How to Develop an Affordable Housing Sector in Ontario

Transcription

1 Building a stronger rental housing system ONPHA S RECOMMENDATIONS FOR THE UPDATE OF ONTARIO S LONG-TERM AFFORDABLE HOUSING STRATEGY

2 ONPHA IS THE VOICE OF NON-PROFIT HOUSING IN ONTARIO WHO WE ARE Our 740 housing member organizations manage more than 163,000 non-profit housing units in more than 220 communities in Ontario. They provide affordable homes to a diverse range of tenants, including: seniors; low-income families with children; Aboriginal people; the working poor; victims of violence and abuse; people living with developmental disabilities, mental illness, addictions, and HIV/AIDS; and the formerly homeless and hard-to-house. For more than 25 years, ONPHA has been an independent, member-funded and member directed association. Our member focus makes us a strong advocate for non-profit housing providers and the communities they serve. WHAT WE DO We unite Ontario s non-profit housing sector and provide non-profit housing providers with the knowledge and resources they need to conduct their business efficiently and ensure that their housing is well-managed, safe, and affordable. We do this through education, policy and research, management advice, networking opportunities, communications, and bulk procurement opportunities. We also work closely with all levels of government to promote sustainable, community-based affordable housing and to represent the interests of our members. WHY WE DO IT More than 400,000 people in Ontario rely on community-based affordable housing. Many need support to maintain their housing and live more independent lives. Studies prove that affordable housing is an essential determinant of health and a key contributor to the vitality of Ontario communities. We believe that all Ontarians need a secure place to call home at a cost they can afford. We know that good housing is the foundation for better lives and healthier communities. Our role is to strengthen this foundation.

3 TABLE OF CONTENTS INTRODUCTION MEETING ONTARIO S NEED FOR AFFORDABLE RENTAL HOUSING A STRONGER, MORE RESPONSIVE SOCIAL HOUSING SYSTEM BETTER OUTCOMES FOR SOCIAL HOUSING TENANTS CONCLUSION

4 INTRODUCTION An affordable home is the foundation of a successful household and affordable housing is the bedrock of prosperous communities. With the security of a safe, appropriate place to live, individuals, families, seniors and people who require support services are able to live healthier and more productive lives. But skyrocketing housing costs, tight rental markets and the growing prevalence of low-wage and precarious employment threaten Ontario s competitiveness and the health, stability and earning potential of its citizens. More than 20 per cent of Ontario renters have lived in homes that are too small for their families, too expensive or in poor repair for more than three years 1. ONPHA shares the provincial government s belief that all Ontarians should have the opportunity to realize their full potential and supports its commitment to alleviating poverty and creating new opportunities for vulnerable people. This commitment is foundational to the work our 740 housing provider members do with more than 400,000 households in 220 communities across the province. All levels of government must work together to improve access to affordable housing and to strengthen Ontario s social housing sector. In its renewal of the provincial Poverty Reduction Strategy, the government recognized the value and importance of investing in affordable housing. It also made an ambitious commitment to end homelessness in Ontario. We hope that the update of Long-Term Affordable Housing Strategy will provide the Province with a roadmap for increased, strategic investment in the housing needs of Ontarians and direct greater collaboration between stakeholders within the provincial government, as well as local health integration networks and municipal governments. The economic multiplier effects of infrastructure-driven housing investment will also help strengthen and stimulate the provincial economy. The affordable housing crisis facing Ontario is the culmination of more than 25 years of insufficient investment. In the absence of supportive tax policy and large-scale, government-funded housing development programs, neither the private nor the community sector have developed the volume of rental housing required to meet rising need 2. At the same time, Ontario has lost more than 86,000 units of purpose-built rental housing 3 and strong population growth and historically low interests rates have created thousands of condominium units and 1. ONPHA (2013). Where s home? 2013: Looking back and looking forward at the need for affordable housing in Ontario. onpha.on.ca/onpha/content/policyandresearch/other_research/wh2013.aspx 2. Ibid 4 Building a stronger rental housing system

