with tenant support workers and advocates. The Plan to End Page 237 of 316 Chronic Homelessness (PECH) and Building Better Futures (BBF) identify that collective action between all levels of government, including area municipalities, is required to successfully address the homelessness crisis. For example, the PECH envisions a Whole of Community Leadership Table to work together to deliver on housing objectives and reduce inflow into chronic homelessness. Local area municipalities play an important role in achieving the actions of both PECH and BBF and directing resources to support this work will be meaningful and impactful and will ensure that resources are aligned and coordinated in order to provide the greatest benefit to support tenants experiencing evictions. Path 2 initiatives identified in this report include the following: • explore how the City can support the relationship between landlords and tenants, together with community partners, the Region and other area municipalities by establishing and supporting a Landlord -Tenant Forum (including Regional and local area municipalities, the development industry, small and large landlords, service providers and tenant advocates) modelled on a Town -and -Gown type of program • create and promote robust and proactive educational tools for tenants and landlords • actively participate with the Region of Waterloo, other area municipalities, service providers and tenant advocates to collaborate on actions identified in Building Better Futures and the Plan to End Chronic Homelessness. Path 2 initiatives should be incorporated into Housing for All 2.0. Any immediate actions are contingent on a reprioritization of existing work and may impact delivery of other housing related initiatives. Path 3 As has been seen in other Ontario municipalities, licensing by-laws have been adopted under the non -explicit authority of the Municipal Act requiring licenses to renovate rental units. A rental renovation licensing by-law provides the opportunity to: • increase municipal oversight to ensure that the Residential Tenancies Act process is followed by landlords. • provide a financial disincentive to landlords seeking to issue an N13 notice. • provide an opportunity for municipalities to provide proactive support to tenants to advise of rights and regulations and provide connections to community resources. Despite the opportunities associated with a rental renovation licensing by-law, staff note the following challenges: • The Residential Tenancies Act and Landlord Tenant Board are the jurisdiction of the Province and exist to regulate and enforce the relationship between landlords and tenants. Regulations in a license by-law cannot supersede these regulations and the presence or absence of a license requirement cannot change the outcomes of LTB proceedings. Page 238 of 316 • Effectiveness is not proven. Hamilton, London, and Toronto have approved rental renovation licensing by-laws. However, only Hamilton and London's are currently in effect. Hamilton received its first application under its by-law at the beginning of May. Given the infancy of these by-laws, it continues to be too soon for staff to evaluate the effectiveness of these Ontario licensing by-laws in preventing evictions. • Rental Renovation licenses are limited in scope. These by-laws only regulate renovations or repairs to units, and do not regulate other types of evictions such as evictions for personal use which could be used as an alternative bad -faith eviction tactic or negotiated evictions using `cash -for -keys' and other coercive tactics. The only mechanism to address bad -faith evictions is through the LTB processes. • By-law may have a limited lifespan. The City of New Westminster Council supported the preparation and implementation of a licensing by-law as part of a larger body of tenant protections. Their by-law was in place from 2019-2021 and was subsequently repealed by Council and found redundant with the British Columbia Provincial government updated Provincial legislation similarto the changes being contemplated in Ontario through Bill 97. • A rental renovation licensing by-law will not stop a lawful eviction process. Evictions will continue in accordance with the RTA and LTB proceedings. • A building permit cannot be withheld pending the issuance of a rental renovation license. Staff explored whether, through the powers afforded by the Municipal Act and the Building Code Act, it was possible to withhold building permits until a rental renovation license is issued. Staff found that licensing by-laws are not applicable law under the Building Code Act and as such a building permit cannot be withheld. Building Division staff have confirmed that they will not issue a building permit when one is not required and in fact have cancelled permits in these circumstances, thereby not facilitating the conditions of a lawful eviction when the criteria of requiring a building permit is not truly met. • A rental renovation licensing by-law cannot compel or prevent the issuance of an N13. The rental renovation licensing by-laws in other Ontario municipalities are triggered when an N13 notice is issued. However, should the city become aware of the issuance of an N13, they can require that a license be obtained and fines can be levied under the by-law for not obtaining the license or complying with conditions. • A rental renovation licensing by-law does not provide wrap around tenant support. Despite Kitchener's authority to enact licensing by-laws, unlike Hamilton, London, and Toronto, the City is not a (housing) services manager, does not have expertise in nor the resource capacity to support or provide advice tenants experiencing evictions, provide funding for legal representation at the LTB, or provide rent gap payments to assist tenants at risk of homelessness. Should Council direct the preparation of a rental renovation license by-law, the following should be considered through the by-law preparation process: • Whether to place focus on providing oversight and enforcement of existing RTA regulations, or whether the by-law should enhance supports for tenants. • Whether a by-law can be effectively implemented in the absence of other licenses (such as a landlord license or safe apartments license) and tenant supports typically provided by the provincially designated service manager. Page 239 of 316 • Whether additional tenant compensation should be built into the by-law and if so, how this is administered. • How a by-law can best work along side the Residential Tenancies Act and Landlord Tenant Board requirements and processes. Additionally, the following comprises necessary next steps and timing: • Immediate -The establishment of a dedicated staff team with expertise in licensing, by-law enforcement, social work/tenant support, and building code. • Summer/Fall 2025 - Continued conversations with advocates and landlords. • Earliest December 2025 - A report back no earlier than December 2025, provided that a dedicated staff team can be established in short order, that includes a proposed by-law and outlines a communications and implementation plan including any staffing resources. • Minimum January to June 2026 — education and outreach on the licensing requirements and obtaining necessary staff resources. Path 3 identified in this report is a Rental Renovation License By-law. This path is contingent on both: • a reprioritization of existing work and initiatives related to the provision and preservation of affordable housing, and will impact delivery of other housing related initiatives, and • dedication of additional staffing resources with an expertise in the area of evictions and tenant support, and by-law enforcement to administer and implement the new license requirements. STRATEGIC PLAN ALIGNMENT: This report supports the delivery of core services. FINANCIAL IMPLICATIONS: Capital Budget — The recommendation has no impact on the Capital Budget. Operating Budget — The recommendation has no impact on the Operating Budget. However, depending on the direction of Council, Path 3 as outlined in this report will have financial and resourcing implications. Should Council direct staff to proceed with a rental renovation license by-law, a full financial assessment will be included in a subsequent report back. Any additional work in this space will require dedicated resources with relevant expertise in this area. Early estimates for the continued exploration, development, and implementation of a rental renovation licensing by-law can be expected to start at $300,000 with additional funds for annual implementation. COMMUNITY ENGAGEMENT: INFORM — This report has been posted to the City's website with the agenda in advance of the council / committee meeting. Page 240 of 316 CONSULT — In researching this report, staff consulted with a range of community partners, tenant advocates and those with lived expertise including: • Waterloo Region Co -creators (Regional Plan to End Chronic Homelessness) • Social Development Council of Waterloo Region • Association of Community Organizations for Reform Now (ACORN) Canada • Waterloo Region Community Legal Services • Lived Expertise Working Group • Residents experiencing evictions through the online evictions survey • Small Ownership Landlords of Ontario PREVIOUS REPORTS/AUTHORITIES: • DSD -24-282 Rental Replacement By-law • DSD -25-051 Evictions due to Renovations — report back timing REVIEWED BY: Kristin VanDerGeld, Manager, Licensing Katherine Hughes, Assistant City Solicitor Gloria MacNeil, Director, Bylaw Enforcement Amanda Fusco, Director, Legislated Services/City Clerk Mike Seiling, Director Building/Chief Building Official Shannon Weber, Chief of Staff Sloane Sweazey, Senior Policy Advisor APPROVED BY: