**Petition to Halt Implementation of Residential Rental License (RRL) in the City of Brampton**

WE SAY NO TO RENTAL LICENCE...!

Dear Esteemed Residents of Brampton,

We, the undersigned, wish to bring forth our collective concern and formal objection to the recent initiation of the Residential Rental License (RRL) program by the City of Brampton. While we acknowledge the necessity for regulation and compliance, the current framework, currently in its pilot phase in wards 1, 3, 4, 5, and 7, raises significant apprehensions regarding its impact on landlords and the broader housing landscape.

After carefully reviewing the Residential Rental Licence program requirements, we acknowledge the requests made by landlords and foresee potential inefficiencies. We strongly urge the City of Brampton to reconsider its decision and cancel the RRL.

Whether you are constructing an entire house as a single unit, have a legally registered basement or garden unit, or are renting a single room with a shared kitchen while living in the house, you are required to apply for a rental licence per the city's directions. We have the following major concerns:

1. Financial Burden on Landlords: One of the primary concerns voiced by landlords is the financial burden associated with compliance. The program requires landlords to pay a $300 annual fee, undergo electrical and gas inspections by a certified inspector at the owner's own expense, and provide interior floorplans and exterior drawings. Small landlords argue that these requirements can strain their financial resources, especially during times of hardship. 
For landlords, this translates into an additional cost ranging from $1500 to $2000 per additional or second dwelling unit. This is a substantial financial commitment, especially when considered in the context of the prevailing economic challenges faced by Canadians, including post-COVID inflation and recent increases in mortgage costs due to interest rate hikes.

2. Landlord Time Challenges in Document Preparation: When our units are already legally constructed and comply with all building, fire, and electrical codes, with the city issuing an occupancy permit for the unit. This program has not any measures defined, how city will chase illegal basements. Despite. under the RRL program, landlords of legally registered dwelling, are required to navigate similar inspections and administrative processes, including documentation submission. The bureaucratic nature of the program has led to complaints about excessive paperwork and time-consuming procedures. 
For complete requirement and other details refer to city of Brampton website www.Brampton.ca/RRL

3. Existing Property Standard and Maintenance By-Law: The city has not modified existing property standard and maintenance by-laws. In the rental licence program, the city is asking owners to acknowledge these by-laws. RRL is deemed necessary only for acknowledgment. The city already has provisions for yearly property owner acknowledgment to comply with these by-laws and self-declaration that there are no modifications to the property. The Rental License is not seen as adding significant value.

4. RRL Conflict with Residential Tenancy Act:
   - A significant concern arises when a landlord fails to obtain a license. Eviction of the tenant is not a viable option as there is no provision in the Residential Tenancies Act (RTA) for such action. The question remains whether the city imposes perpetual fines on the landlord.
   - Similarly, even after acquiring a license, if the tenant does not cooperate with landlords to maintain the property adequately or becomes overcrowded without the landlord's consent, the situation does not equate to shutting down a commercial business. The RTA does not authorize the eviction of tenants under these circumstances. The city lacks the authority to either evict tenants or issue tickets in such scenarios.
   - A potentially challenging situation arises if tenants refuse the landlord entry into the property post-licensing. In this case, the city can only issue tickets to landlords, and both landlords and the city are powerless to take any action against the tenants.

5. Room Sharing: The city's attempt to enforce a maximum of four unrelated tenants in a unit contradicts the Residential Tenancies Act and Ontario Human Rights Code. The city has already mentioned in their Lodging Houses session that the number of occupants alone, or their relationship with one another, does not constitute a contravention of the Zoning By-law. This can be discriminatory based on Code grounds, and people should be able to share a bedroom without scrutiny.

6. Addressing Excessive Garbage Situation: The city issues only a single bin per property instead of per dwelling. When the city is well aware that there are two dwelling units, meaning each unit will be occupied by a separate family, the city should consider issuing garbage bins per dwelling to address the issue of garbage overflow. RRL will not resolve this issue.

7. Discouraging New Home Buyers in Brampton: It will give hesitation to buy a home in Brampton, as individuals may consider other cities due to this license. When someone buys a new home, they are already managing month to month. Any extra burden may force individuals to reconsider the city.

8. Conflict with Provisional Bills: Moreover, the RRL conflicts with the provincial vision in the Bill 23 More Homes Built Faster Act, 2022.

Under Bill 97 Helping Homebuyers, Protecting Tenants Act, 2023, which would amend the Residential Tenancies Act to double the fines under this act, the maximum fines would rise to $100,000 from $50,000 for individuals and to $500,000 from $250,000 for corporations. We believe that increasing these fines would help deter rental housing offenses such as unlawful evictions. Hence, the rental license will create a situation where property owners would become sandwiched between laws in favor of the city and tenants, respectively, potentially leading to decisions by property owners to invest in other cities.

9. RRL Is Revenue Generation Tool: As of January 15, 2024 according to GeoHub Brampton Data, Brampton has a total 20,315 are just ARUs (legal basements are registered with the city. With above facts, we expect that the city will generate approximately $7 - $8 Millions every year from fee.

10 Random Inspections With & Without Notice: Despite of RRL, under current by-laws, city retains the authority to conduct property inspections in cases where concerns regarding building standards and safety arise. The implementation of the Residential Rental License (RRL) is unnecessary for such purposes and may inadvertently lead to heightened legal and human rights implications, particularly in conflict with the Residential Tenancy Act.
A potentially challenging situation arises if tenants refuse the landlord entry into the property post-licensing. In this case, the city can only issue tickets to landlords, and both landlords and the city are powerless to take any action against the tenants.

We wish to draw attention to the fact that such an economic burden may lead to a reconsideration by landlords in renting out their basements, exacerbating the existing housing crisis in Brampton. The impact is counterintuitive to the prevailing housing shortage in Canada, with a need for increased rental options to meet the growing population's demands.

Legal or Additional Residential  units, having been constructed in adherence to building and safety codes, and possessing valid permits from the city, are already subject to random inspections under existing by-laws. The RRL, as it stands, is not required for these routine inspections.

In light of these concerns, we implore the City of Brampton to promptly suspend the ongoing implementation of the Residential Rental License. We are cognizant of the necessity for safety and regulatory measures but believe that a nuanced and balanced approach is required to safeguard the interests of both landlords and tenants.

As a community, we are organizing a peaceful demonstration to articulate our collective concerns and advocate for a more equitable and informed approach to these regulations. Your support is paramount in achieving a comprehensive and fair resolution.

City Hall , thank you for your attention and consideration, in advance.

Sincerely,

Concerned Resident

WE SAY NO TO RENTAL LICENCE...!