Over the last year a group of anti-poverty activists, homelessness and social housing advocates, equity and human rights groups, non-profit housing organizations, tenants with lived experience of poverty have come together to form the Housing Network of Ontario ((HNO).
At a founding gathering in May 2009 over 100 people from these constituencies across Ontario came together to focus their efforts on ensuring that the provincial government delivers an integrated, fully-funded and equitably accessible Long-Term Affordable Housing Strategy (LTAHS) needed by communities throughout the province.
At the same founding meeting a declaration was formally endorsed that noted:
We believe everyone in Ontario has the right to live poverty-free with dignity in housing that is stable, adequate, equitably accessible and affordable
The document also noted a number of priorities that Ontario‟s affordable housing strategy should address including:
The full declaration, which has been endorsed by over 140 organizations across Ontario.
The Housing Network welcomes the opportunity to submit our suggestions to the Province on the Long-Term Affordable Housing Strategy. We view this commitment to develop a ten-year strategy as offering an historic opportunity to replace a patchwork of on-again, off-again housing programs. We expect that the Strategy will provide a vision for affordable housing in this province and a blueprint for achieving it.
The HNO also finds it is commendable that the Minister of Municipal Affairs and Housing, the Honourable Jim Watson took the time and made the effort to travel throughout Ontario, holding 13 regional consultations, to gain valuable public input on the development of the Strategy. A great many members of the Network took advantage of these sessions and welcomed the opportunity to offer their input to the Minister concerning the long-term housing plan.
In addition to the official regional consultation meetings, a number of MPPs held their own sessions in their communities to receive local input on the Affordable Housing Strategy. The Housing Network of Ontario was pleased to receive reports from 30 meetings from HNO members and community contacts who participated in these various consultations.
In many ways this submission is informed by those people who took the time to attend a session and offer their suggestions, expertise and insights as Ontario ponders what should be in the housing strategy.
In this submission we review and make recommendations on what we consider to be the key areas that the Province should address in the LTAHS. These elements include:
The starting point for development of a Long-Term Affordable Housing Strategy must be an agreed-upon vision with guiding principles and clear goals to achieve it. Everything else follows from this.
The Province has set out in its Strategy consultation paper a core commitment to building strong communities and partnerships. The HNO believes this provides a good starting point to guide work on the Strategy. The Housing Network found that three overarching themes emerged from the community meetings and consultations that should underscore the work on the emerging housing strategy:
Long-Term approach required
These three overarching themes form the backdrop to our submission on what needs to be included in Ontario‟s LTAHS. In particular the Province must pay serious attention to the long-term nature that the strategy is intended to map out.
This point cannot be overemphasized. Since the mid-1990s, a fundamental problem that has led to the current housing crisis in Ontario and elsewhere, particularly in urban centres, has been the lack of continuing housing programs that have as their purpose the systematic reduction of housing need.
Instead, housing policy has taken an on-again, off-again approach that has offered no certainty at all as to governments‟ long-term intentions for housing. The Federal/Provincial Affordable Housing Program (AHP) which was launched in the fall of 2001 has always been seen more as a stop-gap measure rather than a long-term vision for housing policy by our senior levels of government.
This will have to change if Ontario is serious about its commitment to a long-term strategy. What will be required is a sustainable approach to addressing affordable housing needs in this province – Queen‟s Park has to signal that it is in for keeps.
Housing must be seen as a core government program
Affordable housing must be considered a core community need and therefore a central government program like health and education. It is hard to imagine either of these being treated to the stop-start approach hitherto applied to housing. The housing program needs to be funded each year in the provincial budget. This fundamental principle must be central to a comprehensive strategy.
Recommendations:
Cornerstone of poverty reduction
It is important to grasp the scope of the Province‟s housing need challenge. According to housing data from the 2006 Census, 14.5 percent of households in Ontario fall into what is called core housing need. The Ontario rate is higher than the all-Canada rate of 12.7%. It means that, by the federal government‟s own measurement, more than one in seven households in the province is unable to afford adequate, suitable shelter – nearly 630,000 households in all.