Justin Readman, General Manager, Development Services Victoria Raab, General Manager, Corporate Services ATTACHMENTS: Attachment A — Jurisdictional Scan of Legislation and Plans/Funding Attachment B — Review of Rental Renovation License By-laws approved in Ontario Attachment C — Data Analysis Attachment D — What We Heard - Summary of Interviews Attachment E — N13 Form and Instructions Page 241 of 316 Attachment A - Jurisdictional Scan of Legislation and Plans/Funding Housing and affordable housing, tenancies and evictions are governed by legislation, policies and planning at all levels of government. This section discusses existing legislation and funding sources. Table of Contents: Part 1 — Federal Legislation, Programs and Financial Supports Part 2 — Provincial Legislation, Programs and Financial Supports Part 3 — Region of Waterloo Plans, Programs and Financial Supports Part 4 — City of Kitchener By-laws, Policies and Financial Incentives Page 242 of 316 Attachment A - Jurisdictional Scan of Legislation and Plans/Funding Part 1 - Federal Legislation, Programs and Financial Supports The federal government offers a variety of housing programs to support affordable housing and address the housing crisis in Canada. These programs include funding for social housing, rental assistance, and initiatives to encourage new home construction. National Housing Act: promotes the construction of new houses, the repair and modernization of existing houses, and the improvement of housing and living conditions. • Provides financial assistance for homeownership, including loans and contributions. • Supports the construction of low -rental housing for low-income families. National Housing Strategy Act (NHSA): recognizes housing as a fundamental human right and to commit the federal government to further the progressive realization of that right. • Recognizes the need to focus government efforts on the needs of vulnerable groups and individuals with lived experience of housing need or homelessness. • Requires the government to implement reasonable policies and programs to ensure the right to housing for all. • Establishes accountability tools to support and monitor the right to housing in Canada. Affordable Housing and Groceries Act: removes the Goods and Services Tax (GST) from new rental housing to incentivize the construction of more apartment buildings, student housing, and seniors' residences built for long-term rental accommodation. Prohibition on the Purchase of Residential Property by Non -Canadians Act: prevents non -Canadians from purchasing residential property in Canada for 2 years. The Act applies to non -Canadians, including corporations and entities not listed on a stock exchange in Canada, and controlled by non -Canadians. Financial Supports for Rental Housing and Tenants The Canadian Mortgage and Housing Corporation delivers the government's housing programs. Programs related to creation and preservation of rental and affordable rental housing include: Affordable Housing Fund: Provides funding to support affordable housing projects. Affordable Housing Innovation Fund: Supports innovative solutions in housing development, including testing new ideas and exploring different approaches. Apartment Construction Loan Program: Offers low-cost loans to builders and developers to construct new rental apartments. Page 243 of 316 Attachment A - Jurisdictional Scan of Legislation and Plans/Funding Canada Builds: combining federal low-cost loans with provincial and territorial investments to scale up construction on rental homes. Canada Housing Benefit: a rental subsidy for low-income, Indigenous, and newcomer families, funded by both federal and provincial governments. Canada Rental Protection Fund: will provide $1.47 billion to create a new source of capital to help the community housing sector acquire rental apartment buildings and preserve affordability of rents over the long-term. The program will help mobilize investments and financing from the charitable sector, private sector, and other orders of government (open for applications). Community Housing Acquisition Program: a program to help acquire and preserve existing social housing. CMHC Refinance: insured financing to allow homeowners to fund the construction of self-contained secondary suites. Federal Community Housing Initiative: provides rental assistance to low-income households living in housing co-ops and non -profits. Federal Lands Initiative: transfers surplus federal lands and buildings to eligible proponents for affordable housing development. Housing Accelerator Fund: supports municipalities in removing barriers to housing supply and accelerating new home construction. Property Tax Exemption Program: provides tax exemptions to affordable housing providers to help with acquiring and maintaining buildings. Public Lands for Homes: unlocking government surplus, underused and vacant lands across the country. Rapid Housing Initiative: focuses on rapid construction of affordable housing, particularly for vulnerable populations. Seed Funding: interest free loans and non -repayable contributions to development affordable housing Page 244 of 316 Attachment A - Jurisdictional Scan of Legislation and Plans/Funding Federal Programs in Development Housing Design Catalogue: provides standardized housing designs, which will reduce the time required for design, approvals, and construction while supporting new and innovative construction methods. Renter's Bill of Rights: provide direction for fair and well-functioning renting and home buying systems, promoting practices such as access to home inspections and price transparency as well as addressing unfair evictions. Tenant Protection Fund: provide funding to legal services and tenants' rights advocacy organizations to better protect tenants against unfairly rising rent payments, renovictions, or bad landlords. Page 245 of 316 Attachment A - Jurisdictional Scan of Legislation and Plans/Funding Part 2 - Provincial Legislation, Programs and Financial Supports The following is a review of the legislative framework that exists in Ontario that governs rental tenancies, municipal authority to and responsibilities to pass by-laws and require licenses, and planning and building legislation related to maintenance of affordable housing, and issuance of building permits. Residential Tenancies Act, 2006 The Residential Tenancies Act, 2006, S.O. 2006, c. 17 (RTA) sets out the rights and responsibilities of landlords and tenants who rent residential properties. The RTA establishes the Province's responsibility for regulating rental housing, and sets out regulations governing the relationship between landlords and tenants in Ontario. Regulations set out the rules for entering into a tenancy, ending a tenancy (including evictions), and resolving disputes between landlords and tenants. Tenancies may only be terminated in accordance with the RTA. There are a range of Landlord Tenant Board (LTB) forms which are required to be used by landlords and tenants (see Table 1). Table 1: Landlord Tenant Board Forms Form Purpose N 11 (Agreement to End the This is a standard agreement form used by a landlord Tenancy) and tenant to mutually agree to end a tenancy. N 12 (Notice to End your Tenancy This form is used by a landlord to notify a tenant that Because the Landlord, a Purchaser they are seeking to end the tenancy because the or a Family Member Requires the landlord, a family member of a purchaser requires the Rental Unit) unit. N 13 (Notice to End your Tenancy This form is used by a landlord to notify a tenant that Because the Landlord Wants to they are seeking to end or the tenancy because they Demolish the Rental Unit, Repair it or are demolishing the unit, converting it to another use, Convert it to Another Use) or are undertaking repairs or renovations that require vacant possession. L2 (Application to End a Tenancy This form is used by the landlord to apply to the LTB and Evict a Tenant or Collect Money) to evict a tenant and is used after an N12 or N13 notice has been issued. T5 (Landlord gave a Notice of This form is used by the tenant to apply to the LTB to Termination in Bad Faith) determine if the landlord gave a Notice of Termination in bad faith. The RTA permits landlords to legally evict tenants for a number of circumstances based on the tenant's conduct including: • not paying the rent in full or persistently paying the rent late Page 246 of 316 Attachment A - Jurisdictional Scan of Legislation and Plans/Funding • causing damage to the rental property • illegal activity • affecting the safety of others • disturbing the enjoyment of other tenants or the landlord • allowing too many people to live in the rental unit ("overcrowding") and for other reason's for which the tenant is not responsible: • The landlord wants the rental unit for their own use or for the use of an immediate family member or a caregiver • The landlord has agreed to sell the property and the purchaser wants all or part of the property for their own use or for the use of an immediate family member or a caregiver • The landlord plans major repairs or renovations that are so extensive that they require a building permit and vacant possession • The landlord plans to demolish the rental property Secfiori i 50 of the IRT/ specifically allows eviction when vacancy is required to complete renovations that are so extensive that they require a building permit and vacant possession. When a landlord exercises their rights under section 50, they are obligated to: Provide a termination date at least 120 days after the date the notice is given, and no sooner than the last day of the rental period. Advise the tenant of their right of first refusal to re -occupy the unit once renovations are completed, and