The Government of Canada announced its 2022 budget on April 7, with housing being among the top areas receiving investments during this pandemic recovery period. This budget is arriving at the halfway mark of the government’s ten-year National Housing Strategy (NHS), and there remains much room for improvement.
As investment dollars in the NHS have increased significantly since the inception of the strategy half a decade ago, the 2022 budget still does not direct adequate funds in the most effective way to address the housing needs of those living on low- to moderate-incomes. For many of these households, homeownership is well out of reach, while rental housing and alternative housing choices are becoming increasingly inadequate, inaccessible and unaffordable. Additionally, experiences of homelessness are growing in Canada.
While the 2022 budget falls short in responding to the urgent housing needs of those most impacted by the housing affordability and homelessness crisis, we analyze here the key housing investments that have been made, followed by a detailed outline of the amounts dedicated to specific housing initiatives.
Overall, this is a modest budget, with less spending than in the years before. A major portion of the budget is directed toward housing initiatives, with a total of $1.95 billion to be spent this fiscal year, and a spending promise of an additional $7.45 billion until 2027. There are also additional funds allocated towards Indigenous housing and infrastructure projects outlined in the budget. However, despite the fact that some of the housing investments are promising, they are unlikely to significantly improve housing affordability, adequacy and accessibility across Canada.
Arguably the most significant new funding initiative introduced in this budget is the investment in building new cooperative housing. The government plans to construct an estimated 6,000 new cooperative housing units, which is a major commitment to non-market housing options after decades of underfunding of the cooperative sector.
The government has also committed to adjusting its existing programs to increase the affordable housing supply. Affordability targets for the Rental Construction Financing Initiative (RCFI) will be increased to 40% of the total number of projects funded, and the government will adopt a new definition for affordability under this program. These changes respond to the important findings of a recent report from the National Housing Council, indicating that only three per cent of units created through the program to date would be affordable to lower-income Canadians. It remains unclear whether, with these measures, the government will prioritize funding for deeply affordable rental housing projects with rents considerably lower than the 80% average market rate through its commitments under the RCFI.
In addition, the government will continue its support for the Rapid Housing Initiative (RHI), one of its most effective programs in generating deeply affordable housing. This investment is estimated to create 6,000 new housing units that will be affordable to lower-income Canadians, with a quarter directed towards projects prioritizing women. Unfortunately, the government did not make the RHI a permanent fixture, and it remains unclear whether this initiative will continue beyond 2024.
The government also announced the new Housing Accelerator Fund, with a $4 billion commitment over five years. This new fund is aimed at supporting municipalities to increase their supply of housing by speeding up developments. The details of the program and requirements are yet to be developed. The government also plans to encourage the creation of secondary suites through its new Multi-generational Home Tax credit. This new fund has been allocated $5 million for this year, with increases in funding in year two and beyond. To stabilize housing for Canadians experiencing housing need, the budget continues to include funding for the Canada Housing Benefit (CHB). It includes an investment of $475 million in 2022-23 to cover a one-time $500 payment to households facing acute affordability challenges. To date, the CHB’s reach has been limited when considering the number of Canadians facing housing affordability challenges, and with its restrictive eligibility criteria, many Canadians will be unable to access this benefit.
The government has also committed $150 million over two years to build affordable housing in Nunavut, Northwest Territories and Yukon.
Finally, the government has indicated that it will conduct a review on the impact of increased commodification of housing, what it refers to as “housing as an asset class”, on renters and homeowners. Actions may be adopted following the review, which includes considerations for possible tax treatments of large corporations involved in speculation in the housing market.
The government committed to funding Indigenous housing through an investment of $4 billion over seven years, including funds for First Nations housing on reserves, and for housing in Inuit and Métis Communities. While this is an important step, it may be insufficient to have a significant impact on enhancing housing adequacy for First Nations communities. The Assembly of First Nations estimates that the cost of upgrading First Nations’ housing stock will be much higher, at $44 billion.
For years, Indigenous housing advocates have called on the federal government to establish an Urban, Rural and Northern Indigenous housing strategy, a recommendation that was once again formally made to the Minister of Housing and Diversity and Inclusion through the National Housing Council’s recent report. The budget commits funding to develop this long-overdue strategy, however, some Indigenous advocates are disappointed that the strategy is not explicitly led by Indigenous communities themselves.
The budget allocates considerable funds to retrofitting programs. Several initiatives are detailed, including a new initiative called the Greener Neighbourhoods Pilot Program. The program will target up to six community housing neighbourhoods to pilot the Energiesprong model, an approach to conducting retrofitting through larger-scale neighbourhood initiatives. Additionally, the expansion of the Canada Greener Homes Loan Program will include low-interest loans and grants to providers of low-income housing. It is unclear whether the government plans to approach these retrofitting initiatives in tandem with capital repair projects, which combined can more effectively increase residents’ health and safety, while reducing emissions and preserving the existing housing stock. It is also important that these projects maintain housing affordability levels and ensure that existing residents are the main beneficiaries of these investments.
The budget includes further commitments to various programs and initiatives meant to support the path to homeownership. Rent-to-own projects continue to receive funding support. The First-Time Home Buyers’ Tax Credit has been doubled and the government has indicated that it will explore ways to make the program more flexible. A new Tax-Free First Home Savings Account was introduced with a total budget of $725 million, which will come into effect next year.
Overall, the budget includes commitments for several important housing initiatives. However, it falls short in making a major contribution to solving the affordable housing crisis or supporting the growing housing needs of low- to moderate-income Canadians. Missing are commitments to urgently tackle the housing adequacy crisis in long-term care homes, plans to repair and preserve the aging affordable housing stock, efforts to build affordable rental housing options, expanding supports to women experiencing hidden homelessness, and effective strategies to tackle housing financialization. Despite the government’s priority to support women and children who are survivors of domestic violence to access stable housing, the budget does not include specific investments to reach this goal.
Additionally, the taxation policies outlined in the budget do not go far enough to effectively regulate domestic investors or curb speculative behaviours in the housing market.
Disappointingly, the budget does not include a commitment to advancing housing as a human right, as legislated in its National Housing Strategy Act. A rights-based approach would ensure that programs and funding allocations, even in the current recessionary context, effectively respond to the needs of those most impacted by the housing crisis.
Here is a detailed outline of some of the 2022 federal budget’s housing commitments:
Cooperative housing is an affordable, secure and inclusive housing option for many Canadians. The new Co-operative Housing Development Program will support the construction of 6,000 new cooperative housing units to be built over five years. This is the largest investment in cooperative housing by the federal government in 30 years. It shows the government’s renewed commitment to community-based non-market housing options. The 2022 budget allocates $500 million in funding and $1 billion in loans for the new program. The program will allocate $6 million this year, which is to be increased to $34 million next year and above $70 million in the following years. A portion of funding under this new stream will be redirected funds from the National Co-Investment Fund and the Rental Construction Financing Initiative. The program will be implemented in partnership with the Cooperative Housing Federation of Canada.
