The Advocacy Centre for Tenants Ontario, the Canadian Environmental Law Association, and the Low-Income Energy Network support removing barriers to the installation of active cooling in tenant apartments. [...] Landlords should be responsible for the safe installation and the ongoing costs of active cooling, and any restrictions on usage should be minimal and clearly listed in the legislation. [...] Section 34 of the Residential Tenancies Act creates a standard for the tenant to repair any “undue damage” caused by willful or negligent conduct by the tenant.7 The proposed standard in s.36.1(3)(3) of “does not damage the rental unit” is a much lower standard and is too burdensome for tenants. [...] If landlords are provided with the ability to pass along the costs of cooling to tenants as proposed by this framework, which we do not support, then landlords should not be able to charge more to the tenant than the actual cost of increased electricity usage for active cooling, as outlined in ss.36.1(4)-(7). [...] Instead, landlords should be required to inform the tenant in writing of the proposed increase in rent, which should be capped by the Act and reflect only the actual increase in electricity.
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