Short-term Accommodations

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Project Timeline

History/Background:

  • 2018 - The municipality of Prince Edward County establishes a licensing program for Short Term Accommodations
  • September 2020 - The municipality paused the issuance of "Whole Home" STA licenses both as a result of the COVID-19 pandemic and to review the program's efficacy. No new Whole Home licence applications were processed during this pause.
  • The municipality commissioned a study of the impact that STAs and the licensing program were having on affordable housing in The County. The results of the study completed by Urban Politics and Governance research group, School of Urban Planning, McGill University are available online.

Current program review:

  • May 12, 2022 - Council passed a motion directing staff to consult with the public regarding several proposed changes to the Short Term Accommodation and Comprehensive Zoning By-Laws. Staff were directed to return with recommendations in June 2022, incorporating public feedback. The proposed changes included:
    • instituting a "natural persons" requirement for all future licenses (i.e. licences would be held by natural persons, not corporations);
    • placing a cap of zero on new licences with some exceptions for owner-occupied properties and a small number of properties that are accessible for people with disabilities;
    • updating fines for advertising without a licence or failing to post the licence number in an advertisement; and,
    • adding certain fire and life safety provisions as a condition of licensing.
  • June 2022 - This Have Your Say project page was launched with a forum for public comment on the proposed changes. Staff also received emails and phone calls directly from stakeholders and took meetings with stakeholder groups. A number of unintended consequences and legal considerations were identified during the consultation process, and staff worked to address many of these in the recommendations that were to be presented to Planning Committee (June 15) and Committee of the Whole (June 21). The public concerns focused on three key areas:
    • The legal non-confirming use rights ("grandfathering" rights) of existing STA properties established under the Provincial Planning Act, and how these rights flow from current owners to future owners in relation to the STA Licensing By-Law.
    • The distinct nature of Bed and Breakfast establishments and how these businesses are reflected in the STA licensing program.
    • The municipality's enforcement of the provisions of the STA Licensing Program and the size of penalties associated with contravening the by-law.
  • June 15, 2022 - Planning Committee - A statutory meeting was held to consider moving certain provisions from the Comprehensive Zoning By-Law to the STA Licensing By-Law where they are more appropriate. Public consultation and audience comments at the meeting reinforced the public's concern with the proposed changes. Planning Committee directed staff to return with a revised report that takes these considerations into account. Committee and staff also agreed to remove the scheduled STA Licensing By-Law report from the June 21 Committee of the Whole meeting to allow time to incorporate more public feedback into that report as well.
  • July 7 - A special meeting of Committee of the Whole was held to consider two new staff reports that attempted to address the feedback heard through public consultation and at the Planning Committee meeting. The staff reports included:
    • Explicit confirmation of the grandfathering rights of existing STAs with respect to future use of the property;
    • New definitions for Primary Residence STAs and Secondary Residence STAs (replacing "Whole Home" and "Owner Occupied,");
    • Restricting the number of days a Primary Residence STA could be rented to 180;
    • Restricting licences for Secondary Residence STAs to one per natural person; and,
    • Future exploration of options for incentivizing the creation of accessible STAs.

While the staff recommendations addressed many of the concerns from previous reports, still more concerns were identified through public comment and discussion at the Committee meeting. The matter was referred back to staff to respond to the following motion:

Motion CW-178-2022
Moved by Mayor Ferguson
Seconded by Councillor Roberts

THAT Clause 2, 3, 4, 5, and 6 be deleted and replaced with the following:

THAT staff report CSPI-19-2022 be referred to staff to investigate the following:

  • higher fines/penalties
  • stronger restrictions on unlicensed operators
  • reduce the 180-day limit for partial primary Residence STA to 45-60 days
  • allowing primary residences with secondary units to operate year round
  • flexibility for commercial properties and removing natural persons restrictions
  • removal of secondary residence STAs

THAT Council direct staff to bring back a report and revised by-law at a Special Committee of the Whole meeting prior to the August 16th Council meeting.

CARRIED

  • August 8 - A special Committee of the Whole Meeting occurred on August 8, 2022 to consider new staff reports. The reports addressed the concerns outlined in the motion above and provided options for Committee to consider. The reports can be read on the municipal website and a video recording of the meeting can be viewed on YouTube. Minutes of this meeting posted on the municipal website as part of the August 16, 2022 Council meeting agenda.

Background

“Short-term accommodations” (STAs) refers to any transient form of accommodation that is occupied for a period less than 30 days. They are typically operated out of an owner’s home, and are frequently posted on sites like AirBnB, Vrbo, etc. STAs, as defined by the County, can come in one of three forms:

  • Whole-home, where an entire property is used as an STA;
  • Owner-occupied, where the operator resides at the property but rents out all or a portion of it as an STA; and
  • Bed & Breakfast establishments, which are similar to owner-occupied STAs and must be occupied by their owners, but come with some additional requirements around food service.

Since 2018, Prince Edward County has had an STA licensing program, whereby people who want to post their properties on AirBnB, Vrbo, and other platforms for temporary rentals have to obtain a licence from the municipality to do so. This licensing process involves home inspections, providing information about the owners, operators and property, and paying licensing fees as well as collecting and remitting the Municipal Accommodations Tax (MAT). A certain number of STAs operating prior to the start of the licensing program, assuming they’ve received a licence given by the municipality, are also considered “grandfathered” and enjoy some special privileges related to the ongoing use of their property as an STA.

In September 2020, the municipality placed a moratorium on new STA licences being issued, both as a result of the COVID-19 pandemic, and to review the program’s efficacy thus far. This moratorium has been in place since then, and the review of the program has resulted in a series of changes and recommendations.

Additional materials

May 12, 2022 Committee of the Whole materials:

June 15, 2022 Planning Committee materials:

July 7, 2022 Committee of the Whole materials:

August 8, 2000 Committee of the Whole materials:

Project Timeline

History/Background:

  • 2018 - The municipality of Prince Edward County establishes a licensing program for Short Term Accommodations
  • September 2020 - The municipality paused the issuance of "Whole Home" STA licenses both as a result of the COVID-19 pandemic and to review the program's efficacy. No new Whole Home licence applications were processed during this pause.
  • The municipality commissioned a study of the impact that STAs and the licensing program were having on affordable housing in The County. The results of the study completed by Urban Politics and Governance research group, School of Urban Planning, McGill University are available online.