allow the tenant to return at the same rent as could have been lawfully changed if there had been no interruption in tenancy ((Secfiori i 153 of the I RTA),) Provide financial compensation or another acceptable unit. Compensation is equal to three months rent (or less if they are displaced for less than three months and the tenant exercises their right -of -first -refusal). This is reduced to one month rent for a building in a complex with four or fewer residential units. It is noted that compensation is not required if the renovation is due to an order under the RTA or any other Act such as the Building Code Act (Section 54 of t[ -ie IG . "M The RTA also provides remedies for tenants who have been illegally evicted, who have been evicted in bad -faith, or who feel that the eviction does not align with requirements of the act through the Landlord Tenant Board (LTB). If a tenant seeks to challenge an eviction they do not need to vacate a unit until ordered to do so by the LTB. Bill 97, Helping Homebuyers, Protecting Tenants Act, 2023 Through Bill 97 the Province has introduced additional requirements and penalties for notices to end tenancy due to repairs or renovations. These include: Page 247 of 316 Attachment A - Jurisdictional Scan of Legislation and Plans/Funding • A requirement for a report from a qualified professional stating that the repairs or renovations are so extensive that they require vacant possession of the rental unit • Providing the tenant with notification of the estimated completion date of any renovations/repairs should they indicate that they wish to exercise their right -of - first -refusal, and provide updates should this date change • Providing the tenant with notice when the unit is ready for re -occupancy, and providing a minimum of 60 days for the tenant to exercise their right -of -first - refusal. • Fines for unlawful eviction under an N13 have doubled from $50,000 to $100,000 for individuals, and from $250,000 to $500,000 for corporations. Bill 97 has achieved Royal Assent but has not yet been proclaimed into force. Municipal Act, 2001 S.O. 2001, c. 25 The I uir lii lii )6� Act 2001 S.C. 2001 25 sets out the rules for municipalities and gives broad powers to pass by-laws and govern within their jurisdiction. The City of Kitchener exists in a two-tier system with the Regional Municipality of Waterloo being the upper tier municipality, and the City of Kitchener being the lower tier municipality. Each tier has distinct roles, responsibilities and powers. There are both disconnects and overlaps in the responsibility of the upper and lower tier municipalities in the planning, delivery and management of housing. The Municipal Act empowers municipalities to address health and safety, well-being, consumer protection, and nuisance control through licensing by-laws — and this has been interpreted by other municipalities to permit the City to require a license for rental renovations. Housing Services Act, 2011, S.O. 2011, c. 6, Sched. 1 The Housing Services Act sets the framework for community housing in Ontario, including the roles and responsibilities of municipalities (service managers) in providing affordable and social housing. It outlines how municipalities should plan for affordable housing, social housing, and housing for people with disabilities, as well as prevent homelessness. The HSA also establishes the criteria for service managers to provide assistance to eligible households, including rent -geared -to -income (RGI) assistance and other forms of housing assistance. The Region of Waterloo is the provincially designated Service manager for the City of Kitchener and other local area municipalities. In this role, they are responsible to plan for affordable housing and ways to end chronic homelessness, by putting measures in place to house people and keep them housed, funding and providing housing and housing support services, managing wait lists for affordable housing and overseeing housing providers. The Region is funded to provide these services and housing programs. Building Code Act The Fulillkdfiliru Lode Act 1902' . 1992 2 is the legislation that governs building construction, renovation, demolition and change -of -use. It sets the legal basis for the Ontario Building Code which outlines the technical and administrative requirements for building construction. The Building Code Act outlines when and under what conditions a Page 248 of 316 Attachment A - Jurisdictional Scan of Legislation and Plans/Funding Building Permit is required. Building permits must be issued in accordance with applicable law. Applicable law is prescribed in the OBC and would not include a rental renovation licensing by law. This could result in an obligation on the part of Building Services to issue building permits for "renovictions" even where there is non-compliance with a rental renovation licensing by-law. Planning Act The IRIair ii'i in gt IR� S% . '1990 c. I � 13 sets out the rules for land use planning. The Planning Act provides some authority to the municipality to protect and provide additional housing including establishing demolition control area by-laws, enacting Inclusionary Zoning By-laws in Major Transit Station Areas, and permitting up to 3 dwelling units on most residential lots. The City has enacted zoning regulations and passed by-laws enacting and requiring such measures in Kitchener. The Planning Act also permits the creation of a Community Improvement Project Area for housing and affordable housing. The Planning Act does not provide authority to regulate tenure or tenancy as it relates to rental accommodation. Under provincial legislation, the City and Region play different roles in planning for housing. As outlined in the Housing Services Act the Region of Waterloo is responsible to plan for housing and homelessness and administering related programs. The City is responsible for land use planning matters including planning for a variety and range housing, building permits and inspections, property and building maintenance standards, and has the ability to pass by-laws relating to licensing. The City has used Municipal Act regulations for such things as Short Term Rental Accommodation By-law (in development), Lodging House By-law, Rental Replacement By-law, and Municipal Property Standards By-law which all help to regulate rentals and ensure they are safe. The Municipal Act empowers municipalities to address health and safety, well-being, consumer protection, and nuisance control through licensing by-laws — and this has been interpreted by other municipalities to permit the City to require a license for rental renovations. Provincial Programs and Financial Supports: Ontario Priorities Housing Initiative: This initiative provides flexible funding to address local housing priorities and improve access to affordable housing options. It aims to increase affordable housing supply and improve the state of repair of existing affordable housing. Ontario Renovates: This program provides funding for the creation and repair of affordable housing, focusing on improving the state of repair of existing affordable housing stock. Page 249 of 316 Attachment A - Jurisdictional Scan of Legislation and Plans/Funding Part 3 — Region of Waterloo Plans, Programs and Financial Supports The Region of Waterloo is the Provincially designated service manager for housing and homelessness in the region, leading efforts to coordinate with community partners, municipalities, and provincial/federal governments to address these complex issues. This includes: • administer and fund subsidized housing • own and operate community housing units managing wait lists for affordable housing, including housing with supports • supporting tenants find and keep market housing including funding for tenant support services • working to create affordable housing options • operate and fund shelter programs • planning for housing needs and ways to end homelessness. • putting proactive measures in place to help house people • funding and providing housing services directly or through community partners. • creating incentives and policies that encourage a broad range of housing Plan to End Chronic Homelessness The purpose of this work is to provide a "roadmap for strategies, resources and timelines to end chronic homelessness in Waterloo Region". Regional Council has directed Regional staff to work with community to develop a suite of policy incentives supporting the creation of new affordable housing and/or for preventing the loss of existing affordable housing stock and tenant displacement in Waterloo Region and bring forward any further recommendations to Regional Council for consideration and approval. The staff report also directs Regional staff to "work with area municipalities to develop and implement housing programming and policy that prevents displacement and the loss of existing affordable housing". Building Better Futures Building Better Futures: 2,500 Homes in 5 Years, is the Region of Waterloo's affordable housing strategy. The strategy aims to develop up to 2,500 new homes by the end of 2025, increasing affordable housing generated from an average of 50 homes per year to 500 homes per year. Currently at 2,350 new homes in development, the Region of Waterloo is committed to making housing affordable for all because we believe communities thrive when everyone has a place to call home. With the need for affordable housing growing, the Region is dedicated to increasing the number of affordable homes. The plan includes the use of lands, funding and resources, community engagement, acquisition programs that increase non -market housing stock, and cross departmental staff support to increase the development of affordable homes. Rent Supplement