UPDATE: Bill 205 did not pass
On Monday, November 16th 2020, Bill 205 the Protecting Renters from Illegal Evictions Act, a Private Member’s Bill introduced by MPP Jessica Bell, will go to 2nd reading in the Ontario Legislature. This Bill targets the growing problem of bad-faith and unlawful evictions in Ontario that are leaving tenants struggling to secure safe, adequate and affordable housing. If passed, Bill 205 has the potential to strengthen protections for tenants facing “no-fault” evictions; expand capacity for tenants, the Landlord and Tenant Board, and other levels of Government to fight bad-faith evictions, including “renovictions;” and increase fines and penalties for landlords who break the law.
Highlights from Bill 205 include:
Bill 205 seeks to expand timelines for “no-fault” evictions, increase transparency during the legal eviction process, broaden the enforcement powers given to the Landlord and Tenant Board and Government agencies to fight bad faith evictions, and expand access to legal services for tenants facing eviction.
At CERA, we routinely hear from tenants across Ontario who receive verbal or informal written demands from landlords to move out of their apartments for reasons relating to renovations or when a landlord claims they need the apartment for a family member. These demands bypass the formal eviction process at the Landlord and Tenant Board, including the use of proper forms that notify tenants of their rights, and are sometimes accompanied by pressure and harassment from landlords. Bill 205 addresses the problem of informal landlord demands to move out by requiring the use of official Landlord and Tenant Board forms for giving tenants notice to end their tenancy. Bill 205 also requires landlords to provide detailed information, in cases where they are seeking to evict a tenant due to extensive renovations or a demolition, directly to tenants when they serve a notice of termination. These requirements will ensure tenants are served with proper forms that include information about their right to proper notice, a legal termination date and notice period in accordance with the Residential Tenancies Act, and the rules regarding compensation for tenants in instances when they are entitled to compensation for an eviction. The requirement to provide all necessary information, including permits and authorization for renovations/demolition, directly to tenants will also help ensure landlords do not attempt to evict tenants under false pretenses. Taken together, these requirements will help ensure tenants are made aware of their rights and do not vacate the rental unit in accordance with informal or bad-faith demands.
Different levels of government are working to develop unique and complementary policies that protect affordable housing and fight illegal evictions. Unfortunately, much of this work is taking place in the absence of good data collection and sharing across levels of government – a key component of well-informed policymaking. Bill 205 will assist with better data collection and sharing by creating a registry of landlord “no-fault” eviction applications that will include data on the geographic location and outcome of these applications. Data from this registry will be published on an annual basis and shared across levels of government and with the public. Among other benefits, the availability of this data will allow governments across the Province to compile and analyze aggregate data to view trendlines about where these types of evictions are more prevalent and the outcome of these eviction applications – information that will allow levels of government to target policy responses to communities most in need. For tenants, the availability of this information will help them to make more informed decisions about whether to rent from landlords with past histories of evicting tenants.
Low vacancy rates, vacancy decontrol and skyrocketing rent prices make securing affordable housing increasingly difficult for tenants across Ontario. Evictions compound this difficulty by forcing tenants out into a difficult rental market under tight timelines and with additional disruption and expenses related to moving. Bill 205 increases the length of time tenants have to vacate their property when given proper notice and increases the mandatory amount of compensation tenants are entitled to when they are evicted for one of the “no-fault” reasons. These provisions have the potential to ease the transition to a new home for tenants who are legally evicted.
