I am very concerned that the…

I am very concerned that the proposed amendment to inclusionary zoning in the Planning Act will not succeed in supporting the government’s stated intent to provide more affordable housing but will in fact create less.

According to Social Planning Toronto, a non-profit charitable community organization that is committed to challenging inequity, when Ontario gave municipalities the power to implement Inclusionary Zoning (IZ) bylaws, this provided cities with a tool to build affordable housing in certain areas and permitted municipalities to determine the set-aside rates and affordability periods that were appropriate for each jurisdiction (Jin Huh, Social Planning Toronto, Nov 24, 2022). However, this amendment proposes to “override those policies, which were determined through a democratic process and informed by extensive consultation with both community and industry stakeholders.” I fail to see why policies that were determined through broad consultation should be unilaterally changed , especially when those changes reduce set-aside rates and affordability periods.

I found the research Social Planning Toronto conducted into the IZ policies of other major cities across North America to be intriguing. They found that cities such as “New York, San Francisco, Boston and Montreal have successfully dedicated 10—35% of new developments to affordable units.” They observed that “reducing the affordability period of units built through IZ from 99 to 25 years goes against best practices developed through decades of IZ implementation in the US, where longer affordability periods are the trend”, concluding that “[r]educing the affordability of units to only 25 years will only pass on the costs of affordable housing to the next generation.”

In an open letter to Premier Ford and Minister Clark dated November 28, 2022, a consortium of leading Ontario architects, landscape architects and urban designers outlined their concerns with Bill 23, and in particular the effect that this amendment will have on affordable housing: “Bill 23 will reduce the supply of truly affordable housing by reducing the affordable housing requirements in Inclusionary Zoning from 20% to 5%. The required period to maintain affordability is reduced from 99 to 25 years” (building.ca, Dec. 7, 2022). Like Social Planning Toronto, they conclude that “this will exacerbate generational poverty and extend inequitable access to resources and infrastructure for the people of Ontario.” It appears that these changes will reduce rather than increase affordable housing, as well as place limitations on the affordable housing that is built.

The Canadian Centre for Housing Rights notes that “[t]he Inclusionary Zoning measures proposed … significantly limit municipalities’ ability to develop IZ frameworks based on local needs and economic conditions.” They too are concerned that “the bill threatens to weaken the effectiveness of IZ as a key tool for creating much-needed affordable housing for [people] struggling to find secure and affordable homes” (housingrightscanada.com).

It seems to me that an upper limit of 5% of the total number of units in a development required to be affordable is counterproductive to creating the amount of affordable housing that is desperately needed in Ontario. I also question why the government would want to limit rather than encourage it in new developments that will be located around a transit hub. People with lower incomes would be better served in such a development as it could allow them to be less car-dependent due to the proximity of transit and other necessary services.

Finally, Alan Broadbent and Elizabeth McIsaac, in an opinion piece they wrote for the Maytree Foundation (an organization committed to advancing systemic solutions to poverty), argue that the housing crisis is a crisis of affordable housing and homelessness, that we need to target most urgently people living in poverty, and their need for long-term, affordable, and adequate housing.

These proposed changes do not appear to be aimed at providing more housing that is affordable to the people who need it most.