Clearly then Ontario has a significant affordable housing gap, and one that exceeds national averages. It is hard to see how such a situation is remotely acceptable in a place as relatively advantaged as the province of Ontario. Yet the problem is a chronic one and seemingly regarded as too big to solve. The Housing Network of Ontario disagrees fundamentally with that position.
One can debate whether Ontarians are in housing need because they are poor, or poor because they are paying too much for their housing, but it would be beside the point, which is that the shortage of affordable housing is a significant contributor to poverty in Ontario. Affordable housing is a public good, a valuable long-term asset that supports healthy, stronger communities.
Strengthen the economy
Unlike some other jurisdictions which have come to realize that in the globalization era, housing and economic efficiency are inextricably linked, Canada has tended to regard housing affordability and core need reduction as dimensions of a purely social problem. This view has caused policy makers to look at the cost of addressing housing affordability out of context, as they overlook the cost to our economy of failing to act on housing need. The lack of housing that the workforce can afford is a pivotal roadblock to growth and investment in our province.
Affordable housing is about more than helping people. It‟s tightly connected to the economy.
A holistic approach to housing policy is essential if we are to get it right and move away from the “silo” thinking which consigns housing to a policy realm unconnected with general productivity and prosperity. Housing helps people participate in the economy; solutions to poverty and economic problems will help provide people with the means to access housing.
Meanwhile, the realities of the current Ontario economy present an ideal opportunity to act now on affordable housing development. Given the current economic downturn in the province, it is well documented that the construction of new affordable housing and rehabilitation of existing stock provide significant economic stimulus, create jobs, use locally produced materials and provide a valuable public asset for the long term. Building affordable housing must be seen as a fundamental building block in Ontario‟s economic recovery.
Need is great
Taking into consideration many factors over the ten-year period from 2009 to 2019, demand for rental housing in Ontario is forecast to be in the range of 10,000 to 12,000 additional units annually. Rental production in the late 1980s and early 1990s averaged more than 14,000 units per year. However, with the lack of significant senior government participation, this figure has declined to average just over 2,000 units per year since 1995.
Solution will not be found in private market
It is tempting, for some at least, to look to the private market for solutions to housing shortages. This was certainly the hope of the Ontario government in the second half of the 1990s. It came to nothing, because private market rental development isn‟t the answer. The financial realities of residential construction are that developers can‟t deliver new rental housing at rents people can afford to pay. That‟s not a political point of view; it‟s simply the reality of real estate economics. Clearly, there is no substitute for government intervention if the shortage of affordable housing is to be addressed.
Low-cost measures to boost supply
There are also some significant and effective steps the Province can take to boost the supply of affordable housing in Ontario without adding significant cost to government. A couple of vehicles are set out below.
Inclusionary zoning
The Province, under its planning authority, can mandate a municipal zoning approval process that requires developers to make a percentage of housing units in new developments available at below-market rents or price. In return, the developer receives a “density bonus”, permitting a higher density of housing units than would ordinarily be permitted under zoning restrictions.
While inclusionary housing policies are set by local governments it is very much up to the Province to ensure that these municipal approaches can be enforced and are not subject to endless challenges at the Ontario Municipal Board. The Province should ensure that municipalities have the authority to establish inclusionary zoning practices.
Make government land available
Ontario has lands of its own that are surplus to its needs and should follow through on earlier commitments to facilitate the development of affordable housing on provincial lands that are available. There are three levels of support: 1) Priority access for affordable housing development: 2) preferential terms and financing: 3) below market or contributed land. Capital costs are clearly going to be lower if land is available with preferred terms or without charge, with the resulting effect, as with inclusionary zoning, that housing costs will be lower. This has potential implications for the level of capital grant required (if any) and certainly for the costs of bridging the gap between economic rent and an RGI rent level.