Because of vacancy decontrol, a policy that allows landlords to raise the rent by an unlimited amount when a tenant vacates an apartment, the financial incentives for landlords to unlawfully evict a tenant are high. This financial incentive is unlikely to be curbed by current fines and penalties given the relatively low amount of these penalties compared to the amount that can be charged by landlords in higher rent. Additionally, the onus on proving an unlawful eviction rests with tenants who are unlikely to have the necessary resources, in the form of legal representation or otherwise, to properly investigate and seek a remedy if they were evicted in bad faith. Bill 205 includes measures to tackle the above problems by increasing the penalties for landlords who unlawfully evict tenants and includes provisions that give tenants the right to return to their unit following an unlawful eviction or be provided with another vacant unit from their landlord at the same amount of rent. Bill 205 also increases enforcement and investigative capacity for the Ministry of Municipal Affairs and Housing (the Ministry) by requiring the Landlord and Tenant Board to notify the Ministry when an Order for eviction is issued based on a “no-fault” reason and compels the Ministry to take measures to ensure the eviction was carried out in good faith. If the Ministry determines that an eviction was unlawful, Bill 205 grants them the power to notify the tenant of the unlawful eviction and extends the period of time a tenant can take action at the Landlord and Tenant Board based on this notification to two years from the date they vacated the unit instead of 12 months from the date they vacated the unit.
Landlords have access to legal representation to help them navigate the eviction process at the Landlord and Tenant Board in a manner that is vastly disproportionate to tenants. This uneven access to legal representation creates a power imbalance in favor of landlords and makes navigating the eviction process an unfair fight for tenants. Bill 205 attempts to ease this power imbalance by requiring Legal Aid Ontario to provide, upon request, legal representation to tenants who are facing eviction for “no-fault” reasons. Given that no-fault evictions target tenants from all economic circumstances, it is encouraging to see that Bill 205 proposes to bypass Legal Aid Ontario’s financial eligibility requirements in these circumstances.
While the above measures have the potential to lessen the financial incentives for landlords to engage in unlawful evictions, these measures need to be accompanied by the elimination of vacancy decontrol to truly tackle the disturbing rise in unlawful no-fault evictions across Ontario.
Further clarification and additional details are required to clarify the methods by which tenants can obtain legal aid services when facing eviction for “no-fault” reasons. It is unclear whether tenants will be able to obtain these services through Legal Aid Ontario’s Certificate program, through increased capacity and resources in Ontario’s Community Legal Aid Clinics, or a combination of both.
Evictions are a highly disruptive events, especially in the midst of a global pandemic and economic crisis, and have long-lasting physical, financial, and mental health consequences. As such, evictions should only be permitted in exceptional circumstances and as a last resort. Tenants facing eviction should be made aware of their rights and be in a position to exercise them at the outset of and throughout the eviction process. Bill 205 includes some positive steps to ensure tenants are able to navigate the eviction process in a fair and transparent manner. Of particular interest are the measures which ensure tenants are made aware of their rights through mandated use of proper documentation and increased requirements for information to be provided by landlords. As well, a province-wide, accessible registry of “no-fault” eviction applications/orders is long overdue and has the potential to influence municipal and province wide policy solutions at a targeted level. Also of interest are the commitments to crack down on unlawful “no-fault” evictions by strengthening the capacity for the Landlord and Tenant Board and the Ministry to investigate and penalize landlords who undertake these evictions. Until vacancy decontrol ends, the financial incentive for landlords to unlawfully evict tenants will remain in place, but the measures included in Bill 205 may help curb the ability of landlords to unlawfully evict tenants with little or no consequences, and are a good first step. We are encouraged by the attention being given to these important issues and hope that Bill 205 receives all due consideration from our elected representatives.
Across Ontario, a worsening housing crisis is making adequate, affordable housing increasingly out of reach, with more and more households lacking housing that meets basic conditions of affordability, security of tenure, accessibility, and habitability. The scope and scale of this crisis requires nothing short of a fundamental shift towards a human-rights based framework to housing policy. At the heart of this framework is the progressive realization of adequate housing as a human right, rather than a commodity to be bought and sold.
