How the City of Toronto can further embed human rights in its proposed renovictions policy

The agenda item to which this deputation is addressed can be found here.

Good afternoon,

My name is Garima Talwar Kapoor and I am the Director of Policy and Research at Maytree, a charitable organization dedicated to advancing systemic solutions to poverty through a human rights-based approach. At Maytree, we believe the most enduring way to fix the systems that create poverty is to safeguard economic and social rights for everyone in Canada.

Thank you for the opportunity to appear before the Planning and Housing Committee to discuss the City’s proposed Renoviction Policy. My deputation outlines the policy’s strengths, and, importantly, how we think it can be improved.

Let me start with the Policy’s requirement for tenants to be provided with information that would empower them with knowledge of the eviction process, including information about their rights.  This requirement is aligned with a human rights-based approach to housing, which is one of the principles guiding this proposal. As noted in Toronto’s Housing Charter and the HousingTO 2020 to 2030 Action Plan, the right to adequate housing is a fundamental human right recognized in international law. All levels of government, including the City, have a role to play in the progressive realization of this right.

With this in mind, the City’s proposed Renoviction Policy and framework are important steps forward in fulfilling this responsibility. By creating guidelines and enforcement mechanisms to improve tenant awareness of their rights, the City is taking measures to protect affordable and secure housing for those in greatest housing need. We also support further work with other levels of government to build and preserve affordable housing, such as through the additional investments and regulatory changes to protect the loss of affordable rental housing that are being requested as part of this framework.

To this end, we are pleased to see the City’s proposal to create a Housing At-Risk Table or HART framework, led by the Housing Secretariat, to coordinate interdivisional planning. The creation of the HART framework would improve the accountability and transparency of the City’s housing policy decisions by bringing a whole-of-government approach to this work.

However, there are elements of the recommendations that could further embed human rights principles into the City’s housing policy. In this regard, we encourage the Committee to direct City Council to:

• Be specific on the elements of a human rights-based approach to housing for which this proposed policy and framework are being guided by, such as accountability, equity, and transparency. This would help to monitor the framework’s progress in achieving its goals and evaluate the need for potential changes in the future.
• Consider expanding the role of HART to include monitoring coordination with other governments and engaging with people with lived experience of housing precarity and homelessness. While we welcome the framework’s requests to other levels of government, this advocacy could be better operationalized if HART’s mandate was enhanced to include tracking and monitoring. Additionally, and in line with a human rights-based approach to housing, it is imperative that those who are in greatest need are given the opportunity to participate in housing decisions, and a table such as HART could be used as a tool to ensure that their voices are heard.
• Consider what other means of enforcement the City has at its disposal beyond voluntary participation in education programs to deter renovictions should landlords not comply with the City’s future by-law. Importantly, the effectiveness of a renoviction policy depends not only on tenant education, but also on the actions of landlords. As such, a multi-pronged approach—outlining the needs of tenants and roles of landlords and governments—is required.

In addition, we would encourage the City to provide more clarity on what specific changes it is advancing with respect to Ontario’s social assistance programs. While we would support the City’s engagement with the Province to improve these benefits, the wording around this advocacy—particularly with respect to “equalizing” Ontario Works and Ontario Disability Support Program benefits—could be changed to clarify which aspects of the benefits should be improved.

Thank you again for the opportunity to appear before the Planning and Housing Committee to discuss the City’s proposed Renoviction Policy. I welcome any comments or questions you may have about my remarks.