Please find attached the…

Please find attached the Comment submitted by the Toronto Alliance to End Homelessness (TAEH) regarding ERO 019-7669.

Recommendations:

Developing consistency in the definition of “affordable housing” across Canada is desirable.

Linking affordability to the gross annual income of households is preferable to using the average market rent/purchase price.

For the City of Toronto and other metropolitan urban areas, the catchment area for determining household income should be census tracts and not the whole municipality.

The proposed 60th household income percentile for rental housing is too high, and this should be lowered to reflect more accurately the “low and moderate income households” most in need of affordable rental housing.

Defining affordable rent as the rent paid by households not exceeding 30% of income is appropriate.

The definition of household should take into consideration that multiple households sharing a single housing unit should not be deemed to be a single household for the purpose of this definition but be counted separately.

If the actual gross annual income of all households is lower than the actual gross annual income of rental households in a catchment area, the latter value should be the deemed value for the purpose of calculating affordable ownership housing.

Restricting databases to household rentals or home purchases made within the past ten years will ensure that the current market realities in both the rental and home ownership markets are reflected in any current definition of affordability.

“Annual accommodation cost” needs to be defined and should be based on the current methodology used by the mortgage industry in determining the affordability of a home purchase.