Current program review:

  • May 12, 2022 - Council passed a motion directing staff to consult with the public regarding several proposed changes to the Short Term Accommodation and Comprehensive Zoning By-Laws. Staff were directed to return with recommendations in June 2022, incorporating public feedback. The proposed changes included:
    • instituting a "natural persons" requirement for all future licenses (i.e. licences would be held by natural persons, not corporations);
    • placing a cap of zero on new licences with some exceptions for owner-occupied properties and a small number of properties that are accessible for people with disabilities;
    • updating fines for advertising without a licence or failing to post the licence number in an advertisement; and,
    • adding certain fire and life safety provisions as a condition of licensing.
  • June 2022 - This Have Your Say project page was launched with a forum for public comment on the proposed changes. Staff also received emails and phone calls directly from stakeholders and took meetings with stakeholder groups. A number of unintended consequences and legal considerations were identified during the consultation process, and staff worked to address many of these in the recommendations that were to be presented to Planning Committee (June 15) and Committee of the Whole (June 21). The public concerns focused on three key areas:
    • The legal non-confirming use rights ("grandfathering" rights) of existing STA properties established under the Provincial Planning Act, and how these rights flow from current owners to future owners in relation to the STA Licensing By-Law.
    • The distinct nature of Bed and Breakfast establishments and how these businesses are reflected in the STA licensing program.
    • The municipality's enforcement of the provisions of the STA Licensing Program and the size of penalties associated with contravening the by-law.
  • June 15, 2022 - Planning Committee - A statutory meeting was held to consider moving certain provisions from the Comprehensive Zoning By-Law to the STA Licensing By-Law where they are more appropriate. Public consultation and audience comments at the meeting reinforced the public's concern with the proposed changes. Planning Committee directed staff to return with a revised report that takes these considerations into account. Committee and staff also agreed to remove the scheduled STA Licensing By-Law report from the June 21 Committee of the Whole meeting to allow time to incorporate more public feedback into that report as well.
  • July 7 - A special meeting of Committee of the Whole was held to consider two new staff reports that attempted to address the feedback heard through public consultation and at the Planning Committee meeting. The staff reports included:
    • Explicit confirmation of the grandfathering rights of existing STAs with respect to future use of the property;
    • New definitions for Primary Residence STAs and Secondary Residence STAs (replacing "Whole Home" and "Owner Occupied,");
    • Restricting the number of days a Primary Residence STA could be rented to 180;
    • Restricting licences for Secondary Residence STAs to one per natural person; and,
    • Future exploration of options for incentivizing the creation of accessible STAs.

While the staff recommendations addressed many of the concerns from previous reports, still more concerns were identified through public comment and discussion at the Committee meeting. The matter was referred back to staff to respond to the following motion:

Motion CW-178-2022
Moved by Mayor Ferguson
Seconded by Councillor Roberts

THAT Clause 2, 3, 4, 5, and 6 be deleted and replaced with the following:

THAT staff report CSPI-19-2022 be referred to staff to investigate the following:

  • higher fines/penalties
  • stronger restrictions on unlicensed operators
  • reduce the 180-day limit for partial primary Residence STA to 45-60 days
  • allowing primary residences with secondary units to operate year round
  • flexibility for commercial properties and removing natural persons restrictions
  • removal of secondary residence STAs

THAT Council direct staff to bring back a report and revised by-law at a Special Committee of the Whole meeting prior to the August 16th Council meeting.

CARRIED

  • August 8 - A special Committee of the Whole Meeting occurred on August 8, 2022 to consider new staff reports. The reports addressed the concerns outlined in the motion above and provided options for Committee to consider. The reports can be read on the municipal website and a video recording of the meeting can be viewed on YouTube. Minutes of this meeting posted on the municipal website as part of the August 16, 2022 Council meeting agenda.

Background

“Short-term accommodations” (STAs) refers to any transient form of accommodation that is occupied for a period less than 30 days. They are typically operated out of an owner’s home, and are frequently posted on sites like AirBnB, Vrbo, etc. STAs, as defined by the County, can come in one of three forms:

  • Whole-home, where an entire property is used as an STA;
  • Owner-occupied, where the operator resides at the property but rents out all or a portion of it as an STA; and
  • Bed & Breakfast establishments, which are similar to owner-occupied STAs and must be occupied by their owners, but come with some additional requirements around food service.

Since 2018, Prince Edward County has had an STA licensing program, whereby people who want to post their properties on AirBnB, Vrbo, and other platforms for temporary rentals have to obtain a licence from the municipality to do so. This licensing process involves home inspections, providing information about the owners, operators and property, and paying licensing fees as well as collecting and remitting the Municipal Accommodations Tax (MAT). A certain number of STAs operating prior to the start of the licensing program, assuming they’ve received a licence given by the municipality, are also considered “grandfathered” and enjoy some special privileges related to the ongoing use of their property as an STA.

In September 2020, the municipality placed a moratorium on new STA licences being issued, both as a result of the COVID-19 pandemic, and to review the program’s efficacy thus far. This moratorium has been in place since then, and the review of the program has resulted in a series of changes and recommendations.

Additional materials

May 12, 2022 Committee of the Whole materials:

June 15, 2022 Planning Committee materials:

July 7, 2022 Committee of the Whole materials:

August 8, 2000 Committee of the Whole materials:

Comments

Greetings all,

My name is Noah Lister-Stevens: I am a programs advisor with the Community Services, Programs and Initiatives department of the municipality, and I'll be the principal Staff contact on this consultation. I'm here to update the page, moderate comments, and I may occasionally answer questions or provide context as necessary. HaveYourSay also employs moderators to keep discussions on-topic, civil and constructive—their moderation policy can be found here. 

We appreciate your feedback, and look forward to reading your comments!

Best wishes,

Noah

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Removed by moderator.