Recommendations:
The issue of affordability is both a large and persistent housing problem. Shelter costs constitute the largest regular expense for most households. The Province‟s recent Poverty Reduction Strategy (PRS) acknowledged that housing is a core contributor to exacerbating poverty issues. Excessive housing costs simply crowd out other necessities for many low-income Ontarians. Decent, adequate and appropriate housing is unaffordable for many Ontarians. Measures must be adopted to close the gap between housing costs and low incomes.
The average rent for a two-bedroom apartment in Ontario has risen to $948/month. In most urban areas in the province it is well over $1,000/month. One in five tenants spends over 50% of their income on housing. The average MLS home sale in Ontario is $320,000. Social assistance rates are very low and are inadequate to pay for rent and living expenses in most communities.
If a new Long-Term Affordable Housing Strategy is to be effective, new housing supply must penetrate down to levels of true affordability for low-income households. The Affordable Housing Program has not achieved this. Some units are rented at a below-market rate but rents are not adjusted based on income and the very neediest households can‟t afford to live in this housing.
Approximately only 6% of Ontario households are able to access Rent-Geared-to Income (RGI) housing subsidies, yet close to half of all renters in the province are paying more than 30% of their income on housing. There is currently little in the way of housing assistance for the working poor. Lengthy waiting lists and subordination to priority need often preclude access to the many Ontarians who are desperate to find a home that they can afford.
Recommendations:
One of the guiding principles that the Province has identified in its consultation materials for the Strategy is that a “people-centred” approach should be taken. The description of the principle notes that “Programs, services and supports will be responsive to need and focus on positive results for individuals and families.” The Housing Network of Ontario agrees. All too often unfortunately, low-income households are left out of decisions about programs, do not have choices in housing, and in some cases are not shown a great deal of respect by some landlords or social housing providers.
People who have experienced homelessness or inadequate housing are the experts in what is needed in a housing strategy. People living in poverty, who need or have accessed affordable housing, should be consulted throughout the development of the strategy, and be involved in the evaluation of its implementation.
The Province should also ensure that a “people-centred” focus is taken up in making a renewed commitment to a community-based approach to developing and operating affordable housing. Such a commitment would be consistent with the priority the government has given to improving the social, health and education systems in Ontario.
In Ontario, there has been a clear erosion of this model in recent years. There has been a shift of power and control from communities to government and more and more of the housing being developed is owned and run by municipal governments. This is at odds with a broad-based international trend away from top-down housing models and towards giving people real influence over the decisions that shape their lives, including decisions about their housing. No group is more affected by this inability to have some semblance of control of their own environment than Ontario‟s marginalized communities.
Marginalized Communities
Members of marginalized groups, including Aboriginal people, communities of colour, people with disabilities or mental health issues, single mothers, members of the lesbian/gay/bisexual/transgendered and queer communities, youth and others face discrimination by landlords when trying to access or maintain housing. Members of historically disadvantaged groups face disproportionately higher rates of poverty, and related housing insecurity. Almost 25% of Aboriginal households living off-reserve live in core-housing need. In Toronto, 60% of poor families are from racialized groups and 39% of recent immigrants live in poverty.
As was reported in the recent Ontario Human Rights Commission policy report on rental housing, this often takes the form of being told that an apartment is rented when it is not, or being asked for illegal deposits, among other discriminatory practices
Supports and Programs
There is a lack of supportive housing. Some people, including individuals with mental health issues, addictions, and disabilities need supports to maintain their housing. For example, over one-third of homeless individuals have a severe mental illness.
Many individuals and households need supports to fairly and equitably access and maintain affordable housing, including supportive housing, eviction prevention and housing retention programs. Tenants face eviction when they face short-term financial hardship, which can lead to homelessness. In 2008, a record 57,148 tenant households in Ontario faced eviction for non-payment of rent. In Toronto, it is estimated that one-third of people that are evicted end up in shelters.
