Canadian Property Management - Fall 2024

FOR BUILDING OWNERS, ASSET AND PROPERTY MANAGERS 

VOL. 39 NO. 3 • FALL 2024 

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VOL. 39 NO. 3 FALL 2024 

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editor’snote 

DISRUPTIVE AND DISASTROUS events often arise 

suddenly, but risk can be identified long in advance. In this issue, 

we examine efforts to do that across real estate’s diverse areas of 

concern from safeguarding building occupants to protecting the 

value of investment assets. Data emerges as an important thread 

that connects risk to preparedness — providing the means to 

identify vulnerabilities, steer priority-setting, monitor outcomes 

and prove compliance. 

Real estate owners, managers, investors, lenders and insurers 

are already confronting the physical, financial, regulatory and 

reputational consequences of an increasingly severe and volatile 

climate. Business players in all economic sectors within the 

nations that are signatories to the Paris Agreement on climate 

change are becoming familiar with a framework that characterizes risk on two distinct fronts. 

Physical risks destabilize assets and business operations through weather-triggered events 

such as hurricanes, tornadoes, floods, landslides, wildfires and prolonged, intense heat waves. 

Transitional risks involve the upheaval of moving away from traditional economic stalwarts 

and business practices in order to meet the ambitious and crucial greenhouse gas (GHG) 

reduction targets that world governments have adopted. 

Both those types of risk are now flowing through to real estate. Owners/managers are 

moving to bolster the physical resilience of their buildings and portfolios and to gauge what’s 

known as “climate value at risk” (although this editor suggests the term should more 

appropriately be “value at climate risk”). The latter provides a forecast of how changing 

climatic conditions could affect the serviceability and costs of building equipment, structures 

and systems, or a building’s ability to attract tenants, generate income and retain its value. 

Fierce climatic forces are likely to be the new status quo — regardless of achievements in 

keeping global temperature rise in check from this point on — making adaptation measures 

a good investment for the future. “We can slow down the rate of change, but we cannot reverse 

it, at least not with the technology that we currently have,” stresses Kathryn Bakos of 

Waterloo University’s Intact Centre on Climate Adaptation. 

On the transitional risk side, there is growing uptake of benchmarking, with an associated 

need for environmental data standards, in response to demands for disclosure and proof of 

performance from regulators, investors and tenants. We’re also transitioning from the almost 

automatically accepted risks of fossil fuel vessels (boilers, furnaces, gas tanks) within 

buildings and vehicles to a new set of health and safety risks related to lithium-ion batteries 

and other forms of potentially explosive energy storage. 

We explore all those topics in this issue. We also look at fire safety communications, 

property-level conflict management, graffiti deterrence and pending new anti-money 

laundering requirements. 

Turning from risk to future possibilities, artificial intelligence (AI) is projected to drive real 

estate demand and greatly enhance the industry’s analytical and predictive capabilities. We 

offer some insights. 

Barbara Carss 

barbc@mediaedge.ca 

Canadian Property Management | Fall 2024 3

contents 

Focus: Protection, Mitigation & Recovery 

6 Returns on Resilience: Physical climate risk affects building 

and portfolio value. 

8 Planning for System Failure: Energy storage prompts a 

battery of precautions. 

14 Thermal Runaway Threats: Compromised lithium-ion 

batteries pose danger. 

20 Critical Messaging: Reaching high-rise residents. 

24 Deadly Lapses: UK fatal fire inquiry slams oversight and 

certification bodies. 

28 Surface Strategy: Graffiti deterrence and removal. 

30 Elevated Safeguards: Protecting rooftop workers. 

38 Asset-level Openness: ESG benchmarking supports risk 

management. 

46 Contentious Condos: Managing conflict and abusive 

behaviour. 

50 Tracking Transactions: Canada bolsters guard against money 

laundering. 

Articles: 

32 Scurry for Skills: Office-using sectors make space for AI 

expertise. 

34 Groundwork Grind: CRE pulling the pieces together to 

enable AI insights. 

42 Buoyant Trends: New water use initiatives afloat. 

48 Onerous Oversight: Toronto’s short-term rental registry stuck 

in manual. 

Departments 

3 Editor’s note 

4 Fall 2024 | Canadian Property Management

PROPERTY MANAGEMENT IS FULL 

OF UNIQUE CHALLENGES. BANKING 

SHOULDN’T BE ONE OF THEM. 

Our easy-to-use banking solutions were designed with you in mind. We aim to provide a 

challenge-free experience for both you and your clients. 

Contact the CIBC property management industry team today 

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“CIBC”, the CIBC logo and “CIBC Commercial Banking” are trademarks of CIBC

RETURNS ON 

RESILIENCE 

Physical Climate Risk Affects Building and Portfolio Value 

By Barbara Carss 

AS THE MARKET GETS more adept at 

computing green premiums and brown 

discounts, attention is turning to how 

resilience fits into that picture. Climate 

change adaptation measures are typically 

viewed as risk management, to avoid costs 

and safeguard assets, rather than levers for 

investment returns, but they are inherently 

linked to building and portfolio value. 

“It is clear that managing physical climate 

risk is now expected of serious, world class 

real estate investors and managers around the 

globe,” Darryl Neate, Vice President of 

Sustainability with the Real Property 

Association of Canada (REALPAC), asserted 

earlier this year during a webinar that tackled 

the topic. “We need to learn how to navigate 

the complexity and uncertainty. It is new and 

we’re still all working our way through it, but 

it comes down to decision-making for asset 

management and development professionals.” 

Floods, wildfires and a barrage of extreme 

weather events resulted in $3.4 billion worth 

of insurable losses in Canada in 2023, and 

that tally is generally presumed to triple or 

quadruple when uninsured losses are added 

in. This is at the high end of a trend that has 

seen insured losses average $2.1 billion 

annually since 2009, even while those years 

demonstrate a dramatic upward spike from 

losses in the range of $250 million to $450 

million per year during the period from 1983 

to 2008. 

Webinar presenters applauded evidence of 

the commercial real estate industry’s progress 

in reducing greenhouse gas (GHG) emissions, 

while expressing concern about its general 

vulnerability to various weather-triggered 

calamities. Kathryn Bakos, Managing 

Director, Finance and Resilience, at Waterloo 

University’s Intact Centre on Climate 

Adaptation, cited the United Nations 

Environment Programme’s (UNEP) 2023 

findings that climate adaptation momentum 

is slowing globally. Meanwhile, climate 

volatility is expected to persist even if the 

global average temperature increase is held 

within the targeted 1.5 degrees Celsius. 

“We can slow down the rate of change, but 

we cannot reverse it, at least not with the 

technology that we currently have,” Bakos 

reiterated. “So much emphasis is being 

placed on mitigating greenhouse gas 

emissions, which is incredibly important, but 

you can reduce greenhouse gas emissions at 

site level or across supply chains and still be 

impacted by the physical risks of climate 

change. We have to be thinking about it from 

both sides.” 

Webinar presenters sketched out some of 

the available resources, including: risk assessment 

matrices to broadly identify prevalent 

climate-related hazards and effective 

responses; benchmarking to plot, compare 

and disclose portfolios’ preparedness and 

vulnerabilities; software to calculate the 

building-level potential financial impact — 

known as climate value at risk — of chronic 

and acute climate-related hazards; and methodologies 

to help translate all this data into 

investment metrics. 

PORTFOLIO TO ASSET LEVEL 

Last year the Intact Centre released six 

industry-specific climate risk matrices to 

guide financial market participants in their 

decision-making and to encourage asset 

owners/managers to evaluate their holdings. 


iskmanagement 

Commercial real estate was included in that 

group because it aligns with the Task Force 

on Climate-related Financial Disclosures’ 

(TCFD) definition of sectors that are well 

placed to serve as models for broader 

industry — i.e. those with operations and 

assets that can be significantly disrupted or 

damaged by severe weather events, but also 

possessing the expertise to understand 

potential business impacts and available 

means to mitigate risk. 

The climate risk matrix highlights likely 

physical threats, recommended safeguard 

measures and key questions for gauging the 

preparedness of assets in a user-friendly 

chart form. Drawing parallels with the wellknown 

ASHRAE energy audit process, 

Mike Williams, Vice President, Climate 

and Performance Engineering, with RWDI 

Consulting Engineers, characterized the 

matrix and similar approaches as a Level 1 

adaptation exercise to map out physical risks 

across a portfolio. 

“It’s a great activity to undertake,” he said. 

“There are a lot of different providers out 

there and the cost has become sufficiently 

accessible that most folks with a portfolio of 

commercial real estate can do that.” 

From there, Level 2 takes the scrutiny 

down to individual buildings and their key 

systems to help decision-makers determine 

where and how to act. Software and reliable 

data are instrumental to that process. When 

armed with both, Williams explained the 

possibilities for gauging how chronic and 

acute climate-related conditions and events 

can affect building systems and the capital 

needed for their upkeep and replacement. 

To demonstrate chronic risks, he used the 

example of a chiller to explore the impact of 

an increasingly hot environment. Computer 

modelling, via RWDI’s ClimateFirst 

software, shows how today’s expected 

25-year life cycle diminishes to 16 years and 

then 12 years at points along the projected 

trajectory of a 250% increase in cooling 

degree days over the next 35 years. 

For acute risks, software modelling considers 

increased frequency of major storms and 

changing loss probabilities so that, in Williams’ 

cited example, the average annualized 

loss for a backup generator increased from 

$2,800 to $3,500. A comprehensive analysis 

of chronic and acute risks across all critical 

systems delivers what he describes as a 

“climate-adjusted cumulative capital 

forecast” for the building. 

“We can then look at the climate value at 

risk at any point in time and really begin to 

think about: what is at risk to this building?” 

Williams said. “We can think about where 

we might begin to make increased investments 

in the building to shore up against 

these very known physical climate risks.” 

INFORMING DECISION-MAKING 

Some Canadian entities participating in the 

GRESB global benchmark for the ESG 

performance of commercial real estate 

portfolios (see story, page 38) appear to be 

doing that. Breaking down resilience-related 

findings emerging from the 2023 survey, Erik 

Landry, GRESB’s Director of Climate 

Change, noted that a larger percentage of the 

80 Canadian participants reported that their 

portfolios are exposed to “most acute hazards 

and chronic stressors” compared to entities 

from other global regions. However, he 

hypothesized that could be as much due to the 

quality of insight as the quantity of risk. 

“In Canada we’re seeing a lot more 

comprehensive risk assessment frameworks 

where we’re actually seeing things like 

climate value at risk being calculated and 

used to inform decision-making, whether 

that’s for maintenance or retrofit decisions or 

things like that,” Landry affirmed. 

That’s also, of course, how proponents 

want such frameworks to be used. 

“Right now, I think a lot of the industry is 

at a point of learning climate risk analyses 

and ingesting whatever data is available just 

for the sake of it — maybe for regulatory 

disclosure or saying that they’ve run a climate 

risk assessment,” Landry mused. “I’d like to 

see that move away from a checkbox exercise 

to something more decision-useful.” 

The other webinar presenters concurred 

that capturing a picture of physical climate 

risk is generally easier than coming up with 

resources to address it. Williams offered the 

statistic that about 90% of investment to date 

has been channelled to mitigation efforts and 

addressing transitional risk. However, Bakos 

argued it’s hard to quibble with the formula 

that shows $1 spent on adaptation saves $3 to 

$8 over a 10-year period. 

“It’s not a return on investment, but it’s 

money you don’t have to pay out over a 

longer- term period,” she said. “It’s cost 

avoidance, and it’s an opportunity cost that’s 

not being lost. That’s money that’s now 

available to use for other initiatives.” 

For more information about the Intact Centre on 

Climate Adaptation, see the website at www. 

intactcentreclimateadaptation.ca. For more 

information ClimateFirst software, see the website at 

https://climatefirst.net. For more information about 

GRESB, see the website at www.GRESB.com. 


PLANNING FOR 

SYSTEM FAILURE 

Energy Storage Prompts a Battery of Precautions 


IN STEP WITH a projected surge in 

energy storage installations, fire safety 

advisors are actively working to help clean 

tech adopters understand and mitigate the 

risks. The U.S. based National Fire Protection 

Association (NFPA), a leading developer of 

standards that are referenced in many 

Canadian codes and standards, addresses 

many of those concerns in a dedicated 

standard, NFPA 855. Other general guidance 

for fire safety planning, emergency response, 

construction, operations and maintenance 

also comes into play. 

The U.S. Energy Information Administration 

reports that 7.7 gigawatts (GW) of new 

energy storage capacity was installed in that 

country in the first six months of 2023, representing 

a 32% increase over the same period 

in 2022. That growth trend is expected to 

continue with the planned flow of significant 

U.S. government spending into clean energy, 

while similar investment incentives are coming 

on line in Canada through a range of tax 

credits and financing options. 

“A lot of the installations we see today are 

battery energy storage systems and 

particularly lithium-ion” Brian O’Connor, a 

senior engineer with NFPA, observed during 

a webinar earlier this year. “We are seeing 

these installations everywhere. We are seeing 


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“Make sure that staff and occupants know what to 

do in the event of a fire, in the event they smell 

smoke or they smell something off with what’s 

going on in the battery room.” 

more installations and, with that, we’re bound 

to see more incidents.” 

Along with NFPA colleagues, he outlined 

a recommended approach for reducing that 

likelihood and more effectively containing 

events that do occur. That includes fire safety 

requirements for: building, configuring and 

equipping energy storage facilities; 

operational procedures; and emergency 

response training. 

