Thank you.
It is my pleasure to be here before this committee. I thank you very much for the invitation.
The Canadian Federation of Apartment Associations, CFAA, is the national voice of Canada's private residential rental sector, advocating the interests of the industry to the Government of Canada. We represent the owners and managers of close to one million residential rental suites in Canada through 17 landlord associations across the country.
We believe that a healthy rental housing market contributes greatly to Canada's national well-being and economic prosperity. We believe that landlords, tenants, and taxpayers have a common interest in free rental markets, in fair taxation of residential rental property, in high industry standards for customer service, and in housing assistance that supports tenants' rights to choose their housing and to move when and if they please.
CFAA is in favour of the creation of a national housing strategy. Getting all interested parties, including the private housing sector, the non-profit community, and others around the table to develop a national housing strategy that helps to establish means to provide adequate housing to all Canadians would be a fine and, frankly, a necessary endeavour.
But CFAA would hope that those discussions would include how to make rental housing more affordable through tax policy changes, and more attractive through removing long-standing biases that favour home ownership over rental housing, to its detriment.
A national housing strategy must fit well as part of a broader poverty reduction strategy. In particular, the national housing strategy should include a universal entitlement to a portable housing allowance.
As proposed in the bill, CFAA supports providing financial assistance for those who are otherwise unable to afford rental housing so that they can choose the appropriate housing for themselves, whether that be in the private rental market, in the co-operative housing environment, or in a not-for-profit building.
That said, we note that CFAA is not in favour of a prescriptive housing strategy. We support making federal housing funding more flexible, not less. For instance, we believe that provinces ought to be permitted to use federal affordable housing money for portable housing allowance programs and others to address affordability issues. We believe that portable housing allowances best allow dignity and choice to low-income tenants and should be an option available for policy-makers across Canada. Better yet, portable housing allowances should be a federal-provincial program available across Canada.
Bill C-304, I suggest, appears to intend to place a particular vision for a housing strategy that may not be optimal for all communities throughout the country. I don't know what level of discussion on amendments has occurred, but for instance, there is, in paragraph 3(3)(a) a requirement that the housing strategy ensure the availability of housing that is “not-for-profit in the case of those who cannot otherwise afford it”. Whether the housing provider is for-profit or not-for-profit should not have any effect on the housing consumer.
I fear that the bill assumes that non-profit housing is a superior model to provide housing for low-income households. We disagree. For instance, portable housing allowances are often a far superior tool to assist those with low incomes.
As a further example, paragraph 3(3)(f) mandates that the strategy ensures the availability of housing that includes, among others, “mixed income not-for-profit housing cooperatives”. Now, while mixed income not-for-profit housing co-operatives may be an important component in some communities, passing a federal bill requiring and mandating that the national housing strategy ensure their presence in all communities is not optimal.
We support the provision of operating funding for housing for special needs that are not met by the private sector and of focusing government funding on building new housing for special needs. We believe that serving the needs of those with mental or physical disabilities is certainly the right thing to do, both morally and for the betterment of public policy, but CFAA is not in favour of imposing priorities throughout the country without discussion with the interested parties, such is set out in subclause 3(4).
That subsection mandates that the policy ensure priority be given to (a) those who have not had secure housing over an extended period; (b) those with special requirements specifically because of family status or size or mental or physical disability; and (c) those who have been denied housing as a result of discrimination. These are all worthy groups for some elements of priority, but the bill appears to preclude choice for other priorities: for refugee claimants, for women who may have suffered domestic abuse, or for the chronically ill who do not have a physical disability.
Again, it seems that we are putting the horse before the cart.
Finally, the CFAA questions the appropriateness of the definition of affordable housing as “housing available at a cost that does not compromise an individual's ability to meet other basic needs”; I would suggest that the definition ought to consider the ability of a “household” to meet its basic needs.
We also note and recommend that more appropriate and accurate measures of housing affordability be developed as part of a strategy. In particular, we suggest revision of the 30% standard for affordability to recognize that one- and two-person households can generally afford to pay somewhat more than 30% of income, while larger families may be able to afford less as a percentage, recognizing recent CMHC research which demonstrated that only one-third of households in core housing in a particular year remained in the core housing for the following two years—it may be transitional.
To wrap up, in our recommendations for a viable housing strategy, as others have brought forward, we recognize the respective roles of housing providers and social service agencies in meeting the needs of low-income or disadvantaged Canadians. That said, the obligation to address people's needs is properly on government, on voluntary charities, and on the community as a whole. It doesn't rest on landlords simply because we are providing the shelter. It's an all-encompassing element.
A viable housing strategy ought to include a universal entitlement to an affordable housing allowance, as I've mentioned, for households that cannot otherwise afford rental housing. Such a program could be delivered by the provinces in coordination, as with medicare plans, or could be delivered by the federal government for the provinces to have a choice. It's important that housing allowances be fully portable within and between provinces. In that way, labour mobility and the economic situation of beneficiaries can be improved.
Second, the strategy must recognize that drawing private capital into the rental market is a very positive attribute of public policy, and that what is needed to do that is a rebalancing of the tax system so the tax treatment of tenants in rental housing is improved, to come closer to the favourable tax treatment provided to owner-occupiers.
New construction subsidies on special needs housing should address accessibility needs, since such needs are a growing issue and it's expensive to retrofit existing housing to universal accessibility standards.
Finally, the strategy should recognize that existing social housing can address the greatest needs if much of it is gradually converted to supportive housing or special needs housing, since substantial supports can often best be delivered in a supportive housing environment, while the private market is less well suited to do so, but is in many ways better suited to deliver only shelter for that component.
My time is probably nearing an end, so I thank you.