HomeMy WebLinkAboutPD-104-94THE CORPORATION O,
Meeting: General Purpose and Administration Committee
Date: Tuesday, September 6, 1994
Report #: P..-D=aDA- _A4File #: R]aa. - -1? 1
Subject: RESIDENTIAL RIGHTS ACT (BILL 120)
APARTMENTS IN HOUSES LEGISLATION
File: Pln. 11.1
File # L) I , /-1 P
Res. #(-x(00 - 1��
By -Law #
Recommend
1. TWA` Report PD- 104 -94 be received for information.
1. BACKGROUND
1.1 On June 18, 1992, the Provincial Ministers of Housing and
Municipal Affairs released a consultation paper entitled
"Apartments in Houses: A Consultation Paper on Legislative
Amendments to Allow One Apartment in a House ". This
consultation paper contained proposed legislative amendments
to the Planning and Municipal Acts and proposed zoning and
property regulations (standards) to allow one apartment in a
house as -of- right. The consultation also proposed to permit
garden suites (also known as granny flats) through amendments
to the Planning Act.
On September 14, 1992, Council adopted Report PD- 198 -92 as the
Municipality of Clarington's submission to the Province
regarding the consultation paper.
1.2 Bill 120 ( "The Residents Rights Bill ") received second reading
on December 13, 1993. In March 1993, Bill 120 was reviewed
clause by clause by the Standing Committee on General
Government of the Legislative Assembly of Ontario. On July
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REPORT NO.: PD- 104 -94 PAGE 2
14, 1994, the Apartment in Houses provisions of Bill 120
became law.
1.3 The Residents Rights Bill authorized a Regulation (384/94)
under the Planning Act on June 23, 1994 which set limits on
the planning standards which can apply to houses with two
units. This Regulation covers such standards as: size, unit
density, age of structure, units below grade, amenity area,
flood plains, parking, etc.
1.4 The Province has supported the creation of apartments in
houses for a number of reasons:
• such units tend to be more affordable than other private
market rental units;
• such units can generate a rental income which can help
first time home buyers, and current owners on fixed or
reduced incomes;
• such units are "environmentally friendly "; and,
• such units are an appropriate housing solution in a
society where there has been a decline in household size.
1.5 This report has been prepared by the Planning Department in
consultation with the Fire Department, and the By -law
Enforcement Division of the Clerks Department. The purpose of
the report is to identify the implications of this legislation
for the Municipality of Clarington.
2. OVERVIEW OF THE LEGISLATION
2.1 Bill 120 amends the following acts: the Landlord and Tenant
Act, the Rent Control Act, 1992, the Rental Housing Protection
Act, the Planning Act and the Municipal Act. The amendments
to the first three Acts are concerned with legislation
regarding care homes.
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REPORT NO.: PD- 104 -94 PAGE 3
2.2 The amendments to the latter acts are an attempt to allow
owners of detached, semi - detached and row houses to have one,
self - contained apartment in their house provided that the unit
meets Building Code, Fire Code and reasonable planning
standards. Secondary objectives of the amendments are to
encourage the creation of garden suites, improve municipal
powers of entry and enforcement, and clarify that for planning
purposes, distinctions should not be made based upon the
relationship of members of a household.
2.3 The primary concern to the Municipality of Clarington is in
regards to the amendments to the Planning Act and the
Municipal Act. These amendments are summarized below.
Bill 120 amended the Planning Act to:
• permit people to create one accessory apartment (self -
contained residential unit) in existing or new single
detached, semi - detached or townhouse dwellings on an as-
of -right basis in any residential area;
• ensure that official plans and by -laws cannot be used to
prohibit two residential units in a detached house, semi-
detached house or row /town house;
• clarify that the authority to approve a plan of
subdivision does not include the authority to prohibit
the construction, locating, or use of two residential
units in a detached house, semi - detached house or
townhouse;
• clarify that zoning by -laws cannot distinguish between
persons based upon relationship (related or non - related) ;
• exempt detached houses, semi - detached houses or rowhouses
serviced by prescribed classes of "sanitary, septic or
sewer system ";
• improve the ability of municipal officials to obtain a
search warrant to search for evidence that certain
offenses have been committed and to make it illegal to
obstruct or attempt to obstruct officials in this regard;
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REPORT NO.: PD- 104 -94 PAGE 4
• include the amended definition of a residential unit
which permits means of exit ( "egress ") through another
unit; and,
• permit municipalities to use temporary use by -laws to
authorize the temporary use of garden suites for up to
ten years.
Bill 120 amends the Municipal Act to:
• ensure that the power of a municipality to license
lodging houses does not extend to residential units;
• define "lodging house "; and,
• define "residential unit" as in the Planning Act but add
the following clause to the definition: "is used as a
single housekeeping unit, which includes a unit in which
no occupant has exclusive possession of any part of the
unit ".
