My comments to the City of Ottawa on their proposed Short Term Rental regulations
Good morning,
My name is Mike Moffatt. You may have seen me in a recent Airbnb video. I, along with my partner and our two children moved to Ottawa, specifically, the Glebe, two years ago. We bought a property with a basement “granny suite”, for visiting family members.
When visiting family is not using the suite, we rent the suite on Airbnb to help pay for our four-year-old son’s healthcare bills. Our son is non-verbal, on the autism spectrum, and cannot perform tasks that we would take for granted in other children. After the provincial government’s botched Ontario Autism Program reforms, we were left with funding his therapy privately. He is making real progress with his therapy, but the bills are steep — $7,000 each month. The money we generate from the suite helps us offset some of those costs.
The new rules, if enacted, would ban us from renting out the suite even one day a year, unless we remove the firewall between the upstairs and downstairs and replace it with a door. It’s important to note the Kafka-esque nature of this request: the previous owners of the house put in the firewall and removed the existing door because the city told them they had to in order to rent it on Airbnb. Now we are being told we most un-do those changes if we want to continue to rent the property on Airbnb.
Needless to say, this issue is important to us.
But for a moment, I’m going to take off my Dad hat, and talk about these issues from the perspective of someone who does public policy for a
The problem with the new rules is straightforward — they’re based on geography, rather than use type.
- Under the new rules, I would be banned from renting my “granny suite” part-time (even one day a year!), because it is in the wrong neighbourhood.
- Meanwhile, an absentee landlord could run 500 ghost hotels all across the city, so long as they’re in an approved zoning designation.
With these rules the city is attempting to tackle two very real problems:
- Reduce community nuisances.
- Increase the availability and affordability of housing.
But the rules fail on both dimensions.
Reduce community nuisances
People like me, who are renting out part of their primary residence while they are present have an incentive to be picky about who we rent to. We are literally the closest neighbour to the short-term renters. If they’re loud, it’s us they’re waking up. If they park in the wrong spot, it’s our car that they’re blocking. We have the incentive to avoid tenants who will cause a disruption since we’ll be the ones who will be disrupted!
Absentee landlords don’t face these same incentives. Yet absentee landlords will still be legal in 80% of Ottawa, due to the blanket exemptions for properties in the AG, RR and RU zones. If tenants in one of these legal ghost hotels are causing a nuisance, it will not bother the property owner, who probably isn’t even aware of it in the first place.
Affordability
The regulations will also fail to adequately address the affordability problem. They target units like mine, which are used for non-short term rentals part of the time; in my case for visiting families. Banning part-time short-term rentals is going to little to create new spaces; rather it’s going to leave a lot of units empty part of the time.
Next let’s look at ghost hotels, which could actually be causing affordability issues. The city could have banned ghost hotels outright. They could have taken a targetted approach, and banned ghost hotels in the parts of the city with the biggest affordability issues. Instead, they kept ghost hotels perfectly legal in “pockets of exurban tracts”, areas that the City of Ottawa Rental
Market Analysis identifies as having the most unaffordable housing!
If the city’s goal is to address the affordability issue, then exempting parts of the city with the biggest affordability problems is a colossal failure.
The failure is even worse than one of neglect. The city fails to realize that businesspeople respond to incentives. Owners of existing ghost hotels in banned areas aren’t going to go away; they’re simply going to buy up properties in areas where they are not banned and open ghost hotels there. Because of these new rules, the affordability issue is going to get a whole lot worse in areas of the city already facing the most substantial affordability issues.
In short, these rules ban a bunch of activities that are not problematic and simply move problematic activities a few kilometers down the road.
While your intentions are noble, these rules, as written, will have significant unintended consequences.
As the husband of a civil servant that has had Phoenix-related pay issues, I implore you to consider the importance of unintended consequences.
As the father of a child caught up in the botched Ontario Autism Program reforms, I implore you to consider the importance of unintended consequences.
Finally, as a daily rider of OC Transpo, I implore you to consider the importance of unintended consequences.
Thank you.