On Monday November 9th, Ontario’s New Democratic Party released a Housing Plan (“the Housing Plan”) titled “Homes You Can Afford” as part of the party’s 2022 election platform. The Housing Plan includes a number of measures aimed at building and preserving affordable housing, cracking down on the financialization of housing, supporting the development of housing for vulnerable individuals and communities, and protecting tenants against unlawful and bad-faith evictions.
Here we run down what the Ontario NDPs’ Housing Plan gets right, what’s missing and CERA’s take.
Encouragingly, the Housing Plan incorporates the language, process and substance of a rights-based approach to housing policy. The Housing Plan begins with an acknowledgment that housing is a human right and that inadequate housing disproportionately impacts women, Black, Indigenous, and racialized people, individuals living with mental health and addictions challenges, and 2SLGBTQIA+ individuals. From here, and throughout the Housing Plan, housing and housing policy are seen as key tools to achieving social, economic, health, and environmental goals such as ending homelessness, reversing the financialization of housing, addressing mental health issues through the use of supportive housing, and taking measures that recognize the important linkages between housing and the climate, in particular increasing energy efficiency through environmentally progressive building standards. Many of the Housing Plan’s proposals focus on improving housing outcomes for those in greatest need and in building sustainable and inclusive communities – both of which are priorities in a rights-based approach to housing policy. A commitment to meaningful engagement with and participation from Indigenous and Northern Ontario communities, individuals experiencing homelessness, and survivors of domestic violence sets the tone for tackling the housing needs of these individuals and communities. In short, the Housing Plan contains many of the protocols and measurements necessary for upholding the human right to adequate housing.
In a human rights-based framework, everyone has the right to equitable access to adequate housing. This right implies more than having four walls and a roof, and is not limited to the basic supply and availability of housing. At minimum, adequate housing meets the following basic conditions:
The Housing Plan includes specific policies aimed at ensuring the various elements of the right to housing listed above are met. Highlights include:
Affordability
Security of Tenure
Accessibility
Habitability
Location
Serviced by necessary infrastructure
Cultural adequacy
A key cause of the housing crisis is the financialization of housing which treats housing as a market commodity rather than a social good – a distortion that is responsible for increased homelessness and a lack of adequate housing. When housing is thought of as a commodity, it is no longer recognized for what it is: a fundamental human right. In order to advance the right to housing, active measures must be put in place to ensure financialization no longer continues.
The Housing Plan responds to and addresses the issue of the financialization of housing through several policy proposals targeting housing speculation and hidden ownership. Many of these proposals are inspired by recent policies adopted by the Government of British Columbia, which include:
There are a number of ways that the Housing Plan could be enhanced to further protect the right to adequate housing.
The availability of timely legal advice, information and/or representation is necessary to ensure tenants can offset the existing power imbalance between landlords, many of whom have access to legal professionals, and tenants. The Housing Plan does not include increased funding for Legal Aid Services for tenants who require legal advice, representation and information to defend themselves against eviction and enforce their rights, nor does it provide increased funding for non-profits and housing advocacy groups that play a crucial role in assisting tenants facing eviction, discrimination and impediments to enforcing their rights as tenants who are not able to avail of legal aid services.
Bill 184, the misleadingly named “Protecting Tenants and Strengthening Community Housing Act,” threatens several critical components of the Right to Housing – security of tenure, affordability, and safety. This Bill strips tenants of several procedural rights guaranteed by the Residential Tenancies Act and will result in more evictions into homelessness for tenants across Ontario. The Housing Plan does not mention any specific intention to repeal this Bill and restore the rights to tenants facing eviction.
While the omissions mentioned above represent some important missed opportunities to level the playing field between landlords and tenants, the remainder of the Housing Plan represents a substantive step forward in addressing the significant housing needs of low income and vulnerable Ontarians, which have only been exacerbated as a result of COVID-19. Of particular interest is the commitment to provide 311,000 tenants with financial support to pay their rent, which could be the most significant opportunity to stem the likely wave of COVID-19 evictions that many of the organizations and individuals we work with remain deeply concerned about. Also of interest are the commitments to crack down on unlawful evictions due to landlord’s own use provisions and above guideline increases, two processes which we know to be widely misused and which contribute to the housing crisis in Ontario by facilitating rent escalation beyond a level that is reasonable. We are encouraged by the Housing Plan and hope that the omissions mentioned above may be addressed in future policy development or platform pieces.