5 driven-up housing costs 4. The cost of shelter is inducing or trapping growing numbers of Ontario households in poverty, squeezing out basics like food and warm clothing in the family budget. All levels of government must work together to improve access to affordable housing and to strengthen Ontario s social housing sector. The sector is a significant asset to the province, and must be recognized as such. While federal and municipal investment is necessary, as the order of government that stands to benefit most from the many psycho-social, health and economic benefits of a strong housing sector, it is incumbent upon the Province to take a leadership role in its renewal. This submission details ONPHA s ideas for improving the availability and delivery of social and affordable housing in Ontario. In preparing it, we consulted with member organizations from across the province who shared their challenges and successes with us and their ideas for improving the delivery of housing in their community. Our recommendations include: Meeting Ontario s need for affordable rental housing Make Provincial land and assets available through long-term leases or favourable sale prices to stimulate and support the development of affordable and social rental housing. Couple capital grants and favourable access to real estate assets together in future housing development programs to help proponents achieve greater affordability. Introduce a policy on the dissolution of Provincial real estate assets that considers how the asset could be used to achieve other Provincial and community priorities and not simply its monetary value. Work with the federal government to develop a program like the Build America Bonds program to encourage much-needed investment in infrastructure projects, including affordable housing. Ensure that affordable housing stays affordable for the long-term Require that housing developed with government investment remain affordable in the long-term and ensure compliance by registering a covenant on title. Review and strengthen the asset sale and liquidation and dissolution requirements in the Not-for-Profit Corporations Act, 2010 to ensure that past social housing investments remain a part of Ontario s rental housing system. Revise exemptions in the Residential Tenancies Act, 2006 to include former, federally-funded housing providers that no longer have operating agreements but are participating in new affordable housing programs. 3. Ibid 4. Ibid Ontario Non-Profit Housing Association 5

6 Strengthen the social housing sector Provide guaranteed, multi-year funding to allow service managers 5 and housing providers to strategically invest in cost- and asset-saving upgrades. Change rent setting practices to reduce administrative burdens for housing providers and service managers and deliver high levels of affordability to tenants. Standardize the treatment of Local Housing Corporations between service managers and ensure that new funding models consider the need for on-going capital investment and rising costs. Review the funding formulas contained in the Housing Services Act, 2011 to ensure that they reflect the actual and types of costs that social housing providers face. Create a Provincial credit backstop or loan guarantee to support the renewal of the social housing sector and the development of new housing. Lead work with the federal government and service managers to ensure that urban Aboriginal housing providers remain financially viable beyond the expiry of their operating agreements. Institute annual cost factor increases for Ministry of Community and Social Services-funded supportive housing providers and develop an approach to compensate housing providers for years of lost revenue and much needed capital repairs. Eliminate the ministerial consent requirements and give service managers discretion over the assets under their administration. Fund a five-year, $600,000 extension of ONPHA s Mentorship Program, which works with housing providers and service managers to build the capacity of at-risk organizations. A stronger, more responsive social housing system Ensure every housing provider has access to community development staff to engage tenants in their building s success and promote the health and well-being of all tenants. Create resource hubs to deliver better psycho-social support to tenants, which will also improve service provider efficiency and reduce costs. Work with the Landlord and Tenant Board to build adjudicators capacity and educate them on what social housing is and is not namely, housing of last resort. Develop a unique housing program to provide households eligible for Special Priority Policy designation with housing and other supports outside of the overburdened social housing wait list system. Clarify the duty to accommodate and undue hardship provisions of the Human Rights Code and help develop strategies that enable social housing providers to better meet current and emerging tenant needs. 5. Throughout this submission the term service managers refers to Consolidated Municipal Service Managers and District Social Services Administration Boards Throughout this submission the term service managers refers to Consolidated Municipal Service Managers and District Social Services Administration Boards 6 Building a stronger rental housing system

7 Better outcomes for social housing tenants Expand Ontario s supply of social and supportive housing to improve outcomes for applicants and tenants and allow the system to function more effectively. Develop programs that provide continuing, not temporary, supports services to help tenants meet their personal goals and the obligations of their lease. Clarify privacy legislation and to convene a working group to develop protocols and best practices for the sharing of tenants and applicants personal information. Promote greater collaboration between the province s housing, health and community sectors to achieve cost savings and better outcomes for people. A system based on evidence and best practices Clarify the Province s interests in the housing and homelessness system as a starting point for data collection. Create a provincial data collection strategy and housing measures for use by housing providers, service managers and transfer agencies. Fund longitudinal research to better understand the impact that government-assisted housing has on psycho-social health and well-being, labour market participation, educational achievement and community participation. Promote innovation by creating a dedicated program to fund pilot programs, demonstration projects and other forms of experimentation that may result in reduced costs, improved interand intra-organizational efficiency, and better outcomes for tenants and communities. Fund the development and operation of a research clearinghouse that would work directly with stakeholders to conduct Ontario-specific research and share research from other jurisdictions. Ontario Non-Profit Housing Association 7

