Response to Ontario's Housing Affordability Task Force

Feb 24 2022

On February 8th 2022, Ontario's Housing Affordability Task Force released a report with 55 recommendations to radically change the Province's approach to development. The Social Development Centre Waterloo Region (SDCWR) has reviewed these recommendations and has two major concerns: omission of affordable housing and significant cuts to public engagement and democratic processes

On Affordable Housing: Despite having affordability in its name, this report does not propose any meaningful recommendations to increase affordable housing in our community. For example, there are no recommendations to build or fund non-market housing, combat the financialization of housing, or address visible/invisible homelessness. This report then offers no support for the folks in our community who are unsheltered,facing evictions, in unstable housing, who are renting, or who do not have access to generational wealth. Even for those that do, we remain unconvinced that these recommendations will lead to a decrease in housing prices.

Recommendations 1-12 do propose significant private development measures and would encourage much more density across the region. Advocates at WR YIMBY and Hold the Line Waterloo Region have prepared a joint statement where they dive deeper into what those recommendations entail. Increasing density and market supply leads to more walkable and more sustainable communities, but it does not lead to more affordable housing.

It is clear that the intention of this report was to facilitate private development and not to provide support to those experiencing unaffordable, unstable, or unsafe housing. The report outright states that "affordable housing (units provided at below-market rates with government support) was not part of our mandate". We are concerned that a report on housing affordability did not have any recommendations to increase the amount of affordable housing or protect current affordable housing. To use the language of affordability to promote market development is misleading to the public and undercuts the critical government action that is needed to ensure housing as a right. 


On Public Engagement: On top of the lack of affordable housing, several recommendations are actively harmful and severely limit the ability of the public to participate in the transformation of their communities. For example, recommendation 13 would prevent municipalities from hosting public meetings beyond the bare minimum. This limits the flexibility, creativity and inclusivity of public engagement processes which should be more responsive to community needs, not less. We believe municipalities should be encouraged to make their engagement process more robust and public meetings more accessible. 

Most concerning is recommendation 27 which increases the fee for a third-party appeal from $400 to $10,000. Similarly it awards full costs to the successful party in an appeal, which means community groups are at risk of having to pay extra if they are unsuccessful in their appeal. It also removes the ability to appeal for projects with at least 30% affordable housing, which seems like a way to protect and promote affordable housing. However, their definition of affordable housing is not affordable as it is tied to market rate and only lasts 40 years. Put together, this recommendation all but shuts out community organizations like the SDCWR from advocating against projects that would harm vulnerable members of the community.

Overall, these recommendations prioritise developers over the community in appeals (recommendation 18, 20, 26), heritage designation (recommendation 16 &17), and project timelines (recommendations 19, 20, 29, 30 & 35). While we understand the desire to speed up the approval process, these recommendations create a system where community voices will be silenced, where community needs will be ignored, and where developers can more easily override the public good. The public should not be punished for the poor engagement practices of developers and municipalities who often treat public engagement as a nuisance rather than an opportunity for collective understanding, education and transformation. 

Recommendations: We strongly encourage the Government to reject recommendations 13, 16, 17,18, 19, 20, 26, 27, 29, 30, 35 (see the full list below) as they are direct attacks on public engagement. While we understand the desire to shorten the approval process, these recommendations go much further and remove the ability of community groups to participate in the development process in a meaningful way. If the government is interested in affordability we encourage them to go back to the drawing board with a mandate of true affordability. There are plenty of actions needed when it comes to preventing evictions and the financialization of housing; building more non-market and supportive housing; increasing property standards and rent controls; and addressing visible and invisible homelessness. Leadership from the provincial government is needed to ensure that everyone has access to safe, stable and affordable housing.

Here is the full report:

David Alton, Social Development Centre Waterloo Region


* 13. Limit municipalities from requesting or hosting additional public meetings beyond those that are required under the Planning Act.

16. Prevent abuse of the heritage preservation and designation process by: 

a) Prohibiting the use of bulk listing on municipal heritage registers 

b) Prohibiting reactive heritage designations after a Planning Act development application has been filed 

17. Requiring municipalities to compensate property owners for loss of property value as a result of heritage designations, based on the principle of best economic use of land. 

18. Restore the right of developers to appeal Official Plans and Municipal Comprehensive Reviews.  

19. Legislate timelines at each stage of the provincial and municipal review process, including site plan, minor variance, and provincial reviews, and deem an application approved if the legislative response time is exceeded.

20. Fund the creation of "approvals facilitators" with the authority to quickly resolve conflicts among municipal and/or provincial authorities and ensure timelines are met.

26. Require appellants to promptly seek permission (“leave to appeal”) of the Tribunal and demonstrate that an appeal has merit, relying on evidence and expert reports, before it is accepted. 

27. Prevent abuse of process: 

a) Remove right of appeal for projects with at least 30% affordable housing in which units are guaranteed affordable for at least 40 years. b) Require a $10,000 filing fee for third-party appeals. 

c) Provide discretion to adjudicators to award full costs to the successful party in any appeal brought by a third party or by a municipality where its council has overridden a recommended staff approval.  

29. Where it is found that a municipality has refused an application simply to avoid a deemed approval for lack of decision, allow the Tribunal to award punitive damages. 

30. Provide funding to increase staffing (adjudicators and case managers), provide market-competitive salaries, outsource more matters to mediators, and set shorter time targets. 

35. Regarding cash in lieu of parkland, s.37, Community Benefit Charges, and development charges: 

a) Provincial review of reserve levels, collections and drawdowns annually to ensure funds are being used in a timely fashion and for the intended purpose, and, where review points to a significant concern, do not allow further collection until the situation has been corrected. 

b) Except where allocated towards municipality-wide infrastructure projects, require municipalities to spend funds in the neighbourhoods where they were collected. However, where there’s a significant community need in a priority area of the City, allow for specific ward-to-ward allocation of unspent and unallocated reserves.