In the Name of Housing Affordability

 

By Hal Jaeger

Affordable housing is a pressing concern in Kitchener, the region, across the province, and throughout Canada.   The problem predates the pandemic and the subsequent rise in inflation and interest rates.  In response, the Province assembled the Housing Affordability Task Force in December 2021 and followed it up with Bills 109, 23 and 97.

The Province implemented one of the Task Force’s recommendations that received support from affordable housing advocates.  It ended exclusionary zoning – the practice of limiting a lot to one single family dwelling.  But the Province also instituted and continues to propose a host of contentious measures on the basis of three principal arguments:

a)      a lack of developable land is constraining the supply and driving up the cost of housing;

b)     delays in municipal and regional processing of development applications are impeding the supply and driving up the cost of housing; and

c)      by reducing costs to developers, the cost of housing can be reduced to the ultimate occupants.

To address the perceived lack of developable land, the Province expanded the powers of the Minister of Municipal Affairs and Housing to overrule local planning decisions and disregard provincial policy and Official Plans, released lands from the Greenbelt, removed protections for endangered species and their natural habitats, rolled back heritage protections and the powers of Conservation Authorities, and removed prohibitions on building on floodplains.  In April 2023, the Province over-ruled additional locally-determined Regional Official Plans -- including the Region of Waterloo’s -- to permit development on more farmland and natural areas.  The Province now proposes, via Bill 97, to eliminate policies requiring municipalities to be efficient and environmentally sensitive in their growth planning and to demonstrate that they are unable to accommodate growth via intensification before expanding outwards.  Many argue that these measures encourage sprawl, a pattern of development that undermines affordable housing.

To reduce the time of processing development applications, the Province increased appeal application fees; eliminated regional planning authorities, opportunities for appeals of decisions, and the capacity of Conservation Authorities to comment on planning applications; and concentrated the powers of municipal and regional councillors into the hands of mayors and the Minister of Municipal Affairs and Housing.

To reduce costs to developers, the Province set a lower cap on Parkland Dedication Fees, Development Charges, and Community Benefit charges, and limited the extent of Green Development Standards, Inclusionary Zoning, and rental replacement requirements that municipalities may implement.  Many argue that these measures both directly and indirectly make housing less affordable.

These changes amount to cuts to local lawful democracy; checks on government inefficiency, fraud, and abuse of power; environmental protection; public safety; quality of life; access to justice; reconciliation with First Nations, and even housing affordability.  The Province claims the cuts are necessary sacrifices in the name of addressing the affordable housing crisis.

But the premises underlying the Province’s policies are false.  And the responses to the false premises do not make housing more affordable.  Furthermore, the costs of the unwarranted sacrifices are unacceptably high.

A quick refutation of the Province’s principal arguments:

a)      There is no lack of land available for development.  Registered Professional Planner and former Region of Waterloo Director of Community Planning Kevin Eby reports that, in 2022, municipalities in the Greater Golden Horseshoe already had sufficient land for twice as many housing units as the Province requires under Bill 23.  Even The Housing Affordability Task Force noted that there was already sufficient developable land available.

b)     Municipal and Regional processing time is not constraining supply.  The Regional Planning Commissioners of Ontario reports that over 1,250,000 housing units were approved and proposed to be built prior to Provincial Bill 23.

c)      Decreasing the costs to the for-profit development industry will not necessarily lead to decreased costs to the ultimate occupants.   The industry charges the maximum rents and sale prices the market will bear.  It is increasingly oligopolistic and wary of releasing new units that could undercut current pricing.   And, even if initial investors are able to save on their purchases, the savings do not necessarily flow to the ultimate occupants.

Those concerned with housing affordability are not surprised.  The Province garnered general support by speaking to “affordable housing” before re-focusing on “housing supply”.  The Province’s appointed Housing Affordability Task Force stated that affordable housing – which they defined as below market rate housing -- was not part of their mandate.   The Provincial Planning Statement, which the Province now proposes in lieu of the Provincial Policy Statement, strips away the definition of -- and all references to -- “affordable housing”.

To truly address housing affordability, we need to align housing with the population and its needs.  And we must refuse the dichotomy of affordable housing versus environmental protections, local accountable government, access to justice, public safety, quality of life and reconciliation with First Nations.

We, the public, can help by commenting on Bill 97 and the proposed new Provincial Policy Statement via the Environmental Registry of Ontario and continuing to convey our perspectives to our MPPs and the provincial government.  At the same time, we can support affordable housing measures at a municipal level.

MPP contact information and further details at Information About Proposed Bill 97 and Information About Bill 23.