3. IMPLICATIONS FOR THE MUNICIPALITY OF CLARINGTON
3.1 Bill 120 has a number of implications for various departments
serving the Municipality including the: Planning and
Development Department, Fire Department, and By -law
Enforcement. This next section will review the implications
or the various departments.
3.2 Implications For The Planning Division
The apartment in houses provision of the Residents' Rights Act
applies to houses with two residential units. "Residential
unit" is defined in the legislation as being a residential
premises which is self contained (with its own kitchen and
bath) except that the exit may be through another unit. The
legislation does not apply to a house with two "lodging units"
where residents in different units share a kitchen or bath.
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REPORT NO.: PD- 104 -94 PAGE 5
In order to ensure that planning standards do not preclude the
legalization of existing second units or the creation of new
ones, Section 49 of the Residents' Rights Act authorizes a
Regulation under the Planning Act which sets limits on the
planning standards municipalities can apply to houses with two
units. Documents which are affected by this provision
include: official plans, property standards by -laws, zoning
by -laws, site plan control by -laws, and Minister's zoning
orders.
The Planning Act Regulation authorized by the Residents' Right
Act has three objectives:
- to identify the types of accommodation and the areas to
which the apartments in houses provisions of the
legislation apply;
to ensure that planning standards do not have the effect
of preventing the creation of or legalization of second
units where they meet reasonable health and safety
standards, and where they are compatible with the
surrounding area;
to provide the forms which are required to implement the
search warrant provisions of the Residents' Rights Act.
The Planning Act Regulation does not:
directly alter the authority of municipalities to
regulate the physical character of neighbourhoods,
although this authority is limited;
generally affect the authority of municipalities to apply
maintenance and occupancy standards to houses with two
units;
- affect the authority of municipalities to prohibit or
establish standards of their own for houses with three or
more units;
affect the authority to prohibit or set standards for
houses with second units in cases where the houses are
not covered by the legislation or the Regulation (e.g.
houses on septic system);
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REPORT NO.: PD- 104 -94 PAGE 6
- affect the requirement that municipal standards comply
with other applicable provincial regulations; although,
if a municipal standard is more restrictive than the
Provincial standard, the Provincial standard will be in
effect; and,
allow municipalities to restrict houses with two units to
those where the owner lives on the premises.
The Planning Act Regulation generally takes precedent over
local documents, although it allows a municipality to continue
to apply certain standards. Where the municipal standard is
more restrictive than the Provincial standard, the Provincial
standard will be in effect. If a standard in a planning
document is less than the standard in the Regulation, then the
municipal standard continues to apply.
The Regulation covers such standards as:
• the types of detached, semi - detached and row houses which
are considered suitable for apartments
• the applicability of the legislation for houses in all
areas except those in certain zoning areas
zones where the only uses permitted are industrial
or commercial activities are excluded
houses connected to private or septic systems are
excluded
areas which only permit residential uses which are
ancillary (secondary) in nature are excluded
• tenure status of house
no distinction is made based on whether or not a
houses sits on its own lot, is part of a rental
project, or is part of a condominium project
• size of house
- cannot require that a house with two units have a
minimum size of floor area that exceeds the
requirement for a house with one unit
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REPORT NO.: PD- 104 -94 PAGE 7
• unit density
cannot prohibit a second unit on the grounds that
the presence of that unit would mean certain "unit -
related" density measures have been exceeded
• age of structure
cannot restrict second units to houses built before
,or after a certain date, or built during a certain
time period
• units below grade
cannot prohibit units on the basis that they are
located below the ground floor, or require that a
least a certain proportion of a unit be located
above ground level
• amenity area
Regulation does not prevent municipalities from
requiring that a certain proportion of a lot be
designated as an amenity area
• parking
Regulation deals with on site parking requirements,
driveway parking, garages, on- street and front yard
parking
• installation and renovation of second units
exterior changes
houses that do not conform with planning standards
- interior alterations
Actions To Be Taken
As a result of Bill 120, the Planning Department will be
undertaking a number of tasks including:
a) amending the draft Official Plan to reflect the
legislation;
b) amending the Zoning By -law to reflect the legislation;
C) establishing a data base for apartments in houses;
d) handling public inquiries regarding apartments in houses
and garden suites;
e) updating the street numbering system to include
apartments in houses to ensure emergency vehicles can
respond quickly; and
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REPORT NO.: PD- 104 -94 PAGE 8
f) producing a standard garden suite agreement which would
be entered into by the Municipality and the land owner.
