suggest that this growth in neighbourhoods wth low vacancy rates should be of concern to policy makers. 

Of the three categories of short-term rentals raised above. it is likely that short-term rentals that occur in non-primary residences pose the risk of impacting housing availability and affordability. 

Impact on economic development and tourism

Some assert that short-term rentals positively impact tourism by providing at times less expensive options for tounsts, the opportunity for visitors to slay in neighbourhoods outside of traditional tourist areas, and an additional source of competition for hotels and bed & breakfasts. 

Businesses that have traditionally provided accommodation to visitors may feel a negative effect on their bottom line. A recent study out of Boston University claimed that for every increase of 10% in supply in short-term rentals has a 0.35% decrease in hotel revenue. 

Concerns have been raised. including by the MaRS Sharing Economy Public Design Report, about whether hotels and bed & breakfasts face unfairly burdensome regulation that does not allow them to innovate in the accommodations sectors. 

Taxation 

There have been concerns raised that short-term rental operators are paying residential property tax instead of commercial, which is typically higher. Further studies are required to determine under which property class short-term rental properties should fall. 

As discussed above, hotels and other tourist accommodations are not subject to any specific taxes by Toronto other than property taxes. If Toronto were to implement a hotel or tourist tax. some have suggested that major short-term rental platforms like Airbnb should pay such a tax, as they do in other cities. 

Complaints from residents regarding short-term rentals 

ML&S continue to enforce existing by-laws as they relate to short-term rentals. Complaints have been made to the City via 311 regarding short-term rentals. Since 2014, more than 45 complaints have been made to ML&S. and two short-term operators were charged for violating the zoning by-law. There are 25 active investigations by 'ML&S into complaints related to short-term rentals. Taking enforcement actions based on current zoning by-laws is challenging and time-consuming because it relies on collecting adequate evidence of non-permitted use. 

Learning from other jurisdictions

Staff did an initial scan of six large cities in North America to examine how they had conducted research, developed regulations and enforced regulations relating to short-