Bella Samaras 9 months ago

Glad I’m not the only one! I offer the following background to my rationale: My late husband died tragically; all of a sudden in a car accident just 2 months after we moved here. He was from Consecon and so we moved to The County in 1997. In February 1998, I was left a single mother with 3 young children and since I was recovering from a disabling illness, we hadn’t had time to arrange a joint bank account. However, The Community was there with condolences and support - food and even money! Later, when I had an opportunity to move, that very fact made my decision to stay. So now I offer my opinion: The County needs to adhere to the minimum 25-33% portion of ANY new developments to be Affordable immediately. Humanity, and humane treatment of our fellow humans and Housing go together. Why? - because having a space we can call our own is a basic human need attributable to our well-being and therefore our Human Rights. Affordable Housing: In order to be attainable NOW we need housing that starts in the $200’s range as 2 people earning $20/hr would only gross $83,000 or so per /annum; 30% of what they could afford is $250,000 approximately, and, that doesn’t include debt, (student loans, (young doctors) credit card debt, transportation and the ever-increasing cost of basic living such as food, clothing. Look at the WHOLE picture: - In order to keep our support workers, we need to keep them here (help locals to be able to ‘Afford’ to live here and even give them a help-up to thrive here and now). Support workers also support our increasingly larger Senior population and our Tourism Industry: - Our Support System is already deteriorating. (We’ve seen Seniors that can’t get help maintaining their property and homes, and businesses that can’t find staff). We need more youth vibrancy now. - Let’s attract more young families to our area too. Let’s get back to our basic history and, be more forward-thinking about what CAN be done now while helping decrease the effects of Climate Change for the next generations! Be forthright, forward-thinking and look-at the whole picture now: - Younger people are also very conscientious of Climate Change. Why not give them a place to live and train them in the trades by providing hands-on experience building Tiny Homes right now? (Akin to raising a barn or a place of worship or a school together, as in the past). Today and right now: - Farmland that isn’t Agriculturally viable, is not as costly as land in Towns. - Outside Developers are not looking at Affordable Housing because it is not profitable. Since COVID, they would actually lose money on building Affordable Tiny Homes - especially in Town. - Let’s allow off-grid Development in ‘Out-Of-Town areas’ right now (historically this has been the pattern and why we have several Hamlets etc.) The County can move towards connecting these to ‘the grid’ systems later). - For now, these Communities of Off-Grid Affordable Housing can collect rain water and use composting toilets; a grey-water recovery system; a plant-based water treatment, solar UV, grow their own food in greenhouses/land and this life is, I believe, more getting back to our roots historically. - Let’s support our local people and businesses first too. Why not extend and increase the frequency of our bus transit system first to these new outlying communities of Affordable and Attainable Housing now? (Easier and more practical and less pollution). So, It’s part of our history to build a cabin, use an outhouse and live off the land, care, share, and ‘take care’: Neighbours helped each other to build communities and as a resource to get the crops in and off the land. The past has been our foundation of who we are. We have heart! We look to give each other a hand and a hand up and to take care of our most vulnerable. The very foundation of Our Community historically is based on this philosophy. We can do this now BEFORE it’s too late! Inter-generational and diverse residents could thrive in Off-Grid Communities located in out-lying areas where utilities and infrastructure is not supported. Let’s not delay for the sake of our Founding Settlers, our philosophy and our history. In combination, let’s be more-forward thinking, look at the whole picture and support Climate Change incentives like in other Municipalities. Please start to actually build Off-Grid Affordable Housing NOW.

Joanne Quinn about 1 year ago

Glad I’m not the only one! I offer the following background to my rationale: My late husband died tragically; all of a sudden in a car accident just 2 months after we moved here. He was from Consecon and so we moved to The County in 1997. In February 1998, I was left a single mother with 3 young children and since I was recovering from a disabling illness, we hadn’t had time to arrange a joint bank account. However, The Community was there with condolences and support - food and even money! Later, when I had an opportunity to move, that very fact made my decision to stay. So now I offer my opinion: The County needs to adhere to the minimum 25-33% portion of ANY new developments to be Affordable immediately. Humanity, and humane treatment of our fellow humans and Housing go together. Why? - because having a space we can call our own is a basic human need attributable to our well-being and therefore our Human Rights. Affordable Housing: In order to be attainable NOW we need housing that starts in the $200’s range as 2 people earning $20/hr would only gross $83,000 or so per /annum; 30% of what they could afford is $250,000 approximately, and, that doesn’t include debt, (student loans, (young doctors) credit card debt, transportation and the ever-increasing cost of basic living such as food, clothing. Look at the WHOLE picture: - In order to keep our support workers, we need to keep them here (help locals to be able to ‘Afford’ to live here and even give them a help-up to thrive here and now). Support workers also support our increasingly larger Senior population and our Tourism Industry: - Our Support System is already deteriorating. (We’ve seen Seniors that can’t get help maintaining their property and homes, and businesses that can’t find staff). We need more youth vibrancy now. - Let’s attract more young families to our area too. Let’s get back to our basic history and, be more forward-thinking about what CAN be done now while helping decrease the effects of Climate Change for the next generations! Be forthright, forward-thinking and look-at the whole picture now: - Younger people are also very conscientious of Climate Change. Why not give them a place to live and train them in the trades by providing hands-on experience building Tiny Homes right now? (Akin to raising a barn or a place of worship or a school together, as in the past). Today and right now: - Farmland that isn’t Agriculturally viable, is not as costly as land in Towns. - Outside Developers are not looking at Affordable Housing because it is not profitable. Since COVID, they would actually lose money on building Affordable Tiny Homes - especially in Town. - Let’s allow off-grid Development in ‘Out-Of-Town areas’ right now (historically this has been the pattern and why we have several Hamlets etc.) The County can move towards connecting these to ‘the grid’ systems later). - For now, these Communities of Off-Grid Affordable Housing can collect rain water and use composting toilets; a grey-water recovery system; a plant-based water treatment, solar UV, grow their own food in greenhouses/land and this life is, I believe, more getting back to our roots historically. - Let’s support our local people and businesses first too. Why not extend and increase the frequency of our bus transit system first to these new outlying communities of Affordable and Attainable Housing now? (Easier and more practical and less pollution). So, It’s part of our history to build a cabin, use an outhouse and live off the land, care, share, and ‘take care’: Neighbours helped each other to build communities and as a resource to get the crops in and off the land. The past has been our foundation of who we are. We have heart! We look to give each other a hand and a hand up and to take care of our most vulnerable. The very foundation of Our Community historically is based on this philosophy. We can do this now BEFORE it’s too late! Inter-generational and diverse residents could thrive in Off-Grid Communities located in out-lying areas where utilities and infrastructure is not supported. Let’s not delay for the sake of our Founding Settlers, our philosophy and our history. In combination, let’s be more-forward thinking, look at the whole picture and support Climate Change incentives like in other Municipalities. Please start to actually build Off-Grid Affordable Housing NOW.

