Not all Short Term Rentals should be classified as the same.  Requiring a new licensing or charging a new 4% MAT tax is not appropriate for each business. 

There needs to be exemptions either across the board, or via application.  Whether only one or all

1. Explicit Exemption / Separate Tier: Request that "Traditional, Owner-Occupied Bed and Breakfasts" be explicitly excluded from the final definition of a Short-Term Rental Accommodation (STRA), given a completely separate tiered class.

2. Double-Regulation: The 3 Bed & Breakfasts in Midland are already strictly bound by the rules of Midland's existing zoning by-law (on-site residency, room limits, and dedicated parking layouts), making additional annual STRA licensing inspections redundant and restrictive for a business that is already fully transparent.

3.  Hosted vs Ghosted:  Short Term Rentals that are hosted in house should not be classified the same as the self serve type rentals.  If the rental is where the owner lives/primary residence and is available during the rental to help the guests or to monitor their activity regarding bylaws they should be excluded from MAT and STR.  

4.  Administrative Burden vs. Scale:  Unlike commercial, un-hosted Airbnbs or large hotels, a traditional B&B or a rental operation run out of a principal residence, forcing them to track monthly room nights, handle quarterly municipal remittances, and manage the technicalities of charging HST on top of the MAT is a heavy burden for someone renting out a room or a few rooms in a home.  

5.  Ceiling on Revenue:  If under a certain threshold not required and if owner is present/available on location.  Homeowners should be able to rent out a room or two without having to get licensed or charge MAT.