Program The Region will cover the gap between how much a landlord charges for rent and how much the tenant can pay. Page 250 of 316 Attachment A - Jurisdictional Scan of Legislation and Plans/Funding Property Tax Exemption The Property Tax Exemption Program allows participating affordable housing providers to have the Region, City and education property taxes exempt to help them acquire and maintain buildings and keep rents low in the long-term. The program aims to maintain affordable housing buildings that exist in the Waterloo Region, and support housing providers who are committed to affordable rents. Administer Ontario Renovates Program Forgivable loan program to assist low to moderate income ownership households to make repairs, add secondary suites, and improve accessibility to allow people to remain in their homes. Renter's Toolkit (Tenant Education Program) A guide to help renters search for and secure housing, deal with issues that come up as a tenant, or help you plan your next move. Tenant Defense Funding The Region provides funding assistance to the Waterloo Region Community Legal Services, a non-profit organization that provides free legal services to low-income residents of the Waterloo region, including providing housing related legal services. Page 251 of 316 Attachment A - Jurisdictional Scan of Legislation and Plans/Funding Part 4 - City of Kitchener By-laws, Policies and Incentives: The City of Kitchener is a leader in utilizing available tools and resources to make meaningful interventions and support the provision and retention of rental and affordable rental housing. Property Standards By-law The Property Standards By-law and associated By-laws under the Municipal Code are an existing legal mechanism to ensure that all dwellings and properties are maintained in accordance with minimum health and safety standards. This suite of tools includes requirements for: - Maintenance of heat in rented dwellings - Interior and Exterior minimum maintenance property standards - Lot Maintenance Standards to keep lands free and clear of waste Demolition Control By-law: Demolition Control applies to the demolition of any dwelling unit within the Demolition Control Area, which includes any residential building, or any building containing one or more dwelling units and is permitted under section 33 of the Planning Act. The purpose of demolition control is primarily to prevent the premature loss of viable housing stock and the creation of vacant parcels of land. Demolition control applies to both rented and owner -occupied dwellings. Demolition Control Permit must be approved before a demolition permit can be issued by the City's Chief Building Official to physically remove the structure. Demolition Control also applies to any former residential dwelling that has been converted to non-residential use. Rental Replacement By-law: The City of Kitchener's Rental Replacement By -Law is a tool designed to protect and preserve rental housing which is proposed to be demolished. This policy provides stability and compensation to Tenants affected by development and provides a path for development without displacement. It balances the interrelated policy goals of creating new housing supply and preserving the health and diversity of the city's most affordable rental housing, its existing purpose-built rental housing stock. The Rental Replacement By-law does not prevent large-scale redevelopment of existing rental housing properties, so long as compensation to Tenants and the replacement of rental units occurs. Applications to demolish or convert more than six dwelling units will require a Rental Replacement Permit. Under the Rental Replacement By-law, Tenants are offered the choice of a replacement unit, a rent waiver or compensation, and replacement units would be required to be provided at affordable rents for 10 years. The Rental Replacement By-law disincentivizes proposals to redevelop existing rental properties without contributing substantially to housing supply. The Rental Replacement By-law was approved under the authority of Section 99.1 of the Municipal Act, 2001 on June 24, 2024 by Kitchener City Council. Page 252 of 316 Attachment A - Jurisdictional Scan of Legislation and Plans/Funding Zoning By-law: Inclusionary Zoning - Inclusionary Zoning (IZ) is a planning tool that requires a certain percentage of affordable housing units within new private developments. The program does not rely on government subsidies, but instead captures some of the increased value arising from high density development and directs it towards affordable housing. Inclusionary zoning is approved and will be in effect beginning in January 2026. Growing Together West & East — This new policy and zoning framework enables more housing and mixed-use projects in transit supportive areas, moving the City towards its housing goals. Enabling Four Units — This zoning initiatives enables up to 4 dwelling units on many lots that permit a single detached, semi-detached or street -townhouse dwelling, allowing additional rental units throughout all residential neighbourhoods. Short Term Rental By-law (under consideration): The Short -Term Rental By-law provides a licensing framework for properties used as short-term rentals. 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. The proposed regulations 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, and neighbourhood concerns. Lodging House By-law: The Lodging House By-law is structured to provide opportunities for more affordable housing types throughout Kitchener and to ensure that shared accommodations are safe for occupants. Lodging Houses are properties where residents rent individual rooms but share common areas, and this important component of the housing continuum is permitted in all residential zones, subject to licensing. Official Plan Policy on Condominium Conversions: Policies of the Official Plan provide a framework to guide the review of Plan of Condominium applications which seeks to convert rental affordable housing to condominium ownership. Matters including rental vacancy rates, creation of affordable ownership housing, and that tenant protection measures in accordance with the RTA are met. Housing for All & Housing for All 2.0: As local area municipality, Kitchener has found creative ways to support and contribute to the provision of housing and it has seized as many opportunities as possible to provide solutions to the housing affordability crisis. Kitchener intentionally prioritized housing with its first housing strategy, Housing for All (HFA) which was approved by Page 253 of 316 Attachment A - Jurisdictional Scan of Legislation and Plans/Funding Council in 2020. HFA is Kitchener's comprehensive strategy to realize the right to housing and help make housing affordable using the tools and resources available to a local municipality. Housing for All 2.0 is the next phase of Kitchener's housing strategy. Work has already commenced on Housing for All 2.0 with early work on a Housing Needs Assessment and updated housing policies in progress through Kitchener 2051 — Official Plan. City of Kitchener Incentives that Support Housing: Not-for-profit Affordable Housing Fee Incentive Policy: This program encourages development of new affordable rental housing units through development application fee and building permit fee exemptions. Priority Review and Concierge Services for Affordable Housing Development The City has created a concierge application service to assist developers seeking approval of development applications for affordable housing. This service helps to streamline review processes, resolve concerns quickly in order to deliver more affordable housing, more quickly. Property Tax Exemption The Property Tax Exemption Program allows participating affordable housing providers to have the Region, City and education property taxes exempt to help them acquire and maintain buildings and keep rents low in the long-term. Housing Accelerator Fund Supported — Affordable Housing Incentives: Not-for-profit affordable rental and co-op housing incentive (pilot): This program provides a grant of $10,000 per unit (up to a max of 50 units per project) for not-for-profit affordable rental or co-op housing units. The grant can cover non - capital upfront costs relating to site design and development approvals to help advance projects from an idea to being shovel ready. Strategic Land Acquisition and Land Contributions Supporting Affordable Housing Projects: The City of Kitchener is unlocking lands to build not-for-profit housing. This initiative, aimed at creating long-term solutions to the housing crisis. Community Improvement Plan (in development): Through the Housing Accelerator Fund initiative, a Community Improvement Plan to further incentivize a range of housing types, including much needed missing middle housing, will be development. 