8 MEETING ONTARIO S NEED FOR AFFORDABLE RENTAL HOUSING Meeting Ontarians need for affordable rental housing will require strong partnerships between governments and the private and social housing sectors. The diversity of Ontario s communities require a nuanced and flexible provincial policy and program environment that empowers Consolidated Municipal Service Managers and District Social Services Administration Boards ( service managers ) and communities to best respond to the needs around them. Governments must also ensure that their investment in affordable and social housing offers long-term benefits to communities and tenants. Leverage provincial assets to build housing Land and construction costs are the two largest expenses in new rental housing development. While recent federal-provincial programs, such as the Canada-Ontario Affordable Housing Program (AHP) and Investment in Affordable Housing Program (IAH) have included capital grant components, the level of funding available per unit and equity requirements did not create large quantities of new affordable rental housing 6. This was particularly evident in high-cost, high-growth areas, where land and construction costs are high and affordable rental housing is badly needed. We encourage the Province to leverage its land assets to support new affordable and social rental housing development. Relax fair market value requirements and account for social benefits Recommendation: Leverage Provincial land assets to support new affordable and social rental housing development. Currently, ministries are required to maximize fair market value for the sale or lease of real estate assets. We encourage the Province to review these requirements and to recognize the cost savings and community benefits that accompany access to affordable homes. By making housing-friendly assets, such as surplus schools 7, available at below market rates, the Province could stimulate rental housing development in many communities where the cost of land makes affordable or social rental housing development impossible. Recommendation: Make Provincial land and assets available through long-term leases or favourable sale prices to stimulate and support the development of affordable and social rental housing. 6. Between 2003 and August 2012, 14,449 units were developed using the AHP and IAH programs at an average rate of 1,500 units annually. From: ONPHA (2013). Where s home? 2013: Looking back and looking forward at the need for affordable housing in Ontario For example, Ontario Regulation 444/98 s. 1(3) requires boards of education to sell or lease real estate holdings at fair market value 8 Building a stronger rental housing system

9 Favourable sale or long-term lease rates may, themselves, provide the equity that developers need to achieve below-market rents in a given project. To achieve even deeper affordability the Province could, in future housing development programs, couple capital grants and favourable access to real estate assets to help the proponent achieve greater affordability for the project. The government s current accounting policy recognizes value of an asset only within the context of its disposition. It does not take into account any social return on investment or revenues (or cost avoidances) that could be derived from other uses, like affordable housing. We recommended that the Province introduce a more robust policy on the dissolution of real estate assets. Ideally, it would consider the how the asset could be used to achieve other provincial and community priorities and not simply its monetary value. Recommendation: Couple capital grants and favourable access to real estate assets to help the proponent achieve greater affordability for the project Recommendation: Work with the federal government to develop a Build America Bonds-like program to encourage much-needed investment in infrastructure projects, including affordable housing. Explore the creation of a Build Ontario Bonds program In the United States, the federal Build America Bonds program provided a partial subsidy to offset the interest cost that municipalities incurred through debt issued to finance capital infrastructure projects. The municipal bonds were issued at market rates, but the subsidy improved municipalities ability to repay loans used for infrastructure investment. This subsidy, along with minor tax credits for investors, helped the program attract private investment in municipal projects. In its 2015 Budget, the Province made clear that strategic infrastructure spending is a crucial part of Ontario s economic recovery and key to reducing unemployment. The Ontario Government has acknowledged that social housing, like roads, schools and bridges, is strategic infrastructure that creates jobs and grows the economy 8. We encourage the Province to work with the federal government to develop a similar program to encourage much-needed investment in infrastructure projects, including affordable housing. Ensure that affordable housing stays affordable for the long-term Legacy housing programs have provided affordable homes to generations of Ontarians. The housing developed under these programs has delivered a significant social return on investment to all levels of government and made smart use of tax dollars. Recent programs have included the use of other tools, such as rent supplements and housing allowances, and done more to engage the private sector in the development of affordable rental housing. The need for rental housing in Ontario is growing steadily. Between 2008 and 2014, nearly 40,000 households joined social housing waiting lists 9. Thirty-three per cent of all Ontario renter households were in Core Housing Need 10. A range of programmatic and policy tools that meet the unique needs of communities coupled with provincial and federal government investment must be used to build permanently affordable housing. 8. In the Infrastructure for Jobs and Prosperity Act, 2015, the Ontario government recognized social housing as infrastructure. 9. In 2008, 129,253 households were waiting for rent-geared-to-income-assisted housing in Ontario, a number that had grown by 39,458 in 2014 (for a total of 168,711). ONPHA (2015).2015 Waiting Lists Survey: ONPHA s report on waiting list statistics for Ontario ONPHA (2014). Big problems need bold solutions. BigProblemsNeedBoldSolutions.aspx Ontario Non-Profit Housing Association 9

