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Letter to the Minister of Municipal Affairs and Housing on the importance of accessible housing

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December 14, 2020

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The Honourable Steve Clark
Minister of Municipal Affairs and Housing
College Park, 17th Floor
777 Bay Street
Toronto, ON M7A 2J3

Dear Minister Clark:

RE: The importance of accessible housing

I hope this correspondence finds you well in these challenging times. I am writing on behalf the Ontario Human Rights Commission (OHRC), to engage you on important human rights matters and our mutual interests related to your portfolio as Minister of Municipal Affairs and Housing.

I read with great interest your December 6 article in the Toronto Sun about the need for “a mix of increased supply and targeted affordable housing investments.” As you direct attention and efforts to promote affordability, I encourage you to also integrate the critical need for improvements in accessible housing and to involve the OHRC in this urgent work. I agree it is important that communities integrate a mix of housing for different people and groups of all incomes, and it is equally important that housing be fully accessible for older persons and people living with disabilities.

The OHRC has a long history of working with stakeholders to reduce discrimination in housing, particularly in promoting the right to accessible housing for older persons and people living with disabilities, and would welcome an opportunity to work with you on this issue.

Almost 16 years ago, the Accessibility for Ontarians with Disabilities Act (AODA) was proclaimed to complement Ontario’s Human Rights Code. Since then, people living with disabilities have continued to routinely face direct discrimination and systemic barriers in seeking adequate housing, especially because affordable housing is often inaccessible. Yet, the AODA has no regulations that deal with accessible housing. This leaves vulnerable communities, such as people living with disabilities or who are aging, at greater risk.

The OHRC has long called for increasing the number of accessible suites in multi-residential buildings: an example is our 2013 submission on proposed changes to the Building Code Regulation. Also in our 2018 submission to the third periodic AODA review, the OHRC emphasized that regulated standards must include “retrofit” requirements to remove existing barriers, and that new standards should be considered to address ongoing barriers in residential housing. As well, we stressed that AODA processes for standards development, review and revision should also be applied to regulated accessibility provisions of the Building Code. Our submissions align with the recommendations of the Honourable David C. Onley in his 2019 report on the third AODA review.

I recently authored an opinion editorial entitled “Staying-home-during-covid-19-isnt-possible-if-you-dont-have-a-home,” and released an OHRC statement for National Housing Day on November 22:  “Accessible housing makes social, economic sense.” These publications speak to imperative need for safe, accessible and affordable housing, and for all levels of government, community planners and housing developers to promote human rights by committing to universal design construction.

The OHRC calls on the Province of Ontario to amend Ontario’s Building Code Regulation to require all units in new construction or major renovation of multi-unit residential buildings to fully meet universal accessibility standards. The OHRC also calls on municipalities to prioritize universal design construction, consistent with their obligations under the Human Rights Code.

The right to housing is a fundamental human right affirmed in international law. Adequate housing is essential to a person’s sense of dignity, safety, inclusion and ability to contribute to the fabric of our neighbourhoods and societies. This is why I agree with you about the important need for affordable housing. I urge your office to integrate a human rights perspective into all housing issues and ensure that Ontarians are able to secure both affordable and accessible housing. I hope that I can speak with you soon about applying a human rights framework to help facilitate amendments to the Building Code to promote universal design. I look forward to meeting you. My administrative coordinator will reach out to your office to schedule a meeting.


Ena Chadha, LL.B., LL.M.
Chief Commissioner

cc:      Hon. Doug Downey, Attorney General
          OHRC Commissioners