Open Letter on the Housing Affordability Task Force Report
Tuesday, February 22, 2022
The Ontario Housing Affordability Task Force recently released its report, which recommends a range of changes to the way housing is planned and built across the province.
Hold The Line Waterloo Region and Waterloo Region Yes In My Backyard (WR YIMBY) would like to highlight those recommendations which we believe could have a positive impact on housing supply and affordability. We’d also like to bring attention to what’s missing from the report, and caution against some of the recommendations that could do more harm than good.
The good
We applaud the report’s recommendation for “as of right” residential housing up to four units and four storeys, as well as “as of right” secondary suites and rooming houses (recommendations 3, 5, and 6). These are all forms of “gentle density” which fit in comfortably within low-rise residential neighbourhoods.
Many so-called “stable residential” neighbourhoods throughout Waterloo Region already include multiplexes and small walk-up apartments among single detached homes. These “missing middle” housing forms enrich our neighbourhoods by allowing for a greater variety of residential forms and unit types. This makes it more likely that someone can stay in their neighbourhood as their housing needs change through different stages of life.
Allowing for more small- and medium-scale development, with more certainty around timelines, is also an opportunity for wealth to remain in our local community.
These recommendations make it easier to build housing on smaller properties, without lot consolidation. That means a greater range of property owners, who may only own one lot, are able to contribute to new housing supply and get shovels in the ground quickly. When “missing middle” development is undertaken by local families or organizations, they’re more likely to hire small businesses and local tradespeople, which builds wealth in the local economy.
The report’s recommendation to allow wood construction up to 12 storeys (recommendation 24), would also benefit the local economy by allowing for faster construction and a larger pool of local tradespeople that, until now, have only been able to work on buildings up to 6 storeys.
The report also recommends “as of right” zoning of six to 11 storeys on transit routes, with no minimum parking requirements (recommendation 9). In our current planning approvals process, asking for increased height and reduced parking requirements near transit is such a common topic that it makes sense for there to be a consistent rule across the province. Developers should not have to keep submitting planning justification reports again and again about this aspect of transit-oriented development.
We agree that property taxes for purpose-built rentals should be aligned with those of condos and low-rise homes (recommendation 37).
Removing aesthetic standards such as colour, texture, and floorplate design from the site review process is a welcome proposition (recommendations 12c and 12d). In a housing crisis, our urban design guidelines should not be so onerous as to delay construction based on architectural details, or to reduce the number of units in service of an angular plane.
Province-wide zoning standards for acceptable shadows and setbacks (recommendation 12c) would help avoid the repetitive NIMBY opposition to specific applications. Shifting these arguments away from individual properties and toward the provincial standards themselves will allow meetings to focus on more substantive issues.
The bad
Recommendation 13 seeks to limit additional meetings. We recognize that time is of the essence, and critically so for affordability, when it comes to housing. Reductions in meetings for exclusionary elements such as neighbourhood character, aesthetics, can prevent delay, as can an increased reliance on broadly consulted established official plans, which already speak to affordable housing needs. Ultimately, consultations should seek to have diverse respondents, methods of participating for accommodating that, and should seek to affirm our official plan aims in these urgent times, while preventing them from becoming individual moments of delaying and upending our loftiest community-wide ideals one project at a time.
Increasing the tribunal appeal fee from $400 to $10,000 is overly punitive (recommendation 27b). Putting up financial barriers will only exacerbate economic inequality. Instead, the province could re-establish the Local Planning Appeal Support Centre (LPASC), which was dismantled in 2021. Its mandate was to help the public understand and navigate the planning process. Requiring appellants to consult with the LPASC before going to tribunal could help scope their objections to the issues that truly have bearing on the application in question.
Parkland fees and development charges are currently vital sources of revenue for municipalities. It is important that investments in public space keep up with population growth. Waiving development charges and parkland fees (recommendations 32, 33, and 35) should be done with caution, and we should take this opportunity to call for perpetual affordability instead of 40-year affordability in exchange for this.
There is a double-standard in the report’s approach to appeal rights and consultation. Recommendation 12b seeks to remove all public consultation on small developments that require minor variances, while recommendation 18 seeks to give more appeal rights for developers and landowners to challenge official plans and municipal comprehensive reviews. This would silence public input and give greater voice to large developers. It will erode trust in local government. These types of recommendations throw out any possibility of good faith cooperation and consultation between residents and developers.
In Waterloo Region, the 2012 official plan was appealed by suburban developers, who resisted smart growth policies. The appeal process introduced significant delays and dragged us backwards on plans for multi-unit and “missing middle” housing.
This report could have presented a definition of affordability, and the fact that it doesn’t is very disappointing. We would like to see a clear, province-wide definition of affordability, based explicitly on average incomes rather than the market rate of housing.
The path forward
While we believe it could go further, the report offers a path towards a positive vision for our community. Some of the recommendations can help build a more sustainable and inclusive Waterloo Region for the benefit of all citizens for years to come, if implemented quickly alongside other effective policies such as rent control, eviction prevention, and building deeply affordable non-profit housing.
Hold the Line and WR YIMBY believe that the future of Waterloo Region lies in increased density and transit-oriented walkable communities. We can meet the need for housing without expanding our countryside line. Such intensification will help provide more homes for people in all stages of life, while also protecting our rural farmland and countryside line.
Our Region established a countryside line to preserve our natural bounty, and to set a long-term vision for equitably shared growth in our distributed city and township cores. We have prepared the soil with community investments like the ION LRT, and policies like the TransformWR Climate Action strategy. It is now time for these fertile grounds to nourish our communities as they grow upwards and welcome more neighbours.
Signed,
Hold The Line Waterloo Region
www.holdthelinewr.org
Waterloo Region Yes In My Backyard (WR YIMBY)
www.wryimby.com
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Media contacts:
Sam Nabi, Hold The Line Waterloo Region
connect@holdthelinewr.org
Melissa Bowman, Waterloo Region Yes In My Backyard
wryimby@gmail.com