10 Require permanent affordability for future government funding Recent housing programs have not required a long-term commitment to affordability. Past housing programs, which built Ontario s social housing sector, had either long-term or permanent affordability requirements. The AHP and IAH program guidelines, however, only required affordable housing commitments of 10 or 20 years 11. Recommendation: Require permanent affordability to ensure that government investment in affordable housing remains affordable in the long-term. Given the scarcity of housing investment and the growing demand for affordable and social rental housing, we believe the Province must take steps to ensure housing affordability. Continuing to develop affordable housing with time-limited affordability requirements, instead of permanent social housing, will only perpetuate the scarcity of affordable rental housing in Ontario. We recommend that all future housing development programs inculde permanent affordability requirements to ensure that government investment in affordable housing remains affordable in the long-term. Use covenants on title to keep housing affordable Currently, the Province requires that service managers register contribution agreements and loans on the title of projects in receipt of IAH funding over $25,000. While doing so helps ensure program compliance and protects public investment, it also has direct, negative consequences on social housing providers that are looking to borrow funds. Recommendation: Ensure program compliance and longterm affordability by registering a covenant on title for projects developed using government funding or built on Provincial land. Registering the funding as a loan on title changes the debt-to-income ratio of project owners and directly affects their capacity to borrow funds. This is particularly problematic for social housing providers that are already coping with a lean debt-to-income ratio. Another strategy for ensuring program compliance and long-term affordability is to register a covenant on title for projects developed using government funding or built on provincial land. In British Columbia, section 219 of the Land Title Act has been used to ensure that affordable rental housing built with government support remains affordable in perpetuity 12. Alternatively, the Province should implement other requirements for social housing providers that do not impede their ability to borrow funds. Social housing providers have mandates to provide affordable housing in their communities and their activities are closely monitored by service managers who, in turn, can enforce program compliance. Ensure housing investments remain in the housing system The growing demand for affordable rental and social housing and the high cost of new construction make the preservation of housing assets a priority. Generations of Ontarians have helped create the province s social housing stock and it is important that we not lose that investment. 11. In the iteration of the AHP program, proponents were required to keep their housing at or below 100% of average market rent. In the 2014 extension of the IAH program, proponents are required to keep rents at or below 80% of average market for a minimum of 20 years. 12. Section 219 covenants are binding on the covenantor and the covenantor s successors on title. Therefore, it can be enforced against successive owners. 10 Building a stronger rental housing system

11 The operating agreements of federally-funded social housing providers will soon expire. Those assets must be secured as affordable rental housing so as not to further erode the province s rental housing supply. We recommend a review and strengthening of the asset sale and liquidation and dissolution requirements in the Notfor-Profit Corporations Act, 2010 to ensure that past social housing investments remain a part of Ontario s rental housing system. Recommendation: Review and strengthen the asset sale and liquidation and dissolution requirements in the Not-for-Profit Corporations Act, 2010 to ensure that past social housing investments remain a part of Ontario s rental housing system. Extend RTA exemptions for housing providers that continue to operate affordable housing Section 7 of the Residential Tenancies Act, 2006 exempts social housing providers from several sections of the legislation related to tenancy administration, notice periods and rent. These exemptions facilitate the administration of government-assisted housing and the implementation of the Housing Services Act, 2011 (HSA). We encourage the Province to review and broaden the exemption to include former, federally-funded housing providers that no longer have operating agreements but that are participating in new affordable housing programs. Doing so will help to ensure that former federal housing projects remain connected to the sector and enable providers to continue to operate affordable housing in their community. Strengthen the social housing sector Ontario s social housing sector is a vital part of many communities. It is also aging and in need of renewal. ONPHA, our members and other stakeholders are working together to preserve the assets under the sector s administration and ownership, and to ensure that the organizations that deliver housing remain strong. But, government support remains vital to the sector s success. Grant programs for repair, energy efficiency and accessibility The majority of Ontario s social housing was built between 25 and 60 years ago. These projects now face a costly period of rehabilitation and renewal to in order to remain in good repair. Many social housing providers are struggling to afford necessary major capital repair and rehabilitation projects. At the same time, rising expenses, such as energy costs, are placing pressure on operating budgets, while aging Recommendation: Review and broaden RTA exemptions to include former federally-funded housing providers that no longer have operating agreements but are participating in new affordable housing programs. Recommendation: Provide guaranteed, multi-year funding to allow service managers and providers to strategically invest in cost- and asset-saving upgrades. tenant communities are placing accessibilityrelated demands on housing communities. As not-for-profit corporations, social housing providers lack the revenue needed to assume and repay debt, which makes it nearly impossible to borrow the funds for repairs and upgrades. They need federal and provincial partners. Ontario Non-Profit Housing Association 11