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This included N12 (Landlord, Purchaser or Family Member moving in), N13 (Demolition or Repair), and T5 (Termination in Bad Faith submitted by a tenant) applications that had been reviewed over that period. In March 2025, staff requested updated data to fill in the gap between July 2023 and the present day. This combined data is provided in Table 1 below. II""a[.)11e 1 Landlord Tenant Board N12, N13, and T5 Eviction Data Year N12 N13* T5 2017 134 15 5 2018 32 10 15 2019 67 21 4 2020 49 7 4 2021 76 17 5 2022 132 28 27 2023 103 57 32 2024 94 60 29 Jan 1, 2025 — March 11 16 4 31, 2025 *The data source includes N13 issued for evictions related to demolition, change -in -use, and renovation repair, and does not distinguish between these. "These summary values that have been provided by the LTB are separate from the aggregate values provided in the raw data that staff have reviewed. There are some discrepancies from what is shown here, and in the analysis below, which is likely the result of the removal of records without applicable forms, and potential repeat applications. The data provided from 2022 and 2025 included a greater level of detail, which staff was able to cross reference between the different application types and compare building permit data over the same period. Staff have chosen to review this aggregate data as it was provided by the LTB to ensure consistency and avoid any omitted values. Of the 144 T5 records received over this time period, 33 aligned with either an N12 or N13 in the same unit or building. This data might be limited due to the potential for buffer period between the initial eviction filing, and the submission of a T5 to the Landlord Tenant Board. For example, a T5 filed in 2022, might be in response to an N12/13 filed in 2021, when our data was less comprehensive. Page 262 of 316 Attachment C: Data Analysis Over this period, 300 building permits were applied for and considered for renovations to multiple dwellings. This includes permits which were closed, cancelled and issued. Of these, there were 43 instances where addresses listed in the eviction data matched the addresses of a building permit. 41 of these instances were N13 evictions, which when compared to the total of 162 N13s during this period, results in a 25.3% correlation. While the exact characteristics of the units referenced in this data are not explicitly stated, some can be assumed based on the associated verbiage to be of a smaller scale. For example, words like "upper", 'lower", "main", "basement", "rear" and "bedroom" were found to be commonly used to refer to units that might be additional dwellings. This search resulted in 87 listed N12, N13, and T5 LTB reports (13% of all records). Of these, the majority were N12 (62), followed by N13 (13) and T5 (12). Market Rent Analysis Staff are aware that there are likely external macroeconomic conditions which have contributed to the rise and fall of certain types of evictions over the years, however this level of analysis was beyond the scope and resources of this study. The following provide a high-level overview and comparison of available data on average market rent and the permitted percentage increase guidelines was reviewed from 2003 to 2024. Chart 1 below outlines the relative consistency between market rent, and the anticipated increase where the rent guideline was applied to the 2003 baseline. The divergence in the two data streams becomes apparent from 2015 onward. Prior to 2015 average market rent was relatively consistent with annual guideline increases. From 2015 onward, the average market rent has increase much more quickly than rents with only guideline increases applied. :,, . , 9 0 0 ,. 0 0 $:I.., '/0a. ()() $1,300.Do $900..00 $ 700 00 ] a..r k.r,L plenl.1- \r. J m G1.:a. i.de 1. 1 n C"Z •+;r� t.O Ir (X) rr, ('7 �I C"d C'"� ";r� tf'7 'D Ir a) C.,l ,--I cIJ C `V C C) C7 C 1 C, CE J f D e.....I i......I i......I �......I e.....1 i......I i......I �......I e—I e.....1 1, N ( V ('� N (D O (D C C) O C::7 D ��, O O C C::] Ca C O �.D O OC, D C N c ('A :,A c11 c� I'dCv N ('\J cv c N ,"v � ev \J N cv c1� c\� 11vr x agr:: S a_rkc t Gu.:i..dr 1 ..nF, Rent. I i is L:eAr er Page 263 of 316 Attachment C: Data Analysis Staff's analysis of this data helps us to confirm that average market rent is increasing substantially faster than permitted by guideline increases where rent controls apply. For example, for a tenant living in a unit since 2015 this could represent a 2025 rent that is more than $600 a month less than if the unit was rented at an average market rent ($7500 annually). This is a substantial difference and can lead one to understand why an economically driven landlord may seek to increase rents by any means necessary. Page 264 of 316 Attachment D: What We Heard (Summary of Interviews) In researching this report staff engaged with the following community based and tenant support and advocacy organizations: April 15, 2025: the Region of Waterloo's Plan to End Chronic Homelessness Co -Creators April 24, 2025: the Waterloo Region Social Development Center May 2, 2025: ACORN (Association of Community Organizations for Reform Now) Canada May 5, 2025: Waterloo Region Community Legal Services May 8, 2025: Lived Expertise Working Group May 12, 2025: Small Ownership Landlords of Ontario (SOLO) Page 265 of 316 Attachment D: What We Heard (Summary of Interviews) Plan to End Chronic Homelessness Co -Creators Meeting Staff attended the April 2025 Co -Creators Meeting alongside staff from the City of Waterloo, to discuss the current condition of evictions in the Region of Waterloo. The Co -Creator community group represents a number of housing, homelessness and health care experts, as they work to implement the Regional Plan to End Chronic Homelessness. Staff spoke to the work and research that had been completed to date, including interviews with other municipalities. Staff asked the group what barriers/challenges/gaps that they were currently seeing related to evictions, and from the items identified, what areas should be prioritized for action. The group identified the cost of housing to be of major concern, noting that this is particularly difficult as rent prices continue to rise, and income has remained the same. Participants expressed concern over the lack of affordable units, the loss of existing housing stock, and the influx of high end apartments and condominiums stating that this market does not meet the needs of the population. The housing stock that is available was noted to often be in poor condition, where the landlord/property management has not kept up adequate maintenance. This has led in instances to fears of, and actualized impacts to the safety and health of residents. Participants described situations of mold, loss of heating/cooling, and concerns over the general structural integrity of their units. This coincides with the group's perceptions and understanding of the Landlord Tenant Board and other legislative/legal frameworks. There was concern amongst participants over the representation of tenants at the LTB, and a perceived power imbalance favouring landlords. This imbalance has led some to not pursue legal action, and has had a silencing effect on tenants experiencing bad faith evictions. This has resulted in more informal evictions, and less reported data available for the LTB and subsequently public groups trying to compile information on the subject. Tenants stated that information and legal support was limited, and many did not know their rights, or have the opportunity to exercise them. The participants emphasized the need for standardization in the rental process, and the need for increased resources and information to support tenants facing poor living conditions. Tracking of data was a priority for the group, to support and communicate the experiences of tenants. Page 266 of 316 Attachment D: What We Heard (Summary of Interviews) Waterloo Region Social Development Center The Waterloo Region Social Development Center (SDC) is an advocacy and support agency which works directly with tenants as social and peer support workers. Staff spoke with representatives about the cases that the agency is seeing in the City of Kitchener with regard to both N12 and N13 evictions. The organization provided insight into the tenant experience which was similar in nature to that which was described by the Co -Creators Group Discussion. The SDC further discussed the prevalence of N12 and N13 evictions, and noted that they had concern over the legitimacy of the application of such tools. While it was understood that there are valid reasons for the eviction of a tenant, the group had significant concerns over the prevalence of bad faith actors. They have provided anecdotes where the stipulations of the eviction notice (including required work, or a family member moving in) have not been met, and the right of first return has not been honoured. There was an emphasis on tools to support and complement those which are already in place through the LTB. This includes additional legal resources, information, and other supports to make the process more equitable for tenants. One of the concerns with the process that was identified was the availability of temporary accommodation for tenants experiencing N13 evictions. While they acknowledge that the tenant has the first right to return to their previous unit, they noted that there is significant onus and uncertainty placed on the tenant to secure housing for a comparable price and condition, for an undefined rental length. SDC representatives suggested to staff that there needs to be greater oversight applied to landlords, not only to directly hold them accountable, but to provide tenants with the opportunity to self -advocate when their rights are being infringed. This sort of tool was recommended to shift the power imbalance that the agency believes favours landlords. Any form of oversight would be intended to be associated with property standards and legal resources, and direct tenants to the appropriate channels for support. Page 267 of 316 Attachment D: What We Heard (Summary of Interviews) Waterloo Region Community Legal Services Waterloo Region Community Legal Services (WRCLS) is a non-profit organization funded by Legal Aid Ontario which provides free legal services to low income residents. Staff spoke with WRCLS about their experiences with representing eviction cases at the LTB. The representatives staff spoke to highlighted their limited resources and staff and emphasized that this area of work only represents one of many facets handled by WRCLS. They