Under NFPA 855, energy storage facilities 

must be located at least 10 feet away from the 

lot lines and other structures, storage areas or 

vegetation on the site or, alternatively, be 

enclosed behind a wall that extends 5 feet 

beyond the energy storage system in all 

directions and is no less than 5 feet distant 

from other external exposures. Inside the 

facility, units are to be separated into clusters 

of no more than 50 kilowatt-hours (kWh), 

each of which must be placed at least 3 feet 

from other clusters and any walls. 

The standard also includes directions for 

sprinklers, fire alarms, ventilation and 

explosion prevention and protection. Where 

lithium-ion, sodium nickel chloride or flow 

batteries are employed, 600 kWh of energy 

storage is the triggering threshold for various 

hazard analysis, training and emergency 

response requirements that will need to be 

documented in supporting plans. 

O’Connor advises facility developers/ 

owners to begin that process with a series of 

‘What if?’ questions related to potential 

“thermal runaway” in the storage units and 

the failure of the battery management system 

(which could cause voltage fluctuations) and 

any element of the fire protection system. 

From there, they should consider what 

precautions and interventions will be needed 

to achieve the required safety performance. 

“You need to make sure that the fire is 

contained in that energy storage system room 

for two hours; that any explosion hazards are 

addressed; and that the products of 

combustion — being smoke, heat and any 

toxins associated with those — do not prevent 

the occupants from evacuating,” O’Connor 

reiterated. 

SAFETY PLAN ELEMENTS 

Safety plan drafters will need to map out 

various operational and emergency 

response procedures, as well as the 

process for verifying that inspection, 

testing and maintenance of key systems 

is occurring. 

Plans should cover: safe shutdown and 

start-up of the energy storage system; 

communications, training and drills for 

on-site personnel, other building 

occupants and emergency responders; 

and key contacts, such as service 

contractors for critical equipment and 

systems. Attention should also be paid to 

potential repercussions for the 

surrounding area and wider community. 

“Make sure that staff and occupants 

know what to do in the event of a fire, in 

the event they smell smoke or they smell 

something off with what’s going on in 

the battery room,” O’Connor said. “Your 

personnel needs to be able to figure out, 

not only how to notify the fire department, 

but when to notify the fire department.” 

Likewise, arriving firefighters should 

know in advance that there are energy 

storage units on site, and be quickly 

directed to the mechanisms that will 

disconnect all electrical charges. 

“Don’t be afraid to bring your local 

authorities in for training, to show them,” 

suggested Holly Burgess, one of the 

NFPA’s emergency planning specialists. 

“Make sure that they understand where 

to go and what the hazards are.” 

Solar photovoltaic arrays can be one of 

those lurking hazards if that’s the power 

source for the energy storage. Dean 

Austin, a senior electrical specialist with 

the NFPA, explained that installed PV 

panels are effectively “live” whenever 

there is sufficient light. Thus, NFPA 

guidance calls for a single-switch shutoff 

for all solar PV arrays mounted on a 

building. 

“It has been documented that some of 

the emergency lights on fire trucks, used 

for illumination at night, will turn on the 

solar panels and begin producing energy,” 

Austin reported. “The disconnect has to 

be able to isolate the energy storage 

system from all other wiring.” 

EXPERTISE NEEDED 

Qualified technicians are a fire safety 

imperative at every stage of an energy 

storage facility’s life cycle from installation 

to decommissioning. Beyond being a 

licensed electrician, NFPA guidance defines 

this as having knowledge of and experience 

with specific types of equipment and 

systems. That includes required technical 

skills along with the ability to assess and 

mitigate hazards, which may involve getting 

training from the manufacturers of those 

products. 

“I have been a master electrician for 30 

years. I’ve done a lot of work myself and I 

can tell you that I am not qualified to go into 

a medium voltage application and start 

doing electrical work in there,” advised 

Corey Hannahs, another of NFPA’s senior 

electrical specialists. “So this qualified 

person requirement is a big part of knowing 

what the problems could be.” 

A poll of webinar participants found most 

are still at earlier stages of the learning 

curve, with 51% of respondents indicating 

that they need a lot more training before 

implementing an energy storage system in 

their facilities and just 3% stating they 

believe they are sufficiently knowledgeable. 

O’Connor promotes the NFPA standard as a 

tool for quantifying the risks, identifying 

gaps and moving forward. 

“Decommissioning without failure [at the 

end of the facility’s life cycle], that’s what 

we’re all hoping for, but, if there is some 

kind of failure, we don’t want to have to 

figure it out on the spot,” he submitted. “We 

want to make sure that we’ve thought about 

this earlier and we have a plan in place, so 

that the failure and whatever damage might 

be done is limited.” 

More information about the National Fire Protection 

Association can be found at www.nfpa.org. 


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GETTING THE MOST 

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RISKS & REWARDS 

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“Black & McDonald offers a full range of consultation and 

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For more info, visit www.blackandmcdonald.com.

THERMAL 

RUNAWAY THREATS 

Compromised Lithium-ion Batteries Pose Danger 

By Steve Eyer 

SINCE MARKET launch in the early 

1990s, lithium-ion batteries have left a 

lasting mark on the energy storage market 

and gradually displaced old technologies. 

They can be tiny and, at the same time, very 

efficient, and are found in a wide range of 

applications from smartphones and tablets 

to electro-mobility. 

Yet, they also come with some risk. 

Explosions and fires involving lithium-ion 

batteries can have devastating consequences, 

causing expensive consequential damage or, 

in the worst case, costing human lives. 

By today's manufacturing standards, 

lithium batteries are considered 

comparatively safe. All certified batteries 

must comply with various safety tests that 

are carried out by the manufacturer before 

products are put on the market. Many 

manufacturers also equip them with various 

safety devices at the cell level. 

For example, if a flammable electrolyte is 

used within the cell, flame retardant additives 

can be added to provide better protection. 

Storage of the battery in an impact-resistant, 

corrosion-proof housing with fire-retardant 

foam can also be an effective measure. 

There are three main sources of fire 

hazards: thermal runaway; deep discharge; 

and mechanical deformation. Those can 

arise from electrical overload, mechanical 

damage or thermal overload. 

Thermal loads, mechanical damage or 

factory defects can all trigger thermal 

runaway. That is an exothermic reaction, 

which can ignite the stored lithium and 

cause an extreme fire that produces its own 

oxygen. 

This occurs when high levels of heat 

energy vaporize the electrolyte fluid, 

creating additional heat and combustible 

gases. Once the temperature rises above the 

ignition point for one of those gases, it will 

ignite and set fire to the battery. 

This thermal propagation can create a 

devastating chain reaction as thermal 

runaway in one cell then quickly heats 

neighbouring cells. Once set in motion, it 


iskawareness 

EMPLOYERS OBLIGED TO INFORM 

AND PROTECT WORKERS 

Although modern electric vehicles, or EVs, have been on Canadian roads since the early 2000s, 

the rechargeable lithium-ion batteries that power most electric motors are a relatively new 

workplace hazard for many industries. Whereas the voltage of a hand-held power tool battery is 

about 18 to 20 volts, EV batteries weigh more than 450 kilograms and range from 200 to 800 

volts, making them a significant handling and electrical risk to workers. 

When damaged, high-voltage electrical systems have the potential to release energy, posing the 

risk of electric shock, electrical burns or electrocution. A crack, or a short circuit in a battery also has 

the potential to leak flammable electrolytes and chemical compounds. That includes hydrofluoric 

acid, which is highly corrosive and toxic, can cause severe burns and is often lethal if inhaled. 

Perhaps most notably, overheating can trigger an irreversible chemical chain reaction known 

as a thermal runaway. This occurs when the heat generated by cells in one area of the battery 

spreads to other cells, spawning extremely high temperatures very quickly. Resulting battery fires 

and explosions release toxic smoke, fumes and chemicals that can result in severe eye damage 

and respiratory issues. 

Blazing lithium-ion battery fires are much more intense than fires fueled by combustible 

materials such as wood. They are difficult to extinguish and can reignite. 

It is important for employers to identify all possible scenarios in which workers could be 

exposed to risk. Emergency first responders, tow truck operators, vehicle repair technicians, auto 

recyclers and manufacturers all increasingly encounter high-voltage EV batteries in the course of 

their work, as do parking operators, building maintenance personnel and anyone who has cause 

to be an area where EVs may be charging, parked or stored. 

The most effective way to manage risk is to eliminate the source of exposure. Electric vehicles 

that are known to be damaged should be removed from the site and kept away from combustible 

materials. 

Areas that store EVs and high voltage barriers should be well ventilated and, of course, comply 

with required fire codes and health and safety regulations. As well, consider installing fire 

suppression barriers and gas detection sensors. To address possible issues with smaller 

batteries, ensure that on-hand fire extinguishers are approved for application on lithium and 

lithium-ion fires. 

Looking to preventative and preparedness measures, it’s essential that workers are trained 

how to safely shut down energized vehicles, and how to store and dispose of lithium-ion batteries. 

They should understand the emergency response and first aid requirements if a battery leak, fire 

or explosion occurs. They should also have access to personal protective equipment such as 

electrical rubber insulating gloves and boots, face shields and fit-tested respirators. 

The good news is that battery safety research and testing is advancing in step with the 

industry. Employers and property/facilities managers can find various specialized resources and 

training programs. In Canada, organizations like Workplace Safety & Prevention Services, 

WorkSafeBC and the Automotive Retailers Association have developed guidance. 

While standard electrical safety measures can help, it’s important for workers to follow 

specialized protocols when working with electrical vehicles and their batteries, including 

manufacturer’s instructions and recommendations. 

The preceding article was developed by the Canadian Centre for Occupational Health and Safety. 

For more information, see the website at www.ccohs.ca. 

only takes a few minutes until the battery 

will burn and explode into a fire that is 

notoriously hard to control. 

Other risks can arise if lithium-ion 

batteries are not used for a long time. During 

prolonged idleness, they can completely 

discharge, compromising the electrolyte 

liquid and causing the formation of easily 

combustible gases. This also results in 

insufficient electrolyte fluid to correctly 

convert supplied energy, which can cause a 

short circuit or a fire if there is an attempt to 

recharge the battery. 

As well, deformed cells, perhaps due to a 

collision or falling onto a hard surface, can 

cause internal short-circuiting and fire. 

There is also a possibility that cells can be 

contaminated during manufacture. In rare 

cases, particles can enter cells and cause 

damage over time, eventually triggering an 

internal short circuit. 

Electrical overload can occur if an 

incorrect charger is used. Storage in incorrect 

temperatures (outside the manufacturer’s 

recommended range) can contribute to deep 

discharge, while external heat such as open 

fire, hot machine parts or storage in direct 

sunlight can cause thermal overload. 

Lithium-ion batteries generate oxygen 

when they burn. Special suppression powders 

and granules are necessary to combat these 

types of fires, which involve burning metals. 

When applied to the fire load, these 

substances melt, cool the fire and form an 

impermeable envelope that separates oxygen 

from the fuel. It’s recommended that 

suppression powders be kept in stock in 

facilities that host high-power or greater 

quantities of lithium-ion batteries. 

Potential risks increase with the size of 

lithium-ion batteries and/or the quantity of 

batteries in an area. Lithium batteries in 

small devices such as computers, cell 

phones and small tools or appliances are 

classified as low risk since they represent 

less than 100 watt-hours (Wh) of energy 

storage. Nevertheless, the manufacturers’ 

advice should be respected. 


iskawareness 

REMINDERS FOR RESIDENTIAL DWELLERS 

An uptick in fires involving lithium-ion batteries underpins the City of Toronto’s recently launched safety campaign. Last year there was a 90% 

surge from 2022, while the first six months of 2024 brought 15 such blazes, including seven related to electric bikes and scooters. 

“Lithium-ion batteries are commonplace for us all as they are in use in a wide variety of devices that are part of our daily lives, but this modern 

convenience is coupled with the risk of devastating fires,” says Toronto Fire Service Chief Matthew Pegg. “We’ve launched a new fire safety 

campaign to empower residents in Toronto and across the province with the knowledge to safeguard themselves, their property and others.” 

Fire prevention officials are particularly stressing the dangers of tampering with and/or using uncertified batteries. Chargers should also carry 

one of the recognized Canadian certification marks: CSA; cUL; or cETL. 

As well, batteries should be used with devices for which they are specified and charged with the charger and cable or cord that came with the 

device. Replacement chargers for electric bikes, remote-control cars and power tools should come from the original manufacturers. 

Stop using batteries if any of the following are detected: odour; change in colour; excess heat; change in shape; leaking; or strange noises. 

Damaged batteries should be immediately taken to a safe disposal site. 

Device owners are reminded to keep them in sight while they are recharging and to unplug chargers when charging is complete. Lithium 

batteries should be stored at room temperature, out of direct sunlight and away from anything combustible. Batteries should not be recharged 

while the device is sitting on a soft surface such as a couch, bed, pillow or magazine. 

Lithium-ion batteries are hazardous waste and should be disposed of accordingly. Once removed from use, batteries should be sealed in a 

clear plastic bag or the battery terminals should be sealed with duct or electrical tape, and stored in a cool, dry place until they can be taken to an 

appropriate disposal depot. 

More information about Toronto’s safety campaign can be found at www.toronto.ca/LithiumBattery. 

Users should guard against mechanical 

damage and protect the battery terminals from 

short circuits. Nor should devices be exposed 

to high temperatures or heat sources, including 

direct sunlight, for long periods. 

Medium-power lithium-ion batteries — 

typically employed in electric bikes, electric 

scooters and larger garden tools — generally 

have 1 to 5 kilowatt-hours of energy storage. 