12 Grant programs like the Social Housing Renovation and Retrofit Program offer social housing providers the funding needed to help them offer safe, green and accessible housing. Removing time restrictions (i.e. use it or lose it measures) and providing guaranteed, multi-year funding would allow service managers and providers to strategically invest in cost- and asset-saving upgrades to their properties. Reimagine rent setting practices in social housing Ontario s rent-geared-to-income subsidy system is complex and administratively-burdensome but it delivers a level of assistance that many households require to remain safely and adequately housed. At the same time, the program s high cost limits its expansion at a time when waiting lists for RGI-assisted housing are growing and rental housing affordability is declining. Recommendation: Change rent setting practices and reduce administrative burdens for housing providers and service managers and continue to deliver high levels of affordability to tenants. ONPHA commissioned an analysis of the RGI subsidy system and rent setting practices to identify legislative, regulatory and policy changes that would reduce the administrative burden that housing providers and service managers experience while efficiently delivering high levels of affordability for tenants and social housing applicants. That in-depth analysis, A simpler, cheaper housing subsidy: Reimagining the delivery of housing assistance in Ontario, is included with this submission and is available ONPHA s website ( Other_Research/A_simpler_cheaper_housing_subsity.aspx). We encourage the Province to examine changes to rent setting practices that reduce administrative burdens for housing providers and service managers and continue to deliver high levels of affordability to tenants. Standardize funding for Local Housing Corporations The funding formulas prescribed in federal operating agreements and the HSA provide social housing providers with regular, predictable funding that enables them to cover costs and plan for the future. Local Housing Corporations (LHCs), which operate the majority of Ontario s social housing, are not treated similarly under the legislation. Recommendation: Standardize the treatment of LHCs and ensure that new funding models consider the need for on-going capital investment and rising costs. Service managers are required to provide LHCs with sufficient funding to maintain their housing in a satisfactory state of repair and fit for habitation 13. Without further direction, this has led to inconsistent treatment of LHCs between service manager areas, inhibiting their ability to plan for the future and maintain their assets. We encourage the Province to standardize the treatment of LHCs and ensure that new funding models consider the need for on-going capital investment and rising costs. Currently, many LHCs are vulnerable to local council priorities which may or may not provide them with the funding necessary to maintain units in good repair. In the absence of dependable funding, many LHCs are required to seek council funding annually to operate, which inhibits entrepreneurship and limits future planning. As owners and operators of millions of dollars in social housing assets, we believe the Province has an interest in ensuring that LHCs have the tools and stability they need to maintain and renew assets for the future. 13. Section 12(1) of Ontario Regulation 367/11 12 Building a stronger rental housing system

13 Review the funding formula to account for new costs The funding formula outlined in Part II and Part III of the HSA provides inflation-adjusted funding for several common expenses, including administration and maintainenance, insurance, utilities and capital reserve contributions. It accounts for the basic expenses of operating rental housing, but does not consider the unique needs of social housing providers and the tenants and communities they serve. Recommendation: Review the funding formulas contained in the HSA to ensure that they reflect the actual and types of costs that social housing providers face. The proportion of vulnerable households in Ontario s social housing is growing and, with it, the need to provide additional assistance and services to tenants. Tenants with excessive clutter and bed bugs are two common challenges that strain staff capacity and operating budgets. Our members also recognize a need to offer quality of life-enhancing programs and services to address the barriers and challenges created by poverty and social isolation. We recommend that the Province review the funding formulas contained in the HSA to ensure that they reflect the actual and types of costs that social housing providers face. Social housing providers are more than landlords and they are committed to meeting the needs of their tenants and communities. Communitybased programs and intensive support services where community-based agencies are unavailable must be considered among the tools that social housing providers require to deliver the type of housing and services that their tenants need. Provide guarantees to enable social housing providers to borrow Ontario s social housing sector is aging and in need of reinvestment and renewal. In the absence of governmentfunded capital programs, housing providers are looking for new ways to use their assets and partnerships with the private sector to fund renewal and development. Recommendation: Create a Provincial credit backstop or loan guarantee to support the renewal of the social housing sector and the development of new housing In the absence of a conventional debt-to-income ratio, access to private lending can be improved through the creation of a Provincial credit backstop or loan guarantee. The creation of such an instrument would enable the Province to support the renewal of the social housing sector and the development of new housing without providing funding directly. We believe that the Province must consider the creation of such instruments despite its concern about the potential impact on the Province s credit rating and borrowing costs. Wide-scale sector transformation and innovation is nearly impossible without direct or indirect financial investment by the government. Ontario Non-Profit Housing Association 13

