Last year, the Office of the Federal Housing Advocate worked to gather evidence-based recommendations to the Minister to improve the National Housing Strategy. This is the start of the work ahead to solving Canada's housing and homelessness crisis. It is a daunting task. But we must be up to the challenge.
Implementing the right to housing in Canada is going to take all of us, working together. It is going to take sustained government action and resources. It will require commitment and coordination at all levels.
It is our job to take a critical look at the problems and at the solutions. It is our job to push for change on the systemic housing issues that are denying people and families their right to housing in Canada. We look forward to identifying ways we can all work together and be part of the solution as we chart the course ahead.
Recommendations to the Minister
Last year, we took the opportunity to take stock of how well the National Housing Strategy is working and where it can be improved. This work was particularly relevant given that 2022 marks five years since the Strategy was published. Furthermore, it is one of the Federal Housing Advocate's duties and priorities to monitor the progress of the Strategy in meeting its goals and timelines and contributing towards Canada's commitment to progressively realize the human right to adequate housing.
In March 2022, we provided the Minister with a series of ten fact sheets based on research we conducted with experts in the field of homelessness and the right to housing. These fact sheets included recommendations on how to strengthen and improve the Strategy. Prior to submitting the fact sheets, our Office and the researchers met with all implicated federal departments and central agencies to present the research and share the recommendations, which aim to ensure Canada's commitments to the right to housing are consistently reflected in all laws, policy and programs.
The Strategy is a positive step forward that sees the federal government reinvest in housing in partnership with provinces, territories and municipalities across the country. The Strategy currently commits $75.3 billion ($36.7 billion in federal spending, $31.2 billion in loans and $7.4 billion in provincial/territorial cost-matching) to “build new affordable housing and renew the existing affordable housing stock” and end chronic homelessness. The Strategy aims to bring together the public, private and non-profit sectors to re-engage in affordable housing. The Strategy's goal is to ensure everyone in Canada, with a focus on the most vulnerable, has access to housing that meets their needs and is affordable.
It is time to re-examine the Strategy and refocus efforts on meeting the needs of disadvantaged groups and those experiencing homelessness. The National Housing Strategy Act and its explicit commitments to the right to adequate housing were passed into legislation in 2019, two years after the Strategy was put in place in 2017. As such there, is an urgent need to reassess the Strategy to ensure its expected outcomes, programs and measurement frameworks are aligned with the right to adequate housing and a human rights-based framework. Furthermore, the Strategy has not been revised since its first iteration in 2017.
The following recommendations are key findings gathered from the research we conducted with experts, fact sheets we provided to the Minister, and analysis on the most critical areas for improvement in the National Housing Strategy. They offer a way forward to align the Strategy with the human rights vision of the Act and with an approach focused on the right to adequate housing.
- Develop a whole of government approach in order to effectively
deliver on the goals of the National Housing Strategy and the National Housing Strategy Act.
Achieving the goals of the Strategy and the Act will require the development of mechanisms for inter-departmental coordination and clear direction to federal departments and agencies on the need to apply the Act consistently to advance the human right to housing. The federal government will also need to develop clear and transparent accountability mechanisms for responding to recommendations from the Advocate and those of the review panels. In addition to housing and homelessness support programs, a whole of government approach will require coordination and funding with other public-good programs such as transportation, public health, mental health and addiction support, income and taxation support, and programs for the elderly, people with disabilities, youth, women, immigrants and other groups. It will require coordinated action on key priorities to reduce barriers for priority groups, such as reconciliation with Indigenous peoples, rooting out systemic racism, and approaching programs with a Gender-based Analysis Plus lens. - Better target the National Housing Strategy's funding to address
the needs of disadvantaged groups.
The federal government's commitment to the progressive realization of the human right to housing means focusing first on those most in need. Research we commissioned as well as research conducted by others, including the National Housing Council, has demonstrated that a number of key National Housing Strategy programs are not meeting the needs of the most disadvantaged groups across the country. The federal government should engage its provincial and territorial counterparts to review and refocus the Strategy's programs that are targeted to people in core housing need and people experiencing or at the risk of experiencing homelessness. This includes discussions on funding included in bilateral agreements, such as the Rental Construction Financing Initiative, the National Housing Co-investment Fund, and the Canada Housing Benefit.
These reforms to the Strategy should include:- Human rights-based measurement frameworks with clear targets and indicators;
- Streamlined approval processes that make programs more accessible for non-profit organizations and projects targeting priority groups; and
- Integration of rights-holders in the Strategy's program design, monitoring, and evaluation.
- The federal government must address the legacy of colonialism and
systemic housing inequality for Indigenous people and recognize the right of Indigenous peoples to create
their own housing strategies.
This is crucial in order to meet Canada's obligations in domestic legislation and international human rights law, particularly the United Nations Declaration on the Rights of Indigenous Peoples Act. Eliminating inadequate housing and addressing Indigenous homelessness must be a priority for the federal government, accompanied by adequate funding. The next iteration of the National Housing Strategy must also be re-framed to address the systemic drivers of homelessness, as well as an approach that emphasizes homelessness prevention and provides adequate housing for Indigenous people regardless of where they reside. - The National Housing Strategy should target its programs to prevent
the financialization of purpose-built rentals and ensure its programs are not contributing to the
financialization of housing.
Housing is a critically important social good and a key social determinant of health. Advocates for the right to housing argue that states should prioritize the social function of housing, meaning that its value as a home should be elevated over its value as a commodity. The National Housing Strategy should fund the acquisition of rental buildings by non-profits, include measures to prevent the erosion of naturally existing affordable housing, and protect renters from the effects of financialization. Government actions should include protecting the housing market from the extractive actions of large corporate investors and financial actors like Real Estate Investment Trusts. It also requires national leadership to help put in place adequate rent controls, including vacancy controls, to protect security of tenure and prevent evictions. The Office of the Federal Housing Advocate is currently conducting research to identify recommendations related to financialization outside of the Strategy, including in taxation and the regulation of financial institutions. - The federal government must ensure that the approach for measuring the National Housing Strategy includes human rights-based targets and indicators and adopts a standard for all government departments and agencies. The measurement of the Strategy must be reassessed to capture rights-based indicators. This will make it possible to measure the impact of investments for priority populations who disproportionately experience homelessness and core housing need. Federal departments and agencies, in addition to CMHC, have a responsibility for achieving the goals of the Strategy. They should be engaged in monitoring its success as well as follow a standard for monitoring progress on the progressive realization of the human right to adequate housing. In order for the Advocate's monitoring mandate to be effective, federal departments should be able to provide the Office of the Federal Housing Advocate with relevant and timely information to assess Canada's progress towards the full realization of the human right to adequate housing.
- The federal government should learn from the pandemic response and ensure that recovery plans take into account the vulnerability of many people experiencing inadequate housing or homelessness. The COVID-19 pandemic had a disproportionate impact on low-income and marginalized people and families who faced a greater risk of eviction into homelessness due to rent arrears. Income support programs, such as the Canada Emergency Response Benefit and eviction moratoriums played a critical role during the pandemic. Organizations and communities mobilized in innovative ways to provide housing for people experiencing homeless. The pandemic response has shown how resources can be mobilized when there is an emergency. The emergency is not over, as we continue to experience a housing crisis in this country. As the government moves towards a recovery, care must be taken to learn from these experiences and ensure that recovery from the pandemic does not lead to a new wave of housing precarity and homelessness.