September 2020 ushered in significant housing policy developments, with the Government of Canada and City of Toronto both taking a solid step in the right direction, and the Ontario government making some progress while still lagging behind its counterparts.
As we enter the second wave of the COVID-19 pandemic in Canada, these developments – big and small – could not come at a better time.
Here we’ve distilled the most important aspects that you need to know.
Toronto’s HousingTO 2020-2030 Implementation Plan was released on September 15, nine months after the City made an historic commitment to realize the right to housing. It contains the very first details of how the City intends to address affordable housing and homelessness over the next ten years.
The City has set the following ten-year targets:
While the City’s plan is a good next step to realize its commitments, key details including timelines and concrete dates, as well as additional resources, are needed to better understand how and when the City will reach the targets it has set for itself. Last week we identified the good and the gaps in their plan.
The good:
The gaps:
We also delivered our ideas of what we are hoping to see in the plan to the City’s Planning and Housing Committee, including establishing an Office of the Housing Commissioner and continued investment in eviction prevention services as a way to ensure the positive gains made by the HousingTO Plan are not erased.
In short, we asked the City to:
What’s next
The Planning and Housing Committee met on September 22 to discuss the implementation plan, and made several recommendations for improvements, in some instances even pushing for more ambitious targets. The Committee’s recommendations will be taken up by Toronto City Council at their meetings on September 30th and October 1st, where we will keep a watchful eye and report on further developments regarding the future of their housing plan.
Tune into Toronto City Council meetings:
On September 17, the Ontario government proposed Bill 204, a piece of legislation to temporarily freeze residential rent increases in 2021 for most rent-controlled and non-rent-controlled units.
Here is what you need to know about your rent in 2021:
Cracks in the ice
While the freeze will certainly provide some relief to Ontarian renters, the legislation fails on two major areas which housing and tenant advocates – including CERA – had called on the government to address:
The Government of Canada made several announcements related to housing and homelessness in their highly-anticipated Speech from the Throne on September 23, effectively moving their National Housing Strategy forward in a crucial moment for the country.
These are the commitments the Government of Canada has made related to housing and homelessness:
While these are all laudable goals, we look forward to seeing key detail and resources to support the implementation of these commitments. Stay tuned for further updates and analysis from CERA as the government releases more detail on their plans.
Nine months after making an historic commitment to realize the right to housing, the City of Toronto has released the very first details of how it intends to implement its 2020-2030 Housing Plan. Concrete action to increase the supply of affordable housing stock is needed now more than ever – in particular for low-income and racialized communities across the city – and the City’s Implementation Plan couldn’t come at a better time. However, while this plan is a good next step to realize its commitment, key details including timelines and concrete dates, as well as additional resources, are needed to better understand how and when the City will reach the objectives it has set for itself to realize the right to housing.
To be fair, the fact that the City has managed to prepare a 10-year implementation plan in the midst of a pandemic which is exacerbating the housing crisis and a range of other systemic issues is in itself a commendable feat. It is also proof of the City’s determination to follow through on its commitment to tackle this crisis head-on, and to not let a year go by – even as challenging a year as 2020 has been – without taking this significant next step.
Additionally, the inclusion of specific chapters dedicated to the most marginalized groups and communities is a hopeful sign that the City has not wavered in its resolve to adopt a rights-based approach to housing. This is highly significant, given that the impacts of the housing crisis are disproportionately borne by marginalized and racialized communities, including Black and Indigenous communities. The plan outlines that half of its new affordable units will be supportive housing, which aim to respond to the needs of the most vulnerable residents, including people who are living in homelessness or are at risk of becoming homeless.
