Your government says its…

Your government says its proposed changes to O. Reg 232/18 (Inclusionary Zoning) are designed to create more affordable housing. I support that goal. There is, as the government has often said, a desperate need. However, the proposed regulation severely limits the use of an important tool, inclusionary zoning, to create affordable housing, leaving us with less affordable housing than we could and should have.

The biggest problem with your proposed changes to O. Reg 232/18 is the very low proportion of affordable units that a municipality can require of developers of new housing, just 5 per cent. You can and should require more like 30 per cent. Here is why.

One of the virtues of inclusionary zoning is that it automatically creates mixed-income communities, integrating lower-income households with households with higher incomes rather than creating low-income ghettos. But achieving that requires a reasonable proportion of lower-rent units. Just five “affordable” units in a 100 unit building with 95 market rent units will fall far short of any real mixing.

Your government earlier restricted the use of inclusionary zoning primarily to major transit routes and stations. In Hamilton, for instance, that is the light rail transit route. Land near that the LRT route, like land on any major transit route, will be given a big boost in value because of its proximity to a new, fast transit system, a boost entirely created by public investment in the transit system. That increase in value has created the capacity for the land owners to provide a reasonable proportion of affordable housing units in any residential projects near the transit route and stations. Requiring 30 per cent is not too costly. The landowners along major transit routes have the capacity to absorb the losses on affordable units both from the elevated value of their land and from the premium rents they will likely charge for the market-rent units in what will be prestige locations.

Your government has argued that the regulation “would provide more development cost certainty and establish a more consistent approach to inclusionary zoning across the province.” That is indeed an argument for setting one provincial standard but isn’t an argument for 5 per cent. A 30 per cent limit would provide equal cost certainty and go much further toward the other reason your government has given for this regulation change, that it would “support government priorities to provide housing that is affordable and within reach of more Ontarians.”

I further urge that units created through inclusionary zoning be affordable permanently, not just for 25 years. The challenge of housing affordability right now is compounded by the expiration of earlier, temporary programs based on, for instance, 35-year subsidies that have ended, or soon will end. We need permanent solutions.

We need to use every tool we have to increase not just the supply of houses but specifically the supply of affordable housing. I urge you to revise your proposed changes to O. Reg 232/18 to allow that 30 per cent of units in developments along major transit routes and at major stations must be affordable, permanently.