The 2022 budget invests $1.5 billion over two years to the Rapid Housing Initiative (RHI), with most of the funds earmarked for this fiscal year, and with at least 25 per cent dedicated to women-focused housing projects. This funding stream has proven to be an effective way to build deeply affordable, supportive housing and to urgently respond to the needs of vulnerable Canadians. While this funding is welcome and an important initiative, it is disappointing that the government has not committed to making it a permanent fixture with future funding commitments.
The new Housing Accelerator Fund received considerable funding to allow the federal government to support municipalities to streamline and speed up the construction of housing projects. It received a budget of $4 billion over four years, to help create 100,000 new housing units, with the majority of funds flowing after the second year. The implementation plan of this fund is yet to be revealed.
No new money has been allocated to the National Co-Investment Fund (NCIF). However, the government will advance $2.9 billion from already provisioned funds, speeding up the delivery of planned investments so that all remaining funds will be spent by 2025-26. The government aims to accelerate the creation of up to 4,300 new housing units and the repair of up to 17,800 units through the NCIF. The budget did not specify whether this fund will be streamlined and how it intends to ensure that it can more effectively support affordable housing projects.
The budget commits to investing $4 billion over seven years in housing for Indigenous Communities. This includes $2.4 billion over five years to support First Nations housing on reserves, as well as funds to support housing in Inuit and Métis Communities. In addition, through a $300 million investment over five years, the government will co-develop and launch an Urban, Rural, and Northern Indigenous Housing strategy.
The budget also outlines the government’s $75 million plan for the implementation of the United Nations Declaration on the Rights of Indigenous Peoples Act, with $4 million budgeted for this year. Through funding and partnership with Justice Canada and Natural Resources Canada, it plans to co-develop an action plan with Indigenous partners.
The budget outlines the government’s commitment to reform the Rental Construction Financing Initiative (RCFI) by enhancing affordability and energy efficiency requirements. It announced that eligible developers could be granted partial loan forgiveness for projects that significantly exceed these requirements. The budget announced that the RCFI’s goal will be to invest at least 40 per cent of its funds in affordable housing developments. The definition of affordability under this stream has also been revised. Affordability will now be defined as rents that are at or below 80 per cent of average market rent. However, in many cities across Canada where rents have skyrocketed, these affordability targets fail to create housing that is deeply affordable.
In its attempt to curb rising prices of residential homes, the budget outlined the federal government’s plans to prohibit investors who are not Canadian citizens or permanent residents from buying residential homes for a two-year period. A list of exemptions is provided, including for international students or people residing in Canada on work permits. Given that a major portion of the speculative and investor-driven demand is from domestic players, it is doubtful that this two-year ban will have any significant impact on reducing residential housing prices.
The Reaching Home stream is part of Canada’s main strategy to end homelessness, funding initiatives to support those experiencing or at risk of homelessness. The government announced new funding starting in 2024 of $562.2 million over two years, which will go to Infrastructure Canada to continue the funding for Reaching Home, ensuring the continuity of this program.
The Canada Housing Benefit received an additional $475 million to provide a one-time payment of $500 to recipients. The details of this one-time payment are yet to be released. Launched in 2020, the Canada Housing Benefit represents a joint funding commitment between federal and provincial governments of $4 billion over eight years.
The government has proposed a new tax credit to provide up to $7,500 for homeowners to build a secondary suite to be used by a senior or a person with a disability. Next year, in the 2023-24 fiscal year, households can use this credit to claim a portion of their renovation and construction costs for secondary suites.
A Housing Affordability Taskforce set up by the Ontario Government recently released a much-anticipated report recommending ways to combat the province’s housing affordability crisis. The Taskforce proposes several recommendations to increase the supply of market housing as the key way to resolve the problem. Broadly, the recommendations include a combination of changes to urban design rules, streamlining the housing approvals process, curtailing delays in developments that result from appeals at the Ontario Land Tribunal, promoting density, and targeting financial support towards municipalities who align their priorities with similar policy changes. The role of non-profits in increasing supply of affordable rental housing is only covered in the appendix of the document while other key options such as measures to protect affordable housing stock and rent regulations to curb arbitrary rent increases are not explored.
The Taskforce had only a couple of months to produce its recommendations during which it made some attempts to consult with myriad actors in the housing ecosystem. However, criticisms have been raised by housing advocates and experts regarding the limits to outreach, particularly in not adequately engaging with enough housing advocates, and the membership of the deliberating body being heavily comprised of representatives from the private sector.
Since the report’s publication, the Taskforce’s 55 recommendations have received a mix of supportive feedback and much skepticism. However, there seems to be some consensus that there is a need to act and be bold given the growing scale of the problem in Ontario. This sentiment is captured throughout the report, beginning with a call to prioritize housing in the province’s planning guidelines.
Many of the Taskforce report’s shortcomings stem from criticisms around scope and conceptual clarity. For example, the Taskforce’s restricted mandate to find “market housing” solutions overlooks the fact that the private sector has historically been unsuccessful in creating sufficient affordable housing options without some government support. More public interventions and the role of non-profits in filling this gap is only covered briefly in the document appendix.
In addition, the diagnosis of the problem, that a shortage of supply is leading to escalating housing prices, is questionable. Specifically, the target of creating 1.5 million homes over ten years has been criticized as not reflective of the problem at hand. In particular, the estimate in the report appears to be based on the assumption that every individual in need of housing is to live alone in a unit, rather than as part of a household. As such, the target appears to be too high and ought to be modelled instead at the household level, which would be a more useful reference to determine housing need. Using the latter frame, it may very well be the case that housing starts, at least for homeownership options, are keeping up with population growth across the country, as the trends of the past few years suggest. However, a shortage of affordable rental options remains no matter what lens is applied.
The implication is to make use of more accurate and granular data to enable nuanced distinctions between factors such as tenure choices, and in turn, help create more appropriate targets and associated interventions to meet those targets. The report does acknowledge that better data is required to determine housing needs including to understand, in more depth, which groups are facing the greatest barriers to accessing housing options.
Based on the premise that housing supply shortages should determine policy priorities, a variety of the recommendations are intended to remove barriers that slow development. Setting aside the contested premise, there remains a compelling case to fix bottlenecks in the development process to speed up construction. For example, the report shows how the development approvals process in Canada is one of the slowest among OECD countries, and that Ontario is particularly slow compared to the rest of the country. To this end, proposals to simplify policy documents and find efficiencies in existing urban design guidelines, for example, may hold promise.