Discharge plans from institutions such as correctional facilities, hospitals, mental health institutions, women‟s shelters and others must include connections to affordable housing and supports, including income and health-related support programs.
A mix of affordable housing needs to be produced
One of the objectives of the Strategy should be to ensure that a mix of affordable housing is produced. This includes supportive housing, municipal and private non-profit housing, co-operative housing, affordable private rental housing, and affordable home ownership.
Unfortunately, the existing AHP program is oriented towards private sector developers or municipal governments who can contribute equity and have the capacity to put together and cash flow development proposals in a way that no community-based sponsor can compete with. This has resulted to a great extent in small-scale community-based housing proponents, such as housing co-operatives, being largely shut out of the program.
Not only is there no mix of housing being developed to give tenants more choice, the permanent affordability features of the non-profit and co-operative housing models are being lost. Part of the mix should also feature government assistance options for low and modest income households to access affordable home ownership, which could assist many families break the cycle of poverty.
Recommendations:
A key area that must play a significant role in the Province‟s Long-Term Affordable Housing Strategy is legislative reform. Two particular pieces of legislation that need a thorough review are the Social Housing Reform Act (SHRA) and the Residential Tenancies Act (RTA). These Acts that govern the social and private market housing worlds, need to be reformed to better protect tenants and provide flexibility for non-profit and co-operative housing providers.
Social Housing Reform Act
The Social Housing Reform Act (SHRA) was brought in by the previous Conservative government at Queen‟s Park. The legislation approved the download of Ontario‟s social housing stock to 47 municipal governments. The SHRA also ripped up existing contracts that housing providers had with the provincial government and set in legislation a heavily rule-bound and administratively complex housing program. The regime set out in the Act and its accompanying regulations go well beyond any previous social housing program in their prescriptive nature. The SHRA details how housing providers must operate – with oversight then focused on whether the mandated processes are being followed, rather than are any worthwhile overall objectives being achieved.
This oversight and level of detailed rules undermines the ability of housing providers to make basic, day-to-day management decisions about how best to run their housing. Such rules interfere needlessly with control of their housing by community boards of directors. It is also worth noting and important to remember that the complicated and punitive approach dealing with households receiving RGI assistance was imported directly from the previous government‟s Social Assistance Reform Act, legislation that has had a very negative impact on recipients of social assistance.
Residential Tenancies Act (RTA)
In 2006 the Province ushered in the Residential Tenancies Act replacing the Tenant Protection Act (TPA) of the previous government, as an attempt to restore a more balanced relationship between landlords and tenants. Unfortunately, a key component of the TPA, the issue of vacancy de-control, was left in place in the RTA. Landlords are still allowed to raise rents well beyond rent control guidelines once a unit becomes vacant. For many renters, this ability fuels a good deal of the lack of affordability we witness in most of Ontario‟s rental markets.
There are other gaps in the Residential Tenancies Act. Landlords in newer buildings are also exempt from existing rules about raising the rent. Some tenants in Sudbury have faced rent increases of upwards of 200%. Tenants living in social housing lack the right to an independent review or appeal of decisions to deny or revoke a rent subsidy.
There is a lack of education about tenant rights, and a lack of enforcement of Landlord and Tenant Board (LTB) decisions made against landlords about repair and other issues. Landlords in a number of communities have been ordered by the Landlord and Tenant Board to repair their buildings, but often do not comply with the orders and seem to be not penalized for this non-compliance.
Recommendations:
Ontario is a large province with very diverse regions and housing markets. Accordingly the province requires a strategy that is responsive and flexible. The housing needs of people living in the City of Toronto and the growing GTA regions are much different than, for example, small cities, rural towns and Northern communities.
Provincial housing investments under the Affordable Housing Program (AHP) over the last number of years have been largely simply responding to federal cost sharing requirements. This has resulted in poorly defined and overlapping government roles. The strategy must include co-operation between different Ministries and levels of government in order to succeed.