14 Ensure the viability of urban Aboriginal housing providers Across Canada, Aboriginal people living in major urban areas are eight times more likely to experience homelessness than the general population 14. Urban Aboriginal households are more than twice as likely as non-aboriginal households to live in poverty, and 45 per cent of urban Aboriginal children grow up in low-income families 15. The challenges facing Canada s Aboriginal population are numerous, and a significant one is access to secure, affordable and culturally appropriate housing. Recommendation: Work with the federal government and service managers to develop a strategy for ensuring that urban Aboriginal housing providers remain financial viable beyond the expiry of their operating agreement. Ontario s urban Aboriginal housing providers offer unique, culturally appropriate housing and services to thousands of households 16. Their tenants depend on the deep subsidies created under their operating agreements, which are beginning to expire. As a result, housing providers and the families that live in their units are at risk. Urban Aboriginal housing providers cannot use many of the strategies that other housing providers with expiring operating agreements are using to ensure post-operating agreement sustainability, like changing a project s rental mix. With the majority of tenants in urban Aboriginal housing communities reporting annual household incomes of under $20, these housing providers cannot charge market rents and continue to house the population they are mandated to serve. The Province must take a leadership role on this issue and to work with the federal government and service managers to develop a strategy for ensuring that urban Aboriginal housing providers remain financially viable beyond the expiry of their operating agreement. Close the funding gap for MCSS-funded supportive housing The Ministry of Community and Social Services (MCSS) is responsible for the administration and funding of more than 3,000 supportive housing units in Ontario. These units and the support services attached to them help individuals living with developmental disabilities, at-risk youth, and young mothers live independently and safely in communities across the province. Recommendation: Institute annual, inflationary budget increases immediately and develop an approach to compensate housing providers for years of lost revenue and much needed capital repairs. These units were transferred to MCSS in the late 1990s and, since then, they have not received budget increases to account for rising costs or inflation. This is in spite of the spirit of the Memorandum of Understanding between the Ministry of Municipal Affairs and Housing (MMAH) and MCSS which sought to ensure that housing providers would have sufficient subsidy to cover operating expenses. As a result of the way in which MCSS has administered the agreement, MCSS-funded supportive housing providers have seen a more than 24 per cent reduction in their purchasing power. They have had to reduce services to tenants, subsidize capital or housing operations with other program funding, and defer 14. In major urban centres, one in 15 Aboriginal people had experienced homelessness, compared to one in 128 people in the general population. Belanger, Y. et al. (2013). Homelessness, Urban Aboriginal People, and the Need for a National Enumeration. Aboriginal Policy Studies, 2(2), Aboriginal Affairs and Northern Development Canada. (2010). Fact Sheet: Urban Aboriginal Population in Canada Urban Aboriginal housing providers that are members of ONPHA own and operate more than 2,500 homes. 17. ONPHA. (2013). Preliminary Survey Results ONPHA s Urban Aboriginal Housing Advisory Committee. 14 Building a stronger rental housing system

15 maintenance. MCSS-funded supportive housing providers also report difficulty hiring and retaining staff and the need to fundraise to provide core services and fund maintenance. We recommend that the Province institute annual, inflationary budget increases immediately and develop an approach to compensate housing providers for years of lost revenue and much needed capital repairs. Eliminate ministerial consents In the absence of large-scale government programs, social housing providers and service managers are leveraging their creativity and the resources of the private sector to rehabilitate and renew communities. They are using the assets and equity at their disposal to deliver more, and improved, housing for low- and moderate-income Ontarians. The ministerial consent process hinders the hard work of social housing providers and their service manager colleagues. Service managers carefully consider their support for such projects, particularly as they relate to their service level standards, 10-year housing and homelessness plans and other local priorities. These projects are also considered and approved by local or regional councils. As those principally responsible for the delivery of housing in Ontario, we believe that service managers should have discretion over the assets under their administration, and the ministerial consent requirement should be eliminated. Support sector transformation Ontario s social housing sector is facing a challenge. How can it leverage the assets it has to renew and build new housing without on-going government subsidy? What cultural change needs to take place to transform from subsidy-recipient to entrepreneur? For three years, ONPHA s Mentorship Program matched sector veterans with non-profit housing providers to answer questions like these. With the financial support of the Ministry of Citizenship and Immigration, our mentors spent hundreds of hours working with service managers Recommendation: Give service managers full discretion over the assets under their administration and eliminate the ministerial consent requirements. Recommendation: Fund a five-year, $600,000 extension of the Mentorship Program, which will enable ONPHA to help housing providers prepare for the evolving needs of the sector and capitalize on new opportunities, while ensuring that sector knowledge is retained. and 25 housing providers that were at-risk, ending their operating agreement, or winding down to build staff and board capacity. Our work received high praise from housing providers and service managers but, in the end, demand for the program outstripped the time and funding available. We ask the Province to fund a five-year, $600,000 extension of the Mentorship Program, which will enable us to help housing providers prepare for the evolving needs of the sector and capitalize on new opportunities, while ensuring that sector knowledge is retained. Ontario Non-Profit Housing Association 15