However, stalled projects may not just be on account of the approval processes. For example, 19,000 units in Barrie that have received approvals have not yet proceeded with construction for various financial, engineering and related matters that are largely under the control of developers. In Toronto, the figure for a similar set of approved projects that are yet to get off the ground stands at 70,000. Plus, even as approvals may be perceived as roadblocks, the mechanisms still serve a fundamental purpose of upholding the integrity of the development process from environmental, social, economic and aesthetic perspectives. Any efforts to find efficiencies cannot be in good faith if not done deliberatively and measured against a rigorous process such as a cost-benefit analysis.
The report also recommends changes to the approval process through depoliticizing it and through fixing gaps in how existing mechanisms to appeal development proposals are perceived to be vulnerable to exploitation by local interests that may halt development for years. Indeed, there is a compelling case to be made against NIMBYism. Pushback from those living in existing neighbourhoods is not just exhibited in opposition to specific developments but against broader changes to regulatory practices, such as changing exclusionary zoning rules to be more inclusive. As the report finds, such practices have resulted in cities such as Toronto restricting 70% of its land for single family homes.
To this end, the report has made bold proposals to permit developments, as of right – in other words, without the need to go through the necessary zoning procedures – to, among other things, promote gentle density across the province, allow “unlimited density” for new construction near major transit stations, permit multi-tenant houses (rooming houses) to operate, and enable housing growth in underdeveloped land. These proposals are significant in acknowledging how the current trajectory of subdivisions for detached homes and condo-led developments are not producing the sufficient variety of housing options that Ontarians need. Notably, the report also states at the outset that existing land is sufficient for development with no further need for urban sprawl.
However, the menu of proposed regulatory rollbacks may also run the risk of watering down local powers. Various local governments have raised such concerns and noted how the province’s diverse demographic, socioeconomic and geographic conditions warrant a continuation of localized, democratic approaches to planning and development. For example, the recommended density threshold for as of right developments generally and across transit corridors might not be suitable in mid-sized communities, broadly implying the need to retain room for differentiated approaches to providing housing options across the province. Proposals to add guardrails to prevent potential delays at the Ontario Land Tribunals by local citizens has also been critiqued for stacking the cards in favour of developers.
To the extent that the province has contemplated ways to push municipalities to adopt these proposed reforms, it has been through recommending the creation of a Housing Delivery Fund that would reward those municipalities that synchronize their policies with the priorities of the Taskforce.
How the combination of proposals will lead to the creation of affordable housing options is not entirely clear in the Taskforce’s recommendations. Indeed, an affordable home is left undefined even though the report calls for a province-wide definition in the appendix. This does not mean that the question of affordability is not addressed. For example, as part of its proposed approaches to align government fees with promoting more housing, the Taskforce recommends waiving development charges for all affordable housing options that are guaranteed to remain affordable for 40 years.
In addition, there is likely room to find cost savings in a bloated regulatory regime. One study suggested that in eight cities in Canada, it costs an additional $229,000 to construct every new single detached house because of requirements such as zoning regulations. Bottlenecks in the labour supply chain can also do with fixing to reduce costs, the broad strokes of which are referenced in the report. Indeed, the premise of the report, that through finding an equilibrium between supply and demand, prices will become “affordable” is another circuitous route to which the document endeavours to fulfill its namesake – “The Ontario Housing Affordability Taskforce.”
And yet, the report overlooks many nuances. First, even if costs are reduced for developers through, for example, efficiency gains in the approval process and savings found in the supply chain, there is no guarantee that the proceeds will be passed on to the consumer, and by extension, a house be made “affordable.” Private developers and their financial backers are instead incentivized to maximize profits with little concern for broader public interest matters such as affordable housing unless they are required to take an interest in such matters. Absent any conditions, developers will likely continue to sell at rates as high as the market can bear.
Similarly, more density does not necessarily lead to more affordability, at least in prosperous areas and hot housing markets. On the contrary, this change may inflate the value of land and produce the opposite effect of making housing less affordable. In part, this is because such regulatory changes attract more people who will demand more services, which in turn, will attract more investments into the neighbourhood, all of which drives up the value of the area, and can be aggravated further by prospective buyers’ speculations of further price increases in the future. Such changes can gentrify neighbourhoods, in turn displacing traditionally lower and moderate-income residents from their communities.
The report does not contemplate such perverse impacts. It does indirectly explore the applicability of inclusionary zoning in its appendix but not in the context of how the policy could dampen the inflation of land prices and contribute to more affordable housing developments. Instead, it is more concerned about possible constraints placed on developers on account of its current iterations in cities such as Toronto.
In general, the Taskforce report pays little attention to how the role of managing “demand” has the potential to moderate prices. It rightly says that current government policies to manage demand, largely those adopted by the federal government, has not worked well. This is likely because the interventions amounted to tweaks to lending and borrowing requirements that effectively tinker at the edges and don’t have much of an impact on affordability. However, more consequential interventions to disincentivize investors to treat houses as investments – such as through charging a vendor a land transfer tax as opposed to the purchaser (which the province has control over) – have been given little attention. Plus, a more thorough investigation into the trade-offs between more rent regulation and vacancy control and its potential impacts on supply could add value to the current crop of proposals.
The report pays some attention to how investments in purpose-built rentals over time have declined. It rightly acknowledges feasibility constraints that inhibit further development of this much needed form of housing. To promote more construction of purpose-built rental apartment buildings, it largely recommends leveraging property tax incentives along with a combination of federal and provincial loan guarantees to support rental projects including affordable options.
There is also much promise in solutions explored to increasing the stock of affordable rentals in the appendix, where more public options are considered. The private market, after all, will not create affordable housing options alone, if at all. As such, proposals to providing incentives for affordable housing providers and surplus land for affordable housing are a good start. Importantly, the report acknowledges that many of the non-profit housing providers face the same barriers that private developers do – costly and time-consuming approvals coupled with restrictive zoning and local pushback to development. However, given the topic is not the focus of the report, a more detailed look into creating the conditions for and strengthening providers of deeply affordable housing options is missing.
As Ontario begins its legislative session, many of the report’s recommendations may be taken up for further consideration. These proposals offer a good starting point. However, the limitations of market solutions to creating affordable housing options are also made clear. Moving forward, a more integrated and effective strategy would more creatively incorporate the role of deeply affordable housing providers, retain a significant degree of local engagement to account for the province’s socio-economic diversity, and entertain matters beyond creating new supply such as through advancing strategies to preserve affordable housing stock.
Canada’s rental housing market is punishingly competitive. Low vacancy rates and out of control rental rates that are divorced from people’s ability to pay have left housing out of reach for many in the city. Finding housing that fits within one’s budget is extremely difficult, and the resulting housing instability has led to countless households being underhoused or homeless.
