Surveillance, Fences, and $5000 Fines

What Bylaw 25 Says About How the Region Treats Unhoused People

As you may have noticed in last week’s post, I’m looking for contributing authors to Citified to offer additional perspectives and information on issues with which I may not be as familiar. This week, we are fortunate to have a guest contributor share more details about the Region of Waterloo’s recent passing of Bylaw 25.

This week’s post comes to us from Jacara Droog who is a housing advocate, member of the Unsheltered Campaign, and is writing in solidarity with residents at 100 Victoria.

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Guest post by Jacara Droog

On April 23, 2025, Waterloo Regional Council passed PDL-LEG-25-017 (Bylaw 25), a sweeping, punitive policy that allows the Region to fine or forcibly remove unhoused people from 100 Victoria Street (100 Vic), the largest encampment in the region. While staff and councillors have described the approach as "human-centred and relational," the bylaw tells a different story of evasion, surveillance, and harm.

Before Bylaw 25 even passed, advocates witnessed Region-contracted security guards already enforcing it—telling residents they were in violation of a bylaw that did not yet exist, mapping tents, and warning people not to put up new ones. Since then, five industrial dumpsters and a mobile office trailer have been moved onto the site, without notifying residents. Ostensibly placed there solely for sanitation, the dumpsters now sit in the middle of the site, blocking space for new tents and attracting rats, just metres from where people live. To residents I’ve spoken with, it feels like the Region sees them as both “garbage” and disposable.

Housing advocates argue the bylaw itself is vague, carceral, and colonial. It prohibits basic survival: storing firewood, erecting tents, even moving tents and structures within the site without the Region’s permission. It allows “designated personnel” to call police at any time. It grants the Region the ability to fence off any unoccupied space at their discretion, prevent residents from relocating or newcomers from setting up without permission. Individuals could face fines of up to $5,000, which is more than many unhoused people on Ontario Works receive in an entire year. All of this is unfolding in a Region where more than 2,371 people are unhoused. Fewer than 60 shelter spaces exist for women and gender-diverse people. The Schwaben Club shelter, with 100 beds, closed in March. Shelters are at capacity daily. There is simply nowhere adequate or accessible for people to go.

Bylaw 25 violates the 2023 Ontario Superior Court ruling that barred the Region from removing encampment residents due to a lack of shelter space, accessible and low-barrier alternatives, and the violation of the Charter. It also undermines the National Housing Strategy Act, which affirms that housing is a human right in Canada. Further, it contradicts the Region’s own Plan to End Chronic Homelessness (PECH). The people who co-created that plan—including those with lived experience—were not consulted before this bylaw was introduced.

It also seems to fail the Region’s responsibilities under the Dish With One Spoon Wampum, a treaty that governs this land. It also contradicts the Truth and Reconciliation Commission's (TRC) 94 Calls to Action, such as addressing systemic inequities in housing access. Given that Indigenous people make up roughly 12% of the Region’s chronically unhoused population, this Bylaw will likely have disproportionate impacts. Criminalizing encampments appears antithetical to reconciliation efforts the Region claims to be committed to.

A Region-hired security vehicle now stationed directly at the entrance of 100 Vic, underscores the Region’s use of deterrence tactics. Its presence discourages mutual aid drop-offs, potentially slows down emergency response times, and escalates tension and fear on site. For residents, it’s another layer of intimidation and an ever-present reminder that they are being surveilled, policed, and pressured to leave.

If this were about health and safety, the Region would be focusing on the PECH recommendations, not spending $466,083 on temporary motel rooms, a contract set to expire by 2026. They’d be building relationships, not building fear. Bylaw 25 seems to be more about optics than solutions. It’s about clearing land and making unhoused people disappear in time for a new transit hub.

Residents at 100 Vic are not obstacles to progress, nor are they expendable. They are our neighbours. A transit hub cannot come at the expense of displacing people. If the Region is serious about ending chronic homelessness, it must begin by listening to people with lived experience and expertise, to housing advocates, to Indigenous leaders, and community members already showing up in solidarity. In the meantime, residents need protection, not punishment, and our community’s support and action.

If you’re reading this, I invite you to show up. Listen. Contact your regional councillors and tell them to repeal Bylaw 25. Sign the petition. Visit the encampment. Bring water, food, or other mutual aid resources. Because our collective liberation is inextricably linked, and what we build in this moment matters.

Be ready to learn and be honest with yourself about what you’re stepping into, because while this work can be deeply rewarding, it also asks a lot of us. At 100 Vic, you might encounter someone in crisis—someone who is grieving, having a mental health crisis, overdosed, or wounded. That is the reality of surviving without shelter or safety, and barriers to healthcare. Carry Naloxone/Narcan and learn how to use it. Know that someone may react unpredictably when revived—not out of ingratitude, but because they are human. Learn how to clean a wound or bandage a leg. Come with solidarity, not saviourism. Ask what’s needed. Shadow someone with experience. Reflect, regroup, and return only if it is right for you. Because no one can do everything, but all of us can do something. And right now, that something might mean bearing witness, building trust, or refusing to look away.

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Jacara notes that “This piece is grounded in firsthand observation, lived experience, and available public data as of May 2025. While shelter capacities and conditions may vary over time, the realities described reflect what many unhoused people in Waterloo Region are currently facing: a lack of safe, accessible, and adequate housing options. Statements are offered in good faith to inform and advocate, not to misrepresent.”

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A huge thank-you to Jacara for sharing this piece with us! You can read more on this issue with the following links:

• Ontario court rules Waterloo Region can’t evict homeless encampment due to lack of shelter space

• A Summary of the Waterloo Encampment Decision

• Legal clinic claims ambulance unable to access Kitchener encampment for medical call

• Region calls claim about delayed response to overdose at encampment ‘unfounded’

• Kitchener encampment needs to be cleared by Dec. 1 ahead of transit hub construction

• 'Where will they go?' Kitchener encampment residents react to region's plan to move them from current site

• Raised tracks and a new platform: What it will take to build Waterloo region's new transit hub?

• Bylaw passes to clear Kitchener encampment gradually with housing supports

• Region to clear Victoria Street encampment despite passionate opposition from delegates

• ‘They won’t disappear’: Residents of encampment react to new bylaw