RE: 019-0279 Developmental…

RE: 019-0279
Developmental Services Housing Navigator Response to the Proposed Changes to the Provincial Policy Statement.

Thank you for the opportunity to comment on the proposed changes to the Provincial Policy Statement.

As Developmental Services Ontario Housing Navigators our role is to provide information and resources to families across the province of Ontario as they plan for independent living. In our role we also advocate for the development of affordable housing in general and in particular for individuals with a developmental disability.
We have chosen to comment on the proposed changes to the Provincial Policy Statement that will affect the creation of affordable housing as opposed to the 5 questions posed in your feedback document as that is our main focus.

Overall we are supportive of the proposed changes especially as they relate to streamlining the process for new residential development. We are particularly pleased to see references to the housing requirements of people with special needs:

1.1.1 Healthy, liveable and safe communities are sustained by:
f) improving accessibility for persons with disabilities and older persons by addressing land use barriers which restrict their full participation in society;

As we often say, we are not trying to create housing for people with developmental disabilities our goal is to promote the development of housing and communities that include adults with developmental disabilities. We are pleased to see proposed changes that will help to create and improve on accessible housing.

Of the proposed policy changes the following are of interest to us:

• encourage the development of an increased mix and supply of housing
• reduce barriers and costs for development and provide greater predictability

“Take action to fast-track development applications for certain proposals (eg. Housing)” and to “streamline development approval processes and facilitate faster decisions by reducing decision timelines for municipalities and the province to 120 days for official plans and amendments, 90 days for zoning by-laws and amendments (except where there is a concurrent official plan amendment) and 120 days for plans of subdivision.”

We welcome these proposed reductions in decision timelines. This is particularly important for the developers wishing to create the affordable housing that is desperately needed in all communities and especially for the developmental services sector.

1.2 A coordinated, integrated and comprehensive approach should be used when dealing with planning matters within municipalities, across lower, single and/or upper-tier municipal boundaries, and with other orders of government, agencies and boards including:
h) addressing housing needs in accordance with provincial policy statements such as the Policy Statement: Service Manager Housing and Homelessness Plans.

Currently there are more than 15,000 adults with a developmental disability waiting for housing supports with the Ministry of Children, Community and Social Services. In 2017 a joint memo from the Ministry of Children, Community and Social Services and the Ministry of Municipal Affairs and Housing was sent to Service Managers (MMAH) and Regional Directors which encouraged greater collaboration to address the housing needs of adults with a developmental disability. We have reached out to the Service Managers (across Ontario) and in many cases participated in the 10 Year Housing and Homelessness Plan update consultation process.

Adults with a developmental disability are one of the groups to be considered by Service Managers when developing housing and homelessness plans and referenced in Policy Statement: Service Manager Housing and Homelessness Plans referenced in 1.2 h).

Housing options: means a range of housing types such as, but not limited to single-detached, semi-detached, rowhouses, townhouses, stacked townhouses, multiplexes, additional residential units, tiny homes, multi residential buildings and uses such as, but not limited to life lease housing, coownership housing, co-operative housing, community land trusts, affordable housing, housing for people with special needs, and housing related to employment, institutional or educational uses.

We appreciate the definition of Housing options but would suggest a method for creation of tiny homes when the square footage is less than minimum zoning requirement. Tiny homes could be an appropriate option for individuals with a developmental disability however these types of homes are often difficult to build as they do not conform to the minimum square footage requirements of the Zoning By-law. A student housing model and/or seniors who are open to shared living accommodations with people who have a developmental disabilities are two additional housing options that are also quite viable.

1.4.3 Planning authorities shall provide for an appropriate range and mix of housing options and densities to meet projected market-based needs of current and future residents of the regional market area by:
b) permitting and facilitating:
1. all housing options required to meet the social, health, economic and well-being requirements of current and future residents, including special needs requirements and needs arising from demographic changes and employment opportunities

Housing for people with a developmental disability is a priority as noted in the National Housing Strategy with co-investment funding directed toward at least 2400 units for people with a developmental disability. This is a much needed investment as, according to the Canadian Council on Disabilities the poverty rate for an individual without a disability is 9.7%. For individuals with a cognitive/psychological disability the rate is more than double the national average at 22.3%.

These statistics amplify the need for individuals with a developmental disability to be considered in all policies relating to affordable housing and inclusion in “healthy, liveable and safe communities”. We are hopeful that the proposed changes to the Provincial Policy Statement will streamline and simplify development regulation which is expected to provide a strong response to the overwhelming need for the creation of affordable housing.