In addition to having to compete for housing in this environment, many Black households face anti-Black racism and discrimination from landlords and housing providers when trying to access housing, even though race is a protected ground under the Ontario Human Rights Code.
Discrimination in the housing market is unfortunately not rare. In July 2021, CERA and the Right to Housing Toronto held a workshop on discrimination, where two Black women shared some of the challenges they have faced when trying to find and maintain safe and accessible housing in the GTA – from passive aggressive comments to blatantly discriminatory housing ads. The women shared that the racial discrimination they faced was compounded by other factors related to their income, family status and disabilities. After long searches and multiple refusals from landlords, both women were forced to accept the only options open to them, in unsuitable housing where they did not feel comfortable or safe.
In 2009, CERA conducted a study about discrimination faced by renters in Toronto’s housing market. The important findings from this work have informed our advocacy efforts for equitable changes to housing policy and legislation. CERA’s research study found that Black housing seekers faced discrimination based on multiple human rights grounds, such as race, family status and/or place of origin. Intersectionality is also relevant to the difficulties Black renters can experience when trying to find housing. Our study found that 1 in 4 single parents who were Black experienced discrimination when searching for rental housing, and this continues to be reported by the media.
In the same CERA study, the research found that racial discrimination, while prevalent, was not explicitly stated by housing providers. Media reports show that it is common for Black renters to face additional questions and inquiries from housing providers due to discriminatory stereotypes. The consequences of housing insecurity for racialized communities have only worsened in the decade since our study was released and have become dire with the onset of COVID-19.
Acknowledging the systemic racism that has prevented many Black Canadians from accessing housing is crucial to advancing effective change. This discrimination has not only impacted individuals but has also meant that Black renters have been shut out of entire parts of the city. The right to housing must be a reality for all households on an equitable basis, and it cannot be fully realized without addressing the housing discrimination experienced by the Black community.
In order to even begin to address anti-Black racism in housing, governments must take some basic steps:
CERA is dedicated to helping renters facing anti-Black racism and discrimination from their housing providers. If you are being discriminated against by your housing provider,please contact us to speak with a caseworker about how we can help to advocate for you:
Renters can also reach out to:
The City of Toronto has formulated an Inclusionary Zoning (IZ) policy following two years of extensive research, analysis, and consultations to chip away at its target of creating 40,000 affordable rental homes by 2030, a commitment enshrined in its HousingTO 2020-2030 Action Plan.
This planning tool is a significant addition to the City’s existing menu of initiatives that are designed to increase affordable housing stock – notable examples include financial incentives through the Open Doors Program and utilizing surplus municipal properties for mixed income developments. Inclusionary Zoning is a policy that captures value generated from development activity and sets it aside for affordable housing options to be created, ideally, within the same development. This strategy has the potential of creating 25,000 new affordable units by 2030 across Toronto.
Last week, the Planning and Housing Committee approved a version of an IZ proposal which will be voted on at City Council next week. We hope that Toronto will not only adopt the policy but move forward with a version that is needs based and is consistently strengthened based on robust data as the policy evolves over the coming years.
City of Toronto Staff have made innumerable proposals related to extracting more significant contributions from the development industry for affordable housing for over twenty years. Yet, it has only been about ten years since provinces across Canada have started to empower their municipalities to adopt IZ. Toronto appears to be one of the first cities to consider a version that is comprehensive and mandatory.
The City’s current iterations have emerged following provincial passage of amendments to the Planning Act in 2016 which authorized municipalities to use IZ. A regulatory framework was released shortly thereafter laying out key conditions and parameters for municipalities in Ontario to adhere to when considering adoption of the policy.
Regulation 232/18 has afforded some flexibility for municipalities to chart their own path so long as a preliminary needs analysis and financial feasibility study is conducted while planned projects with less than 10 units are exempted. Subsequent provincial amendments in 2019 restricted the application of the policy to the boundaries of transit hubs or “Protected Major Transit Station Areas” (PMTSA).
The City has since conducted its own housing needs analysis along with three rounds of financial impact assessments, the details of which have been the subject of considerable feedback from myriad stakeholders in the housing ecosystem. The studies and engagements inform a policy that consists of design elements that have potential for increasing and sustaining affordable housing supply, while some aspects warrant reconsideration.
IZ as a requirement
The City has proposed that inclusionary zoning will be mandatory in new developments. Various exemptions remain, for example, for those development applications that were received before the policy was introduced. In general, however, evidence from other jurisdictions that have introduced a mandatory approach typically demonstrates greater success in producing affordable housing options compared to voluntary arrangements.
Set aside rates and phase-in
The proportion of units that should be set aside for affordable use varies by dwelling type and the area of the city in which the development will take place. This reflects the need for flexibility and alignment with local context to effectively deliver affordable housing. For example, some of the suburban areas of the city are exempt from the policy because there is not enough projected growth to absorb the costs of IZ. Over time, purpose built rental units have lower set aside rates partly because of greater uncertainty associated with returns on investing in such buildings. Adding stricter conditions may disincentivize construction of this much needed housing option.
Indeed, concerns around shocking the markets on account of the new policy, and in turn restricting supply, have helped shape an approach that slows the phasing in process of the policy and lowers the set aside rates of all property types relative to earlier estimations calculated by the same city commissioned third party organization (NBLC). Remarkably, purpose-built rentals do not face any requirements for the first five years.
In practice, such conclusions are based on two tests. The first calculates whether a certain area’s land value increases by at least 10% after rezoning and the introduction of IZ. Lower rates are assumed to render the policy unviable in that area. This threshold has been applied in all the feasibility analyses (In addition, the profits of developers are also accounted for, at 15%, as part of expected costs of development).
A second test was recently introduced to measure the drop in potential land values after an area is rezoned. It is conceivable that in a rezoned land, projected profits from land price increases might drop dramatically after factoring in IZ costs while still remaining above the 10% threshold. The test posits that a drop of anything beyond 15% could spook the markets, potentially prompting landowners to withhold their assets from sale in anticipation of prices to increase at an undetermined later date.
The rationale for this second test, in particular, is flawed. It adds an additional layer to maximize profits for a group that are already guaranteed windfalls on account of the first threshold. Second, the limits on the drop seeks to create a floor so that speculative behaviour can continue, a practice the policy is supposed to dampen significantly. Thirdly, it would not make sense for landowners to sit on their assets for a prolonged period in anticipation of land increases given that the program is here to stay, permanently. Four years of study, and two years of consultations that IZ is coming has been a clear signal for markets to start adjusting. Plus, earlier versions also gave room for the program to be phased in albeit at a quicker pace. The additional test therefore looks unnecessary and can be removed.