It’s recommended that they be stored at least 

2.5 metres away from other combustible 

materials unless they are in a storage facility 

with automatic extinguishing capabilities. 

Faulty or damaged batteries should be 

removed immediately and kept in a firerated 

space until they can be safely 

transferred to a disposal depot. 

High-power lithium-ion batteries have 

at least 50 kWh of energy storage. They 

must be stored in fire-rated, separated 

areas, with required spatial distances 

depending on the quantities stored, and 

in a facility with automatic extinguishing 

capabilities. 

Steve Eyer is Manager, Engineered Solutions, at 

DENIOS, a company specializing in work safety and 

hazardous material storage, including storage rooms 

and cabinets for lithium batteries. For more 

information, see the website at www.denios.ca. 

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CRITICAL MESSAGI 

Reaching High-Rise Residents 

By Rebecca Melnyk 

RESULTS FROM 2023 — which saw a 

10% year-over-year increase in fires in 

Ontario, resulting in 109 fatalities — are 

generally disconcerting. Along with that, 

fire safety specialists express concern that 

many high-rise residents aren’t prepared and 

don’t respond appropriately when there is a 

need to evacuate. 

The Ontario Fire Code mandates training 

for residential managers, superintendents 

and security staff, but there is no mechanism 

to compel those who, statistics show, are 

most vulnerable to injuries and death. Jason 

Reid, Senior Advisor, Fire, Safety and 

Emergency Management, with the 

consulting firm, National Life Safety Group, 

frequently confronts potentially lifethreatening 

misperceptions, such as 

residents thinking that building staff will be 

focused on assisting them when the fire 

alarm sounds. 

“Nowhere in the official emergency 

procedures does it say that security guards 

should help people out of the building and 

provide guidance to those who are phoning 

in,” he reiterates. “Residents are the only 

ones in a high-rise building who are not 

required to be familiar with their own 

unique roles and responsibilities.” 

In the case of a fire, the first priorities for 

on-site building personnel are to call 911, 

make an announcement over the emergency 

voice communication system (if there is one 

in the building) and retrieve the materials 

that they will need to hand over to the 

arriving fire services. Those include the 

building’s fire safety plan, floorplans, keys 

and a list of residents with disabilities and 

their suite locations. 

Meanwhile, residents will need to 

promptly decide whether to evacuate or 

remain in their units — an option known as 

sheltering in place. In the best case scenario, 

firefighters should be on-site within about 12 

minutes of being contacted, and that is time 

that prospective evacuees should not waste. 

“Once that building is filled with smoke, 

you can’t leave,” warns Brent Brooks, an 

acting Captain with Toronto Fire Services 

and a specialist in high-rise firefighting. “On 

average, it takes us six minutes to get to your 

place, and our vertical response time can 

take another six minutes on average. So we 

really can’t help you until after 12 minutes of 

that first alarm going off.” 

The fire department will also likely need 

to confer with someone who knows the 

layout of the building and can answer 

questions, such as which stairwell leads to 

the roof. That can be problematic in cases 

where there is no property management 

staff present and/or a superintendent does 

not live in the building. 

“Sometimes we get there, the alarm is 

going off, and they are not on site. That has 

its own layers of issues,” Brooks recounts. 

“In Canada, commercial properties have fire 

wardens, but there aren’t really any for 

residential, other than what the 

superintendent does, if they are on site.” 

Among the safety threats that firefighters 

have long encountered — such as missing or 

damaged automatic door closers, which are 

critical to mitigate the spread of smoke — 

there are some disturbing new trends. 


emergencycommunications 

EXPEDITING EMERGENCY RESPONSE 

By Quintin Johnstone 

NG 

Experts participating in inquests and post-incident inquiries have stressed that 

emergency responders typically need faster access and a better understanding of how 

to navigate high-rise buildings. Ideally, arriving firefighters, police or paramedics should 

be able to quickly communicate with key building personnel to gain guidance about 

structural features and the location of occupants who need assistance. 

The Peel Regional Police, serving residents in the cities of Mississauga and 

Brampton, Ontario, are currently piloting a secure online portal to give emergency 

responders advance access to digital floorplans, contact information for property 

managers and building security and, perhaps most importantly, the ability to remotely 

open a building’s main doors. The initiative is known as Safe Buildings, and landlords 

and condominium corporations in those municipalities can voluntarily register to 

participate. 

For now, Ontario’s Fire Code simply requires that this information be stored in 

labelled lock-boxes (also containing access keys and a list of occupants with disabilities 

who will need assistance) on-site in high-rise buildings. This leaves emergency 

responders to flip through hard copies of cumbersome documents in what are often 

less than ideal conditions for reading fine print. 

In addition to saving vital time, the online portal and application can also bolster the 

security and safety of emergency responders. For example, it is particularly important 

that they be aware of where chemicals are stored. Opening the wrong door could have 

serious repercussions, perhaps triggering an explosion, causing injury and further 

fueling a fire. 

The Ontario government now offers funding to help municipalities implement 

initiatives to enhance community safety. Looking outside Canada, New York City 

mandates a system similar to the Peel Region pilot project for high-rise buildings. 

“By adopting responsive technologies, governments can fulfill their commitments to 

serve their residents effectively while also safeguarding both citizens and emergency 

responders,” says Aamer Merchant, one of the private sector partners working with the 

Peel Police on the Safe Buildings initiative. “It’s not just about keeping pace with the 

times, but also staying ahead to meet the evolving needs of communities.” 

For more information about the Safe Buildings pilot program, see the website at www. 

safebuildings.ca. Quintin Johnstone is Chief Executive Officer of the risk management 

consulting firm, Riskboss Inc. For more information, see the website at www.riskboss.com. 

COMBATTING DEAD ZONES 

By Dawn Wotapka 

Radio communication dead zones can occur within buildings if 

structural configurations or materials such as concrete, metal or 

low-emissivity glass block or weaken the transmission of signals. 

This can pose challenges and risks for emergency responders 

relying on two-way radio systems, which can also put building 

occupants and property at greater risk. 

Emergency responder communications enhancement systems 

(ERCES) can address those issues in both new and existing 

buildings. They boost signals through a custom-tuned UHF or VHF 

channel employing a rooftop directional antenna that conveys an 

over-the-air link to the public safety communications network. 

The antenna is connected via coaxial cable to a bi-directional 

amplifier (BDA), which increases the signal level to provide sufficient 

coverage within the building. The BDA is connected to a distributed 

antenna system (DAS) — a network of relatively small antennas 

installed throughout the building that serve as repeaters to improve 

the signal coverage in isolated areas. 

Multiple amplifiers may be required in larger buildings, 350,000 

square feet or more, to drive an adequate signal level across the 

system. Besides the building’s square footage, other criteria can also 

affect the number of amplifiers required, such as the building design, 

type of construction materials used and the density of construction. 

A radio frequency (RF) survey, which measures the downlink/ 

uplink signal strengths in decibels-milliwatts (dBm), can determine 

whether an ERCES is needed in either an existing or new building. 

However, this can sometimes be problematic with empty warehouse/ 

logistics space since signal strength can change in areas of the 

facility after racking and other equipment is installed and 

merchandise is added. 

Nevertheless, it is generally easier to install ERCES before a 

building is occupied, given that it will entail fixing cable and placing 

antennas. 

ERCES are mandated in building codes in the United 

States, with specifications for design, installation and 

performance set out in NFPA (National Fire Protection 

Association) standards. Regulatory requirements are at an 

earlier and much more piecemeal stage in Canada, but 

several of British Columbia’s urban municipalities, including 

Vancouver and Victoria, have bylaws to mandate them in 

larger buildings (greater than 5,000 square metres or about 

54,000 square feet) that incorporate specified materials such 

reinforced concrete, structural steel, metal cladding and 

reflective or low-emissivity glass. 

Dawn Wotapka is the Director of External Communications at 

Honeywell, a provider of emergency responder communication 

enhancement systems (ERCES). For more information, see the website 

at www.honeywell.com. 


emergencycommunications 

“In Canada, commercial 

properties have fire wardens, 

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residential, other than what the 

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Electric bikes and scooters can be both a fire 

source (see story, page 14) and an obstruction 

to evacuation if they are charging within units. 

Brooks gives the recent example of a condo 

dweller who had to flee to the balcony because 

a blazing E-scooter blocked escape to the 

hallway. 

Cooking and throwing smoking materials 

off balconies remain among the leading 

causes of fires in high-rises. In 2022, a year 

that saw Ontario’s highest death rate 

attributable to fires in 20 years, 50% of 

fatalities were linked to non-functioning 

smoke alarms. 

Some proactive property managers and 

condominium boards are turning to in-person 

events to reinforce fire safety procedures. Reid 

is one of many fire safety consultants who 

offers education sessions to explain roles and 

responsibilities for staff and residents along 

with some details about the life safety systems 

in their buildings. 

He notes that residents are sometimes not 

aware that they should sound the alarm to the 

building, through a manual pull-station, if they 

see smoke or fire. However, it’s a lesson that 

goes two ways since building staff have 

sometimes learned that there are residents 

who can’t locate or pull the stations. 

“Through the training, they have an 

opportunity to physically do that to see if they 

are comfortable with it,” Reid recounts. 

“The residents walk away feeling more 

empowered about what to do during an 

emergency,” concurs Jennifer Lawther, a 

property manager with Whitehill Residential. 

She manages a 300-unit condominium in 

Mississauga, which is home to 50 people who 

are identified as needing assistance to 

evacuate, and says the annual education 

sessions have proved a good way to impart 

information that may otherwise go overlooked 

in written documents. 

“They meet people they haven’t met before 

and it also creates a greater sense of 

community,” Lawther suggests. 

“Rather than just sending out the policies 

and procedures once a year, we thought a 

resident information session would be 

beneficial for the residents to clarify some of 

the questions that keep coming up,” agrees 

Jackie Walker, a property manager with 

Crossbridge Condominium Services. “There 

is always turnover; emergency situations 

change; sometimes you need to be added to 

the list of persons requiring assistance and 

sometimes you don’t. It’s a good learning 

opportunity for residents to clarify what they 

should and shouldn’t be doing and the roles 

and responsibilities of everyone involved.” 

Rebecca Melnyk is Editor of CondoBusiness. 


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DEADLY LAPSES 

UK Fatal Fire Inquiry Slams Oversight and Certification Bodies 



MULTIPLE FAILINGS and systemic negligence 

have been identified as contributing 

factors to the deadly fire that killed 72 residents 

of a 24-storey apartment building in the 

United Kingdom in 2017. The recently 

released report and recommendations from a 

UK government sponsored inquiry into the 

Grenfell Tower fire casts a wide net of blame, 

beginning with the manufacturers and marketers 

of the exterior cladding systems that 

served as a welcoming and rapid path for 

travelling flames. 

Beyond those actions — which the threemember 

inquiry panel calls “dishonesty” — 

the report is highly critical of various 

oversight and certification bodies that are 

central to the safety and performance of the 

built environment. Although building codes 

in other countries, including Canada, have 

not allowed designers, developers and 

building owners to make the choices that 

directly led to the Grenfell Tower catastrophe, 

there are arguably lessons for onlookers 

everywhere about slipshod diligence, 

inappropriately trained and/or overworked 

safety administrators and the possible risks 

of commercial pressures in regulatory and 

certification processes. 

“It is not possible to identify any single 

cause of the tragedy; many different acts and 

omissions combined to bring about the Grenfell 

Tower fire, although some were more 

significant than others,” the introduction to 

the report states. “We have identified many 

errors, due in the most part to incompetence, 

carelessness and a failure to take responsibility 

for important aspects of the work that 

affected fire safety.” 

Notably, the report finds fault with: 

• the UK’s Building Research Establishment 

(BRE), a 103-year-old organization that 

develops standards, conducts testing and 

research, oversees industry and 

professional certifications such as 

BREEAM, and is widely recognized for 

its expertise, including related to fire, 

safety and security; 

• the British Board of Agrément (BBA), an 

independent certification body for the 

construction and civil engineering 

industries, including certification of 

construction products; 

• the National House Building Council 

(NHBC), an independent warranty and 

insurance provider for new home 

construction, including standards, training 

and quality assurance for builders; 

“In some cases we saw 

evidence of a desire to 

accommodate existing 

customers and to retain its 

status within the industry at the 

expense of maintaining the 

rigour of its processes and 

considerations of public safety.” 

• the United Kingdom Accreditation 

Service (UKAS), the national body 

tasked with assessing and accrediting 

organizations that provide certification, 

testing, inspection, calibration, validation 

and verification services; 

• the Local Authority Building Control 

(LABC), a joint agency of the UK’s 

municipal governments, intended to 

provide centralized technical support, 

training, marketing and business 

development services for its members’ 

building control departments; 

• the Tenant Management Organisation 

(TMO), an organization established 

under the UK’s housing regulations to 

provide services to housing communities 

on behalf of their public landlords; and 

• local building officials with the Royal 

Borough of Kensington & Chelsea. 

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The inquiry panel concludes BRE was 

complicit in enabling the manufacturer of 

the combustible polyisocyanurate foam 

insulation used on the Grenfell Tower to 

pass fire safety testing. When the product 

was tested in BRE labs in May 2014, “two 

sets of fire-resistant magnesium oxide 

boards” were used to augment its resistance, 

but that fact was omitted from BRE’s 

subsequent fire safety report. 

