Tenant Assistance Policy Engagement Report
An engagement summary report detailing feedback from stakeholders, including non-market housing providers and renters, regarding the impact and requirements of the proposed Tenant Assistance Policy.
Q: What types of supports would have the greatest impact for the renters that you serve in Saanich?
We heard the greatest impact of the Policy for renters in Saanich would be having established tenant relocation guidelines and a tenant assistance program that applies to for-profit development during the rezoning process before occupancy permits are granted.
Participants stressed that the TAP should be seen as one approach to supporting tenants within a larger housing system. In addition to the Policy, there is a need to increase the general rental housing stock across the region, including co-ops and non-profit housing.
Q: Are there population groups that face more challenges in finding affordable, adequate rental housing?
Non-market housing organizations identified the following vulnerable tenant populations:
- Youth
- Seniors
- Indigenous peoples
- People of colour
- Newcomers
- Tenants with disabilities
- Tenants with mental health challenges
- Single-parent households
- Large households with four or more children
Q: Do you have any ideas for how to identify and support renters who may need additional support, beyond the basic policy requirements?
Participants raised the difficulty in identifying individuals living with mental health challenges. The group also shared that supporting vulnerable tenants could include:
- Education and awareness. It was suggested there is a need to improve tenant awareness of existing programs and supports (e.g., BC Housing Registry), and improve education and training for service providers who work with tenants with mental health challenges.
- Partnerships. We heard that collaboration and partnerships across non-profit organizations may help to improve tenant relocation and sharing of resources.
POLICY SUCCESS
Q: How do you see the TAP impacting the work your organization (or sector) is already doing?
We heard the TAP would negatively impact the work the non-market housing sector is already doing. Participants also provided suggestions to support non-market housing in general. Concerns and suggestions included:
- Delays in the redevelopment process. It was suggested that delays to redevelopment would impact rent rates. We heard concerns about the cost implications if Policy requirements would need to be met before development approval.
- Financial viability. Participants shared concerns that meeting the Policy would impact the financial viability of non-profit housing development, particularly given the current high cost of land in Saanich. Participants suggested a Community Amenity Contribution or Development Cost Charge requirement towards non-market housing may help the sector to manage costs related to the Tenant Assistance Policy.
Q: What additional resources may be needed from the District in order to meet the Policy expectations?
The group suggested the District could provide the following resources to support non-market housing organizations to meet Policy requirements:
- Staffing. Participants referenced the City of Vancouver’s Renter Office as a means of providing additional capacity to support tenants through relocation.
- Funding. It was suggested that increased funding would be needed for non-profits to take on the additional workload associated with required tenant relocation support.
Q: What is reasonable to expect of non-market housing developers in terms of proving that the policy has been met?
Non-market housing organizations raised the following considerations and concerns related to the Policy implementation:
- Final report. We heard concerns that requiring a final tenant assistance report prior to occupancy permits will delay the process and increase costs.
- Policy monitoring and review. The group raised questions about how the District will measure the impact of the TAP, and the challenges associated with conducting tenant follow-up without breaching the Privacy Act.
Q: What does success look like for this policy from the non-market housing perspective?
Participants defined success as:
- Building in flexibility for, or excluding, the non-profit sector from the Saanich Tenant Assistance Policy.
- Non-market housing developers can continue to provide affordable rent rates.
Beyond the TAP, we heard ideas for how the District can support affordable non-market rental properties. These included:
- Pre-zoning across the District to support higher density for rental development without a rezoning application, like in Vancouver.
- Implementing policies to prioritize non-profit development, similar to Burnaby.
- Streamlining rezoning approval processes for non-market development, like in Colwood.
- Equal support of non-market housing development across jurisdictions in BC.
- Allowing more flexibility in building typologies (e.g., modular housing).
- Addressing the financialization of housing and lack of rental stock.
- Providing funding to the non-market sector.
4.2. RENTERS & COMMUNITY REPRESENTATIVES
POLICY AND ELIGIBILITY CRITERIA
Q: What aspects of the policy criteria are most important to you and why?
We heard support for the Policy and the importance of protecting a diversity of Saanich tenants, particularly as the District continues to grow. Participants shared that:
- All tenants, regardless of the length of tenancy and rental types, should be included under the Policy and eligibility criteria.
- Saanich tenants experience housing insecurity.
- Tenants who identify as disabled experience challenges in finding accessible housing.
- Long-term tenants are feeling forced out of their homes when neighbouring units are renovated.
POLICY SUPPORTS
Q: Which policy supports are the most important to you and why?
