Submission to the Government of Ontario regarding Bill 184, Protecting Tenants and Strengthening Community Housing Act, 2020
The onset of the COVID-19 pandemic has underscored why housing is a basic human right. Without access to secure and adequate housing, not only is the health and well-being of the individual compromised, but also that of society at large. The pandemic has brought systemic inequities into sharp focus. These inequities have disproportionately saddled people with disabilities, and Black and Indigenous individuals and communities, with poorer health, economic, and housing outcomes.
Bill 184, Protecting Tenants and Strengthening Community Housing Act, is an opportunity for the province to put in place new legislation to advance the right to housing and address the housing issues that have been amplified by the pandemic.
Bill 184 introduces some positive new measures that better support tenants. However, the proposed legislation compromises the right to adequate housing in five major ways. In particular, Bill 184:
- Ignores the crisis situation many tenants face as a result of the COVID-19 pandemic;
- Reduces tenants’ access to justice;
- Lacks the robust enforcement and institutional capacity required to implement proposed changes;
- Does not address the patchwork rent control system; and
- Fails to provide sufficient protections for tenants who face housing discrimination and a greater risk of homelessness.
To truly protect the tenants and their housing rights, the government should:
- Protect tenants from accruing unsustainable arrears and facing eviction due to the pandemic;
- Provide tenants with access to financial and legal support to prevent homelessness;
- Strengthen institutional capacity to ensure the rights of landlords and tenants;
- Increase affordability of rental housing through key regulatory changes; and
- Focus on measures to prevent housing discrimination.