Joanne Quinn about 1 year ago

Glad I’m not the only one! I offer the following background to my rationale: My late husband died tragically; all of a sudden in a car accident just 2 months after we moved here. He was from Consecon and so we moved to The County in 1997. In February 1998, I was left a single mother with 3 young children and since I was recovering from a disabling illness, we hadn’t had time to arrange a joint bank account. However, The Community was there with condolences and support - food and even money! Later, when I had an opportunity to move, that very fact made my decision to stay. So now I offer my opinion: The County needs to adhere to the minimum 25-33% portion of ANY new developments to be Affordable immediately. Humanity, and humane treatment of our fellow humans and Housing go together. Why? - because having a space we can call our own is a basic human need attributable to our well-being and therefore our Human Rights. Affordable Housing: In order to be attainable NOW we need housing that starts in the $200’s range as 2 people earning $20/hr would only gross $83,000 or so per /annum; 30% of what they could afford is $250,000 approximately, and, that doesn’t include debt, (student loans, (young doctors) credit card debt, transportation and the ever-increasing cost of basic living such as food, clothing. Look at the WHOLE picture: - In order to keep our support workers, we need to keep them here (help locals to be able to ‘Afford’ to live here and even give them a help-up to thrive here and now). Support workers also support our increasingly larger Senior population and our Tourism Industry: - Our Support System is already deteriorating. (We’ve seen Seniors that can’t get help maintaining their property and homes, and businesses that can’t find staff). We need more youth vibrancy now. - Let’s attract more young families to our area too. Let’s get back to our basic history and, be more forward-thinking about what CAN be done now while helping decrease the effects of Climate Change for the next generations! Be forthright, forward-thinking and look-at the whole picture now: - Younger people are also very conscientious of Climate Change. Why not give them a place to live and train them in the trades by providing hands-on experience building Tiny Homes right now? (Akin to raising a barn or a place of worship or a school together, as in the past). Today and right now: - Farmland that isn’t Agriculturally viable, is not as costly as land in Towns. - Outside Developers are not looking at Affordable Housing because it is not profitable. Since COVID, they would actually lose money on building Affordable Tiny Homes - especially in Town. - Let’s allow off-grid Development in ‘Out-Of-Town areas’ right now (historically this has been the pattern and why we have several Hamlets etc.) The County can move towards connecting these to ‘the grid’ systems later). - For now, these Communities of Off-Grid Affordable Housing can collect rain water and use composting toilets; a grey-water recovery system; a plant-based water treatment, solar UV, grow their own food in greenhouses/land and this life is, I believe, more getting back to our roots historically. - Let’s support our local people and businesses first too. Why not extend and increase the frequency of our bus transit system first to these new outlying communities of Affordable and Attainable Housing now? (Easier and more practical and less pollution). So, It’s part of our history to build a cabin, use an outhouse and live off the land, care, share, and ‘take care’: Neighbours helped each other to build communities and as a resource to get the crops in and off the land. The past has been our foundation of who we are. We have heart! We look to give each other a hand and a hand up and to take care of our most vulnerable. The very foundation of Our Community historically is based on this philosophy. We can do this now BEFORE it’s too late! Inter-generational and diverse residents could thrive in Off-Grid Communities located in out-lying areas where utilities and infrastructure is not supported. Let’s not delay for the sake of our Founding Settlers, our philosophy and our history. In combination, let’s be more-forward thinking, look at the whole picture and support Climate Change incentives like in other Municipalities. Please start to actually build Off-Grid Affordable Housing NOW.

Joanne Quinn about 1 year ago

Fines should be high enough to drive unlicensed operators out of the game. I have seen several municipalities go as high as $50,000 for repeat offenders. Anything less and it becomes a cost of doing business. Some of these STA’s can net over $100,000 a season.

Andrew Janikowski over 1 year ago

I'm unable to specifically comment about my future endeavours or that of my group (at this time) but the constant news of the Council's proposed changes for STAs and the larger implications on the tourism sector leaves a lot to be desired in terms of securing our trust and providing financial stability to the region.

I will say that my group will be investing in a region like PEC to the tune of hundreds of millions of dollars but the Council's lack of commitment to the tourism industry has us now considering alternate locations such as Kelowna, Niagara, and Quebec for our next investment.

I truly hope Council can see fit to stabilize the tourism industry (of which STAs are the backbone of) and promote responsible growth that can benefit all businesses and individuals of the PEC.

In cognito almost 2 years ago

The report is missing key information needed to drive out solutions to help fix the housing issue that is plaguing all of Ontario at this time. Focusing and blaming STA's will lead to incorrect decision making and drive out solutions that will negatively impact the people who need the extra work to make ends meet.

The study has missed on the following points:
Comparison of other vacation areas across Ontario. Quinte area is middle of the pack in the areas impacted with double digit house pricing increases over the past 5 years. Based on Canadian Real Estate Association CREA data.
Understanding the number of people impacted by housing stress, by ward is critical. Knowing the number of people, not percentages upon percentages without key data blurs the true scope of the problem. Knowing the true number could lead to real solutions quicker.
I don't understand why the impact of reducing STA's along with the income they provide for the very people who need supplemental income was not included in the study. Not including the casual and full time income earned by the very people who are experiencing housing stress is hard to comprehend. Taking away an income source then proposing to fix the price of housing which the county has no control over will increase the number of people in need.

The report is based on incorrect details about the STA ownership models. It makes a broad assumption that there are only 2 ownership models, which is incorrect. The ripple effect of this assumption is throughout the report.

This study was not completed by an impassionate analyst, rather it seems the group used a previous study https://upgo.lab.mcgill.ca/2019/06/20/short-term-rentals-in-canada-paper/ which took the view point to blame STA's to come up with recommendations.

More comprehensive work is needed to include all pressures on housing in Ontario and Prince Edward County, which the STA’s will be a small part of the problem. This should be done by the province working with regional governments to start solving the low income housing problem. This is a province / country wide problem that was exacerbated by Covid when people decided to escape from the city to set up a second home in the country. I agree that STA's have to be controlled and regulated but not by using recommendations from a flawed report. Prince Edward County has already taken a good step forward in controlling STA’s through their licensing program, which is already reflected in the negative STA growth numbers.

Best case scenario:
figure out how many people need help and create a plan to help them now
don't take away jobs from these people
control STA volumes by ward so that any one area isn't over run with STAs but marry the control with the tourism long term plan. Meaning, put the STA’s where they are needed, to the volume needed, to support the tourism industry which provides jobs for Prince Edward County residents.
Work with the province to develop a long term action plan to develop more low income rental units and low income housing.