noted that they currently have 17 staff (including lawyers, paralegals, social workers etc.), and have been directly involved in providing representation or summary advice for 55 N13 LTB cases. Additionally, lawyers/paralegals from WRCLS regularly attend the LTB to support hearings where possible. WRCLS is currently conducting a survey on renovictions which has, at the time of staff's discussion, received 21 responses. They found that the two most common reasons for eviction were N12 followed by N13 notices. In these cases, they found that the majority of tenants received some form of compensation, usually ranging from one month's rent to the equivalent of three months' rent. The most common form of rental unit of those surveyed was multi -unit residential buildings, followed by single detached dwellings. The survey asked for information regarding the follow up of landlords/property managers with regard to the requirements of the given eviction forms. In the case of N12 evictions, the majority of respondents reported that the landlord, purchaser, or a family member did not move into the unit. Similarly, with N13 evictions, responses stated that the landlord either did not offer the unit back to the evicted tenant, or they were not aware of the status of the repairs/renovations. Page 268 of 316 Attachment D: What We Heard (Summary of Interviews) Association of Community Organizers for Reform Now Canada ACORN (Association of Community Organizers for Reform Now) Canada is a national organizing body which advocates for numerous issues of equity in support of its low -and moderate -income membership. Staff spoke to the Waterloo Region chapter of the organization which has been active in the space of supporting residential tenants. The discussion sought clarity on the memberships' experiences with evictions including N13 and N12, and what benefits they saw in the by-laws which had been enacted by other municipalities. ACORN members highlighted a rise in N13 notices, especially in older buildings where the members noted there was the biggest incentive for evictions to increase rental profits. These (pre -2018) buildings are subject to rent control and tend to have longer term tenants who are paying below market rent. The members noted that even in the circumstances where there are successful fines applied through an LTB hearing, the result of increased rent from the new tenants often surpasses any penalties. Finally, the ACORN members noted that from what had been reported to them, in the circumstances where the renovations were absolutely necessary and required vacant possession, the repairs were due to long term neglect on behalf of property management. It was stated that the majority of renovations would not require vacant possession, and those which do would be for a short period. ACORN spoke to their involvement and support for the drafting of Hamilton's Renovation License and Relocation By-law and the intent and best practices of similar policies in Toronto, and London. They key elements of Hamilton's by-law that they noted should be replicated include: local government oversight, a qualified person confirming the scope of work requires vacant possession, accommodations/rent gap payments to tenants, the requirement for a building permit, and consequential fines for landlords who do not follow the necessary process. Page 269 of 316 Attachment D: What We Heard (Summary of Interviews) Lived Expertise Working Group The Lived Expertise Working Group (LEWG) advises the City of Kitchener regarding the affordable housing actions and programs that address the challenges of people experiencing marginalization. LEWG members were asked about gaps and barriers that exist for tenants experiencing evictions, what they feel is effective about rental renovation license by-laws and recent successes at the landlord tenant board. The largest barriers identified included the Landlord Tenant Board and lack of supports for those defending themselves. Members also expressed concern that landlords were using coercive and intimidation tactics when attempting evictions, and that evictions are often experienced by vulnerable people including seniors and newcomers who may lack resources and knowledge to defend themselves. LEWG members expressed that the benefit of license by-laws is that there is municipal oversight, proof that legislative requirements are being met and that the landlord is being held accountable. The group commented that a license allows the municipality to intervene in the relationship between the tenant and landlord and lessen the power imbalance. A license also helps to ensure that a tenant is informed of their rights. The group expressed a sentiment that it is the municipality's role to protect its citizens and house people. Page 270 of 316 Attachment D: What We Heard (Summary of Interviews) Small Ownership Landlords of Ontario (SOLO) Staff met with a member of the Small Ownership Landlords of Ontario (SOLO) to discuss their perspective on the current conditions and challenges of small-scale rental management (duplex, triplex or other types of additional dwelling units). The representative owns a duplex in Kitchener and another rental property in Waterloo. Rental property ownership and management is not their primary source of income but rather is a secondary source of revenue and an investment for retirement. This member highlighted the relationship that exists between small scale landlords and their tenants, emphasizing the personal nature of their interactions. Unlike larger corporate owned properties, this model requires landlords to play multiple roles, including direct involvement in leasing, maintenance and other aspects of property management. The representative told staff about the difficult conditions of property management that were leading to landlords to leave the business, or which cause reluctance to become a landlord in the first place. Non-payment, property damage, and backlogs at the LTB were cited as some of the biggest threats to small scale landlords. In cases where there has been an extended hearing for the eviction of a tenant, landlords have gone months to years without income on their properties. The stated dissatisfaction with the LTB has led to some seeking alternative means for eviction, including cash payouts to tenants, or the use of N12 forms (to end tenancy for personal use). The landlord stated that increased non -market, supportive, and cooperative style housing options would likely fill the gap that exists in the housing spectrum, and reduce the strain on small ownership landlords. Speaking to staff's exploration of licensing, the landlord stated concern over any additional costs (financial and time) being borne by small scale landlords. She noted that this would have a direct impact on the affordability of units and may further dissuade property owners from renting their additional dwelling units. She suggested that any regulation should exclude individuals operating small rentals and focus on larger property management corporations. The representative suggested that licensing and further regulation of renovations, works at cross-purposes to other programs and incentives which seek to increase investment and encourage renovations to increase rental housing stock. Such programs include CMHC sponsored loans for secondary suites, and new regulations that encourage homeowners to add additional dwelling units. Page 271 of 316 Attachment E: N13 Form and Instructions The attached IN 1 3 IFoirim aind Il linstawcl:joi ns document were obtained from the Landlord Tenant Board website. Page 272 of 316 Notice to End your Tenancy Because the Landlord Wants to Demolish the Rental Unit, Repair it or Convert it to Another Use N13 (Disponible en frangais) To: (Tenant's name) include all tenant names I From: (Landlord's name) Address of the Rental Unit: The following information is from your landlord I am giving you this notice because I want to end your tenancy. I want you to move out of your rental unit by the following termination date: I I I / I I I / dd/mm/yyyy My Reason for Ending your Tenancy I have shaded the circle next to my reason for ending your tenancy. ❑ Reason 1: I intend to demolish the rental unit or the residential complex. ❑ Reason 2: I require the rental unit to be vacant in order to do repairs or renovations so extensive that I am required to get a building permit and the rental unit must be vacant to do the work. Note: You have the right to move back into the rental unit once I have completed the repairs or renovations. If you want to move back in once the work is done, you must give me written notice telling me you want to move back in. Also, you must keep me informed in writing any time your address changes. ❑ Reason 3: I intend to convert the rental unit or the residential complex to a non-residential use. Details About the Work I Plan to do I have described below the work I plan to do for the reason shown above, including specific details about how I will carry out the work. Work planned I Details of the Work v.01/04/2022 Page ge pof116 Necessary I have shaded the circle to indicate whether I have obtained any necessary building permits permits. ❑ I have obtained the necessary building permits or other authorization to convert, demolish or repair the rental unit. ❑ I will obtain the necessary building permits or other authorization to convert demolish or repair the rental unit. ❑ No permits or other authorization are necessary in this case to convert the rental unit or demolish it. Important Information from the Landlord and Tenant Board (LTB) The The termination date the landlord sets out in this notice must be at least 120 days after termination the landlord gives you the notice. Exception: If you