Three ways the Housing Action Plan can better support people with greatest housing need

The agenda item which this deputation addresses can be found here.

Good morning, my name is Elizabeth McIsaac, and I am the President of Maytree, an organization dedicated to advancing systemic solutions to poverty through a human rights-based approach. My comments today are in response to the proposed priorities and actions in the City’s 2022-to-2026 Housing Action Plan.

By way of introduction, and as some of you will know, Maytree has worked closely with the City on housing initiatives—multi-tenant housing, the role and function of a Housing Commissioner—some of which are included in the Housing Action Plan.

Our approach has been, and continues to be, to support the City in its efforts to address the needs of those living in deepest housing need and poverty. We believe that through a human rights-based approach to housing, many of the challenges confronting the City today can be addressed. At its core, a human rights-based approach requires us to centre the person, or communities, whose rights are in question.

It is in this spirit that I am speaking to you today on the proposed Housing Action Plan’s workplan, which presents a robust set of activities and goals to move the marker on the structural supply challenges that the city is facing. My comments today will be focused on the framework for this action.

In adopting the Housing Charter and the HousingTO 2020-2030 Action Plan, the City committed itself to recognizing adequate housing as a fundamental human right, and to the progressive realization of that right. The Charter and plan provided guiding principles for how the City should approach housing, in all its dimensions, including its plans and its activities. While I recognize that the City is still creating and implementing some of the mechanisms to guide this work, it is nonetheless obliged by this commitment to apply this framework to the development and approval of plans such as the Housing Action Plan before you today.

Housing is a complex system that exists within a dynamic market. It is essential that we recognize action at one end of the housing continuum has effects on the other. And so, while it is clear that the focus of this four-year plan is on dramatically increasing supply, from a human rights-based approach it is imperative to ensure that housing supply options are available at every level of affordability.

For example, the absence of a priority area dedicated to developing and preserving deeply affordable housing represents a notable gap in the Housing Action Plan. Evidence from the City’s Rental Housing Roundtable shows that there is a need for more non-market, deeply affordable solutions to support those in greatest housing need.

Similarly, while Council approved the City’s new multi-tenant housing policy framework in December 2022, the Housing Action Plan only speaks to the application of this new policy as a subset of preserving the overall rental housing stock. More attention to this area of work would ensure that those in greatest need remain a priority.

Although the City staff report does note that the Housing Action Plan will complement the HousingTO plan, it is not clear how it will do so, how priorities will be set, which policy actions will take precedence, or how this will be reviewed over the next four years. Nor does it make explicit how the actions outlined will reflect a human rights-based approach to housing and thereby ensure that people in housing need are served by the plan.

And, critically, there is no locus of accountability at the City to ensure that the Housing TO 2020-2030 Action Plan, the proposed Housing Action Plan, and the many other plans noted in the report are functioning together to achieve the progressive realization of the right to adequate housing.

Without such a locus of accountability, there’s a good chance that the extensive and complex set of actions outlined in the individual plans will not work together, not solve the city’s housing crisis, and that those in greatest housing need will continue to have their rights compromised.

We know that there is a deputy ombudsman of housing that is being proposed to Council. And we know that the Housing Action Plan recommends a Council Housing Committee on the right to housing. But it is critical that there is a point of accountability, resourced and capable of ensuring that the priorities set, and the balance of housing investment made, reflect the progressive realization of the right to housing in Toronto.

To this end, we recommend the Executive Committee direct City staff to:

1. First, ensure that the Housing Action Plan is guided explicitly by the recognition that adequate housing is a fundamental human right and a human rights framework to further the progressive realization of this right, as per the Toronto Housing Charter.
2. Second, develop a specific priority area within the Housing Action Plan’s workplan to support deeply affordable rental housing. This area could include the actions identified by the City’s Rental Housing Roundtable, such as ways to support the non-profit sector and the purchase of existing affordable rental buildings, along with implementing the City’s multi-tenant housing policy.
3. Develop a comprehensive articulation of what all the plans mean together— their potential cumulative impact—ensuring that the plans don’t operate in silos. And to this end, consider the allocation of the City’s overall fiscal and resource capacity, in order to realize the right to housing for everyone in Toronto.

Thank you for the opportunity to appear before the Executive Committee today regarding the City’s new Housing Action Plan. I welcome any comments or questions from the Committee about my remarks.