I have attached notes to the study, where I think they have got it wrong. Basing decisions on data collated during the period of covid, where every area of the province saw double digit increases to the price of homes does not seem to be the common sense thing to do.

It's important for the county to do their part to help their citizens but I am hopeful council won't take action based on this flawed report.

A comprehensive long term tourism plan and a long term housing plan should be driving decision making of which STA's are a part of the actions that need to be taken. Driving actions for tourism and housing based on a flawed STA specific report is reactionary and will lead to unintended repercussions that will hurt rather than help the people of Prince Edward County.

BASE on CREA data – rise in housing prices comparing 2020 to 2020, by tourist region: (I also have 3 year comparison and 5 year comparisons)
This is key data that was not included in the report!

Peterborough / Kawarthas 37% increase
North Bay 38% increase
Bancroft area 37% increase
Windsor Essex 34% increase
Northumberland hills 33% increase
Kawartha Lakes 32 % increase
Huron Perth 32% increase
Barrie district 31% increase
QUINTE DISTRICT 30% increase
(for comparison: Toronto 31% increase)

REGARDING THE PROPOSED BY-LAW CHANGES:

SECTION 2: #27. All licenses issued after XXXX, 2022, shall only be issued to, and may only be held by, natural persons.
 This is where the flawed study is leading staff to incorrect assumptions about ownership models. Missing is single entity owners who have purchased and are operating under a corporation. Because the study assumes there is no such model, they don’t include it in the study. This could be a large number of single owners who have set up a corporation or included it in an existing corporation. UNTIL THIS DATA IS KNOWN AND THE IMPACTS OF THIS MODEL IS KNOWN, THIS CHANGE SHOULD NOT BE INCLUDED IN THE BYLAW CHANGES.

SECTION 9: # 7. The Council of the Corporation of the County of Prince Edward reserves the right to use its discretion to limit the number of licenses that are to be issued each year, when it deems it necessary to do so. Such action shall be done by a Council motion.
a) The number of Licenses issued after XXX XX, 2022 shall be zero (0)
THE BYLAW ALREADY STATES THAT PEC RESERVES THE RIGHT TO LIMIT LICENSES. ADDING ZERO LICENSES TO THE BYLAW DOESN’T MAKE SENSE. THIS ONLY ADDS TO FUTURE ONGOING ENDLESS DEBATES AT COUNCIL ON MAKING CHANGES TO THE BYLAW AND CONSTRAINS PEC STAFF FROM IMPLEMENTING PLANS THEY SHOULD BE CONTROLLING.

Using a flawed report to react to STA’s in the county instead of driving out the number of STA’s needed based on the Tourism plan and the housing plan is a mistake that can be prevented by not including #7 in the bylaw changes.

Valerie Barclay
Owner of a STA since 2014 who is not impacted by these changes

Valerie Barlcay almost 2 years ago

Hello. Thanks to everyone for contributing to this lively discussion. In a rush to get this note submitted, I’ve summarized points raised that align with my point of view without any intention of plagiarism:
Council seems to be supporting and furthering the myth that STA’s are responsible for the lack of affordable housing in the county when affordable housing is an issue throughout the country and beyond. The goal to remove/reduce STAs will do far more to hinder tourism and the local economy than to rebound from a national issue with roots far deeper than acknowledged. Further, R3/R4 new development for condos and townhouses will likely further increase home prices and the burden for first home buyers, and reducing STAs will do little to change that.



The economy of Prince Edward County is based primarily on tourism, recreation and the service sector, and has been for many years, and having a supply of STAs throughout the County is essential for the maintenance and growth of tourism in Prince Edward County. Personally, I visited here long before owning, and stayed in a whole-home STA when visiting.


It’s important to understand that home STAs play an important role in PEC tourism. Many families and groups prefer to stay in whole-home STA rather than share with a principal owner or to stay in an expensive hotel/motel. By allowing zero growth of whole-home STAs and the inability to transfer an STA licence at the time of a property transfer, we will reduce options for larger groups and families, and they’ll go elsewhere to vacation and spend their tourism dollars.



The grandfathering of STAs can help maintain these active rentals that bring tourism dollars. But if grandfathering is removed, these homes will likely remain just as expensive to purchase, but are likely become second homes that sit vacant for most of the year and contribute little to the local economy or the fabric of the community.
 
Striking a balance that will support sustainable, long-term growth of tourism in the county while supporting the needs of local residents is no easy task, but the attack on STAs seems like a short sighted and politically motivated move that will ultimately do more damage than good. I think more time is needed for a more thorough and balanced analysis, and ideally with conditions not exacerbated by a global pandemic.

Thank you

Owen Milburn almost 2 years ago

Mayor, Councillors and Staff:

My wife and I purchased a farm in PEC in 2013 and began operating it as a part time STA shortly afterwards. The ability to use our property as an STA, and the resulting income, has afforded us the opportunity to renovate the house inside and out, top to bottom. It has caused us to invest in our property and ultimately form our life and our future plans around Prince Edward County. Due to family circumstances we are unable (yet) to move to the County full time, but it's part of our plan. We have invested over $500,000 in local goods and services, and plan to invest many times that throughout the rest of our life.

Except, that the County doesn't seem to want us to grow our life here. The County seems to want to frame us as opportunistic tourists who are driving up the property values at the expense of "real" County residents who somehow haven't benefited from the similar rising property values and the jobs that have come with tourism. Ultimately though, this isn't about that, it's about property rights.

It's one thing for the County to regulate STA through the licensing program. We are supportive as it brings a level of professionalism to the space for those of us that treat it as a business. We are happy to pay taxes on our income and are pleased for the County to benefit. It's another thing to forbid the practice entirely. I think it borders on illegal. Using a house as a restaurant? Understandably the County would have something to say. Operating a house as a house? That's not allowed any more? Excuse me?

Cottage rental is an Ontario pass time. The County is an Ontario treasure. The two together are a recipe for decades of economic development and a booming economy. Please, don't shoot us all, and future generations, in the foot because change is hard and growth can cause challenges. These are good problems to have. Solve them with proper planning, low cost housing developments and incentives for people to build multifamily residential.

This is a knee jerk reaction to rising property values, which has nothing to with STAs. it has to do with macro economic policies at the federal and provincial level, and pour planning at the local level. Are there ANY apartment buildings in the County? I honestly can't think of one.