Incentives and alternatives
IZ programs tend to have incentives and alternatives that are meant to help developers manage their costs and effectively deliver. However, only a few seem to work. The City’s limited menu demonstrates its cognizance of such evidence. First, newly zoned areas where IZ is applied will allow for more density. However, no further density bonuses are made available unless developers volunteer to add more affordable units than what is required. This is a fiscally responsible approach that also ensures projects are financially viable.
Second, developers are given some room to construct affordable units off-site so long as the options are made available in the same market area and in a timely manner. Such requirements mitigate the real risks of less lucrative options being constructed later, when affordable housing is desperately needed, and ensures that they are not located in less resourced areas, depriving lower income communities from accessing key amenities and opportunities that are critical requirements for an adequate home. The process for availing of this option is also laid out meticulously in the City’s implementation guidelines.
Definition of affordability
The City has also proposed revising its definition of an affordable IZ unit using two steps. First, the average market rate of a particular unit is compared to whether income groups that fall below the 50th to 60th percentile, depending on the unit size, are paying no more than 30% of their income on shelter. Second, whichever option is the lowest amount determines what is deemed affordable for that unit size. Currently, this means that most unit types are pegged against income, and in turn imply that they are to be made available at below market rates. However, the average market rate metric continues to be adopted for two-bedroom rental units given that the calculated amount is lower than the income-based measure in this case. While this arrangement accounts for market and demographic variations over time and attempts to prioritize lower income earners, households on the lowest end of the income spectrum are likely not able to live in these units unless they receive additional financial supports.
Coverage and cut off
Provincial restrictions on where the City can apply IZ is at odds with an otherwise broad framework that affords considerable flexibility for municipalities to craft its own IZ policy according to its own needs. Indeed, the policy typically works better when applied as widely as possible given that this strategy offers more variety of options and creates mixed income communities across the city.
The City has tried to counter part of these restrictions through barring developers from adding replacement units as part of new proposals. Only new developments are considered to ensure that affordable stock is increased. However, project plans with less than 100 units or with a gross floor area of less than 8000 metres squared are exempt. This is less expansive than earlier proposals developed by the City, limiting the range of housing options for prospective tenants.
Period of affordability
It is required that units built through IZ remain affordable for 99 years, allowing for an arrangement that is effectively permanent. The challenge will be in enforcement, a consideration that appears to have received significant attention. In the proposed arrangement, the City has articulated high level roles and responsibilities along with annual reporting requirements to track and ensure compliance. A process is also in place to enable resale of units by owners during this period while maintaining that they remain affordable. However, there is likely room for more iteration, for example, in more clearly detailing out the function of third-party administrators, actors who are expected to manage much of the affordable units.
Other implementation considerations
The policy stands out in its requirements that prospective residents of affordable units have the same access to amenities and other dwelling services, and that the quality of the unit be the same as their market counterpart. Such provisions ensure affordable housing is accessible and livable. In addition, it also accounts for demographic variations, such as family needs, through requiring that there are sufficient multi-bedroom options available at affordable rates for projects that have a significant number of units with more than one-bedroom.
The selection process of tenants or owners consists of clear allocation of roles and responsibilities to minimize any uncertainties. In addition, it appropriately leverages City resources to administer the process and is reasonably inclusive which is demonstrated in eligibility criteria that includes citizens, permanent residents, and temporary residents who have applied for permanent residents.
The City’s policy has many important ingredients to increase the supply of affordable housing options for those living on low to moderate incomes. In addition, through extending the period of affordability into perpetuity, this policy can ensure that prospective residents are afforded a much needed degree of tenure security.
But there is room for this policy to evolve beyond its current form to become more effective and inclusive. It is still unclear how many affordable units the policy can truly create. Data gaps need to be filled to form clearer conclusions about the variety of housing options that can be created, whether the threshold for where IZ can be applicable can be lowered, and whether a larger portion of units within a building can feasibly be set aside for affordable use. In particular, assumptions around how the market will react need to be revisited keeping in mind that the policy ought to reduce some speculative behaviour.
The policy also creates innumerable new opportunities for collaboration with civil society and non-profit housing providers, many of whom will likely be tasked with administering the affordable units. It will be imperative to create platforms for such entities to engage consistently and share lessons learned from their day-to-day management experiences. Plus, there will likely be a role for the province to reconsider its current restrictions as the program evolves.
Inclusionary Zoning alone cannot create enough affordable housing options for the growing housing needs of Torontonians. Indeed, it is not feasible to rely exclusively on extracting value from private development to create deeply affordable homes. A major reason for the housing crisis in Toronto is due to federal and provincial governments retreating from their traditional obligations to support the creation of affordable housing, such as social housing options for lower income households.
While the federal government stepped up its commitments through its National Housing Strategy, there has been limited focus on increasing deeply affordable housing options and maintaining social housing. Plus, there is room for greater intergovernmental collaboration, for example, through ensuring provinces cost-match funds made available through federal initiatives. In addition, local level barriers to development, such as NIMBYISM and rickety approvals processes also warrant attention. Such issues must be considered alongside policies such as IZ to deliver on a comprehensive approach to addressing Toronto’s affordable housing crisis.
“One misconception is that people don’t want to get better”
In recent years, there has been an uptick in public campaigns aimed at destigmatizing mental health. While these campaigns are undoubtedly important and have had a positive impact, there remains work to be done, especially when it comes to mental health and homelessness.
We spoke with two people who have experience working with the homeless population about some of the challenges that this group faces and how a Housing First model can help.
Mo Moore is a family doctor who runs a clinic out of a homeless shelter in St. Catharine’s, Ontario. In her clinic, she sees people with a variety of concerns.
“For some visits, I see some regular family medicine issues like diabetes and blood pressure control —things I might see in another setting — but I see a much higher proportion of complex mental health concerns, substance use concerns, complex physical health concerns, and chronic disease.”
Studies have shown that people who are homeless are more likely to experience mental health challenges than the general population. For some, these issues can precede the onset of homelessness. As the Homeless Hub notes, “people with poor mental health are more susceptible to the three main factors that can lead to homelessness: poverty, disaffiliation, and personal vulnerability.”
Mental health challenges can also contribute to homelessness or worsen with continued homelessness.
“Some people are quite forthcoming with the story of how they became homeless, and it sort of varies,” Dr. Moore says. “A lot of the time, people may have had a job and a family and may have gone through some sort of trauma which impacted their mental health, which led them to using substances to cope, and then the substance use sort of took over and they lost [things] they had because of that. I would say that is a relatively common scenario.”
Another common issue is supporting people’s mental health in shelters.