The inquiry panel also underscores that 

BRE had been aware of fire safety issues 

with the cladding in question as early as 

1991, but had failed to effectively 

communicate such concerns to government 

authorities or to properly identify its 

contributory factors in at least three 

noteworthy fires investigated prior to the 

Grenfell Tower catastrophe. 

BRE’s testing of the fire safety of 

external walls is negatively cited for 

“unprofessional conduct, inadequate 

practices, a lack of effective oversight, poor 

reporting and a lack of scientific rigour”. 

This is partly attributed to organizational 

failure to properly train staff or instill a 

culture of responsibility. Egregiously, senior 

staff at BRE were found to have coached 

manufacturers on how to get better safety 

testing results. 

“In some cases we saw evidence of a 

desire to accommodate existing customers 

and to retain its status within the industry at 

the expense of maintaining the rigour of its 

processes and considerations of public 

safety,” the inquiry report states. 

Similarly, the BBA is chastised for “an 

ingrained willingness to accommodate 

customers” exhibited in its deference to the 

manufacturers of the combustible cladding. 

The inquiry panel maintains the BBA 

lacked both the required expertise to assess 

the manufacturers’ disingenuous conduct 

and the robust processes to catch it. It did 

not assess any aspect of the product’s 

manufacture, testing or fire performance, 

and allowed the manufacturer to supply 

wording for the certificate. 

“The underlying problem was that the 

BBA failed to manage the conflict between 

the need to act as a commercial organisation 

in order to attract and retain customers and 

the need to exercise a high degree of rigour 

and independence in its investigations in 

order to satisfy those who might consider 

relying on its certificates,” the report states. 



As the cascading consequences of 

Grenfell Tower catastrophe demonstrate, 

subsequent product specifiers/purchasers 

and oversight agencies rarely reassess, 

question or dispute certifications. 

Overreliance on the honour system opened 

the way for other safety players to overlook 

misconduct. 

The Local Authority Building Control is 

criticized for failing to ensure competent 

assessment of products or scrutiny of 

manufacturers’ claims. United Kingdom 

Accreditation Services is called out for an 

approach that relies too much on “the 

candour and co-operation of the 

organisations being assessed” and lacks 

repercussions for accredited organizations’ 

missteps or encouragements and supports 

for their improvement. 

Like BRE and BBA, the National House 

Building Council is accused of succumbing 

to commercial pressure. The inquiry panel 

suggests the NHBC was well placed to 

sound the alarm about combustible cladding, 

particularly through its large contingent of 

accredited inspectors providing services to 

the building industry, but it failed to 

adequately do so. 

“It was unwilling to upset its own customers 

and the wider construction industry by 

revealing the scale of the use of combustible 

insulation in the external walls of high-rise 

buildings, contrary to the statutory guidance,” 

the inquiry report asserts. 

CARELESSNESS AND INCOMPETENCE 

Drilling down to on-site at the Grenfell 

Tower, numerous failings are highlighted 

in the management, delivery and oversight 

of the recladding project that precipitated 

the disaster, and in fire safety monitoring 

and coordination within the building. The 

tenant management organisation, the local 

government authority (which was both the 

landlord and the building department of 

record) and the contractor are all held 

culpable. 

“The choice of combustible materials for 

the cladding of Grenfell Tower resulted 

from a series of errors caused by the 

incompetence of the organisations and 

individuals involved in the refurbishment. 

Everyone involved in the choice of the 

materials to be used in the external wall 

thought that responsibility for their 

suitability and safety lay with someone 

else,” the inquiry report states. “None of 

those involved in the design of the external 

wall or the choice of materials acted in 

accordance with the standards of a 

reasonably competent person in their 

position.” 

Of these, the building department is 

flagged for “considerable responsibility” in 

failing to ensure the project complied with 

building regulations. The surveyor assigned 

to the project is described as overworked, 

inadequately trained and lacking 

understanding of the risks of the materials 

involved. 

Nor do senior government officials escape 

scrutiny. The UK government is lambasted 

for: its complacency related to fire safety; 

failing to act on well documented evidence 

of the cladding system’s combustibility; 

failing to amend the Fire Safety Order 

(equivalent to the Fire Code) to clarify that it 

applied to exterior walls of multifamily 

dwellings; and for resisting calls to regulate 

fire risk assessors. 

The report arises from the second phase 

of the public inquiry, which former UK 

Prime Minister Theresa May announced 

immediately after the fatal fire occurred. 

Findings are drawn from documentary 

resources and oral evidence presented in 312 

days of proceedings. 

More information about the Grenfell Tower inquiry 

can be found at www.grenfelltowerinquiry.org.uk. 

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propertyprotection 

SURFACE STRATEGY 

Graffiti Deterrence and Removal 

By Katie Lee 

GRAFFITI VANDALISM pervades 

urban areas, sometimes creating jarring 

tableaus of slapdash or offensive images. 

Unwanted script and drawings that show up 

on walls, roofs and pavement without 

owners’ consent can be an eyesore that 

detracts from curb appeal, diminishes 

property value and alters the perception of 

safety in a neighbourhood. 

Graffiti is typically applied with ink 

markers, latex or spray paint, or it can be 

scratched or etched (dubbed ‘scratchiti’ and 

‘etchiti) into glass. It can take various forms: 

• tags, which often convey vandals’ names 

and/or other affiliations; 

• stencils, derived from a stencil outline 

that has been filled in with spray paint; 

• bombs, which are larger pieces created 

with spray paint or latex paint; or 

• stickers and posters adhered to buildings. 

The first step in countering graffiti is to deter 

it from happening. Lighting can make 

potential vandals feel exposed and less 

likely to target a property. Consider 

installing motion-activated lights in dark 

corners, alleyways and around the building. 

Defensive landscaping, such as 

strategically placed thorny or prickly plants, 

can act as a natural deterrent against graffiti. 

Consider planting bushes like roses or holly 

near walls and fences to create a barrier that 

makes it difficult for vandals to gain access to 

property surfaces. 

Surveillance cameras can be a powerful 

tool for deterring graffiti and identifying 

vandals if an incident does occur. Make sure 

the cameras are visible and are accompanied 

with signage warning the property is under 

surveillance. 

Graffiti-resistant coatings create a 

protective barrier, making it easier to remove 

graffiti and may discourage vandals from 

tagging. As well, the presence of a mural can 

also serve to dissuade taggers from marring 

a property. It’s an investment that can have 

the additional benefits of beautification and 

building relationships with local artists, but 

be sure that it, too, is protected with a coating. 

When graffiti does occur, photograph it, 

document the time and place of its arrival 

and report the incident to local authorities. 

Taking the wrong approach to cleaning a 

tagged surface can actually set the ink and 

make the image more difficult to remove. 

Chemicals in some graffiti removal products 

can also be toxic and harmful to humans 

and/or the environment, so consider 

consulting a contractor with specialized 

knowledge of the procedures. 

It can be a complex exercise, depending on 

factors like the media used and the substrate 

underneath. There is no one-kind-fits-all 

approach because different inks require 

different chemicals to pull ink to the 

surface. Similarly, different substrates 

require specific products for successful 

treatment. 

For example, removing an ink marker tag 

from glass would simply require a graffiti 

removal solution and rag, while the same 

medium on a brick wall would require a 

different graffiti removal solution and a hot 

water pressure washer to remove. The 

‘scratchiti’ and ‘etchiti’ types of graffiti 

require a three-step buff and polish process 

to remove them from each surface. 

The longer graffiti remains visible, the 

more likely it is to attract additional tags. 

Quick removal sends a message that the 

property is well-maintained and not an easy 

target for future vandals. 

For repeatedly targeted properties, it may 

make sense to have a tailored maintenance 

program with a graffiti removal vendor. 

Programs can include weekly patrols by 

certified technicians and unlimited graffiti 

removal for a set monthly price. 

Katie Lee is an owning-partner with Goodbye Graffiti, 

a provider of anti-graffiti coatings and graffiti removal 

services. For more information, see the website at 

https://goodbyegraffiti.com. 


Membership 

matters 

The Commercial Real Estate landscape is changing. Property managers and 

stakeholders look to BOMA Toronto for educational support and resources to help 

navigate critical issues, deliver operational excellence, and inspire success. 

Build your skills. Build you network. Build your career. 

JOIN TODAY! 

For membership and sponsorship inquiries contact: 

Rahim Datoo 

Coordinator, Membership Engagement 

rdatoo@bomatoronto.org 

416.596.8065 ext. 227 

Nadeyah Kailan 

Manager, Stakeholder Engagement 

nkailan@bomatoronto.org 

416.560.0428 

www.bomatoronto.org

ELEVATED 

SAFEGUARDS 

Protecting Rooftop Workers 

PROVINCIAL RULES vary, but Canada 

has a strict regulatory framework to protect 

workers on rooftops, including in-house 

property maintenance teams and 

technicians and employees of third-party 

contractors. Employers, whether they be 

landlords, property/facility managers or 

contractors, are mandated to ensure safe 

access and compliance with the standards 

that the governing authority has set. 

The statistics are profound reminders of the 

human cost of preventable accidents. Ontario’s 

Workplace Safety and Insurance Board 

(WSIB) reports an average of 20 workplace 

fatalities per year in the province due to falling 

from heights. British Columbia’s government 

agency, Worksafe BC, accepts more than 

1,000 claims per year related to falls from 

ladders. A fall of less than three metres (10 feet) 

can be fatal and Occupational Health and 

Safety (OHS) Canada estimates that 95% of 

injuries involving ladders are attributable to 

unsafe use. 

Employers should be aware that 

Canadian legislation, known as the 

Westray law, holds corporations, their 

representatives and organizations 

accountable for negligence related to 

workplace safety. It establishes criminal 

liability for safety failures that result in 

worker injuries or deaths. Rigorous 

safety protocols will be key to proving, if 

necessary, that appropriate steps have 

been taken to safeguard workers. 

The Hierarchy of Controls is a systematic 

approach to risk mitigation, emphasizing 

SECURITY EQUIPMENT REBATE ROLLING OUT 

Small landlords and all residential tenants in Manitoba can now apply for a provincial 

rebate on security equipment purchased since September 2, 2023. Funds for the onetime 

rebate will be dispersed on a first-come, first-served basis to applicants who 

submit proof of purchase, installation and Manitoba residency. 

“Our government committed to this rebate during the election and we’re excited to 

roll it out to help lower the cost of cameras, lights and other security measures for 

homes and small businesses,” says Matt Wiebe, Manitoba’s Justice Minister. 

Recipients are eligible for a maximum of $300 for security improvements at a single 

address they own or occupy. However, it can be put toward more than one measure up 

to the allowable threshold. Eligible security equipment includes: security cameras; 

alarm systems; motion detectors; reinforced doors or windows; anti-graffiti film and 

paint; security gates; pull-down protection shutters; and permanent security fencing. 

– REMI Network 

prevention as the cornerstone of safety. It 

categorizes control measures into five distinct 

levels, each compounding upon the other to 

create a comprehensive safety net. Ranked 

from most to least effective, these include: 

• Elimination of the hazard so that there is 

no source of potential harm; 

• Substitution, or implementing a safer 

alternative when the hazard cannot be 

removed; 

• Engineering controls, or making physical 

changes to the environment to reduce 

risk; 

• Administrative controls to ensure proper 

training and risk mitigation procedures 

are in place; and 

• Personal protective equipment (PPE) for 

workers, which employers should view as 

the last line of defence after they’ve 

implemented all other measurers rather 

than as the leading or sole source of 

protection. 

Rooftops present an array of safety issues 

for building owners/managers and 

employers to consider, including its physical 

features, workers’ suitability for their tasks, 

regulatory requirements, weather conditions 

and vulnerability to non-authorized access. 

The area surrounding roof hatches should 

have guards and visual clues so that workers 

can clearly see where these openings are 


TOWER CRANES ON B.C. WORKPLACE SAFETY AGENDA 

operationalsafety 

Tower cranes are essential to enable a broad range of construction projects, and are now operating on increasingly complex, multi-employer 

worksites. They typically operate safely, but have the potential to inflict catastrophic harm on workers and the public if they fail. 

There were 22 tower crane incidents in British Columbia during the 2019-2023 period, including a 2021 collapse that killed five 

workers on a Kelowna job site, prompting the provincial workplace safety agency, WorkSafeBC, to conduct a comprehensive review. 

It’s now rolling out a new risk reduction strategy and urging employers to actively identify and eliminate unsafe work practices and 

equipment hazards that have the potential to cause death, serious injury and/or catastrophic equipment failure. 

“We need to ensure that employers provide the training, supervision and safe-work practices needed to keep workers safe in an 

evolving work environment,” says Todd McDonald, Head of Prevention Services with WorkSafeBC. 

Beginning in October 2024, employers must give WorkSafeBC written notice at least two weeks before tower cranes become active 

on one of their worksites. This will give the agency a record of the qualified crane operator performing the work and other details of 

the project. 

There are currently 650 credentialled operators and 400 tower cranes operating around the province. 


located and avoid potentially dangerous 

collisions when an arriving colleague 

suddenly opens it from below. Workers 

climbing up or down through hatches can 

also be more prone to tripping as they move 

from a ladder to a flat surface or vice versa. 

Moisture, snow/ice or debris on ladder 

rungs or steps can cause slips, and these 

surfaces can also degrade from long-term 

environmental exposure. Sloped or irregular 

surfaces pose other risks, which may be 

greater if portable ladders are used. 

Misalignment, setting it at an improper 

angle or placing it on an uneven surface can 

compromise ladder stability, increasing the 

risk of tipping or sliding. Secure anchorage 

is a must when ladders extend significantly 

above the landing surface to prevent 

swaying or collapsing under weight. 