Put the blame where it belongs, develop policies and programs to solves the real problem, which is a separate issue from encouraging local economic development such as what is provided through businesses such as STAs. What the County is considering is akin to cutting off your nose to save your face.

I encourage increased enforcement of the existing rules. There is no need to create new ones. Spend the energy on planning housing instead. Plain and simple.

Regards,
Clayton Miller

Clayton Miller almost 2 years ago

Hi

These changes still seem very rushed and not thinking long term or big picture. I think the past two years the county has gone through all sorts of ups and downs along with the rest of the world. I think the smart thing to do would take a moment and see how things play during a year without lockdowns. So much of this is being based off of two years of extreme uncertainty. It’s like the Wellington beach, we had one crazy summer so changes were made. This was as followed by a much less crazy summer and more people not even going to the beach to avoid the $10 fee. Now onto this summer, the beach is back to being a quiet beach with more security, county workers and locals then paying people on the beach. Big decisions in the moment seem smart and correct but we have not been dealing with normal circumstances so why make big decisions now.

I think the fact you are going to take away grandfathered whole home
STA’s is completely unreasonable. People purchased homes for a premium knowing that it was part of it so to just take that away seems again rushed, extreme and not thinking about the big picture. It’s time to just slow down to the county pace and see how things go. At the very list check in on these changes a year from now and see if they are still relevant.

Thanks

Stefan Naccarato almost 2 years ago

Mayor, Councillors, Staff,

I completely disagree with the proposed Municipal By-law amendments. My family as well ourselves have been property owners in Prince Edward County for as long as 40 years.
Whether or not you are an STA operator, or wish to be in the future , this is more about the decimation of private property owner's rights, and what can be interpreted as a gross over-reach of Municipal Government on private property owners.
What are property rights in Ontario?
Every person has a right to own the real and personal property that he or she has acquired in accordance with law and, except to the extent provided by law, to the peaceful enjoyment and free disposition of the property.
The main legal property rights are the right of possession, the right of control, the right of exclusion, the right to derive income, and the right of disposition.

The economy of Prince Edward County is primarily based on tourism, recreation and the service sector, and has been for many years. This sector must continue to be actively supported and enhanced. There is great desire by the travelling public to come to PEC, spend time and money in every category of local business and enterprise. This is what drives the local economy.

Isn’t it possible to consider that PEC Council and Administration have not adopted the proactive practices of procuring land and development of geared-to-income housing over the past 20 - 30 years? More multi-family housing is needed in PEC, that is well suited to local residents.

It would appear that due to the Municipality's lack of action on their part to take action to develop multi-family housing, that they are now attempting to regulate private property owners and diminish primary property rights.

The proposed amendments are a gross over-reach of municipal government to burden the property rights of private property owners.

This discussion is not unique to Prince Edward County.

At this time, a few months in front of a Municipal election, it would be prudent for further consideration and perhaps legal input, prior to any changes to the by-laws. Perhaps new ideas can come to the table, that enables Municipal government and private property owners with a way forward that benefits all concerned citizens & business owners and potentially could generate additional revenue that can be actioned or ear-marked to the development of multi-family properties.

NT

Nancy Troke almost 2 years ago

I agree with the proposed changes to the STA regulations. The current density of whole-home STAs in some parts of the County is far too high. Many full-time residents now have transient neighbours or, in some months, none at all. Not the way to encourage or preserve a vibrant community.

It’s interesting that so many of the anti-regulation comments suggest that those with alternate views are anti-tourism. I doubt that this is true. Tourism has brought many benefits to the County. But too much transient accommodation, as in whole-home STAs, has indeed hollowed out the communities that made this place special and that helped create the conditions that attracted tourists in the first place.

Gerry Jenkison, Hillier

Gerry Jenkison almost 2 years ago

On B&B’s:

B&B business should not fall under STA category. They are independent businesses, likely purchased as such, or built over time with a lot of effort and care. In one’s home is zoned to allow a B&B they should remain a business that can be purchased and sold as such.

On Zero Whole Homes:

Cottages and homes will be vacant rather than responsibly hosting guests to the County. The tradition of cottage rentals in Ontario, which falls under the category of whole home, is a huge missed opportunity, ignoring a great Ontario tradition. Residents who own homes in the County also miss the opportunity to offer their homes responsibly to guests and earn some likely needed income. An example is a senior on a fixed income, wanting to escape some of the harsher weather, and employs a local licensed Property Manager who is available 24/7.

I’d like to also point out that in my experience, just because a host offers short-term-accommodation in a separate unit or dwelling on their property, there is NO GUARANTEE that owner will actually be on site, or in The County, or even in the County for that matter. The cost to track that type of information is cost prohibitive. No one will ever know. My point is that I see no difference between hosting whole home accommodation or hosting a secondary unit on site. What should be required by all is hiring a licensed Property Managers available 24/7.

I have hosted a whole home long stay rental in a different country long distance for over 10 years, professionally, and with great success. I have been involved in Real Estate, Development, and Property Management my entire career – always working with the conscience of Community first. I hope your reconsider B&B’s and whole homes (where whole homes meet all other requirements re zoning, density, etc.)

Susan Mullen almost 2 years ago

Why?
Why is the question we should all be asking about the STA issue. I have a license for my STA from PEC as required. The license fee is the highest in the country, even more than Toronto or Vancouver! Where I do agree it is important for safety reasons to be inspected, I do not agree with the price structure or unreasonable requirements. The County staff is already being paid to do this inspection job, a small fee should cover the cost.
That is not the real issue here though. It is all smoke and mirrors to make us debate what's right and not about ZBLs and grandfathered license transfers. We are having to wool pulled over our eyes by an overreaching local government. It is not clear if what has been done so far is even legal. Is the County allowed to except the MAT fee/tax? I paid my share. It seems like they are scrambling to make changes to the bylaws and create new not for profit organizations,DMO, to become legal. Why are we not talking about this overreaching of power?
Here is the outcome of research I have done. I contacted the County Clerks office with a list of all different types of businesses in PEC.i asked about what license the Municipality of PEC required to open one of them. Here is the list:
Real estate office
Ice cream shop
Clothing store
Coffee shop
Bakery
Insurance company
Restaurant
Bar
Food shop
Jewelry store
Kitchen shop
Art gallery
Boutique
Thrift store
Convenience store
Dollar store
Theater
Doctors office
Brewery
Home decor shop
Lawyer office
Pot shop
Museum
Pet shop
Florist
Nail salon
Hotel
Bank
Car wash
Gas station
Pharmacy
Book store
Hair salon
Auto shop
Tax agency
Account office
Vap shop
Funeral home
Municipal office
The Clerk was slightly baffled about it. She said that NONE OF THESE BUISNESSES REQUIRE A LICENSE FROM THE MUNICIPALITY.
So I go back to my original point of WHY? Why are we the only buisness in PEC that are required to get a license? This is what the counselors don't want us talking about! We shouldn't be debating grandfathering and 0 new whole house ect.
We should be asking WHY? Why are we being singled out and unfairly treated by the local government. They are overstepping their power and its time we take notice and do something about it.
I for one will be happy to join up with all of the County residents that are being unfairly persecuted by the Government of the County and bring the lawyers to test the legality of what is being done.
Have your say!

