This brief, submitted jointly by United Ways across Ontario, Tower Renewal Partnership and Neighbourhood Change Research Partnership provides feedback on proposal changes to enable the Minister of Municipal Affairs and Housing to set minimum requirements which municipalities must impose on landowners, if they have rental replacement by-laws. It follows an earlier submission in December 2022 with recommendations to the provincial government on preserving and renewing existing affordable rental stock so that low-income Ontarians can remain safely and securely housed.
The network of United Ways in Ontario spans both rural and urban communities and recognizes the nuanced challenges facing residents in both environments. Rental options are limited and lagging affordability is a reality across the Province. Rental replacement policies provide a stabilizing framework to the rental housing system. They are a critical policy lever to address deteriorating rental housing security, affordability and attainability, particularly during times of neighbourhood change. Since 2007, the City of Toronto’s Rental Housing Replacement bylaws have secured 3,571 rental replacement units alone. The absence of such policies would be detrimental to the housing system, eroding the housing security of low- and moderate-income Ontarians and adding more strain on an already overburdened rental market.
We acknowledge and applaud the government’s commitment to maintain and expand rental replacement policies throughout the Province, to support both urban and rural affordability and community vibrancy. We look forward to continuing to work with all levels of government and the non-profit and private sectors to ensure that all Ontarians can attain safe, accessible and stable housing.
The proposed regulatory amendment would enable the Minister to set minimum requirements which municipalities must impose on landowners, if they have rental replacement by-laws. The government has provided four areas where it intends to consider future regulations:
- Prescribe minimum requirements for landowners to give tenants the option to rent a ‘replacement unit’ at the same location as their demolished unit, and at a similar rent. This requirement would apply in instances where a ‘replacement unit’ is required to be built at the same location as the demolished unit.
- Set common rules about the types of compensation that would be required to be provided to displaced tenants.
- Prescribe minimum requirements for landowners to build ‘replacement units’ with the same core features (e.g., same number of bedrooms) as demolished units.
- Limit municipalities from imposing minimum square footage requirements for ‘replacement units’.
While setting minimum requirements and common standards might meet the province’s objective to increase consistency across and between municipalities that establish by-laws, a balanced framework approach may inadvertently deter cities from enforcing more stringent by-laws already in place, minimizing the potential impact of existing and effective rental replacement by-laws and leading to decreased affordability, and increase resident displacement across the region, especially of lower income residents. Further, the proposed approach is only relevant for the small number of Ontario municipalities that currently have rental replacement by-laws in place. Requiring all municipalities to establish strong and effective rental replacement by-laws would enhance protections to more Ontario tenants, in both urban and rural contexts.
Submission to the Ministry of Municipal Affairs and Housing
Read the full submission: Providing Feedback on Future Regulations to Create a Balanced Framework Around Municipal Rental Replacement By-Laws