The most glaring gap in this plan is that, for the most part, the City’s targets fall short of responding to the scale of the crisis. One example of this can be seen in how the plan aims to respond to the needs of Indigenous communities. Research by the Colour of Poverty in 2019 found that 87% of Indigenous people in Toronto qualified as low-income – representing roughly 40,000 people – and presumably most of them are in need of affordable housing. The target in Toronto’s housing plan aims to create around 5,000 new affordable housing units for Indigenous communities. By this measure, Toronto would need to increase its target by roughly 700% to respond to the needs of Indigenous people in the city, and they are just one community in need among many.
Another significant absence is that of a commitment to put a Housing Commissioner’s office in place. This is an essential accountability mechanism to ensure that the City continues to uphold and advance its commitment to realize the right to housing. Not only are their plans for establishing a Commissioner’s office vague, importantly there is also no mention of resources to be dedicated to this area of the plan.
The City’s Planning and Housing Committee met on September 22 to discuss the Implementation Plan, and following this meeting, they will bring their recommendations on the adoption of the plan to the next meeting of the City of Toronto Council on September 29. CERA delivered two deputations to the Planning and Housing Committee outlining our concerns around the necessity of establishing an Office of the Housing Commissioner and continued investment in eviction prevention services as a way to ensure the positive gains made by the HousingTO Plan are not erased. We will continue working with the City as part of the Right to Housing Toronto Network (R2HTO) to ensure that the City fully realizes its commendable commitment to right to housing for all.
In July 2020 the Ontario government passed Bill 184, which makes several amendments to the Residential Tenancies Act.
At CERA, we are deeply concerned about the negative impacts that this Bill will have on tenants, in particular for marginalized Ontarians who will be disproportionately impacted – individuals who are low income, racialized, newcomers to Canada, youth, and persons with disabilities.
Bill 184 comes at a time when Ontario renters are experiencing a decades-long, province-wide housing affordability crisis, and in the context of an unprecedented economic crisis caused by COVID-19.
Renters in Ontario have experienced an affordability crisis for years
Over the past decade, average market rent for a one-bedroom apartment has skyrocketed and in Toronto now sits at $2,300 per month, while half of Ontario renters earn less than $40,000 per year.
The current policy environment, which includes vacancy decontrol and the removal of rent control from units constructed after November 2018, combined with decreased funding for social housing initiatives, have contributed to record low vacancy and turnover rates and the driving up of average rent costs up by as much 50% over 10 years.
The discrepancy between current market rental rates with those of just five years ago provides landlords with strong incentive to illegally evict longer-standing tenants to increase profits. This troubling trend is evidenced by the fact that Landlord’s Own Use eviction claims (N12 applications) at the Landlord and Tenant Board have nearly doubled since 2015.
Once pushed out of their homes into an astronomically high rental market, low-income renters have little choice but to work extra jobs, move away from their communities, and limit spending on necessities. Many of the most vulnerable risk joining the 12,000+ homeless individuals currently living in Ontario.
The impacts of the housing crisis are disproportionately borne by marginalized and racialized communities including Black and Indigenous communities
Low-income renters across Canada are at the highest risk of eviction into homelessness, and they are disproportionately more likely to be racialized, young people, single parent households and immigrants.
Research by the Colour of Poverty shows that over 50% of racialized people in Canada live in homes which are unaffordable, inadequate and overcrowded, as compared to 28% of non-racialized households. Additionally, 52% of racialized people in Canada with the lowest incomes reside in Ontario, and 69% of low-income neighborhoods in Toronto are racialized communities. The research also found that 87% of Indigenous individuals in Toronto qualified as low-income.