We heard about the benefit of providing a range of supports to meet a range of tenant needs. Tenants and community representatives commented on the following supports:
- Relocation coordinator. Participants most often identified a relocation coordinator as the most important policy requirement. Tenants shared that finding affordable housing that meets their needs is challenging, particularly for newcomers or those with unique housing needs. We heard that a relocation coordinator could help to alleviate some of the time, energy, and stress of relocation in supporting tenants through the process. It was suggested this role would help to coordinate viewings and applications, negotiate costs, and liaise with BC Housing for supportive housing. We also heard a concern about the capacity of a coordinator to be able to take on this workload.
- Communication plan. We heard that clear, written requirements can help to manage tenant expectations and to ensure all parties are on the same page. It was suggested that communication from the developer should include the timeline and plan for redevelopment.
- Financial compensation & moving expenses. We heard that covering moving expenses is important to many tenants, particularly those without family in the area. Participants also suggested that financial compensation may be more important to younger tenants than other Policy requirements, like relocation support or the Right of First Refusal.
- Right of First Refusal. Renters and community representatives suggested the ROFR may be most important for long-term tenants with ties to the neighbourhood such as their medical services and social connections. There was support for the ROFR in the event tenants are displaced because of renovations.
Q: If you have any previous experience with tenant assistance, what worked well? What didn’t?
Tenants and community representatives did not have any experience with formal tenant assistance and shared challenges related to finding affordable rental housing in Saanich. These included:
- The time and energy needed to find new rental housing.
- The lack of rental housing options.
- The high cost of rental housing in Saanich.
- A lack of resources to support the rental process, particularly for newcomers.
Q: Are there population groups that face more challenges in finding affordable, adequate rental housing? What types of support would have the greatest impact for these renters in Saanich?
The group suggested that most renters are vulnerable and raised the challenge of using income to define vulnerability. Renters and community representatives identified the following vulnerable tenant populations:
- Youth and students
- Seniors
- Families
- Indigenous peoples
- People of colour
- Newcomers
- Long-term tenants with ties to the community
- Persons with disabilities
- Individuals living with mental health challenges
- Individuals with low or very low income
- Individuals on fixed incomes
- Victims of abuse
It was suggested that the ability to support tenants aging in place would have a great impact to vulnerable tenants.
POLICY SUCCESS
Q: What additional resources or materials do you think the District can provide that would help tenants through this process?
We heard that additional communication materials from the District would be helpful through this process. Suggestions included:
- Clear and accessible communication to tenants on the Policy requirements, tenant rights and supporting resources. It will be important that these resources are simple and translated when appropriate.
- Early and accessible communication from developers that are standardized by the District. Communication should outline the redevelopment process and description, including the timeline and opportunities for engagement (ideally before the rezoning application is submitted). We heard a reference to the City of Victoria’s Tenant Assistance Policy Guide that outlines a process for property owners when submitting a Tenant Assistance Plan and provides supporting documents (e.g., instructions for applicants, sample letters to tenants, etc.).
- Communication and resources may be provided through centralized support (e.g., one webpage or phone line) with responses to frequently asked questions for tenants, as well as in-person or via social media. This could also be linked to other initiatives within the Housing Strategy.
Q: What does success look like for this policy from your perspective?
Participants defined success as:
- Ensuring everyone has a place to call home.
- Protecting tenants from the financialization of housing.
- Engaging with renters through all stages of policy development, including implementation and evaluation, and conducting follow-up interviews to monitor policy success (i.e., how they experienced the process, where they are relocated, etc.).
- Promoting strong, socially connected neighbourhoods where residents live nearby the services and amenities they access regularly. Additional suggestions beyond the TAP included development requirements for supportive housing and community supports like childcare through methods such as Community Amenity Contributions.
4.3. MARKET HOUSING ORGANIZATIONS
POLICY AND ELIGIBILITY CRITERIA
Q: What are some of the opportunities and challenges of the Policy applying to secondary rentals?
Market housing organizations shared the following opportunity of the Policy applying to secondary rentals:
- Level playing field. We heard that including secondary rentals would ensure all development is treated the same in Saanich.
The group shared the following challenges:
- Additional workload. Participants shared concerns that applying the Policy to secondary rental housing would create an increased workload for both the District and the sector. It was noted that there are efficiencies of scale, and the process should be streamlined for both the applicant and the District to avoid additional delays and cost implications.
Q: What do you think about encouraging voluntary Policy compliance with applications that do not require rezoning?
We did not hear any comments or concerns about encouraging voluntary Policy compliance for applications that do not require rezoning.
Q: Are there any other thoughts on the qualifying criteria you would like to share?
The market housing group provided several considerations related to the Policy’s qualifying criteria. These included:
- Tenant eligibility. It was suggested that an income-based approach to tenant eligibility may tailor the program to tenants’ financial needs rather than to the length of tenancy. Participants noted the length of tenancy does not necessarily equate to vulnerability and that a needs-based approach would help to place greater focus on more vulnerable tenants.