3.3 Building Division Implications
For a second unit in a house to be considered "legal ", the
house in which it is found must meet applicable planning
standards, standards of safety and construction in the Ontario
Building Code, fire safety standards in the Ontario Fire Code,
and property standards. The standards are intended to allow
flexibility in creating and upgrading units while maintaining
reasonable levels of safety.
Different provisions of the Ontario Building Code apply
depending on the scenario under which a second unit is added
to a house. The Building Code specifies requirements for the
health and safety of a building being altered or constructed.
The owner must obtain a building permit prior to starting any
changes to the structure or to the use therein. The
alterations must be performed as outlined in the building
permit and in accordance with the Building Code. The areas
being renovated or constructed may be subjected to periodic
inspections while construction is ongoing in order to ensure
that construction will comply with the Building Code.
The legislation makes a distinction between standards that
apply to existing dwellings more than five years old and
existing dwellings less than five years old.
Existing Dwellings More Than 5 Years Old
Second units that are created by renovating a house more than
five years old are regulated under Part 11 (Renovations) of
the Ontario Building Code. Renovation Standards are different
than for new construction, reflecting the need for
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REPORT NO.: PD- 104 -94 PAGE 9
flexibility in the treatment of buildings built before the
current edition of the Building Code.
The Building Code only applies to portions of the building
that are subject to construction, plus any upgrading that is
specifically required elsewhere in the building to restore
safety standards to minimum requirements.
Existing Dwelling 1 -5 Years Old
Second units that are created by renovating a house less than
five years old will be subject to Part 9 of the Building Code.
Part 9 provides simple requirements to ensure a minimum level
of fire safety and structural adequacy. Section 9.41
establishes the required upgrading of dwellings 1 -5 years old.
Dwelling units constructed in this time period often have the
necessary components ready for establishing a second dwelling
safely.
For all conversions, the Ontario Building Code will require
adequate exits and smoke detectors in both dwelling units to
help ensure early warning and safe evacuation of the occupants
in the event of fire.
Actions To Be Taken '
Building officials, when required, will need to inspect
apartment units to determine if they meet the Ontario Building
Code. It is expected that if there is an increase in
renovations, alterations, or construction of units, the amount
of time that is necessary to process a building permit will
increase since many applications require substantial review
and sometimes negotiation. However, the processing time can
be substantially reduced if plans and specifications are
prepared by individuals who have knowledge of the relevant
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REPORT 0; ., PAGE 10
sections of the Ontario Building Code and who are familiar
with renovation practises.
3.4 Fire Department Implications
The requirements for fire safety in apartment units are
regulated under one of two provincial regulations, either the
Building Code or Section 9.8 of the Fire Code.
The Building code regulates the construction of new buildings,
additions, material alterations, and changes in use within
existing buildings. With respect to apartments in houses, the
Building code applies to situations where someone intends to
construct or install a second dwelling unit.
Retrofit Section 9.8 of the Fire Code regulates minimum
provisions for fire safety in existing residential buildings
which contain two existing dwelling units operated as
housekeeping units situated in a detached house, semi - detached
house or row house. The owner must ensure that requirements
for fire separations, means of egress, smoke alarms and
electrical safety are satisfied in order to provide for the
life safety of the building occupants. This may require that
repairs or alterations are carried out in the building in
order to comply.
Depending upon the nature and the extent of the alterations
required within the building, the owner may also need to
obtain a building permit before making the material
alterations. This would need to be discussed with the Chief
Fire and Building Officials serving the municipality where the
building is located. The legislation states that when it is
necessary to comply with the Retrofit provisions, the required
alterations made within the building are not considered to be
in contravention of the Building Code.
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REPORT NO.: PD- 104 -94 PAGE 11
Compliance
Section 9.1 of the Fire Code requires that each building
regulated under Retrofit Section 9.8 must be brought into
compliance within specified periods of time.
The legislation required that smoke alarms be installed in
each dwelling unit as of August 13, 1994. This requirement
provides a nominal degree of protection for the occupants
within each dwelling unit until other fire safety features can
be provided where required.
The legislation also requires those portions of the building
which do not comply with requirements for fire separations,
means of egress, and electrical safety be brought into
compliance by July 14, 1996. If the owner is not able to
complete all of the required work by the time period
specified, the owner must apply for an "Extension of Time" or
submit a "Life Safety Study" to the Chief Fire Official. If
an extension is not granted, the owner may appeal the decision
to the Fire Marshall or to the Fire Code Commission.
Actions To Be Taken
It is expected that the legislation will produce many requests
for fire inspections, which will be very time consuming for
the Fire Department. It will not be possible to conduct house
to house inspections to locate all unsafe and unregistered
apartment units. However, it is anticipated that a number of
these units will be identified as a result of citizens wanting
to make their units comply with standards.