Frequent use by workers climbing up and 

down with heavy loads also contributes to 

wear and tear. Regular inspections and 

maintenance are crucial to ensure that all 

access equipment remains safe and reliable. 

Worker fatigue is another factor. Climbing 

to a rooftop can be physically demanding, 

particularly at tall buildings, when multiple 

ascents and descents are required throughout 

the day or when workers are carrying heavy 

equipment and tools. Depending on the 

worksite and task, all three scenarios may 

occur together, potentially affecting 

workers’ stamina and increasing the 

likelihood of mistakes and accidents. 

Rooftop work may be necessary in all 

types of challenging weather conditions, 

whether that’s winter’s harsh cold and 

slippery substances, summer’s heat or the 

rainy slickness of spring and fall. Safety 

measures should address risks of slippery 

surfaces, snowfall coverage that obscures 

what’s underneath and heat exhaustion. 

Occupiers liability legislation also 

makes building owners/managers 

responsible for accidents that result from 

unauthorized access. It is important to 

CLEANING CHEMICAL CAUTIONARY 

Toxic ingredients in commercial cleaning products are a cause for concern. It’s 

important to read labels and pay attention to the possible presence of volatile organic 

compounds (VOCs) and other hazardous substances. 

VOCs can contribute to chronic respiratory issues, allergic reactions and headaches, 

and may be found in air fresheners, chlorine bleach, dry cleaning chemicals, detergents 

and dishwashing liquid, rug and upholstery cleaners, furniture polish and oven 

cleaners. Resources like the U.S. Environmental Protection Agency or Green Seal can 

provide guidance on products to avoid and/or environmentally safe alternatives. 

Recent research has highlighted potential dangers of quaternary ammonium 

compounds that could be linked to brain cell damage, developmental and reproductive 

toxicity, metabolic function disruption and other adverse health effects. Further 

research is underway, but, in the interim, cleaning supervisors and product procurers 

could consider avoiding products containing these ingredients to reduce exposure 

risks. 

Best practices for usage should apply for all commercial cleaning products. That 

starts with reading the product label, and includes proper dilution and storage 

practices. As well, ventilation, airflow and personal protective equipment are central to 

safe working conditions. 

“Any cleaning product can be used safely if workers are trained and have knowledge 

about cleaning ingredients and are provided with and wear personal protective 

equipment that decreases the risk of exposure to chemicals,” says Dr. Gavin 

Macgregor-Skinner, Senior Director of the Global Biorisk Advisory Council (GBAC), a 

division of ISSA. 


monitor and address safety breaches 

where ladders to the rooftop may be 

accessible to the public. 

The following measures can enhance 

safety and support regulatory compliance: 

• Fixed access ladders for securely anchored 

direct vertical access to rooftops; 

• Cage ladders with an added protective 

barrier to prevent falls; 

• Guardrails to create perimeters along the 

edges of rooftops and around openings or 

other dangerous zones; 

• Ships ladders with a stair-like design to 

support ascent and descent; 

• Lifeline ladders equipped with cable that 

can be attached to safety harnesses in 

order to catch climbers who fall or lose 

their footing; 

• Bumplines and warning lines to alert 

workers of the presence of a hazard and 

increase situational awareness; 

• Walkways to facilitate safe passage 

across rooftops; 

• Crossover bridges for passages over 

rooftop obstacles, such as ducts, piping or 

equipment; 

• Anchor points to provide secure tie-off 

points for personal fall arrest systems; 

• Safety hoists for lifting equipment from 

the ground to the rooftop; 

• Platforms to provide stable areas for 

specific tasks requiring access to 

particular rooftop equipment or zones; 

and 

• Safety netting placed around the roof 

perimeter to catch falling objects or 

debris and prevent injuries below. 

The preceding article was provided by the safety 

experts at Skyline Group, a Canadian-based 

specialist in rooftop safety systems and consulting 

services. For more information, see the website at 

www.skylinegroupintl.com. 


industrydrivers 

SCURRY 

FOR SKILLS 

Office-using Sectors Make Space for AI Expertise 

ARTIFICIAL INTELLIGENCE (AI) 

underpins job growth and real estate demand 

in North America’s most active markets for 

tech employment, including Toronto, 

Vancouver and Montreal. Canadian cities 

again place highly in CBRE’s newly released 

annual rating of thriving hubs and emerging 

centres for both core tech companies and techrelated 

hiring across broader regional 

economies. This year’s findings highlight that 

employers in many office-using sectors are 

seeking AI expertise. 

“The postings for AI-related talent was 

about 9% of total tech talent jobs in late 2019, 

and that number has shot up to about 14% 

currently and continues to grow,” Colin 

Yasukochi, Executive Director of CBRE’s 

tech insights centre, observed during a 

webinar in conjunction with the release of the 

2024 tech talent scoring report. 

That’s happening in the context of more 

muted job growth across all fields of techrelated 

talent. The United States gained about 

213,000 new positions in 2023, representing a 

3.6% increase in the total tech workforce from 

2022, but the quotient of AI specialist jobs 

jumped by nearly double that rate. Canada 

added 18,400 new jobs last year, equating to a 

1.7% increase in the tech workforce. 

Roughly 60% of North American techrelated 

employees work outside the core tech 

industry, and those non-tech sectors 

collectively accounted for about 86% of new 

hires in the U.S. last year. Job growth was most 

notable in the transportation/warehouse/ 

wholesale, professional/business services and 

finance/insurance/real estate (FIRE) sectors. 

Drilling down to this year’s rankings, 

Toronto is the highest placed Canadian city 

— climbing up to fourth from fifth in 2023. 

That’s based on a combination of factors 

considered important for employers and 

employees, including: labour and operation 

costs; availability of post-secondary graduates 

with tech-related training; strength of the local 

tech economy along with opportunities for 

business growth and career advancement; cost 

of living; and lifestyle attributes. 

“Operating in Toronto is more affordable 

than in other U.S. tech hubs,” Liz Nucci, 

Senior Vice President, office leasing, for 

CBRE in Toronto, advised during the 

webinar. “We have skilled talent here with 

world renowned institutions like the 

University of Toronto and the University 

of Waterloo producing highly educated 

graduates in fields like computer science 

and AI, and Canada’s favourable 

immigration and visa programs, relative 

to the U.S., attract international talent, 

creating a more diverse and innovative 

workforce.” 

The top three markets — San Francisco 

Bay Area, Seattle and Metro New York — 

remain unchanged from last year, but Austin 

has moved into the top five, switching places 


OSCRE SETS PRINCIPLES FOR AI IN DATA MANAGEMENT 

The Open Standards Consortium for Real Estate (OSCRE) has 

enunciated seven principles to be applied when artificial 

intelligence (AI) is employed in collecting, processing and/or 

interpreting real estate data. The global organization’s newly 

released policy statement underscores AI’s potential to advance 

data management capabilities and better inform valuation 

processes, investment decision-making and property 

management and operations, provided those exercises and 

outcomes are grounded in a standardized, industry-approved 

approach. 

“We remain committed to the development and continual 

improvement of the OSCRE Industry Data Model (IDM) to provide 

a firm foundation for employing AI technology and associated 

ethical implications,” it states. 

The policy statement calls for AI applications in real estate data 

management to be: 

• secure and trusted; 


• reliant on a standardized data model; 

• beneficial to society; 

• respectful and protective of human values and privacy; 

• fair and unbiased; 

• understood and transparent; and 

• accountable to people. 

“This policy statement underscores OSCRE’s commitment to 

advancing data standards and AI integration in the real estate 

industry while prioritizing collaboration, education, continuous 

improvement and accessibility. By adhering to these principles, 

we commit to support a more transparent, efficient and 

sustainable real estate ecosystem for all stakeholders,” the policy 

statement affirms. 

For more information about OSCRE, see the website at 

www.oscre.org 

with Washington, D.C., which now sits in sixth. 

Boston, Denver, Dallas/Fort Worth and Ottawa 

round out the top 10. 

Vancouver (11th), Montreal (15th), Waterloo 

Region (18th), Calgary (20th) Quebec City 

(40th) and Edmonton (49th) also crack the top 

50, while Halifax and Winnipeg are ranked 

fifth and 13th respectively in an associated list 

of 25 emerging markets. In a repeat of last 

year, the eight Canadian markets were found 

to have the lowest operating costs in the group 

of 50, based on average annual wages for a 

500-person workforce and rent for 60,000 

square feet of office space. 

“They generally will have advantages there 

from a labour cost perspective, and have been 

the recipients of a lot of growth because of those 

lower wages and the relative value that you get 

for the quality of the tech talent in those 

markets,” Yasukochi acknowledged. 

MULTI-SECTOR HIRING 

CBRE’s research points to notable clusters of 

AI specialists in a few key markets, with 

approximately 44% of such positions in the U.S. 

located in San Francisco, Seattle or Metro New 

York. AI-related jobs are even more 

concentrated in Canada where approximately 

60% are in Toronto, Vancouver or Montreal. 

“When we look at who the AI tech talent 

actually works for, we found that half of them 

worked for the tech industry, but also found that 

tech talent in AI specialty roles work across all 

industries,” Yasukochi reported. “Finance and 

professional services also employs a significant 

amount of this tech talent.” 

Real estate insiders in the four top-ranked 

tech employment markets relayed what they’re 

seeing, which also illustrates something of a 

split in the economic profiles of San Francisco 

Bay and Seattle versus New York and Toronto. 

About 55% of tech workers in the San Francisco 

Bay Area and Seattle are software designers 

and programmers and two-thirds of total tech 

employment is in core tech companies. In 

contrast, the majority is employed by non-tech 

companies in the other two cities and a much 

larger percentage — 19.2% in Toronto and 

20% in New York — work in the FIRE 

sectors. 

Luke Ogelsby, a CBRE Executive Vice 

President based in San Francisco, noted that 

half of the U.S. venture capital invested in 

AI has flowed into the San Francisco Bay 

Area, while universities in the region are 

producing about 5,000 graduates with AI 

specializations every year. AI firms 

accounted for about 1 million square feet of 

office absorption in 2023. 

“The Bay Area really feels like we’re at the 

beginning of the next innovation cycle,” 

Ogelsby asserted. “When we look at AI, we 

think it’s going to be pervasive in everything 

we do. It’s not just going to be the large 

companies that are hiring tech talent. The 

impacts to hiring are going to be across all 

industries.” 

Bill Cooper, a CBRE Senior Vice President 

in Seattle, suggests that’s already evident in 

retail, transportation and aerospace. Legal 

services have also been early adopters, in part, 

he speculates, to keep up with their clients’ 

evolving business needs and the many issues 

arising with the burgeoning technology. 

Meanwhile, Seattle-based tech companies 

and academic institutions have been pioneers 

of AI development, giving the region a 

ecosystem of talent and support for 

innovation that has been built over 20+ 

years. Cooper characterizes the region as a 

magnet for American and international 

talent and also credits the tech industry’s 

robust intern programs that attract highcalibre 

students, who then decide to stay. 

“With AI, we’re also seeing a lot more 

collaboration. It’s in-office work due to the 

need for collaboration and sharing 

knowledge so that’s creating more of an 

office need,” he added. 

In Metro New York, Sacha Zarba, a 

CBRE Vice Chair, reports active 

requirements from dedicated AI firms or 

larger tech companies with growing AI 

divisions for about 500,000 square feet of 

space. That follows the roughly 500,000 

square feet that AI-related ventures have 

leased since early 2023. 

“A lot of the AI-related growth is not 

necessarily with huge companies,” Zarba 

said. “A lot of these companies are smaller, 

scaling companies that are just getting 

their legs and really represent the 

beginning of a new cycle.” 

That could bode well for Toronto, where 

previous examinations of tech-related talent 

have shown a greater number of smaller firms 

than in the other top-five markets. Nucci 

likewise identifies “homegrown AI startups” 

as an engine of job growth and real estate 

leasing. She notes that some are now 

expanding their footprints in downtown 

Toronto to more than double their original 

spaces, with big and small firms collectively 

looking for 50,000 to 100,000 square feet. 

Zarba foresees demand for AI expertise, 

and space to accommodate it, will continue to 

filter through to the many industries that have 

an interest in pursuing the predictive 

capabilities that AI is expected to enable. 

“We’re seeing that in finance, which is a 

large, if the not the largest contributor of 

leasing volume in the city,” he affirmed. 

CBRE’s Scoring Tech Talent 2024 report 

can be found at www.cbre.com/insights/books/ 

scoring-tech-talent-2024. 



GROUNDWORK GRIND 

CRE Pulling the Pieces Together to Enable AI Insights 


ARTIFICIAL INTELLIGENCE (AI) is 

expected to enable a dramatic leap in the 

commercial real estate industry’s analytical 

and predictive capabilities, but a significant 

amount of fastidious work to wrangle data 

and train generative models is foreseen 

before those new efficiencies and insights can 

be achieved. 

Early adopters and leading enthusiasts 

tally a long list of possibilities for portfolio 

management, risk management, valuation 

and assessing investment performance. For 

now, though, they’re mostly slogging through 

the monumental task of gathering and 

integrating the underlying intelligence. 

“We’re spending our time cleaning client 

data so we can feed it into our models to 

provide the analytics back to them,” Charles 

Fisher, JLL’s Director of Global Real Estate 

Risk Analytics, reported earlier this year 

during a webinar sponsored by the Open 

Standards Consortium for Real Estate 

(OSCRE). “To get to scale, it gets more 

complicated. Definitely, there are lots of 

levels of maturity on this curve.” 