16 A STRONGER, MORE RESPONSIVE SOCIAL HOUSING SYSTEM Most of Ontario s social housing was originally designed to meet the affordable housing needs of low- and moderate-income individuals, families and seniors. These households were expected to live independently and be able to maintain their tenancies without any additional assistance. Over time, the nature and composition of tenants in Ontario s social housing has changed. While many are able to live independently, an estimated 22,400 social housing tenants are living with serious and persistent mental illness 18. More than 75,000 seniors, many in their 80s and 90s, are aging-in-place 19, and more than 50,000 additional senior households are on waiting lists for social housing 20. We also know that more than half of all new tenants in social housing are vulnerable enough to warrant priority status 21. In part, this change can be attributed to provincial policy decisions, like the closure of psychiatric hospitals, eliminating second stage housing for families that have experienced domestic violence, and commitments to end homelessness using a program model that prioritizes rapid access to housing. It s also the result of the Province s priorities and programs that are intended to yield better outcomes for individuals and to save the government money 22. Social housing providers are impacted by the changing needs of the tenants they house, and by provincial funding decisions that prioritize moving the most vulnerable members of our communities into housing that they can afford. In most communities, the most affordable housing is social housing. In an environment where housing is scarce, it has been politically expedient to use priority statuses on housing waiting lists to tackle social issues and community challenges. That has a direct impact on the wellbeing of social housing tenants, communities and staff. The nature of social housing in Ontario is changing, and the new composition of communities means the need for more support from government. This must be recognized in the renewed LTAHS, and steps must be taken to give social housing providers and service managers the tools they need to respond. 18. ONPHA (2015). Name of Joy s report in italics. Unreleased. 18. ONPHA (2015). Strengthing Social Housing Communities: Helping vulnerable tenants maintain successful tenancies. Unreleased. 19. Ibid 20. Ibid 21. Ibid 22. Based on the Mental Health Commission of Canada s (MHCC) At Home / Chez Soi report, it costs $21,089 annual to support and house a formerly homeless person with serious mental illness and $14,731 annually to support and house a formerly homeless person with moderate needs. These costs are less than institutional care, such as long-term care and hospital. The MHCC research identified an average savings of $15 per $10 spent to house and support people with serious mental illness and a savings of $2.90 per $10 spent to house people with moderate needs. 16 Building a stronger rental housing system

17 Invest in stronger social housing communities To grow strong and healthy, communities require attention and time. Nowhere is this more evident than in social housing communities. Social housing tenants often live in poverty or earn low wages. As a result, social housing providers work hard to improve tenants quality of life and access to services by delivering programs in-house, or in partnership with others. Recommendation: Ensure every housing provider has access to community development staff to engage tenants in their building s success and promote the health and well-being of all tenants. But, these investments in their community take time and resources. While current funding agreements fund social housing providers as simply a landlord, but the reality is that they re much more than that. We believe that funding for community development programs must be restored, because they are a core part of social housing management. We encourage the Province to help ensure every housing provider has access to community development staff to engage tenants in their building s success and promote the health and well-being of all. For large housing providers, this means a minimum of one community development worker for every 1,000 units. For small providers, it may mean increased funds to expand the role of existing housing staff, or sharing a specialized community development worker among several providers. We also believe that tenants and communities would be well-served by the provision of health, mental health and Recommendation: Create resource support services on-site, particularly where there is a high hubs that can improve efficiency of concentration of need or existing service use. Often our service providers, reduce costs, and members find themselves coordinating community-based deliver better outcomes for tenants. supports to help a tenant or prevent eviction. At times, they are also providing direct psycho-social support to the resident, an activity for which they may not be qualified or resourced. Funding partnerships between housing providers and mental health, seniors and other agencies to create resource hubs can improve efficiency of service providers, reduce costs and deliver better outcomes for tenants. A joint MMAH and Ministry of Health and Long-Term Care (MOHLTC) strategy to make supports in social housing part of the core provincial budget would enable MOHLTC to designate funds for local health integration networks (LHINs) to fund transfer agencies to partner with social housing providers. Where partnerships with health-funded agencies are unavailable or poorly-matched with resident needs, we encourage MMAH to designate funds for service managers to fund or create new service packages to promote housing stability and successful tenancies. Ontario Non-Profit Housing Association 17