The Fire Department placed newspaper advertisements in July
1994, informing residents of the compliance measures. In
addition, residents in Bowmanville and Courtice will also be
receiving brochures during Fire Prevention Week (October 10 -
14) .
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REPORT NO.: PD- 104 -94 PAGE 12
3.5 By -Law Enforcement Implications
The legislation has a number of implications for By -Law
enforcement in terms of Council's previous moratorium on
enforcement and improved abilities to obtain search warrants.
Council's Moratorium
At its regular meeting on June 22, 1992, Council passed a
resolution stating, in part:
"THAT the Town of Newcastle deems it advisable to suspend the
enforcement of the Zoning By -law as it applies to accessory
apartments."
Since that time, By -Law Staff have received in excess of one
hundred complaints concerning accessory apartments. In each
incident, Staff have had to advise the complainant that
nothing could be done as long as the moratorium remained in
effect. Several of the complaints were from disgruntled
tenants who were attempting to use the by -law as a means of
getting back at their landlords.
Staff will not be re- opening these files since in some cases,
complainants and subjects have moved, while in other cases,
the problems have been resolved.
Search Warrant
A major disadvantage to enforcing the zoning by -law related to
accessory apartments has always been the limitations on the
ability to gain access to the unit. Section 49(3) of the
Planning Act reads as follows:
"Except under the authority of a search warrant issued under
Section 158 of the Provincial Offences Act, an officer or any
person acting under his or her instructions shall not enter
any room or place actually used as a dwelling without
requesting and obtaining the consent of the occupier, first
having informed the occupier that the right of entry may be
refused and entry made only under the authority of a search
warrant."
ST) ilk
. • •
This section of the Provincial Offences Act limited an
official's ability. Usually once informed that they are not
required to permit entry, many tenants would refuse to allow
an officer in for inspection.
The warrant referred to in the section is made up of two
separate and distinct parts. Commonly known as a search
warrant, it is in fact a warrant to search and seize. Despite
indications in the Act to the contrary, Justices of the Peace
would not issue a warrant strictly to inspect a property for
an illegal apartment. Justices of the Peace required hard
physical evidence which the officer needed to specify. If the
evidence to be seized could not be specified, a search warrant
was not issued.
Bill 120 has improved the powers of entry for municipal
officials. This legislation has removed the reference to the
Provincial Offences Act and has replaced it with Section 49.1
which has created a new type of warrant. The officer can now
obtain a warrant to enter and inspect without the need to
seize any evidence. The officer may apply for a warrant to
enter and search any building, receptacle or place if the
Justice of the Peace is satisfied on reasonable and probable
grounds that, an offence has been committed under either the
property standards or zoning by -laws, and that entry and
search will afford evidence relevant to the commission of the
offence.
The Bill further assists the investigating officer by creating
a specific offence for obstructing or attempting to obstruct
an officer in his or her investigation. A conviction for
obstruction carries the same fines as other zoning offences,
that being a maximum fine of $25,000 for a first offence and
for a subsequent conviction, not more than $10,000 per day for
each day of continued contravention. For a corporation, the
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REPORT NO.: PD- 104 -94 PAGE 14
fines are $50,000 maximum on first conviction and $25,000 per
day for continued contravention.
Actions To Be Taken
The new legislation will be dealt with in the same manner as
the existing by -law. Enforcement will continue to be handled
on a complaint basis only. Staff will not investigate
anonymous complaints. It is anticipated that there will be a
significant increase in complaints received as public
awareness of the existence of the new law increases.
4.0 CONCLUSION
Bill 120 has become law and as a result various departments
serving the Municipality of Clarington will be required to
carry out certain tasks.
The Planning and Development Department, Fire Department and
By -law Enforcement will cooperatively place an advertisement
in local newspapers informing residents of the new legislation
and the implications it has for the homeowner. This
advertising should increase the number of inquiries which will
be handled by the appropriate departments. Any assistance
with inspections and renovations will be provided by the
Building Division, Fire Department and By -law Enforcement. In
addition, these departments will deal with any grievances
concerning apartments in houses on a complaint basis only
since a door -to -door inspection would be impossible.
Any planning documents that are not in conformity with the new
law will need to be amended to eliminate any confusion
concerning the Provincial standard and the Municipal standard.
REPORT NO.: PD- 104 -94 PAGE 15
Respectfully submitted,
Franklin Wu, M.C.I.P.
Director of Planning
and Development
TH *DC *FW *df
25 August 1994
Reviewed by,
W.H. Stockwell r
Chief Administrative
Officer
Interested parties to be notified of Council and Committee's
decision:
Fred Storsbergen
Box 416
Orono, Ontario
LOB 1MO
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