Jim Hartley
Resident, buisness owner, licensed STA

Jim Hartley almost 2 years ago

Once again, Bed & Breakfasts are caught in the web of licensing bylaw changes and restrictions designed to control STAs. Specifically, the ongoing lack of differentiation between B&Bs and vacation rental properties would cause the following three proposals, if accepted, to severely impact our B&B business:

- Potential elimination of grandfathering.

B&Bs are owner-operated tourism businesses. Many B&B owners either purchase an existing operation or start their own, investing time, money and hard work to build its success and brand in hopes of potentially selling it as an ongoing turnkey business. This is not any different a practice than what other businesses like restaurants, retail stores, hotels, etc., do to recoup their investment.

Eliminating grandfathering would severely impact our ability to sell our B&B as an ongoing business, killing the value of everything we are currently investing into this chosen livelihood AND the future financial security we hoped for when we retired from the business.

- Corporate vs “natural persons” ownership.

B&Bs are legitimate businesses created on whatever business model provides good fiscal tax and liability benefits. That may be an incorporated company, or a partnership, or even structured as a numbered corporate holding firm for property with a separate operating company responsible for day-to-day operations.

Whatever the model, quite honestly, what business is it of Councils to deem how a business should be corporately structured or titled?

- Removing B&B references from the ZBL.

Removing B&Bs from the ZBL is problematic, as this would not only compromise the resale of currently operating B&Bs (as addressed in point 1), but it may also dissuade new B&Bs from opening in the future, which would be a huge loss for the local tourism industry.

Keeping all provisions for B&Bs in the ZBL would further acknowledge the material differences between B&Bs and whole-home STAs.

There are about 30 B&Bs currently operating in The County. Several have been in operation for well over a decade. Many of our businesses were purchased as turnkey business operations.

B&Bs are legitimate accommodation/tourism businesses that should never have been thrown into the STA licensing pool of vacation-rental properties in the first place.

It is time for Council to recognize and value the contribution of B&Bs to our tourism industry by not only disengaging B&Bs from the proposed STA licensing restrictions/changes, but to also reclassify B&Bs completely separate from vacation rental properties.

Thank you for your consideration.

Sincerely,
Karen Orme & George Amaro
Runaway Rooster B&B

Karen Orme almost 2 years ago

Hello, i am looking at building a 324 sq ft house on my property next to my house that I live in. I would be putting $150,000 into the local economy by doing this so am wondering when this moratorium will be lifted as I do not want to build this and not be able to use it as an STA.

glenn schmidt almost 2 years ago

To Mayor Steve Ferguson, Members of Council, Marcia Wallace, Emily Cowan, Noah Lister-Stevens, Michael Michaud,

As a member of the Bed & Breakfast Association owners of Prince Edward County, we are expressing my concern about the proposed Short-Term Accommodation (STA) regulations going before Council on June 15th.

Specifically, the current lack of differentiation between B&Bs and vacation rental properties in particular the potential elimination of grandfathering.

Proposals to limit or restrict the transference of licenses upon the sale of a property would severally damage a B&B’s ability to be sold as a turnkey operation, where a premium is paid for the business goodwill, customer database, branding, collateral, etc., all of which is tied into the property.

B&B owners spend many years investing time, money and effort in building a B&B’s brand awareness and customer-service reputation, always with an eye on having the option to potentially sell it as an ongoing operation once they are ready to move on from the business.

My husband and I purchased our property 20 years ago. We have been running a successful Bed & Breakfast for over 10 years. Before we invested money it renovating the home into a Bed & Breakfast where we could comfortably live while providing accommodation to the visiting public we did our due diligence and contacted the County to ensure running a Bed & Breakfast was a acceptable activity in our area and to ascertain if any business licensing was required. At that time no licensing was in place or in discussion.

Any grandfathering restrictions greatly impact the future ability to sell a B&B business as an ongoing accommodation business by essentially negating the value of all we have invested in and worked hard to build. This is not acceptable.

The solution is to finally recognize/license our accommodation group separately from STAs.

BED & BREAKFASTS ARE UNIQUE

Bed & Breakfasts are a distinct accommodation group that should not be part of the catch-all category of STA accommodations.

Since the 2018/19 implementation of by/law change regulations and STA licensing, B&Bs have continuously red-flagged for Council and municipal staff the issues created by being thrown into the STA pool.

Operating worldwide since the 18th century, bed & breakfasts are defined as owner-occupied, private accommodation residences in which the hosts provide hands-on hospitality to guests along with a full-service breakfast each morning.

For decades, bed & breakfasts have been The County’s main accommodation providers, alongside motels and inns. There are approximately 30 B&Bs currently operating in The County.

B&B accommodation is not the same as a vacation rental property. In fact, B&Bs operate on the same hospitality level as hotels, motels and inns, only on a smaller scale. And, yet our larger accommodation counterparts are excluded from STA categorization.

It is important to recognize:

· Year-round Residency: B&Bs are owner-occupied year-round principal residences and are not responsible for “dark streets.”

· Distinctive Homes: Most B&Bs are sizeable, beautifully restored/renovated homes with historical significance, or custom-built properties. B&Bs would not be considered affordable housing.

· Supporting Local: B&B-generated revenue is spent locally and re-invested back into the community year-round.

· Our Livelihood: For many B&B owners, this is a chosen tourism-hospitality career and often the only source of income.

· Professional Standards: B&Bs uphold all safety and operational standards, maintain our properties, ensure guest protocols are followed, and support our communities and our tourism industry.