COVID-19 has significantly escalated income instability and housing precarity for renters in Ontario and they need help
Ontario renters were already struggling in a hostile and unaffordable housing market before COVID-19 arrived. Between mid-March to June 2020, an estimated 4.9 million Canadians lost their jobs or had their employment hours drastically reduced. Those hit hardest are low-income earners, with half of those earning less than $16 an hour losing all or most of their income due to COVID-19.
Preliminary data shows that young people aged 18-24 are facing a 43% unemployment rate, with women being the first to be laid off and last to be re-hired. The Canadian Centre for Policy Alternatives estimates that 16% of unemployed workers are not eligible for CERB, nor are workers whose hours were reduced but whose monthly earnings remained above $1,000.
The fallout from Bill 184 could propel a mass homelessness crisis in Ontario
Bill 184 came forward in the context of an unprecedented economic crisis caused by COVID-19, where an estimated 50,000 arrears applications awaited processing when the eviction moratorium was lifted in August 2020.
The mass homelessness that could result from these evictions could be the largest human rights crisis that this province has ever faced and Bill 184 is only going to make it easier for that to happen.
Moreover, all of these impacts will disproportionately accrue to our most vulnerable and marginalized residents – people who face multiple barriers in particular those who are low income, racialized, newcomers to Canada, people who don’t speak English, youth, and people with disabilities. These are all groups who tend to have less information about their rights and the ability to assert them.
While the rest of the world is finally waking up to the systemic racism faced by black, indigenous and other racialized groups, we are deeply concerned that this bill will render significant numbers of racialized people homeless.
At CERA, although our recommendations to the Ontario government to reconsider provisions in Bill 184 were not taken into account, we will continue to advocate for a rights-based approach to housing, and for strengthened protections for tenants in Ontario, at a time when they are needed more than ever.
The Canadian Centre for Housing Rights (CCHR) has a long history of developing and driving forward precedent-setting litigation.
When we were known as the Centre for Equality Rights in Accommodation (CERA), we represented clients across Canada and acted in an advisory capacity on many ground-breaking legal challenges to policies and practices that denied disadvantaged groups access to housing, including:
CCHR also led a coalition of organizations, and served as a plaintiff on Tanudjaja, the historic challenge against the federal and provincial governments for violations of section 7 and 15 of the Canadian Charter of Rights and Freedoms. The case argued that governments created and maintained conditions that lead to and sustain homelessness and inadequate housing.
Across our history, CCHR has promoted interpretations and applications of the Canadian Charter of Rights and Freedoms in order to address rights violations faced by disadvantaged groups in need of housing. In this regard, CCHR worked in collaboration with the Charter Committee on Poverty Issues (CCPI), a national committee of low-income people and legal experts that advanced the rights of impoverished persons in Canada. CCHR assisted CCPI in test case litigation involving particularly marginalized groups.
CCHR also coordinated CCPI’s intervention at the Supreme Court of Canada in Gosselin v Québec (Attorney General), [2002] 4 SCR 429 – the only Charter case to date in which the Court had the opportunity to consider the extent to which section 7 of the Charter places obligations on governments to provide an adequate level of social assistance to prevent homelessness and its adverse effects.
CCHR also coordinated CCPI’s intervention in the case of New Brunswick (Minister of Health and Community Services) v G. (J.), [1999] 3 SCR 46 which dealt with access to legal aid for those living in poverty; Baker v Canada (Minister of Citizenship and Immigration), [1999] 2 SCR 817, on the status of international human rights law in the exercise of administrative discretion; Eldridge v British Columbia (Attorney General), [1997] 3 SCR 624 on positive obligations to address needs of disadvantaged groups under section 15 of the Charter; Thibaudeau v Canada, [1995] 2 SCR 627 on the rights of single mothers; Walker v Prince Edward Island, [1995] 2 SCR 407 and R. v Prosper, [1994] 3 SCR 236 on the right to state-funded counsel for impoverished accused; and Symes v Canada, [1993] 4 SCR 695 on the application of section 15 to socio-economic policies and taxation.
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