- Policy triggers. There was concern the Policy may disincentivize new construction in the District. It was suggested that a greater attention be placed on supporting tenants in the case of major renovations.
- Policy flexibility. We heard there is an opportunity to adjust the Policy depending on the current vacancy rate across Saanich. For instance, the regulation could be relaxed when there is a high vacancy.
POLICY SUPPORTS
Q: What might be some of the biggest challenges for your business when it comes to meeting the requirements of a Tenant Assistance Policy?
Market housing organizations raised many challenges to meeting the TAP requirements. These included:
- Relocation coordination. The group shared that it is difficult to support individual tenant needs and manage tenant expectations through the process of finding new housing. Participants noted concerns about a Policy that places too strong a requirement on relocation coordination as a responsibility of the developer, and expressed financial compensation is an easier support to provide. It was also suggested the District could develop standardized information sheets for tenants to navigate the subsidized housing process.
- Right of First Refusal. In the group’s experience, there is often little uptake of the ROFR through redevelopment as tenants most often only move once. We heard concerns that the ROFR is challenging to meet given it adds uncertainty to the process and can impact the financial viability of projects. Participants raised the need for additional clarity regarding the requirement for the ROFR returning rental rates. In other words, whether the Policy would require affordable rates based on individual income or standard rates that are subsidized and/or below market. We also heard a comment for BC Housing to support relocating tenants to non-market housing, so to lessen the developers’ expense associated with the ROFR.
- Tenant eligibility. The group raised challenges with instances where tenants are forced to relocate more than once due to redevelopment or major renovations at multiple locations and subsequently qualify for tenant assistance more than once (e.g., as can occur with the Victoria Tenant Assistance Policy). They suggested adding a clause to prevent this (e.g., the City of Burnaby’s policy).
- Vulnerable tenant support. We heard that there are greater challenges in finding housing for those living with mental health challenges, compared to those who qualify as priority groups within BC Housing (e.g., older adults and those with disabilities). We also heard there is little available rental stock for tenants with unique housing needs, like accessible or subsidized units, and there is a need for advocacy to create demand for new units.
- Financial viability. Participants raised concerns about the current cost of land, and that a TAP could create more barriers for development in Saanich. We also heard the TAP could discourage landlords from renting their properties during a rezoning process based on when tenant eligibility starts (i.e., one year before application, etc.). We heard that other jurisdictions have faced uncertainty with interpreting and respecting tenant eligibility.
- Financial compensation. Market housing organizations suggested financial compensation is easier to guarantee than relocation. We also heard support for a Policy that factors compensation based on tenant income and length of tenure. In some cases, tenants may not need or seek financial support for relocation but could still benefit from compensation such as moving expenses. Consideration for different types of compensation may help to address these instances.
POLICY SUCCESS
Q: How might the District help to support your business and the market housing sector to meet the Policy requirements?
We heard the District may help to support market housing organizations to meet the TAP requirements by way of:
- Clear communication. The District should clearly communicate the Policy requirements to Council and tenants to help to manage expectations. Participants also suggested that resources to support tenants navigate the relocation process would be helpful.
- Provincial coordination. The District could support for-profit developers by way of Provincial coordination, such as advocating through the Union of British Columbia Municipalities or working with BC Housing to support tenants in securing subsidized housing. It was suggested that a stronger link is needed between municipal policy and Provincial efforts through BC Housing, and that this type of sustained support would be more impactful for some tenants than short-term financial compensation.
- Policy updates. Participants suggested the Policy be reviewed on a regular basis to adjust as needed.
Q: How might the District follow up to ensure that the requirements are being met?
The market housing group shared there would be no issues in meeting Policy reporting requirements.
Q: Beyond the TAP, how can the District protect existing affordable rental stock in Saanich?
The group questioned the value of protecting Saanich’s existing affordable rental stock. Rather than a focus on protecting existing rental, participants suggested a need for continued development of purpose-built rental housing. Participants noted:
- The aging rental stock in Saanich presents issues related to energy efficiency and seismic standards, particularly in preparation for the risk of natural disasters.
- It is difficult to conduct needed maintenance and upgrades in occupied buildings.
- In places like Victoria, there are many long-term tenants with protected rents who would be unable to find comparable rental rates if they were forced to move.
- A TAP may push development into unoccupied, greenfield sites in other parts of the region.
- There is a need for a mix of the scale of development and flexible site density.
- A focus on Community Amenity Contributions may help to support tenants being displaced while encouraging new developments and meeting sustainability and affordability goals.