Eventually, he anticipates AI will be 

enlisted in that task, once models can identify 

and remove rogue data. In the interim, the 

industry is accumulating and refining 

resources, and employing a range of 

application programming interfaces (APIs) 

to integrate data from across its 

multidisciplinary landscape to spot trends, 

forge connections and inform decisionmaking. 

Firms are also implementing AI 

where it’s workable. 

“We’re already using generative AI to 

update some of our repetitive tasks like 

summarizing documents, data collection, 

aggregation, report generation or even some 

of our more administrative tasks like taking 

notes during meetings, summarizing the 

outcomes, takeaways and action items,” 

Amanda Carrillo, Director of Analytics 

Insights and Intelligence for CBRE 

Investment Management in the Americas, 

told the webinar audience. 

Kevin Shtofman, Global Head of Innovation 

with the real estate data and analytics 

consulting firm, Cherre, highlighted some of 

the machine learning functions — which he 

characterized as “the step before you get to 

AI” — that have become fairly commonplace. 

For example, it can serve as a swift and 

meticulous proofreader, cross-referencing the 

many contributing details in companies’ 

reports with the source documents. 

“It’s automatically running some 

validation rules around lease length, correct 

lease dates, correct square footage, correct 

number of units, matching and netting trial 

balances,” Shtofman explained. “It’s just 

applying a lot of basic rules to prevent a 

flawed dataset from being presented.” 

He also described some early inroads in 

using AI to predict the risk of tenants 

defaulting. Risk profiles are derived from 

history of rent payment timeliness and 

occurrences or patterns of falling behind and 

requesting restructuring of payment terms, 

which are analyzed across all leases a tenant 

holds within a landlord’s portfolio. 

“Understanding AR [accounts receivable] 

risk has been the first use-case where we’ve 

found a lot of success in AI,” Shtofman said. 

Looking to the future, webinar participants 

noted both generative AI’s interface, which 

would allow information-seekers to pose a 

question and get the program to retrieve the 

answer from a vast trove of data, and the 

many new insights that such dexterity could 

quickly and straightforwardly reveal. Carrillo 

cited a raft of performance analytics that will 

presumably become much easier to obtain, 

while Fisher envisioned how AI could 

support investors’ pursuit of value growth. 

“We’re really focused on drivers of 

performance: sector allocations; market 

allocations; property selection; our valuation 

metrics and how they’re moving against the 

benchmark; impacts of leverage; and, at the 

end of the day, how our portfolio performed 

versus the underwriting and why,” Carrillo 

affirmed. 

“I am definitely interested in arbitrage 

opportunities, looking at what a property is 

selling for versus what the model says the 

value should be, and taking advantage of AI’s 

scale to start layering in other data,” Fisher 

mused. “I think there’s a lot of interesting 

scale use-cases, which we’ll see embedded 

into other platforms to make investment 

decisions faster.” 

Data is tapped to be increasingly vital once 

generative AI capabilities are in place, with 

bigger players better placed to reap the 

benefits. 

“The more information that you’ve got, 

proprietary from your own investments or 

proprietary data from your own occupied 

portfolio, combined with purchased data, the 

more you’ll likely be able to make more 

intelligent decisions that are predictive and 

prescriptive,” Shtofman submitted. “I think 

the biggest firms with the biggest budgets for 

purchasing data will end up with an outsized 

advantage.” 


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FROM BATTLEFIELD TO 

SECURITY WITH PURPOSE: 

Commissionaires Great Lakes 

celebrates 100 years 

of veteran support 

As Canada’s only national not-for-profi t security company, 

Commissionaires has a proven history of duty, integrity, 

and service. The Canadian Corps of Commissionaires was 

founded in 1925 to provide employment to those who had served 

during the First World War. This commitment is entrenched in its 

social mandate to provide meaningful employment to veterans of 

the Canadian Armed Forces and RCMP, members of their families 

and others who wish to contribute to the safety and security of the 

country. Today, Commissionaires remains Canada’s largest private 

employer of veterans who apply their specialized skills as part of a 

national workforce of 22,000. 

“It’s the connection to military and security culture that makes 

Commissionaires such a natural fi t for veterans transitioning to 

civilian life,” says Terry Hunter, a veteran of the Canadian Armed 

Forces and Vice President, Client Services with Commissionaires 

Great Lakes. “Veterans are well represented at all levels of the 

commissionaires.ca


organization including governance and leadership, working 

alongside civilians to fulfi ll our social mandate. It’s a deliberate 

choice that helps veterans feel at home.” 

STRUCTURE AND BELONGING 

The importance of a sense of service and belonging cannot be 

overstated. This seamless transition is crucial as many veterans 

struggle to fi nd their footing in the civilian world, often feeling 

adrift and disconnected from the structure and camaraderie 

they once knew. The structured, disciplined environment of 

Commissionaires provides familiarity and purpose that can be 

diffi cult to fi nd elsewhere. 

This was the case for Hunter, who recalled the challenges of 

transitioning from military life to a more traditional corporate role. 

“It was a shock to me when I left the military and went to work 

in a civilian job. In the military, you’re trained so well and to such a 

high standard as team members that if your surroundings are not 

to your expectations, it can be a letdown.” 

Long known for its security of federal government and military 

properties, Commissionaires provides services to many residential 

and commercial clients including residential and offi ce buildings, 

warehouses and distribution centres, commercial enterprises 

and more. 

Veterans who work for Commissionaires take pride in having 

permission to display their service ribbons as part of their uniform. 

“When people enter a building and they see someone in uniform 

with their service ribbons displayed, you know that person served 

the country,” Hunter says. “That goes a long way.” 

VETERANS: A PERFECT FIT FOR SECURITY 

Offering a wide variety of security services including access 

control, concierge and reception services, parking monitoring, 

visitor registration and mobile patrol, Commissionaires has ample 

ability to deliver with law enforcement and military veterans being 

particularly well-suited to these positions. Commissionaires also 

provides employee background checks, fi ngerprinting and ID 

services, and alarm response services. 

“The work involves multitasking, customer service, and 

attention to detail—at which all our veterans excel. If you take a 

condominium for example with a staff member in uniform sitting 

at the front desk, their job is not only to protect the building but, 

as the fi rst point of contact with all who enter, our guards need to 

respond well to every resident in that building and their guests. 

Our veterans are customer service oriented and have the security 

background and training to ensure that unauthorized persons are 

not provided access.” 

For Hunter, being part of the Commissionaires is a way to 

continue serving his country, even if it is not in the traditional 

military sense. “It’s an organization that’s committed to Canada, 

and organizations within Canada,” he summarizes. “We offer 

security with purpose. I get the feeling of giving something back 

every day, and it feels good.” 

1 877 322 6777

ASSET-LEVEL 

OPENNESS 

ESG Benchmarking Supports Risk Management 


ENERGY EFFICIENCY will gain 

standing in the 2025 GRESB assessment 

when the global benchmark for ESG 

performance of commercial real estate 

portfolios introduces revised scoring for its 

energy performance metric. The move to 

assign energy efficiency scores to individual 

assets within benchmark participants’ 

portfolios reflects the GRESB mandates to 

push continuous ESG improvement and 

accelerate decarbonization, and is made 

possible through its increasingly 

sophisticated database. 

“The idea of rating energy efficiency is 

not necessarily all that novel. However, 

given the geographic scope, the diversity of 

property types, the types of people we’re 

talking to, we have never overtly done it 

before,” Chris Pyke, GRESB’s Chief 

Innovation Officer, advised during a 

recent webinar sponsored by the Open 

Standards Consortium for Real Estate 

(OSCRE). “We have made some strategic 

decisions to do that using our own data as 

a benchmark because of the lack of 

globally comparable things that we could 

use. We will demonstrate some methods 


continuousimprovement 

GRESB TO REVISE MULTIFAMILY INDICATORS 

Multifamily real estate entities reporting to GRESB, the global assessment and 

benchmark for the ESG performance of portfolios, can expect new criteria next year. 

The GRESB Foundation has issued a notice of changes to be implemented in 2025 with 

a promise of more details later this fall. 

The slate of ESG indicators, which collectively underpin GRESB scores, will be 

revamped to better reflect residential operations and management considerations. 

Some existing indicators will be culled; others will be revised or given new weights 

within the total score; and new ones will be added. 

GRESB calls the move part of a “wider effort to bring greater sector specificity to the 

standard” and it is also in sync with growing participation from the multifamily sector. 

Speaking during a recent webinar, Dan Winters, GRESB’s Senior Director, Strategic 

Initiatives, reported that multifamily accounted for the largest share of new respondents 

to the recently completed 2024 assessment from a property sector perspective. 

In its 15th year, more than 2,200 real estate entities, encompassing roughly 210,000 

individual assets worldwide, participated in the GRESB assessment. That’s up from 

2,084 portfolios, collectively comprised of 170,000+ assets, in 2023. 

Winters theorized that the ever-expanding slate of reporting entities is tied to investor 

demand and, particularly, institutional investors’ need to meet targets for the reduction 

of greenhouse gas (GHG) emissions and to verify other types of environmental and 

social compliance. At the same time, many of those investors are shifting their real 

estate allocations away from office properties and into other asset classes. 

“We’ve got a lot of 2050, 2045, 2040 commitments, particularly from the big pension 

plans, and they’re looking for partners in progress to drive down their carbon footprints 

and to report up to their chief investment officers as well,” he said. “We traffic in nonfinancial 

data, and we’ve put a framework and process around non-financial measures 

that are first and second order material to LP (limited partners) and pension plans.” 

“Operational energy 

performance, operational energy 

data and its interpretation are 

really coming to the forefront 

next year.” 

this fall and we will incorporate them into 

next year’s standards.” 

For now, GRESB number-crunchers are 

working to produce the 2024 results slated 

to be released in October. Participation grew 

again in this 15th year of the benchmark 

with more than 2,200 real estate entities — 

encompassing roughly 210,000 individual 

assets worldwide — submitting information 

to meet the July 1 deadline. 

This is the fifth year that the assessment 

exercise has required asset-level information 

for operational performance metrics related 

to energy, greenhouse gas (GHG) emissions, 

water and waste, which underpins the 

capability for the pending energy-efficiency 

rating. Also speaking in the webinar, 

GRESB’s Director of Strategic Initiatives, 

Dan Winters, suggested the focus on assetlevel 

reporting galvanized industry action, 

and has done so with expedient timing given 

the rise of market-driven and mandated 

disclosure requirements thus far this 

decade. 

“In 2018, we announced that asset-level 

data would be required in 2020, and that 

really moved the market forward on rolling 

up the sleeves and being able to access this 

data, and to look at it and say: Is it timely? Is 

it quality? Where does it come from?” he 

maintained. 

As it relates to energy performance, 

GRESB participants have been uploading 

information related to each building’s 

consumption, metering, year-over-year 

changes and quotient of renewable supply. 

At the macro level, energy performance is 

worth up to 14 points of a 100-point total 

score. (GHG and water are each worth up to 

seven points, while waste maxes out at four 

points.) 

“We have rated improvement; we have 

rated data coverage; we have collected 

intensity metrics and those types of things, 

but we have never explicitly rated energy 

efficiency at the asset level,” Pyke said. 

“That is going to drive an ever-greater 

priority on operational energy efficiency 

within the benchmark. Operational energy 

performance, operational energy data and 

its interpretation are really coming to the 

forefront next year.” 

Looking to the future, he expects there 

will be reporting requirements related to 

electricity grid-integration and refrigerants 

once they can be tied to measurable data 

points. It’s part of the larger decarbonization 


continuousimprovement 

agenda, which has spurred the formation of 

a net-zero working group (including four 

Canadian representatives in the 23-member 

group) within the GRESB Foundation. 

PLATFORM-AGNOSTIC DATA EXCHANGE 

It’s also in sync with what’s characterized as 

a “perennial effort” to adhere to, promote 

and improve credible, consistent approaches 

to collecting, managing, integrating and 

interpreting data. 

“Data will continue to be central to 

GRESB’s ability to fulfil and enhance its 

mission,” the GRESB Foundation’s 2024 

roadmap report affirms. 

OSCRE is very much an ally in that 

endeavour. The organization’s energy 

management data standard, released last 

year, is the first of three environmental data 

standards intended to forge unity, 

interoperability and quality control in an 

increasingly dense tangle of metrics, data 

system providers and reporting demands. 

The water data standard is now being 

finalized (see story, page 42) and 

development of a waste data standard is set 

to follow. 

“Recently, we were talking with a CDO 

(Chief Data Officer) who said: We collect 

information across 40 different platforms. 

I think that’s more the norm than the 

exception,” recounted Lisa Stanley, Chief 

Executive Officer of OSCRE. “As we look 

at what has been an onslaught of legislative 

and regulatory mandates occurring in the 

U.S. and elsewhere, the responsibility and 

accountability for reporting is growing to 

the point that many, many organizations 

are trying to figure out: How do we find the 

resources to do all this?” 

The new OSCRE environmental data 

standards align with the reporting parameters 

of GRESB, the Carbon Risk Real Estate 

Monitor (CRREM) and three other ESGrelated 

platforms. Stanley describes her 

organization as a “convenor” of the standards 

development process that brings together a 

wide range of stakeholders, including investment 

managers, corporate owners and occupiers, 

data management providers, consulting 

firms and software developers. 

“They come together with a common 

focus to create more value in a way that is 

platform-agnostic,” she reported. “There’s 

a lot more interest in collaboration because 

it is both strengthening the data that’s 

reported, as well as the value that is 

provided to the customers.” 