“Mental health wise, you are in a setting where you’re really just in survival mode, you are trying to get through your day. And a lot of people have a history of trauma and violence and sometimes that happens within shelter walls,” Dr. Moore explains. “You are looking out for your own. You are making sure your stuff is not getting stolen. It is really not a place where you can make any meaningful steps forward to healing when you are just trying to survive through the day, and I think that is a huge challenge.”
Safiyah Husein is a senior policy advisor with the John Howard Society of Ontario (JHSO), an organization that has been operating in Ontario for over 90 years, and has 19 community offices across the province. JHSO provides “programs and services that help people affected by the justice system develop key life skills, navigate issues of criminal justice, and build productive futures after incarceration.”
Husein says that what a lot of people don’t realize is that mental health, homelessness, and justice system involvement are interconnected.
In 2018, John Howard Society took part in research project called Closed Quarters that looked at how the “criminal justice system fosters housing insecurity and contributes to homelessness, and the extent to which mental health and addictions problems are implicated in this.”
“It is sort of a cyclical relationship. We see that that mental health issues can result in justice involvement, which can result in homelessness and vice versa,” Husein says. “When we’re talking about mental health, we recognize that there is often a lack of mental health service providers in the community. There’s a lack of support. A lot of the time, for folks that are struggling with mental health issues, that can often be exacerbated by homelessness, but it can also lead to homelessness.
And then we know that those are also risk factors for criminal justice involvement, which can again worsen those issues.”
Both Dr. Moore and Husein say they have seen Housing First approaches help people experiencing mental health challenges and homelessness to better be able to navigate those challenges and find a semblance of stability.
Housing First involves quickly moving people experiencing homelessness into stable and long-term housing, and then providing additional supports as needed.
“There has been some research done of the Housing First model where people are provided with safe housing first, with supports usually built into the program, and that has been shown to have positive outcomes. [These studies show that] housing stability [results] in decreases in violence, fewer accidental overdoses, and overall fewer deaths with those type of supports been built in,” Dr. Moore says.
The John Howard Society often takes a Housing First approach with their clients and has found this approach successful for many of their clients.
Husein shared one example with us:
“Jack* is a true example of the benefits of our Housing First mentality. The client has struggled for over a decade with substance abuse issues and homelessness resulting from those same struggles. When the client reached out to our housing worker at John Howard Society of Toronto, he had been living in an encampment at Trinity Bellwoods with his female partner who was dealing with similar addiction and legal issues as the client in question.
With the help of our Post incarceration Housing Department, the client was found housing and immediately his life began to change for the better. Both in his wardrobe and appearance, the client quickly began presenting himself better physically, as he had access to a laundry room, and place to store his clothing…After being housed the client began to reach out to his housing worker for information on drug treatment programs, and for aid in securing his rent payment moving forward through income support programs.
Jack has since completed an in-treatment addiction program that he says has changed his life. It is also worth mentioning that since being housed the client’s live-in partner, Anna*, has also had the opportunity to successfully complete an in-treatment drug program. Both clients are currently sober for the first time in over a decade, and have sustained housing for six months, which is the longest time they have held housing in over two years. Jack is currently seeking to re-enter the work force, as he has a degree in social work and would like the opportunity to help people in at risk communities like the ones he has inhabited as best he can.”
*Names changed to protect the clients’ privacy
Mental health and homelessness are complex topics but learning what “some of the challenges and barriers that this population faces just in day to day living” can help with understanding this complexity, as well as the resiliency of this population group, Dr. Moore says.
“I think maybe one misconception is that people don’t want to get better and if they could just do more, or get a job, then they would be able to get housing and get out of the situation,” Dr. Moore says. “But when you see what people have gone through and see the barriers they face every day, you would realize that is just not possible without our system having better supports for this group.”
If you would like to know more about mental health, homelessness, and the justice system, check out these resources by the John Howard Society of Ontario: Broken Record, Closed Quarters, and Poverty Reduction Submission.
Canada recognized the right to housing in 2019 through the passing of the National Housing Strategy Act, which commits our government to the progressive realization of the right to housing. This means that housing should meet certain conditions to be adequate such as being affordable, habitable and accessible. For Canada’s aging population living in long-term care (LTC) homes*, the right to housing means that their homes are safe, adequate and accessible. However, the COVID-19 pandemic has intensified the substandard conditions experienced by residents of many LTC homes, many of which sadly became sites of viral transmission that resulted in a high number of preventable deaths. It is important that our governments adopt policies that will prevent such a tragic outcome in the future.
LTC homes are different than assisted living facilities or retirement homes as these are designed to house residents who are more independent and require less assistance with activities of daily living (ADL). Individuals who suffer from chronic conditions, trauma or illness that limit their ability to carry out basic self-care tasks live in LTC homes, which support them with the provision of care.
As such, LTC are homes to their residents and their right housing, including adequate facilities, should be protected. This includes proper infection control, clinical management and the maintenance of a basic standard of living, and ensuring that residents live in safety and dignity with essential health services provided.
In Canada, LTC homes are funded by the federal government through the Canada Health Transfer to the provinces and are a provincial responsibility governed by the Federal-Provincial Fiscal Arrangements Act. However, LTC is not included in the Canada Health Act as an insured health service, so the provinces and territories are not required to fund LTC homes in order to receive federal funding. This has led to the uneven allocation of funds which has in turn resulted in the delivery of varying standards of care across the provinces
According to the Canadian Institute for Health Information (CIHI), there are 198,220 LTC beds across 2,076 homes in Canada. Of those homes, 46% are publicly owned and operated and 54% are privately owned and operated. This means that with a population of 6,835,866 people aged 65 and older, there are 29 LTC beds per 1,000 older persons.
While not every older person in the country will rely on a LTC home, the limited availability of these homes means limited housing options for residents who need them. But older persons are not the only people who rely on LTC homes. In Ontario, while older persons represent the majority of LTC residents, 6.6% are younger than 64 years old, and the limited number of LTC options impact them as well.
There are several systemic issues that serve as barriers to adequate housing in LTC homes, which were exacerbated by the COVID-19 pandemic. Understaffing, overworked staff, lack of inspections and accountability mechanisms, poor design and age of the homes, the presence of mould, bug infestations, overcrowding and neglect are just some examples. The pandemic has brought these systemic issues to the surface, forcing our society to reflect on ways our aging population is treated and initiating a renewed call to make LTC homes safe and adequate for their residents.
People over the age of 70 are twenty times more likely to require hospitalization from COVID-19 and are at even greater risk of death, as indicated by the rates of infection and death across geographies. LTC facilities in Ontario and Quebec represented 82% of all COVID-19 cases and 88% of all deaths. Many of the residents of LTC homes were reported to live in conditions that were undignified and unsafe. For many of the residents who were forced to physically remain in their rooms and unable to leave, isolation also became a major concern.