live in a mobile home park or land date lease community and you own the mobile home or land lease home, the termination date must be at least 1 year after the landlord gave you this notice. Also, the termination date must be the last day of the rental period. For example, if you pay rent on the first of each month, the termination date must be the last day of a month. Finally, if the tenancy is for a fixed term the termination date cannot be earlier than the last day of the fixed term. For example, if you signed a one-year lease, the termination date cannot be earlier than the last day of the one-year period set out in the lease. A tenant can You can terminate the tenancy sooner than the date set out in this notice as long as you give 10 days' give the landlord at least 10 days' notice in writing that you intend to move out of the notice to end rental unit. You must use the Landlord and Tenant Board's Form N9 Tenant's Notice to End the tenancy the Tenancy to give your written notice to the landlord. What if you You do not have to move out if you disagree with what the landlord has put in this notice. disagree with However, the landlord can apply to the LTB to evict you. The LTB will schedule a hearing the notice? where you can explain why you disagree. What if you If you move out of the rental unit by the termination date, your tenancy ends on that move out? date. What if the The landlord can apply to the LTB to evict you immediately after giving you this notice. If landlord the landlord applies to the LTB to evict you, the LTB will schedule a hearing and send you applies to the a copy of the application and the Notice of Hearing. The Notice of Hearing sets out the LTB? date, time and location of the hearing. At the hearing, the landlord will have to prove the claims they made in this Notice to End your Tenancy and in the application and you can respond to the claims your landlord makes. If the LTB issues an order ending your tenancy and evicting you, the order will not require you to move out any earlier than the termination date included in this notice. Compensation The landlord may have to pay you compensation for moving out because of this notice. or another unit If the landlord is giving you this notice for Reason 1 or Reason 3: If you live in a residential complex that has at least 5 residential units, the landlord must: • pay you an amount equal to 3 months' rent, or • offer you another rental unit that is acceptable to you. If you live in a residential complex that has fewer than 5 residential units, the landlord must: pay you an amount equal to 1 months' rent, or offer you another rental unit that is acceptable to you. Page pdg� p& 16 Compensation If the landlord is giving you this notice for Reason 2: or another unit If you live in a residential complex that has at least 5 residential units and you do not plan (continued) to move back in once the repairs or renovations are done, the landlord must: • pay you an amount equal to 3 months' rent, or • offer you another rental unit that is acceptable to you. If you live in a residential complex that has fewer than 5 residential units and you do not plan to move back in once the repairs or renovations are done, the landlord must: • pay you an amount equal to 1 months' rent, or • offer you another rental unit that is acceptable to you. If you live in a residential complex that has at least 5 residential units and you plan to move back in once the repairs or renovations are done, the landlord must pay you: • an amount equal to 3 months' rent, or • the rent for the period of time the rental unit is being repaired or renovated, whichever is less. If you live in a residential complex that has fewer than 5 residential units and you plan to move back in once the repairs or renovations are done, the landlord must pay you: • an amount equal to 1 months' rent, or • the rent for the period of time the rental unit is being repaired or renovated, whichever is less. Exception for mobile homes and land lease communities: If: you live in a mobile home park or land lease community, you own the mobile home or land lease home, and the landlord is giving you this notice for either Reason 1, Reason 2 or Reason 3, the landlord must pay you: • an amount equal to one years' rent, or • $3,000, whichever is less. Where compensation has to be paid, it must be paid by the termination date in this notice. The landlord is not required to pay you compensation: Your landlord is not required to pay you compensation for moving out because of this notice if your landlord is giving you this notice because they were ordered to demolish or repair the rental unit under any Act or law. How to get For more information about this notice or your rights, you can contact the Landlord and more Tenant Board. You can reach the LTB by phone at 416-645-8080 or 1-888-332-3234. information You can visit the LTB website at tribunalsontario.ca/Itb. Page P7g� p& 16 Signature ❑ Landlord ❑ Representative First Name Last Name Phone Number ( ) Signature Date (dd/mm/yyyy) Representative Information (if applicable) Name LSUC # Company Name (if applicable) Mailing Address Phone Number Municipality (City, Town, etc.) Province Postal Code Fax Number OFFICE USE ONLY: File Number Delivery Method: F-1inPerson F] mail F] Courier F] Email F]Efile E] Fax FL m Page g7gQ 4p&j16 Tribunals Ontario 1 Landlord and Tenant Board Ontario Form N13 • Section A: When to use this notice............................................................. L1 • Section B: Information about compensation .............................................. • Section C: How to complete this notice ....................................................... L2 • Section D: How to give this notice to your tenant ........................................ • Section E: What happens after you give this notice .................................... L4 • Section F: What to do if you have any questions ......................................... July 28, 2020 Page 277 of 316 When to use this notice You can give this notice to the tenant for the following reasons: • Reason 1: You intend to demolish the rental unit or complex. • Reason 2: You need the rental unit to be vacant in order to do extensive repairs or renovations. ■ Note: If you are giving the tenant this notice for this reason, the tenant can choose to move back into the rental unit after the repairs or renovations are complete. However, before the tenant moves out, the tenant must inform you in writing of their intent to re -occupy the rental unit. The tenant also has to keep you informed in writing of any change in their address. • Reason 3: You intend to convert the rental unit or complex to non-residential use. Giving this notice is the first step in evicting a tenant for the above reasons. See Section E below for information about what happens after you give this notice to your tenant. Information about compensation If the reason you are giving this notice is that you are converting or demolishing the rental unit or complex: • If the rental unit is located in a residential complex that contains at least five residential units you must give the tenant an amount equal to three months' rent, • If the rental unit is located in a residential complex that contains fewer than five residential units you must give the tenant an amount equal to one months' rent, or • you must offer the tenant another rental unit that is acceptable to the tenant. If you are giving this notice because you are repairing or renovating the rental unit and the tenant does not give written notice that they will be moving back into the rental unit once the repairs or renovations are complete: • If the rental unit is located in a residential complex that contains at least five residential units you must give the tenant an amount equal to three months' rent, • If the rental unit is located in a residential complex that contains fewer than five residential units you must give the tenant an amount equal to one months' rent, or • you must offer the tenant another rental unit that is acceptable to the tenant. 1 Notice to End your Tenancy Because the Landlord Wants to Demolish the Rental Unit, Repair it or Convert it to Another Use — Form N13 Page 278 of 316 If the reason for the notice is that you are repairing or renovating the rental unit and the tenant has given written notice that they will be moving back into the rental unit once the repairs or renovations are complete: • If the rental unit is located in a residential complex that contains at least five residential units you must give the tenant an amount equal to three months' rent or an amount equal to the rent for the period of time the rental unit will be under repair or renovation, whichever is less, • If the rental unit is located in a residential complex that contains fewer than five residential units you must give the tenant an amount equal to one months' rent or an amount equal to the rent for the period of time the rental unit will be under repair or renovation, whichever is less, or • you must offer the tenant another rental unit that is acceptable to the tenant. If you are giving the notice because you will be converting, demolishing, repairing or renovating a site on which a tenant -owned mobile home or land lease community home is located, the landlord must give the tenant an amount equal to one year's rent, or $3,000, whichever is less. Compensation must be paid to the tenant on or before the termination date in the notice. Exception: You are not required to compensate the tenant if the reason you are giving this notice is because you have been ordered to demolish or repair the rental unit or complex under any Act. How to complete this notice Read these instructions before completing the notice. You are