Winters stressed that GRESB’s 

investor partners are seeking the same 

rigour that they expect from financial 

data, as ESG-related non-financial 

information becomes increasingly 

material to charting investment 

performance. Meanwhile, Pyke 

underscored that GRESB is embedded in 

econometric analysis, which may be 

removed from what some onlookers 

perceive as the “feel-good” aspects of 

ESG. 

“When we don’t have adequate 

material non-financial information, that 

failure is reflected in a misallocation of 

risk and resources. Our effort at GRESB 

is to provide that necessary non-financial 

material information to allow people to 

make risk-adjusted investments and to 

fix those allocation problems,” he 

submitted. “That really pushes down to 

an emphasis on data quality and assetlevel 

information.” 

For more information about GRESB, see the 

website at www.gresb.com. For more 

information about the Open Standards 

Consortium for Real Estate, see the website 

at www.oscre.org. 

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For more information, please visit: BODProgram.com 

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esources 

BUOYANT 

TRENDS 

New Water Use Initiatives Afloat 

bathrooms; 4.7 L/min for faucets in private 

bathrooms; and 7 L/min for kitchen faucets 

and shower heads. Automatic faucets (also 

known as metering faucets) would have a 

maximum flow rate of 0.95 litres per cycle. 

This would apply for faucets, shower heads 

and replacement aerators manufactured in or 

imported into Canada after July 1, 2026. 

NEW WATER use initiatives are afloat 

on two fronts. The Canadian government 

is preparing to include faucets and 

shower heads in the national energy efficiency 

regulations for the first time, 

while the Open Standards Consortium 

for Real Estate (OSCRE) is finalizing a 

data standard to support industry consistency 

in collecting, interpreting and 

reporting water consumption, discharge 

and related environmental impacts. 

Faucets and shower heads are set to be 

newly added to the energy efficiency 

regulations, along with air compressors, pool 

pumps and line-voltage thermostats. They’ll 

join five categories of already regulated 

commercial and residential appliances/ 

equipment — air conditioners, heat pumps, 

furnaces, water heaters and general service 

lamps — slated for revised, more stringent 

standards beginning in 2026. 

Proposed amendments to the energy 

efficiency regulations will generally align 

performance and testing requirements with 

energy standards that have been nationally 

adopted in the United States. 

Faucets and shower heads have long been 

regulated energy-using products in the U.S. 

so their pending inclusion in Canada’s 

energy efficiency regulations will 

harmonize that status on both sides of 

the border. However, the U.S. department 

of energy (DOE) has not updated 

performance requirements for the 

fixtures in several years so the Canadian 

regulations correspond with California’s 

more rigorous state standards for waterflow 

rates. 

“At this time, there are unnecessary 

regulatory differences across jurisdictions, 

which can hinder cross-border trade and 

investment and ultimately impose a cost on 

citizens, businesses and economies. In this 

context, regulatory actions are necessary for 

some energy-using products to keep pace 

with changes that have taken place in the 

United States,” the accompanying regulatory 

analysis states. “Some products require going 

further than the United States on energy 

efficiency standards to drive more significant 

energy savings and assist with the 

Government’s goal to reduce GHG emissions 

and achieve net-zero by 2050.” 

The proposed regulations set a maximum 

flow rate of 2 litres per minute (L/min) for 

manually operated faucets in public 

SAVINGS PROJECTIONS 

It’s estimated that, by 2050, the new faucet 

standards will save 41 petajoules of energy 

and avoid two megatonnes (Mt) of greenhouse 

gas emissions in the commercial sector, 

equating to $372 million in energy 

benefits and $694 million in emissions 

avoidance benefits. Shower head standards 

are projected to have a much more modest 

impact, amounting to about 1.9 petajoules of 

energy savings and 100 kilotonnes of GHG 

avoidance. 

In both cases, residential outcomes are 

expected to be dramatically more significant 

with estimated energy savings of 401 

petajoules from faucets and 242 petajoules 

from shower heads. That comes with a 

projected 35 Mt reduction in GHG emissions 

to 2050. 

Across all building types, the new 

measures are projected to result in about 

3.3 billion cubic metres of water savings 

to 2050. 

The regulatory analysis accompanying 

the proposed amendments also addresses 

concerns about potential inadvertent 

results that were identified in an earlier 

stakeholder consultation. That includes: 

• possible health risks of water’s slower exit 

from faucets and shower heads and, thus, 

longer duration within piping systems; 

• propensity of consumers to use more 

water to make up for a diminished flow 

rate; and 

• an altering of the assumptions that water 

and wastewater utilities have used in their 

planning processes. 


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esources 

The analysis, informed with input from 

Natural Resources Canada (NRCan), 

counters that there has been little evidence 

of those detrimental outcomes in other 

jurisdictions that have adopted similar 

flow-rates. 

It acknowledges that “the risk is not zero” 

when water sits in piping for longer periods, 

but concludes it is not sufficient to override 

the intent of the regulation. As well, it cites 

California’s track record of energy and water 

savings and notes that water and wastewater 

system operators have readily adapted to 

lower average water use. 

Appliance/equipment specifications are 

characterized as an easier intervention ahead of 

other more complicated and capital-intensive 

approaches through building design. They can 

quickly penetrate both the retrofit and newbuild 

markets and would be consistent across 

Canada. 

“NRCan determined that using the 

regulations to reduce fixture flow-rates is the 

most cost-effective approach to deliver 

significant and immediate energy and water 

savings,” the regulatory analysis states. “The 

regulations apply to products shipped from one 

province to another or imported into Canada 

for the purpose of sale or lease.” 

BOLSTERING DATA QUALITY 

OSCRE’s new water data standard likewise 

targets consistency. It aligns with several 

voluntary and mandatory reporting 

frameworks, including ENERGYSTAR, 

International Financial Reporting Standards 

(IFRS), Europe’s Corporate Sustainability 

Reporting Directive, the Global Reporting 

Initiative and the Taskforce on Naturerelated 

Financial Disclosures. 

It is the second of three standards under 

OSCRE’s environmental data standards 

umbrella, and follows the energy data 

standard introduced last year. Work is still 

pending to develop a waste data standard. 

The water data standard is intended to 

assist real estate asset, property and 

operations managers, investors, lenders 

and insurers through credible, consensusdriven 

methods to ensure the quality, 

comparability and transferability of 

data. The non-profit industry 

organization’s broad reach encompasses 

the generators, consumers and 

conveyors of data — corporate owners 

and occupiers, investment managers, 

consultants and software service 

providers — and provides a forum for 

collaboration and peer networking. 

“OSCRE’s position has been to find 

common ground,” Lisa Stanley, OSCRE’s 

Chief Executive Officer, affirmed during a 

recent webinar. “I think there’s a recognition 

in the industry at large that the data that’s 

being collected across their organizations 

may have some challenges, and that data 

consistency and integrity may be tied to 

bigger consequences than was the case in the 

past.” 

The water data standard is promoted as a 

tool that can help: 

• simplify the baseline for water use 

monitoring; 

• measure the return on investment on 

water-related capital projects; 

• mitigate risk and collect information 

needed for insurance and underwriting; 

and 

• improve the attractiveness of assets to 

investors with ESG obligations. 

More information about Canada’s energy 

efficiency regulations can be found at https:// 

natural-resources.canada.ca/energy/regulationscodes-standards/7043. 

More information about 

OSCRE’s environmental data standards can be 

found at www.oscre.org/Industry-Data-Model/ 

Environmental-Data-Project. 


THE 

BUILDINGS 

SHOW 

Dec 4 - 6, 2024 

Metro Toronto Convention Centre 

AVE THE DATE

safespaces 

CONTENTIOUS 

CONDOS 

Managing Conflict and Abusive Behaviour 

By Luis A. Hernandez and Ingrid Kulik 

A RECENT COURT case reveals how one 

Toronto condo dweller upended other residents’ 

peaceful enjoyment of their homes and 

created security challenges for the condominium 

corporation’s board of directors and 

property management team. The case centred 

on the disruptive and threatening behaviour 

of one condo owner’s son over the course 

of a couple of years. 

Instigating actions included: yelling and 

screaming at residents and staff; subjecting 

female residents to inappropriate language 

and gestures; refusing to comply with 

security requests; and obstructing fire 

safety inspections. This culminated in the 

discovery of a disturbing note in the 

condominium’s parking garage, which 

contained threats of sexual violence 

toward management and residents, 

derogatory language and the “Z” symbol 

that Russia has subverted to represent its 

military invasion of Ukraine. 

The case highlights several legal and 

safety implications for condominiums and 

property managers: 

Compliance with the law: condominiums must 

ensure that all residents comply with the 

Condominium Act, 1998, declarations, bylaws, 

and rules. This includes taking reasonable 

steps to address any behaviour that may cause 

damage, injury or interfere with other 

residents’ enjoyment of their property; 

Workplace harassment and violence: the 

Occupational Health and Safety Act defines 

harassment as any vexatious conduct or 

comments that are unwelcome. In this case, 

the son’s behaviour towards the management 

staff can only be characterized as workplace 

harassment and violence; and 

Financial accountability: this ruling reinforces 

the principle that residents who violate 

condominiums’ governing documents can 

and should be held financially accountable 

for the consequences of their actions. 

Disputes between an owner and a 

condominium’s agents, individual board 

members or between owners themselves can 

come with a hefty price for the corporation, 

including legal, administrative and soft 

costs related to tracking, recording and 

expending time and efforts to curb a 

dispute. Notably, the condo corporation 

in this situation was compelled to take 

extensive security measures. 

These included: hiring additional security 

guards at a cost of more than $31,000; 

installing more closed-circuit television 

(CCTV) cameras, costing approximately 

$17,000; and conducting a $5,400 security 

assessment. The condo corp. also had to 

repair the door of the unit where the 

disruptive resident lived after the police 

forcibly entered, bringing total securityrelated 

costs to $54,624.30. 

The court ultimately awarded the 

condominium the complete amount it 

incurred in security costs plus legal costs in 

the amount of $39,805.38. Thus, the 

respondent owner and son were jointly 

ordered to pay the condominium $94,429.68. 

As this case illustrates, condominium 

boards and managers must be vigilant and 

proactive in identifying and mitigating risks to 

ensure the safety and well-being of all 

residents and workers. Key takeaways include: 


CRIMINAL CODE ACKNOWLEDGEMENT SOUGHT 

safespaces 

Ontario’s leading condo associations are pushing the federal government to amend the Criminal Code of Canada to give courts more leeway to 

impose stricter sentencing measures on individuals who commit or attempt to engage in violent assaults against condo directors, officers, 

managers, and related support staff. 

The Association of Condominium Managers of Ontario (ACMO), the Toronto and Area and Eastern Ontario Chapters of the Canadian 

Condominium Institute (CCI), and the Canadian Chapter of the Community Associations Institute (CAI) launched a joint initiative early last year to 

propose legislative reforms and develop resources following the mass shooting at Bellaria Residences in Vaughan, Ontario, on December 18, 

2022. They argue that there are currently insufficient safeguards to protect management staff from violence. 

“It is alarming to see a rise in incidents where condominium directors, condominium managers and related support staff are subjected to 

physical assault while carrying out their responsibilities,” the associations’ recent letter to the federal government states. “Actual, attempted or 

threatened violence not only jeopardizes their well-being but also undermines their ability to effectively fulfill their duties.” 

That’s creating new difficulties in encouraging condo owners to stand for election or re-election to boards. “Many condominium managers feel 

equally unsafe and are leaving the profession,” the letter maintains. 

The groups have suggested that the Criminal Code should extend the conditions that now apply to the assault of a public transit operator to 

condominium directors, condominium managers and/or agents of the condominium or strata corporation. 

“The purpose of this provision is to provide an additional deterrent to protect transit operators while performing their duties,” the associations 

state. “This same rationale applies to those who are fulfilling their duties under various forms of condominium legislation across the country.” 

More than two million Canadian households live in condos. ACMO, CCI-T and CAI-C call for a “clear message that such behaviour will not be 

tolerated” to be passed through to Canada’s criminal justice system, and stress that condo officers and managers are, themselves, tasked with 

upholding legislation. 

“These persons have a duty to enforce provincial condominium legislation and the governing documents of the condominium corporation that 

they serve,” the letter reiterates. “A person who, through violence, interferes or attempts to interfere with someone who is discharging their duties 

in this regard should face an increased criminal penalty.” 


Early intervention: prompt action can prevent 

situations from escalating. Regular 

monitoring and addressing minor infractions 

early can deter more serious violations and 

will generally set an expectation in the 

x 

community that issues will be dealt Expiry 

x Expiry with; 

Code Expiry 

Documentation and proof: document Code any 

Version Code 

interactions with the wrongdoer and Version establish 

Other Version 

clear boundaries to 

(specify) 

avoid Other any 

Other 

(specify) 

misunderstandings. If at all possible, (specify) avoid 

interacting with these individuals by phone; 

Comprehensive security plans: it is essential to 

invest in comprehensive security systems, 

including CCTV, security personnel, and 

regular assessments. These measures 

enhance safety and also provide valuable 

evidence in case of disputes. Connect with 

security and concierge service providers to 

carry out a comprehensive security audit or 

highlight the “hotspots” or problem areas; 

Resident education: making residents aware of 

the consequences of non-compliance with 

condo rules can foster a cooperative 

community environment. Clear 

communication and reminders regarding the 

existing rules and, their legal obligations with 

respect to the condominium’s governing 

documents can help set expectations and 

reduce conflicts; 

Policy implementation: condominiums can 

implement complaint response and 

harassment policies in consultation with their 

property management service providers, 

legal counsel and other professional advisers. 