Additionally, many of these homes are experiencing staff shortages, which has led to an overworked staff who experience physical and psychological stress. LTC staff are also increasingly vulnerable to infection, representing 10% of infection cases across the country. In larger LTC homes with shared rooms, the likelihood of an outbreak was much higher, which led to increased absenteeism, increased workloads for already overworked staff, and ultimately, reduced the ability of these homes to provide an adequate standard of care.
The pandemic not only showcased the living conditions of our LTC residents in Canada, but it also illuminated the challenges associated with providing adequate housing for older populations living in LTC homes globally. However, some countries have fared better than others, as their LTC homes are able to meet standards of care and housing adequacy.
So, what makes some countries more successful at providing adequate LTC homes to their residents?
The approach to managing and funding LTC homes that a country takes will depend greatly on several factors including a country’s history, political landscape, available resources, culture, community standards, the role of government in social welfare and the varying emphasis on personal/familial responsibilities. Despite differences in funding mechanisms and qualifications, there is very little difference between public expenditures dedicated to LTC homes, taken as a percentage of GDP, but the standard of care varies greatly.
According to the Global AgeWatch Index, Norway is a leader in the delivery of LTC homes. It offers universal coverage as part of a tax-funded social care system, though care is municipally implemented and there are strong federal regulations. There is also an emphasis on the adoption of technology to account for staffing issues and as a means of prolonging the transition from in-home care to a LTC home. Generally, Scandinavian countries take great efforts to enable older persons to stay in their own home with the necessary accommodations to ensure a standard of care and quality of life is provided. Denmark and Sweden both offer the option of home or institutionalized care. In Denmark, private care providers are subject to quality and price standards. The government will reimburse family members for lost wages when informal care is provided to loved ones in their own homes. Three-quarters of municipalities sponsor integrated home care systems which has helped to reduce the number of people who rely on nursing home care. In Sweden, individuals can opt for private home care. In 1992, reforms decentralized care which resulted in a 50% decrease in the ratio of beds to clients. There are also separate facilities for individuals living with dementia.
Just as the delivery of LTC in Norway, Denmark and Sweden is distinctly Scandinavian, in the United States the approach is distinctly American. In the United States there is stark political opposition to tax-funded LTC homes through universal healthcare coverage and instead they rely on safety net or means-tested programming. The country relies on insurance-based care and private care models, and an LTC home is offered through Medicare and Medicaid. The federal government sets the standards, individual states are responsible for inspection of the facilities.
Australia has proven to be a leader in the delivery and monitoring of LTC homes. There are strict accreditation and inspection processes in place, and strong oversight which enabled it to fare well during the COVID pandemic. All homes are expected to provide equal care and funding is allocated based on overall resident dependency.
While LTC homes exist in other countries that are not included in this article, it is important for policy-makers to look at ways other countries protect their older persons and provide a LTC home that is adequate for their residents, allowing them to live with dignity.
Looking both inward, and at other examples globally, there are several ways our governments can ensure adequate housing for older persons living in LTC homes.
One way to do so would be to institute better standards and oversight in our LTC homes. Some advocates have pointed to the need to set national standards as a condition of federal funding to provinces in order to improve the provision, oversight and accountability of care delivery that may include infection prevention practices. If this is the direction the federal government takes to improve our LTC homes, it’s vital that the federal and provincial governments better coordinate and adopt an emergency response plan to proactively address systemic barriers to adequate LTC homes.
Another important move that can increase adequate LTC homes is to make home care an option, enabling older persons to stay in the comfort of their home. This move would improve a person’s dignity while relieving the strain on LTC homes to care for the most vulnerable. To make home care a viable option, it’s important to ensure that resources are made available to caregivers to provide the necessary standard of care.
Staffing and resources for LTC homes also needs to be improved in order to lift the strain on this system as a whole. Governments can ensure there are enough trained staff and make available the necessary resources to run these homes adequately, improving the minimum standard of care. Likewise, infrastructure improvements such as the age and design of LTC facilities could also enhance the delivery of care.
Lastly, LTC homes that are culturally adequate should be increased to help residents who suffer from cognitive decline and regression as their sense of security, fulfillment and dignity of personhood would improve greatly. This could include something as simple as having a staff member who speaks the same language or grouping together people with similar cultures and beliefs. Cultural adequacy also means providing spaces for traditional practices and healing approaches.
While many conversations around the inadequacy of LTC homes and their inability to protect their residents during the pandemic have revolved around the private vs. public debate, what we can conclude is there is a defined need to rethink the care model altogether. Solutions may lie in increasing resources to enable home care or adopting transformative resident approaches like a compassionate dementia care model.
Rethinking the care model also means listening to the needs of the residents of LTC homes and finding ways to engage them in identifying solutions that will meet their needs. It means listening to the families of residents, who care about their loved ones and often shoulder the burden of LTC unaffordability and inadequacy. Family members have been calling for improvements to LTC homes’ living conditions from a place of compassion so their loved ones can live dignified lives. It also means listening to policy makers and advocates who are equipped with the knowledge and evidence-based research pertaining to this complex issue and the approaches that can be leveraged to enhance LTC homes and the standard of care being delivered.
When we rethink the care model, we ensure that our older persons are not only able to live in safe, adequate and affordable homes, but it also reflects who we are as a society when we take care of our aging population and ensure their fundamental human rights.
*An LTC home is defined by Health Canada as a “living accommodation for people who require onsite delivery of twenty-four hour, seven days a week supervised care, including professional health services, personal care and service such as meals, laundry and housekeeping.” In the province of Ontario, the Long-Term Care Homes Act states that, “a long-term care home is primarily the home of its residents and is to be operated so that it is a place where they may live with dignity and in security, safety and comfort and have their physical, psychological, social, spiritual and cultural needs adequately met.
Canada is in the midst of a deepening affordable housing crisis. Forty percent of Canadian renter households are paying unaffordable rents, spending nearly a third or more of their income on housing. Increases in average housing costs continue to outpace increases in the average income for renter households – a dire situation that has been exacerbated by the COVID-19 pandemic crisis. Having safe, adequate, and affordable housing will be essential throughout the remainder of the pandemic and is critical for the post-pandemic recovery.
Housing is a major concern for the majority of Canadian voters in this upcoming federal election. The Centre for Equality Rights in Accommodation (CERA) and the Advocacy Centre for Tenants Ontario (ACTO) have come together to present a summary of eight housing policy priorities of each major party’s platform. By knowing the housing priorities and policy proposals of each party, voters can be more informed when they head to the polls on September 20, 2021.
See the party platforms in full:
Liberal Party | Conservative Party | New Democratic Party | Green Party
Canada has an obligation under international law to use the maximum of its available resources to realize the right to housing for all. The National Housing Strategy Act – Canada’s current housing policy that was passed into law in 2019 – acknowledges this obligation and commits the government to progressively realize this right over time.