responsible for ensuring that your notice is correct and complete. Follow the instructions carefully when you complete the notice. If you do not complete the form properly, your notice may not be valid and you may have to start over. Under To, fill in the name of the tenant to whom you want to give the notice. If there is more than one tenant living in the rental unit, fill in the names of all of the tenants. Where there is a subtenant or assignee, you should name these people in the notice. However, you do not need to name other occupants, such as children or guests of the tenant. Under From, fill in your name. If there is more than one landlord, fill in the names of all of the landlords. Under Address of the Rental Unit, fill in the complete address of the rental unit, including the unit number (or apartment or suite number) and the postal code. 2 Notice to End your Tenancy Because the Landlord Wants to Demolish the Rental Unit, Repair it or Convert it to Another Use — Form N13 Page 279 of 316 The Termination Date Fill in the termination date. The termination date must be at least 120 days after the date that you give the tenant this notice. Also, the date must be on the last day of the rental period or, if the tenancy is for a fixed term, the last day of the fixed term. Note: If the rental unit is in a mobile home park or land lease community and the tenant owns the mobile or land lease home, the termination date cannot be earlier than one year after you give the tenant this notice. The termination date must also be effective on the last day of the rental period or fixed term. Once you have given this notice to the tenant, the tenant may end the tenancy on an earlier date by giving you at least 10 days written notice. When you are counting the days, do not include the date you are giving the notice to the tenant. If you are faxing the notice, it is deemed to be given on the date imprinted on the fax. If you are sending the notice by courier, add one business day for delivery. If you are sending the notice by mail, add five days for delivery. Example: The landlord has a monthly tenancy agreement with a tenant. The landlord must give the tenant at least 120 days notice and the termination date must fall on the last day of the rental period, or last day of the fixed term. If the landlord wants the tenant to move out of the rental unit by August 31 st, the latest date that the landlord could hand this notice to the tenant would be May 3rd. If the landlord chose to mail this notice to the tenant, the latest the landlord could mail this notice would be April 28tH My Reason for Ending your Tenancy: Shade the circle completely next to the reason for giving the tenant this notice. Details About the Work I Plan to do: Fill in details about the work you plan to do. Include dates, a description of the work you are going to do, etc. It is important to be as specific as possible. If you need additional space, complete and attach an additional sheet of paper. Necessary permits: Shade the circle to indicate whether you have obtained or will obtain any permits or other authorization that are required to do the work. If you are serving this notice because you want to convert the rental unit or complex to a non-residential use or to demolish it, and no permits or other authorization are necessary, check the appropriate box on the form. Note: The Landlord and Tenant Board (LTB) will not issue an order terminating the tenancy and evicting the tenant unless you have obtained any permits or other authorizations that are required. If it is not possible to obtain the permits or other authorizations until the unit is vacant, the LTB will not issue an order terminating the tenancy and evicting the tenant unless you can show that you have taken all reasonable steps to obtain the permits or authorizations. 3 Notice to End your Tenancy Because the Landlord Wants to Demolish the Rental Unit, Repair it or Convert it to Another Use — Form N13 Page 280 of 316 Signature: If you are the landlord, shade the circle marked "Landlord". If you are the landlord's representative, shade the circle marked "Representative". Fill in your name and phone number. Then, sign the notice and fill in the date you sign the notice. Representative's Information (if applicable): If you are the landlord's representative, fill in your name and phone number. Then fill in your name, company name (if applicable), and mailing address. Include your phone number and fax number, if you have one. M How to give this notice to your tenant There are many ways that you can give this notice to your tenant. You can: • hand it directly to the tenant or to an adult in the rental unit, • leave it in the tenant's mailbox or where mail is ordinarily delivered, • place it under the door of the rental unit or through a mail slot in the door, • send it by fax to a fax machine where the tenant carries on business or to a fax machine in their home, • send it by courier, or • send it by mail. You cannot give the tenant this notice by posting it on the door of the tenant's rental unit. What happens after you give this notice It is important that you keep a copy of the notice you give your tenant. You can apply to the LTB for an order to terminate the tenancy immediately after giving the notice to the tenant. To make this application, you need an Application to End a Tenancy and Evict a Tenant (Form 1-2). You will also need to file a copy of the Notice to End your Tenancy at the End of the Term (Form N 13) you gave the tenant, and a Certificate of Service to tell the LTB when and how you gave the notice to the tenant. You must apply no later than 30 days after the termination date you put in this notice. The L2 and the Certificate of Service forms are available at your local LTB office, or from the LTB website at tribunalsontario.ca/Itb. 0 Notice to End your Tenancy Because the Landlord Wants to Demolish the Rental Unit, Repair it or Convert it to Another Use — Form N13 Page 281 of 316 What to do if you have any questions You can visit the LTB website at: tribunalsontario.ca/Itb You can call the LTB at 416-645-8080 from within the Toronto calling area, or toll- free at 1-888-332-3234 from outside Toronto, and speak to one of our Customer Service Officers. Customer Service Officers are available Monday to Friday, except holidays, from 8:30 a.m. to 5:00 p.m. They can provide you with information about the Residential Tenancies Act and the LTB's processes; they cannot provide you with legal advice. You can also access our automated information menu at the same numbers listed above 24 hours a day, 7 days a week. 5 Notice to End your Tenancy Because the Landlord Wants to Demolish the Rental Unit, Repair it or Convert it to Another Use — Form N13 Page 282 of 316 Leslie Macredie Mayor Berry Vrbanovic and City Councillors C/O Office of the Mayor and Council Kitchener City Hall 200 King St. W. Kitchener, ON N2G 4G7 Re: Evictions due to Renovations Report DSD -2025-248 Dear City Councillors and Mayor Vrbanovic: June 13, 2025 I submit in writing my delegation to the Planning and Strategic Initiatives Committee regarding Report DSD -2025-248 Evictions due to renovations. Firstly I want to acknowledge staff for their work on this extensive report. Their consultation with local housing advocates: the Region's Plan to End Chronic Homelessness Co -Creators, the Social Development Center, ACORN, Waterloo Region Legal Services and the Lived Expertise Working Group should be lauded. And yet somehow that has led to a recommendation to follow Path 2 whose principle mandate is to include developers and both small and large landlords in forging relationships with tenants and housing advocates. Tenants need protection from bad -faith landlords not a forum for landlords to exercise their control in an inherent power imbalance. The report admits that it was difficult to find landlord associations and was able to quote only one member. Furthermore, tenants are al- ready protected during development through the Rental Replacement by-law. Developers do not need to be included. Regarding Path 3, saying that the effectiveness of a renoviction by-law has not yet been proven is starting to sound disingenuous since it's been quoted every time this comes before Council. Does Council always wait for by-laws to be proven elsewhere? Another argument is that it does not protect against all bad -faith evictions. No one is asking it to do that. Finally, staff argue that a renoviction by-law does not provide wrap-around tenant support. However, were it passed it Page 283 of 316 would become a powerful tool for those already providing that support those very organiza- tions consulted by staff. The tenant support is already there. Give them this tool and they can ac- complish so much more. It is true that Path 3 will require more staff and more funding but is the protection of vulnerable tenants not worth the expenditure? At a June 2nd Finance and Corporate Services Committee meeting staff recommended the licensing of short-term rentals and that would require more staff- ing. Could some savings to be found in combining these two licensing infrastructures? The Rental Replacement by-law is in place. Is there not a way to utilize that administration? The City of Kitchener is deservedly proud of its Rental Replacement By-law and its Inclusionary Zoning. However, these protect the affordability and the tenants of the future. Without a renovic- tion by-law ensuring place -based protections for tenants, landlords will continue to abuse gaps in tenant protections. I am calling on Mayor and Council to please follow Path 3 but within a much shorter time flame. Waiting until June 2026 is not viable. Thank you for your time and consideration. Leslie Macredie Page 284 of 316