They can also consider policies and concepts 

that have worked in other condo communities; 

Conflict resolution skills: all community 

stakeholders ought to work on improving 

their conflict resolution skills and MV-P(sp) learning RD-R1(sp) For more information, see the website at https:// 

how to deescalate situations. This is MV-P(sp) 

MV-P(sp) 

advisable One Version 

RD-R1(sp) 

RD-R1(sp) 

lddclawyers.com. Ingrid Kulik, RCM, CMCP is a 

for managers and directors. One 

One 

Version 

Version condominium manager with Icon Property 

Management Ltd, based in the Greater Toronto Area. 

Luis A. Hernandez is a condominium lawyer with For more information, see the website at https:// 

Levitt Di Lella Duggan & Chaplick LLP in Toronto. iconpm.ca. 

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ONEROUS 

OVERSIGHT 

Toronto’s Short-term Rental Registry Stuck in Manual 

THE CITY OF TORONTO’S licensing 

department has been directed to improve 

data management for the short-term rental 

registry after a municipal audit found that 

about 10% of approved housing hosts may 

have overstepped the rules. Toronto 

Auditor General Tara Anderson also 

flagged challenges in determining 

whether municipal accommodations tax 

(MAT) has been accurately collected 

because details are missing from the 

information licensed short-term rental 

companies submit to Toronto’s revenue 

services department. 

She concludes that administrators’ 

heavy reliance on manual review processes 

hinders oversight of the approximately 

8,400 registrants currently approved to 

offer short-term rental accommodations in 

their principal residences. Her report and 

recommendations were adopted by Toronto 

Council in July. This follows after Council 

updated the municipal bylaw governing 

short-term rentals earlier this year in an 

effort to make it easier to enforce. 

“Challenges persist due to ongoing 

non-compliance and difficulties in 

enforcement, alongside limited resources, 

outdated techniques in data analysis and 

highly manual, labour-intensive internal 

processes,” the audit report observes. “It is 

essential to implement efficient and 

effective monitoring of the short-term 

rental operators’ adherence to the 

regulations to ensure the goals of the bylaw 

are being achieved as intended.” 

Under Toronto’s rules, homeowners and 

tenants can rent out up to three bedrooms 

within their principal residence for a 

maximum of 28 consecutive days and no 

more than 180 days total in a calendar year. 

To do so, they must be registered with the 

City and the registration number must be 

cited in cross-listings with any of the three 

companies — Airbnb, Booking.com and 

PodsLiving.com — that are licensed to 

facilitate short-term rentals in the city. 

In applying to join the registry, owners/ 

tenants must supply identification and 

information for an emergency contact or 

contacts who will be reachable 24/7. Auditors 

found that successful applicants generally 

received approval and a registration number 

within three weeks, but, on average, 

administrators took four months to render 

decisions on the roughly 16% of rejected 

applications during the 2021-2023 period 

due to the “additional investigation efforts” 

required. 

Approved registrants are required to 

pay an annual registration fee, remit 

municipal accommodations tax (MAT) 

equivalent to 6% of revenue earned from 

room rentals and make quarterly 

declarations to Toronto’s revenue services 

department even if they have no earnings 

for the period. Although Airbnb has 

committed to collect and convey MAT on 

behalf of registrants listed on its platform, 

which accounts for about 92% of tax 

collected from the registry thus far, 

housing hosts are still obliged to submit 

individual quarterly reports to the City. 

Audit data shows Toronto garnered 

roughly $20 million in MAT in the 42 

months from the launch of the registry 

in September 2020 to the end of 

February this year. An additional $3.7 

million was collected up to the end of 

2023 from registrations and a surcharge 

applied on nightly bookings through 


licensed short-term rental companies’ 

platforms. 

However, the recent update to the 

authorizing bylaw will increase the 

revenue from the latter fees. The annual 

registration fee for housing hosts will 

jump from $53.22 to $375 beginning in 

2025, while short-term rental facilitators 

are now levied $1.50 per nightly stay 

booked through their platforms — up 

from the previous charge of $1.06 prior to 

June 30 this year. 

AUTOMATION AND API RECOMMENDED 

The audit report acknowledges the many 

challenges that licensing staff faces in 

reviewing applications for the registry and 

underscores the impossibility of keeping 

track of every transaction for every night 

of stay, which numbered approximately 

2.4 million across all registered properties 

during the period scrutinized. 

As part of the bylaw update, City 

Council has already called for the 

development and implementation of an 

application programming interface (API) 

to enable better information exchange 

with the licensed short-term rental 

platforms. The audit report further 

recommends advanced analytics and 

automation to focus on six indicators of 

rules violation. 

The following are considered plausibleto-strong 

hints that short-term rental 

accommodations are not located in 

registrants’ principal residence: 

• exceeding the limit of 180 nights per year 

for rentals; 

• renting out more than three bedrooms per 

night; 

• owners with multiple short-term rental 

properties: 

• properties with legally approved 

secondary suites; 

• using the same registration number for 

multiple properties; and 

• relying on professional property 

management. 

These are all risks that human 

administrators are currently monitoring 

through intuitive, labour-intensive 

processes. 

“To pinpoint non-compliance, the 

MLS (municipal licensing and 

standards) compliance team primarily 

analyzes the transaction data for 

short-term rentals, focusing on past 

violations and active non-compliant 

listings. They target suspected 

operators, looking particularly for 

violations of the three-bedroom rule, 

by manually analyzing the transaction 

data,” the audit report advises. 

During the period covered in the 

review, the auditor found that:1,438 

housing hosts may have exceeded the 180- 

night limit; 545 may have exceeded the 

three-bedroom limit; and 170 may own 

more than one short-term rental property. 

Notably, 1,100 of the registered 

homeowners had a different mailing 

address for their property tax bill than that 

for the short-term rental accommodations. 

As well, there are concerns about pirated 

and non-compliant registration numbers 

showing up in listings on the short-term 

rental companies’ platforms, which are 

evident in a mismatch of information for 

advertised and registered properties 

bearing the same number. 

Airbnb’s voluntary agreement to collect 

and remit MAT on behalf of registered 

housing hosts who are listed with the 

platform is described as “beneficial” for 

the City of Toronto. 

“It improves compliance, simplifies tax 

deduction at the source, streamlines collection, 

reduces reliance on remittance by 

operators and reduces the administrative 

burden on City staff,” the audit report 

maintains. 

Nevertheless, the auditor calls for more 

transaction details from both Airbnb and 

the smaller number of housing hosts who 

collect and submit MAT themselves. The 

latter group is simply required to remit a 

lump sum and declare the number of 

nights of rentals it represents. 

Airbnb does submit transaction data 

separately to the licensing department, but 

this typically chronicles patrons’ check-in 

and check-out dates rather than when 

payment was received. 

“Without additional transaction details 

accompanying remittances, reconciling or 

verifying the accuracy and completeness 

of Airbnb’s MAT remittances is 

challenging,” the audit report states. 

“Operators who remit the tax themselves 

are not required to provide transaction 

details. This results in the City relying on 

an honour system, expecting operators to 

collect and remit the correct amount of 

MAT.” 

It’s recommended that Toronto’s 

revenue services department establish a 

quarterly reconciliation process to 

compare MAT remittances from more 

detailed transaction data that Airbnb and 

other short-term rental facilitators would 

be required to provide. Random “sampling 

and comparing” procedures are also 

proposed for housing hosts. 

datamanagement 

VERIFYING CONSENT 

Among key concerns for landlords and 

condominium corporations, the audit 

report calls for more vigilance to ensure 

renters have the unit owner’s consent, and 

that offered condo units are not located in 

buildings where short-term rentals are 

prohibited. The City currently does not 

require proof that tenants have permission 

to rent out short-term accommodations in 

their units, but there is an expectation that 

they do and that they will also abide by 

Ontario’s Residential Tenancies Act when 

they effectively become landlords. 

The audit report cites examples of other 

cities, including Ottawa, Vancouver and 

New York, that directly inform property 

owners when tenants apply to register 

units for short-term rentals or require 

tenants to submit written consent from 

their landlords with their applications — 

and suggests a similar policy could better 

protect Toronto against liability. As of 

January 2024, three lawsuits had been 

registered against the City for neglecting 

to confirm a tenant had the landlord’s 

permission. 

“The City needs to clarify the roles and 

responsibilities regarding landlord-tenant 

matters of all involved parties and 

consider adopting risk-based sampling 

procedures in the future for verifying 

landlord consent for short-term rental 

registrations,” the audit report states. 

Meanwhile, the auditing team 

sampled the 20 downtown condo 

buildings that sport the highest 

concentration of registered short-term 

rental units (collectively amounting to 

1,459 units). That exercise uncovered 

42 registered units in a building that 

prohibits short-term rentals along 

with 41 scenarios where renter 

occupants had registered a unit even 

though condo rules restricted shortterm 

rental hosting to owners only. 

Toronto’s licensing department does 

keep a list of condominiums that have 

rules restricting or prohibiting shortterm 

rentals, which numbered 145 

buildings when the audit was 

conducted in January 2024. However, 

the report suggests more proactive 

monitoring could be employed at the 

application stage, rather than drawing 

on the information to revoke 

registrations at a later time. 

The Toronto Auditor General’s report and 

recommendations can be found at www. 

toronto.ca/legdocs/mmis/2024/au/bgrd/ 

backgroundfile-247092.pdf 


diligence 

TRACKING 

TRANSACTIONS 

Canada Bolsters Guard Against Money Laundering 

TITLE INSURERS, real estate brokers 

and sales representatives will have new 

obligations to guard against money 

laundering and terrorist financing under 

proposed federal regulations. The 

intended measures were first announced 

in the Canadian government’s 2023 fall 

economic statement and were posted for 

public review earlier this summer. 

As proposed, title insurers would be added 

to the roster of entities mandated to report to 

Canada’s financial transactions and reports 

analysis centre (FINTRAC), which entails 

vigilance and record-keeping around 

potentially irregular transactions and the 

parties to them. As well, the current directive 

that real estate representatives take 

“reasonable measures” to ascertain the 

identity of unrepresented and third parties to 

a transaction would be formalized into 

required documentation. 

The accompanying regulatory analysis 

notes that both stakeholder title insurers and 

the Canadian Real Estate Association 

(CREA) opposed the proposed measures 

when they were floated in a consultation 

paper the government released in 2023. 

However, it advises that those concerns have 

been taken into consideration in the draft 

regulations, particularly in provisions for 

accredited third parties to conduct identity 

verifications and “flexibility” for recordkeeping. 

In joining the ranks of entities reporting to 

FINTRAC under the auspices of Canada’s 

Proceeds of Crime (Money Laundering) 

and Terrorist Financing Act (PCMLTFA), 

title insurers would be expected to obtain, 

verify and keep information about property 

purchasers and other details related to the 

deal. 

The latter includes the source of funds for 

the purchase, and names and addresses of 

lenders, real estate representatives and/or 

individuals holding liens on the property. If 

the purchaser is a corporation, there is an 

obligation to verify the identity of all directors 

and beneficial owners, who are defined as 

individuals who directly or indirectly own or 

control at least 25% of the corporation’s 

shares. 

Many potential parties to real estate 

transactions, including brokers, sales 

representatives, lenders and mortgage 

administrators are already required to 

report to FINTRAC. The regulatory 

analysis frames the inclusion of title 

insurers as another layer of vigilance 

“which would be used by FINTRAC and 

disclosed to law enforcement to help 

detect and disrupt illicit activities in the 

real estate sector”. 

Currently, real estate brokers and sales 

representatives are required to keep 

information records about the individuals 

and entities for whom/which they act as an 

agent in transactions. The proposed 

regulation expands that requirement to 

include “any party to the purchase or sale 

that is not represented by a real estate broker 

or sales representative”. 

That’s part of the package of existing 

obligations under the PCMLTFA, which 

also requires them to keep a receipt of funds 

received when acting on behalf of a vendor, 

and to keep information related to 

transactions that involve more than $10,000 

in cash or virtual currency payments. 

“This change would help identify suspicious 

behaviour when agents cannot identify 

unrepresented parties in transactions, which 

could lead to more suspicious transaction 

reports to FINTRAC,” the regulatory analysis 

states. “Based on this information, FINTRAC 

would be better equipped to identify potential 

money laundering and terrorist financing 

activities in the real estate sector and disclose 

that information and analysis to law enforcement 

officers.” 

In addition to the real estate measures, the 

proposed regulations also address: properties 

subject to national/international sanctions; 

money services businesses such as those 

dealing in foreign exchange, money orders or 

virtual currency; privately owned and 

operated cash machines, known as whitelabel 

ATMs; and reporting on casino payouts. 

Collectively, they are all intended to reinforce 

Canada’s commitment to the international 

financial action task force (FATF). 

It’s proposed that the new requirement for 

real estate brokers and sales representatives 

would go into effect as soon as the regulation 

is finalized and officially filed. Title insurers 

would have until October 1, 2025 to begin 

reporting to FINTRAC, in recognition of the 

need to get new procedures in place. 

“It will also provide FINTRAC with 

sufficient time to update and issue guidance 

and best practices regarding how reporting 

entities should meet their obligations, 

undertake outreach activities, and work with 

industry to establish typologies that can help 

new reporting entities gain a better 

understanding of relevant money laundering 

and terrorist financing risks,” the regulatory 

analysis states.

Canadian Property Management - Fall 2024

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