A letter to City of Kingston regarding "Residential Rental Licensing"

I am a landlord that your proposal would impact and I am truly disappointed, angry, and strongly against the 'Residential Rental Licensing' program proposal.

Considering it only targets properties of three units or less I see this as nothing more than a money grab. You failing to include 4 plus unit property owners conveniently excludes large corporations like Homestead. I find this discriminatory and I haphazardly conclude you choose to do so to avoid the lobbying against it you would receive from someone of bigger pockets.

Also, given the fact that as of April 30, 2018 we are required to provide a standardized lease, I see the goals of this licensing program made obsolete and redundant. The 14 page long lease document, in particular section 'J - Maintenance and Repairs' outlines and educates the tenant as to the landlord's responsibilities and if these are not met to seek assistance through Landlord and Tenant Board (LTB).

Your goal to prevent substandard conditions in rental units will not work - bad landlords that fail to comply with LTB’s standard lease requirement will not suddenly have a change of heart and decide to license with the city so they can be inspected – it’s totally illogical to expect they would. Tax payers money would be better spent on tenant education through billboards in strategic locations and TV ads.

Kingston is also struggling with low vacancy and is pushing aggressively for the average Joe/Jane to turn portions of their houses into second units through rebates and grants. Having the recurring licensing costs and the time hassle of the program – however small - will only discourage new entry into the market. For me it will result in passing the monetary and time costs onto my tenants.

I also have a problem with the actual questions in your survey. The latest results from ‘New Permissions Survey’ shows the respondents to be in favor of licensing but I would argue that these results are skewed because of leading questions like:

• Q3: Would you have any concerns if one of your neighbours wanted to build a second residential unit inside their (single detached, semi-detached, row or linked) home?
• Q4: Would you have any concerns if one of your neighbours wanted to build a detached second residential unit (often referred to as a coach house) in their back yard?

These questions were designed to tell a pro-licensing story by cleverly failing to determine the actual root cause of people’s concerns. Are these respondents concerned because of the possible noise and length of construction, or the impact on their backyard skyline view the detached unit will have? The respondents concerns might actually have nothing to do with the subsequent ongoing rental activity that will occur at the property.

I would argue that if the below questions were asked instead we would have gotten a different story, one where the public is against the licensing proposal:

• “Given that the landlord by law is required to provide a standardized lease informing the tenant of their rights and to seek assistance with the Landlord and Tenant board, do you find a landlord registry and conducting this survey to be an ineffective use of tax payers money? “
• “Do you find that the rule of three units or smaller which excludes corporation like Homestead to be unfair and discriminatory to the smaller landlords that will be impacted by this licensing program?”
• “Given the fact that the landlord must voluntarily register with the city as part of this proposed program, do you think that bad landlords will actually choose to register to be inspected by the city?”
• “Would you be in favor of the licensing program if it would lead to possibly higher average rents?
• “Compared to the costs of a licensing program, do you believe a billboard and TV advertising campaign educating tenants of their rights and displaying the contact information for the Landlord and Tenant board to be a more effective use of tax payers money?”

My wife and I work really hard between juggling our daily jobs, raising two kids and being landlords. The rental business is not as easy as people imagine and it has potential for great risks. Risks which we have experienced first hand and also witnessed others go through forcing them to fold and quit.

But we choose to continue still and we do so that we can leave a financial legacy to our children - we should not be punished for our success and this licensing proposal is a disguised tax that does just that.

Please come to your senses and don't introduce it.