· Hosted Experiences: B&B owners are invested 24/7 hands-on concierges providing a hosted experience, serving daily full-course breakfasts, and function as our guests’ local tourism ambassadors.

In conclusion, we ask Council to recognize the detriment to B&Bs if restrictions on license transference upon sale go forward. We request that B&Bs be excluded from that legislation.

It is time to finally recognize that we are NOT THE SAME as a vacation rental and should not be blanketed by the same regulations designed to control STAs. In order to effectively recognize and safeguard B&Bs as distinct accommodators, requires Council to remove B&Bs from their definition of an STA, and reclassify/license our group separately.

Thank you for your time and consideration.

Sincerely,

Susan & Glen Wallis, Away in the County Bed & Breakfast, Cherry Valley, Ontario

Susan Wallis almost 2 years ago

The proposed changes to the STA bylaw and ZBL mirror the sentiment of many residents.
At the moment many owners of STA’s do not declare themselves as STA’s and therefore it is hard to judge how prevalent the use of STA’s is.
The proposed changes to the STA bylaw and ZBL are a good first step to regulate what has been an overwhelming invasion by the tourism industry.
Most people concentrate on the lack of affordable housing as the genesis for the bylaw changes.
A more important aspect is the impact that non-resident ownership has on the social fabric of our community. People who visit the county do not volunteer. In the last 2 years we have seen store shelves depleted which has forced many of us to shop outside the county. The effect of large fluctuations in population densities also has impacts on Police, Fire, health care services and county staffing to name a few.
The impact of the previous points vary depending on whether the STA is occupied by the owner or not. Placing a cap on non-owner occupied STA’s until a clearer picture of the extent of the problem can be determined is waranted.
Not allowing STA licenses to be sold with a property is one way of controlling the supply and demand of STA’s. One respondent on this blog suggested that the “grandfathering” of existing STA’s may not be as valid as some wish or hope. Either way forcing the expiration of an STA license after a sale of a property is one way of ensuring compliance with regulations in force.
Clearly the situation requires action and the sooner the better. I have no wish to live in a “theme park” and would like to enjoy the beauty and peace that the county offered when we bought our property 20 or so years ago and the county I remember from the 1980’s & 90's.
Change is a constant in any system, but we do have some control over what impact the changes have.
The STA and ZBL changes are a step in the right direction for the people living in the county.

Eric De Pauw almost 2 years ago

One intention of a new STA Bylaw requirement appears to be to eliminate whole home and cottage rental opportunities through attrition, whether 3 season cottages or 4 season. The result, should the bylaws pass as written, will be that nobody wins and the biggest loser will be the County overtime.
Overtime - the County will suffer a huge decrease in income as MAT remittences will be considerably reduced. The County will have to find money for road repairs and the multitude of other County expenses through an increase in property taxes for principle residences and second homes.
Overtime - the County will have to lose Bylaw officers or increase property taxes to cover these salaries. The STA licence fees were always intended to contribute significantly cover the cost of additional Bylaw officers.
Overtime - the decades old tradition of the County summer cottage industry will be lost forever. The current thinking is that it is too complex to distinguish 3 season cottages from 4 season accommodation so all will be grouped together and eliminated through attrition. A tradition, 100 years of years old, will be lost in just a few years.
Overtime - Visitors to the County who want to stay for a week or more will be comprised of only the wealthy. With scant opportunity for middle class families whoo have vacationed here for decades to find reasonably priced, good quality accommodation for a week in the County they will go elsewhere. A look at the new resorts planned for the County provides clear evidence that the future of tourism will be to cater to the 1%.
Overtime - as current cottage and STA owners sell their properties there will be a significant increase in second home properties. Expecting cottage and STA properties to meet the criteria for residents who need affordable housing is not feasible as these properties were never met the criteria to begin with. A finding reported by the consultants hired by the County, that has slipped many minds, indicated that the real crises the County is facing is the proliferation of second homes over the last two years. They also reported that the actual number of STA's in the county had declined over the last two years.
Overtime - more and more areas of the County will become dark and not only through the winter but through all four seasons as second homes sit empty.
Overtime - second homes will be the reason tourism and the many businesses that currently depend on tourism will collapse. The resorts, hotels and motels will all be self sufficient - it just good business and these are smart business people. As well, any hope of being a four season destination will be very over.
Overtime - We all lose when we legislate away a critical tourist segment . We all lose when we reduce an important tax and licence revenue stream. We all lose by eliminating existing whole home cottages or STA's through attrition. We all lose by not balancing the big picture needs of the County.

J.H.Roberts

John Roberts almost 2 years ago

I agree that the whole-home STA licencing process needs some updating but placing a permanent moratorium on issuing new whole-home STA licences and not allowing current STA licences to transfer from one owner to the next is not the answer.
I have been renting whole-home vacation properties in Prince Edward County through my company Sandbanks Vacations since 2009. Over the years, most of the properties that we represented were either rural or waterfront and captured the true charm of this community.
When large third-party booking platforms such as Airbnb, VRBO and HomeAway became readily available, the DIY vacation rental industry began to thrive. As a result, some vacation rental operators began to encroach on quiet neighbourhood communities and that has led to the situation that we find ourselves in now.
When I think of a whole-home STA, I think of a cute little cottage on the shores of East Lake, West Lake, Lake Consecon, etc. I also think of rural retreats located throughout our beautiful countryside as well as stunning estates located along the shores of Lake Ontario, and so on.
I do not think of a three-bedroom, two-bathroom side splits in the middle of a residential district owned by an absentee owner who rents it out as a party house every weekend. They should have never been allowed to obtain an STA licence.
Having an abundant supply of whole-home STAs throughout the County is essential for the growth and popularity of tourism in Prince Edward County. These vacation rentals play an important role in attracting family reunions, group getaways, small corporate retreats, etc.
With zero growth of whole-home STAs and the inability to transfer an STA licence at the time of an STA property transfer, we will eventually have very few options for larger groups and families who want to spend their holidays together. They will simply opt to travel to a more accommodating region.
Agreed, there is a problem with the location of some STAs in The County. Don’t just randomly shut this accommodation sector down, work with local accommodation experts to come up with a viable solution.
I urge Council to reject the proposed amendments to the STA By-law and work with local industry experts to come up with a viable solution.
Richard Barrett

Richard Barrett almost 2 years ago
Page last updated: 09 Sep 2022, 03:05 PM