Given that every level of government is now involved in the AHP program it is very confusing as to which jurisdiction is responsible for what. Many layer on their own additional requirements. As well the current design of the AHP reflects each government‟s instinct to minimize risk and shift it to another party, particularly the proponents of the affordable housing projects. Senior levels of government are not doing enough to ensure non-profits and co-ops receive funding when needed, thereby passing the risk on to the party with the least resources.
Further, policy responses tend to remain in “silos”, and the interconnections between health, social services, and housing policies and programs are fragmented and often contradictory. For example, the Ministry of Municipal Affairs and Housing may provide funding for the building of supportive housing, but the Ministry of Health provides funding for supports, and combining the two programs is challenging for many housing proponents. Hopefully this overall lack of vision is something the Long-Term Affordable Housing Strategy will address.
Leveraging federal participation
The federal government has been active in the funding and financing of housing programs for 60 years. Although it no longer delivers development programs directly, Ottawa has continued to support affordable housing throughout the present decade in partnership with the provinces and territories, principally by means of the Affordable Housing Initiative (AHI), the Homelessness Partnering Strategy (HPS) and the Residential Rehabilitation Assistance Program (RRAP). AHI, HPS and RRAP, all of which feature valuable capital grants, were renewed by Ottawa in September 2008 for five years, with program redesigns scheduled for the third year.
Ontario therefore has a very timely opportunity to influence the look of the reworked federal programs in conjunction with the development of its long-term strategy, and ensure the continuity of the grant features of the programs.
Recommendations:
An important component of the Affordable Housing Strategy must be the preservation of the existing affordable housing stock, both in the social housing and private rental sectors, for generations to come.
Social housing stock
The long-term viability of much of Ontario's social housing stock administered by municipalities is at serious risk. Many of the housing units are 30 to 50 years old and require major capital investment. A series of studies has found that the capital reserves of these properties are seriously under-funded.
The Social Housing Renovation and Retrofit Program (SHRRP), introduced in the 2009 provincial budget, provides for $1.2 billion in combined federal and provincial funding for the renovation and retrofitting of the social housing stock over two years. This funding is both welcome and extremely significant. However, as valuable as the SHRRP program is, it provides one-time funding and will still not come near to making up the funding shortfall or providing a long-term solution.
Additional measures are urgently needed to deal with this long-term liability. One significant step the Province could take with little cost to the provincial treasury would be to change program rules to allow co-ops and non-profits to borrow additional funds against their equity for capital repairs.
Private rental sector
Many landlords do not maintain their buildings and ignore tenant complaints about poor and dangerous living conditions. Tenants in many communities are very frustrated with a lack of enforcement of bylaws around health & safety conditions in both the social housing and private rental universe. They report poor and dangerous conditions where some landlords or social housing providers may not be maintaining or repairing apartments. Many tenants voiced this concern at the public consultation meetings conducted by Minister Watson around the province.
Recommendations:
We need a range of indicators to measure progress on reducing and eliminating housing insecurity. Some specific examples of housing indicators that could measure progress and should be considered include:
Many programs which aimed in the past to help low-income people did not benefit certain equity- seeking communities such as Aboriginal People, people of colour, immigrants and refugees, lone mothers, people with disabilities.
Recommendations:
In this submission we have set out the key elements we believe the Province should include in its strategy to address Ontario‟s long-term housing needs. Feedback from almost 40 community consultation meetings across the province confirm that Ontarians are calling for leadership from Queen‟s Park for a comprehensive Long-Term Affordable Housing Strategy driven by a bold vision and supported by ongoing investment.
Some of the key planks that the Strategy should include are the following:
Minister Watson has made it clear during the public consultations that he held across the province that he is anxious to work with all partners to find answers to Ontario‟s affordable housing problems and put a sustainable long-term strategy in place.
The Housing Network of Ontario is a willing and able participant. We look forward to working with the Province and all stakeholders in ushering in a new era over the next decade, where all Ontarians are proud to have a decent and affordable place that they can call home.