18 Social housing is not housing of last resort We also encourage MMAH to work with the Ministry of the Attorney General, Social Justice Tribunals Ontario and the Landlord and Tenant Board to build adjudicators capacity and educate them on what social housing is and is not namely, housing of last resort. Social housing is for households that are able to live independently and in harmony with their neighbours. In practice, social housing staff undertake extensive eviction prevention work prior to serving Notices and appearing before the Landlord and Tenant Board. Their hard work and responsibility to other tenants should not be undermined by the misinformation and misplaced expectations of adjudicators, particularly when the merits of the case stand. Build a unique program to meet the needs of SPP applicants The Special Priority Policy (SPP) designation was designed to provide families that were experiencing violence with rapid access to housing. Unfortunately, more than a decade after the policy was introduced, it is inadequate in responding to the urgent needs of these households. Currently, the average wait time for SPP households is eight months. In some part of the province, the wait time for a household with SPP designation is as long as Recommendation: Work with the Landlord and Tenant Board to build adjudicators capacity and educate them on what social housing is and is not namely, housing of last resort. Recommendation: Develop a unique housing program to provide households eligible for SPP designation with housing and other supports outside of the overburdened social housing wait list system. 18 months. While eight to 18 months is faster than the average wait experienced by other social housing applicants in Ontario (3.83 years), for families in crisis that are longing for security, it is much too long. The SPP does other social housing applicants a disservice as well. More than 95 per cent of households waiting for social housing in 2014 were waiting in queue, on chronological lists. But, 25 per cent of available vacancies went to households with SPP, lengthening the wait time for chronological applicants 23. In the absence of large-scale government investment in social or affordable rental housing, wait times for social housing are expected to continue to rise. In part, this is due to increasing demand for housing. It is also due to lower unit turnover in social housing, which may reflect a lack of affordable rental housing alternatives in many communities. It would be compassionate and practical for the Province to develop a unique housing program for SPPdesignated households that provides them with housing allowances and other supports in the community. The program should be outside of the overburdened social housing wait list system in order to be more responsive to the needs of these households. Such a program would also make new social housing units available more quickly for the more than 165,000 other applicant households waiting for social housing. 23. In 2014, there were 15,177 households housed from social housing waiting lists in Ontario. More than three thousand of them (3,796) were households with SPP designation. ONPHA Waiting list report 18 Building a stronger rental housing system

19 Clarify duty to accommodate where the cumulative effect of housing vulnerable people changes the nature of the project The provincial Human Rights Code requires landlords and tenants to work together to address barriers to the tenant s equal participation in their housing and to accommodate the tenant s needs. The landlord is required to do everything it can up to the point at which it feels further action would be an undue hardship. Undue hardship is considered only in the context of cost and the health and safety to the person from whom the accommodation is sought (i.e. the landlord) 24. It does not consider the rights or needs of those around the tenant, namely their neighbours or community, to which the landlord is also responsible. Recommendation: Clarify the duty to accommodate and undue hardship provisions of the Human Rights Code and help develop strategies that enable social housing providers to better meet current and emerging tenant needs. Approximately 30 per cent of the households housed in 2014 were vulnerable enough to be eligible for a priority designation on their service managers centralized waiting list. In previous years, similar numbers of households with priority designation have also moved into social housing 25. Over time, an increasing concentration of vulnerable households in need of support and/or accommodation may, cumulatively, place an undue hardship on a landlord and threaten its mandate and viability. In the absence of increased internal capacity, community and/or health-funded supports or funding ear-marked for meeting accommodation requirements, social housing providers struggle to meet the increasingly complex needs of their tenants and communities. We encourage the Province to convene a working group comprised of social housing providers and representatives from the MOHLTC and MCSS and also from the Ontario Human Rights Commission to clarify the duty to accommodate and undue hardship provisions of the Human Rights Code and to help develop strategies that enable social housing providers to better meet current and emerging tenant needs. 24. Human Rights Code,1990 s. 17(2) 25. Look into past WLSRs to highlight years and numbers etc. Ontario Non-Profit Housing Association 19

20 BETTER OUTCOMES FOR SOCIAL HOUSING TENANTS The creation of priority applicants for rent-geared-to-income assistance, commitments to housing first-based responses to homelessness and targeted assistance programs for very vulnerable or hospitalized Ontarians26 have all contributed to a change in the nature of social housing communities. Our members believe they are in a powerful position to help create positive change for their tenants and households waiting for affordable housing. To be successful, social housing providers need greater internal and community capacity and a much higher level of collaboration between key provincial ministries, and service managers and LHINs. Our members want to help their most vulnerable tenants succeed and ensure all social housing tenants can enjoy a safe and happy home. To make this possible, we need a systematic approach to supporting vulnerable tenants, facilitated by local co-ordination and resourced by the Ontario Government. We recommend an approach with the following elements. You can t coordinate your way out of a supply problem : Ontario needs more housing Ontario s social housing sector has been called upon to help meet the priorities of the provincial government, often without the tools and increased capacity that the sector needs to succeed. Recommendation: Expand Ontario s social and supportive housing supply to improve outcomes for applicants and tenants and allow the system to function more effectively. Priority categories and targeted programs help the government achieve short-term objectives at the expense of other applicants for social and supportive housing. These other applicants are eligible for assistance and often wait for years for social and supportive housing. Their and their families health, mental health and other needs worsen while they wait and they may, in turn, become priority applicants. Expanding Ontario s social and supportive housing supply will not only improve outcomes for applicants and tenants, it will also allow the system to function more effectively. Increasing the supply and range of housing available will allow people to transition between types of housing and levels of support as their needs change. The cyclical nature of illness and increasing prevalence of low-wage and precarious employment ALC program, Addictions supportive housing program as examples Building a stronger rental housing system