Response to the City of Vancouver’s proposed approach to regulating short-term rentals

Below are the written remarks I gave today at city hall – actually a slightly longer version because I crossed out a few things just before speaking in order to fit the time limit.

Here is the staff report to which these remarks respond.

You may also wish to see my related comments in response to an October 4 story in Metro News, in which Airbnb proponents suggest a more flexible approach to regulation than restricting eligibility for licences to principal residences. Airbnb’s representative, Alex Dagg, confirmed today at city hall that the company does want to see STRs allowed in secondary suites and laneway housing.

October 5, 2016

I support the approach to regulating short-term rentals, or STRs, outlined in staff’s report. I’m speaking as someone who recently defended my master’s thesis in urban studies, in which I investigated the nature and extent of Airbnb listings in Vancouver. I looked at Airbnb’s growth, where listings were located, how much they cost and the type of listings. I also looked at the implications of this data in light of the local rental housing context and the city’s housing policy goals, concluding that the unchecked growth of Airbnb is an obstacle to the city reaching its housing goals, which include the protection of existing rental stock and ensuring that people of all incomes and ages can afford to live here. Having immersed myself in this topic for almost three years, I can probably appreciate the complexity of staff’s task more than most. I think they’ve done a very good job and thank them for their work.

Most broadly, I appreciate what I see as a framework that prioritizes the protection of existing and potential rental housing. I understand the importance of tourism to our local economy and the desire to balance the protection of housing with other interests, such homeowners wanting to earn money from STRs and the benefits of having options for tourists. Staff have struck a good balance between these interests for now and I especially endorse the proposal to limit STR licences to principal residences, so that investment condos, secondary suites and laneway houses can’t be used full-time for tourist purposes. I also believe that limiting licences to principal residences is important if council wants to increase support for further diversification or densification of the housing stock. While I favour more diverse and dense options myself, I think it’s reasonable and predictable that people who are less supportive of that direction will resist it more if they don’t see the city taking proactive steps to ensure our existing housing supply is used for its intended purpose, especially when the need for that housing is so great. I also support this approach based on its simplicity and believe it will be easier to explain, administer and enforce than adopting models that involve caps on the number of nights rented or limits on the licences granted by neighbourhood or dwelling type. However, enforcing STR rules has proven challenging in most jurisdictions, not least because of a lack of actual, rather than just rhetorical, cooperation from the platforms. But that is certainly not a reason to move forward or to lower reasonable expectations. I suggest you move ahead, understanding that rules and strategies may need to be adjusted based on how conditions change on the ground, including how cooperative STR operators and the platforms turn out to be.

I commend staff for including a requirement to display the licence number in the online listing itself and hope you will make it a separate offence to omit or fake that number. I also agree with the proposal to commit resources to monitoring through a third-party service that can match listings with addresses.

 I do, however, worry that this approach seems to allow for people to use individual bedrooms for STR purposes on a full-time basis, as long as a principal resident also lives in the dwelling. It seems we could have a person who lives in a two or three-bedroom apartment, or even a five-bedroom house, and rents out all but one bedroom for STR purposes on a full-time basis. When we have so many people, including but not only young people, whose wages don’t allow them to rent a self-contained studio or one-bedroom for less than 30% of their gross pay, I see that as a problem. For some, the only affordable option is shared housing. This concern also pertains to the need for family housing. We know we have a shortage of units with two or more bedrooms. Airbnb makes it possible and lucrative for some to fill those scarce larger units with tourists instead of families with children. Is that a practice we want city policy to allow? I recognize this “spare” (or private, in Airbnb terms) rooms issue is complicated for a variety of reasons, but I think it’s at least worth flagging for future consideration.

The report also limit discussion of non-compliance penalties to the STR operators or hosts, excluding the platforms. Perhaps that discussion is yet to come. I suggest that effective and fair regulation would require the platforms, which are after all earning money from non-compliant listings, to share the burden of compliance and also be liable to penalties.

An argument I’ve heard against limiting STRs and that we may hear today is one where one property owners say they could not afford their house, or run their business, or have the quality of life they want without renting out their basement suite, investment condo or laneway home on Airbnb. My response is that if someone can’t afford their housing without doing something that breaks city bylaws and has so many negative impacts on others, including those whose housing security is more precarious than their own, their decision to purchase that housing in the first place was probably unwise. Similarly, many of us could have an easier or better quality of life if we chose to earn extra money in ways that were illegal or socially damaging. I don’t believe city policy should implicitly endorse people buying more housing than their own incomes and long-term rental revenue allow for. Finally, in a broader sense, it’s worth remembering at this point that the revenue stream Airbnb provides is overwhelmingly available only to homeowners, since provincial law says tenants must have their landlord’s consent to sublet and, understandably, many landlords are unwilling to give that. So, by allowing part-time use of dwellings as STRs you will help homeowners afford their housing and I’m sure many will be glad for that. But you will not be helping the vast majority of renters afford their housing – and census and NHS data shows they are much more in need of that help. I argue that one of Airbnb’s broad effects is to undermine tenants by providing property owners with a cash-flow solution that is more lucrative and flexible than renting to long-term residents. In so doing, I believe it contributes to housing inequality and further commodifies housing. In light of this, it’s urgent that council take steps to limit and hopefully reverse the growth of STRs in Vancouver. I urge you to move forward with doing so.

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