Bill 23, as passed, will…

Bill 23, as passed, will have devastating impacts on low- and moderate-income tenants as not only will it create more unaffordable housing but it will also take away the powers cities have in building and protecting affordable housing. As a residential architect, I have a good understanding of the housing industry and I know this Bill is wrong for so many reasons.

These issues are detailed below:
1. The Act aims to build 1.5 million homes in the next 10 years. However, building more unaffordable housing in the green belt is not the solution to the housing crisis, as the Governments own Task Force stated. Ontario needs affordable housing and not single family homes in the green belt. We need to provide the 'missing middle' homes built where people want to live, close to shopping, existing infrastructure and other amenities.

2. Currently, cities have some powers to legislate their own IZ bylaws and build some real affordable housing. While the IZ policy was limited to major transit areas only, this Bill goes a step further limiting the potential of IZ in creating real affordable housing.
- The 5% set aside rate for affordable housing units is extremely low given the extent of the housing crisis and smacks of inequity.
- Further, limiting the period for which the units will be kept affordable for 25 years will deepen the housing crisis. There are massive incentives for landlords to up the rent once a tenant vacates the unit. After 25 years, the affordable housing unit will return to the market and the tenants will lose their affordable housing and communities. For IZ policies to be effective, the IZ units need to be kept affordable forever!
- The definition of affordable housing will be changed. There will be a standardized approach to determine the rent of an IZ unit. CMHC defines housing as affordable only if the rent is no more than 30% of the household income. The standardized approach will build unaffordable housing if it doesn’t meet this definition. One councilor from Mississauga stated that this ‘standard approach’ would put the affordable income at $90,000!! How does this support a large percentage of the population to afford homes?

3. It will make tenants more vulnerable to renovictions/demovictions, increase homelessness crisis and destroy existing affordable housing. In Ontario, landlords are increasingly using renovation/demolition as a tactic to evict tenants so that once the tenant moves out, they are able to substantially jack up the rent.
- One, the Bill strips the tenants’ right to return in case of demolition.
- And second, the Bill proposes launching consultations to standardize municipal by-laws in cases of renovations and demolitions. Standardizing could also lead to diluting some of the strong tenant protections that ACORN and several other organizations have won across cities that have prevented evictions and homelessness.

4. Other issues
Other aspects of the Bill that are concerning are the following:
- It proposes to exempt new developments, including affordable housing, from development charges. Municipalities will lose millions in the absence of these charges, costs for important services such as transit and other city services will not be met. Will these charges be downloaded onto taxpayers to pay for growth?
- Reducing the capacity of conservation authorities in the process of building more housing. To pave over wetlands and conservation areas is just downright stupid and shows a total lack of understanding on how conservation areas work. The Government needs to listen to its own experts.

5. Call for an inquiry into the relationship of the Ford Government and developers who bought Greenbelt land since this government has been elected. Who knew what and when? As an Ottawa City Councilor remarked "this government is corrupt".

In short, the new legislation works to the detriment of low- and moderate-income tenants, endangers our wetlands and conservation areas, and lines the pockets of a few, select developers.

I strongly urge you to scrap these aspects of the Bill as it will worsen the housing crisis. Keep your promises to not touch the Greenbelts and conservation areas.