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Re: Sale of Toronto Community Housing Corporation scattered housing units

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January 12, 2012

His Worship Rob Ford and members of Toronto City Council
Office of the Mayor
Toronto City Hall,
2nd Floor,
100 Queen St. West,
Toronto ON
M5H 2N2

The Honourable Kathleen Wynne
Minister – Minister’s Office
Ministry of Municipal Affairs and Housing
College Park, 17th Flr
777 Bay St
Toronto ON
M5G2E5

I am writing to express concern about the proposed plan to sell the TCHC’s scattered housing units. This plan has the potential to negatively impact individuals and groups protected by the Ontario Human Rights Code (the Code).

As you may know, in the past few years. the Ontario Human Rights Commission (OHRC) has done extensive work in the area of discrimination and housing. This work has included a focus on the lack of affordable housing opportunities in the province and the impact that this shortage has on groups that are identified and protected by the Code.

In 2007, the OHRC held a province-wide public consultation on human rights issues in housing. The OHRC heard about the impacts of inadequate housing options and the dearth of adequate affordable housing on many groups protected by the Code, including older Ontarians, families, people with disabilities, racialized people and people with low social and economic status.

Adequate and affordable housing is integral to an individual’s ability to fully participate in and be a part of his or her community. There is an undeniable link between adequate and affordable housing and quality of life. Housing provides the foundation for general well-being and social inclusion. Adequate housing facilitates access to suitable employment, community resources and supports, and educational opportunities.

Many people who participated in our consultation were concerned specifically about the lack of coordinated actions on behalf of all levels of government to provide sufficient levels of adequate and affordable housing and to address homelessness. The OHRC shares this concern. In 2008, in our consultation report entitled, Right at Home: Report on the Consultation on Human Rights and Rental Housing in Ontario, the OHRC recommended

THAT the Government of Canada adopt a national housing strategy, in consultation with provincial, territorial and municipal governments (where feasible and appropriate), that includes measurable targets and provision of sufficient funds to accelerate progress on ending homelessness and ensuring access of all Canadians, including those of limited income, to housing of an adequate standard without discrimination.

We also recommended

THAT the Government of Ontario, in the absence of a national housing strategy, adopt a provincial housing strategy. Such a provincial strategy should include measurable targets and provision of sufficient funds to accelerate progress on ending homelessness and ensuring access of all Ontarians, including those of limited income, to housing of an adequate standard without discrimination. It should also take into consideration the needs of Aboriginal people, people with disabilities including mental illness, women experiencing domestic violence, lone parents, immigrants and newcomers and other people living in poverty or with low incomes who are identified by Code grounds.

In 2009, the OHRC made a submission to the Ministry of Municipal Affairs and Housing’s Long-term Affordable Housing Consultation that further emphasized the importance of all levels of government working together to develop a coordinated national strategy to improve housing options for low-income people and address homelessness.

The OHRC has also been clear that affordable and supportive housing should be integrated throughout Ontario’s communities to avoid “ghettoization.” When designing housing projects, steps should be taken to integrate more affordable forms of housing into the broader community. In 2009, the OHRC presented this position in a deputation to the City of Toronto’s Affordable Housing Committee. Since then, we have worked with the Ministry of Municipal Affairs and Housing and municipalities, including the City of Toronto, to address discriminatory neighbourhood opposition (also know as “Not in My Backyard” attitudes or “NIMBYism”) to affordable and supportive housing projects. It is the OHRC’s position that, to the greatest extent possible, people should be able to live in the community of their choice.

The plan to sell TCHC’s scattered housing units will further decrease the already limited stock of affordable housing in Toronto. These units were created deliberately to ensure that affordable housing options were integrated throughout the city, so that people of all income levels could live together in the same neighbourhoods. Eliminating these units will lead to a concentration of affordable housing options in specific parts of the city, thus increasing segregation or ghettoization of the individuals who live there, many of whom are identified and protected by the Code.

I would urge you to seriously consider the potential negative impact of the sale of these units before allowing such a plan to proceed. If I can be of any assistance, or if you would like to discuss this matter further, please do not hesitate to contact me or my office.

Yours truly,

Barbara Hall, B.A, LL.B, Ph.D (hon.)
Chief Commissioner