Toronto ACORN’s Response to the City of Toronto’s Housing Action Plan

Toronto is making big decisions on how it deals with housing, and voting on it’s ‘action plan’ for 2022-2026 this month.

ACORN members know big changes are needed to deal with housing problems in the city, but we’re concerned that a lot of what our members are dealing with isn’t in this report.

ACORN’s biggest concern is that there is NOT ONE MENTION of the RentSafe program, which is supposed to protect affordable rental housing by enforcing property standards.

Does City Council think RentSafe is working perfectly, or are they trying to ignore the program because they don’t want to improve it? Either way, this is a major red flag.

One of the biggest tools the city has to protect existing low end of market units is RentSafe, yet the proposed work plan has no mention of RentSafe.

There are major issues with RentSafe, and major components of the program that was passed over 6 years ago that have still not been implemented. ACORN members have called attention to this pressing need consistently. Seeing RentSafe ignored in this housing action plan is a slap in the face to low and moderate income tenants across the city.

Our biggest concern is the lack of RentSafe in the plan, we also have some other areas where the plan could be improved, which we detail below.

Increasing Permissions for Housing and Addressing Exclusionary Zoning

Facilitating Apartment Infill

There needs to be requirements on landlords that want to fill in green space and parking lots with additional buildings. The city needs to ensure that the existing buildings are well maintained and up to code through additional enforcement of RentSafe before any development is approved. Too often we hear tenants are afraid that new buildings will displace them through gentrification – enforcement of property standards is essential to prevent the potential displacement that occurs via infill.

Major Growth Areas

There needs to be affordability requirements for these major growth areas. Areas of the city such as Downsview, the Waterfront, Quayside, Villiers Island and the Port Lands, as well as parts of Scarborough, North York, and Midtown, as well as other Transit Oriented Communities all should have affordability requirements. If major growth is expected, there needs to be major requirements for affordable housing. ACORN members demand 30% of all new developments in major growth areas are set aside as permanently, deeply affordable, rental housing.

Rental Roundtable

The city held a discussion about rental housing. Some ideas ACORN is concerned about include making rental replacement laws more flexible and weak affordability period requirements. Affordable isn’t affordable if it’s not affordable for 99 years; 25 years, or 40 years is not acceptable. And rental replacement laws should be strengthened, not weakened.

Community Housing Modernization and Growth

Many ACORN members live in TCHC. The city is planning to increase the amount of units on TCHC lands, by tearing down low rises and rebuilding with highrises. We have concerns about displacement. But we also have concerns that there is no addition of affordable units when these ‘intensification’ efforts happen. TCHC is public land – it should require 100% of the development as rental, with 50% of the units affordable.

Affordable Housing Program Updates

Any city program that gives money to developers should have a universal definition of affordable: 99 years, 30% of income. Open Door and Housing Now should be actually affordable for the people who work in the city!

3. Leveraging Public Land to Increase the Supply of Housing

Housing Now Sites

The report outlines that “The affordable units created through Housing Now will, on average, be rented at 80% of Toronto’s average market rent.”

The city should apply its’ new definition of affordable rental to all affordable housing being created or it risks that housing not being affordable.

4. Preserving the Existing Rental Housing Stock

Evictions, including renovictions, result in the displacement of tenants, housing instability, increased rates of homelessness and the permanent loss of affordable and mid-range rental homes. What about eviction due to lack of maintenance? RentSafe is the tool created to protect existing affordable rental, if the city doesn’t prioritize making this tool effective it risks bleeding more affordable housing then we are creating!

It is good the city is moving forward with their Renoviction Policy but this needs to go hand in hand with an effective Rentsafe program!