LIBERAL PARTY
CONSERVATIVE PARTY
NEW DEMOCRATIC PARTY
GREEN PARTY
A legacy of colonization and ongoing systemic racism have contributed to significant housing challenges for Indigenous communities. Indigenous peoples make up 4.3% of the population in Canada, but represent between 28-34% of the homeless population, and 20% of Indigenous households are in core housing need. Indigenous communities and housing advocates have repeatedly called for national Indigenous housing strategies to be created by and for Indigenous people.
LIBERAL PARTY
CONSERVATIVE PARTY
NEW DEMOCRATIC PARTY
GREEN PARTY
Canada has a major shortage of affordable housing, especially for lower to middle income households. A wider variety of affordable options are required to meet the needs of an increasingly diverse population. Policy solutions that increase housing choices are essential, especially to build affordable purpose-built rentals, non-profit housing, and co-operative housing.
LIBERAL PARTY
CONSERVATIVE PARTY
NEW DEMOCRATIC PARTY
GREEN PARTY
The ‘financialization of housing’ is the rising trend of treating a home primarily as an investment that generates wealth rather than a place to live. Institutional investors now own nearly 20% of the country’s purpose-built rental apartment stock, and their profit-maximizing business model is one of the main reasons behind the loss of affordable rental housing across Canada.
LIBERAL PARTY
CONSERVATIVE PARTY
NEW DEMOCRATIC PARTY
GREEN PARTY
Over the past 15 years, affordable housing units have been lost without enough units being built to replace them. Policy options that could help retain the supply of affordable housing include implementing rent control and making investments in maintenance and capital repairs to ensure these units remain in good condition. Addressing the backlog of repairs to social housing units is also needed, and could be a more affordable option than creating new affordable units.
LIBERAL PARTY
CONSERVATIVE PARTY
NEW DEMOCRATIC PARTY
GREEN PARTY
It is estimated that a quarter of a million households were unable to pay their rent in 2020 alone, with many facing the threat of eviction from their homes. While some direct financial support has been available to help commercial tenants stay afloat, resources like rent relief have not been provided to support residential renters directly.
LIBERAL PARTY*
CONSERVATIVE PARTY*
NEW DEMOCRATIC PARTY
GREEN PARTY
* No mention of direct rent relief to tenants
An estimated 35,000 people experience homelessness in Canada on any given night, and the number of people experiencing ‘hidden homelessness’ is estimated to be at least double that figure. Indigenous people, youth, women, people living with disabilities, and racialized communities all face unique challenges with homelessness.
LIBERAL PARTY
CONSERVATIVE PARTY
NEW DEMOCRATIC PARTY
GREEN PARTY
Homeownership is increasingly out of reach for people across Canada, and it is no longer only an issue in and around major urban centres like Vancouver and Toronto. According to the Canadian Real Estate Association, across Canada the average price of a home increased by more than 30% between July 2019 to July 2021. Low mortgage rates, low housing supply, money laundering and the financialization of housing are some of the major factors contributing to soaring prices.
LIBERAL PARTY
CONSERVATIVE PARTY
NEW DEMOCRATIC PARTY
GREEN PARTY
Lorem ipsum dolor sit amet, consetetur sadipscing elitr, sed diam nonumy eirmod tempor invidunt ut labore et dolore magna aliquyam erat, sed diam voluptua. At vero eos et accusam et justo duo dolores et ea rebum. Stet clita kasd gubergren, no sea takimata sanctus est Lorem ipsum dolor sit amet.
Lorem ipsum dolor sit amet, consetetur sadipscing elitr, sed diam nonumy eirmod tempor invidunt ut labore et dolore magna aliquyam erat, sed diam voluptua. At vero eos et accusam et justo duo dolores et ea rebum. Stet clita kasd gubergren, no sea takimata sanctus est Lorem ipsum dolor sit amet.
Lorem ipsum dolor sit amet, consetetur sadipscing elitr, sed diam nonumy eirmod tempor invidunt ut labore et dolore magna aliquyam erat, sed diam voluptua. At vero eos et accusam et justo duo dolores et ea rebum. Stet clita kasd gubergren, no sea takimata sanctus est Lorem ipsum dolor sit amet.
Lorem ipsum dolor sit amet, consetetur sadipscing elitr, sed diam nonumy eirmod tempor invidunt ut labore et dolore magna aliquyam erat, sed diam voluptua. At vero eos et accusam et justo duo dolores et ea rebum. Stet clita kasd gubergren, no sea takimata sanctus est Lorem ipsum dolor sit amet.
Lorem ipsum dolor sit amet, consetetur sadipscing elitr, sed diam nonumy eirmod tempor invidunt ut labore et dolore magna aliquyam erat, sed diam voluptua. At vero eos et accusam et justo duo dolores et ea rebum. Stet clita kasd gubergren, no sea takimata sanctus est Lorem ipsum dolor sit amet.
Lorem ipsum dolor sit amet, consetetur sadipscing elitr, sed diam nonumy eirmod tempor invidunt ut labore et dolore magna aliquyam erat, sed diam voluptua. At vero eos et accusam et justo duo dolores et ea rebum. Stet clita kasd gubergren, no sea takimata sanctus est Lorem ipsum dolor sit amet.
Lorem ipsum dolor sit amet, consetetur sadipscing elitr, sed diam nonumy eirmod tempor invidunt ut labore et dolore magna aliquyam erat, sed diam voluptua. At vero eos et accusam et justo duo dolores et ea rebum. Stet clita kasd gubergren, no sea takimata sanctus est Lorem ipsum dolor sit amet.
Lorem ipsum dolor sit amet, consetetur sadipscing elitr, sed diam nonumy eirmod tempor invidunt ut labore et dolore magna aliquyam erat, sed diam voluptua. At vero eos et accusam et justo duo dolores et ea rebum. Stet clita kasd gubergren, no sea takimata sanctus est Lorem ipsum dolor sit amet.
Lorem ipsum dolor sit amet, consetetur sadipscing elitr, sed diam nonumy eirmod tempor invidunt ut labore et dolore magna aliquyam erat, sed diam voluptua. At vero eos et accusam et justo duo dolores et ea rebum. Stet clita kasd gubergren, no sea takimata sanctus est Lorem ipsum dolor sit amet.
Lorem ipsum dolor sit amet, consetetur sadipscing elitr, sed diam nonumy eirmod tempor invidunt ut labore et dolore magna aliquyam erat, sed diam voluptua. At vero eos et accusam et justo duo dolores et ea rebum. Stet clita kasd gubergren, no sea takimata sanctus est Lorem ipsum dolor sit amet.