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Submission to the Standing Committee on Social Justice

March 31, 2011

Proposed Amendments to Bill 140. An Act to enact the Housing Services Act, 2010, repeal the Social Housing Reform Act, 2000 and make complementary and other amendments to other Acts.

Proposed Amendments to Bill 140

An Act to enact the Housing Services Act, 2010, repeal the Social Housing Reform Act, 2000 and make complementary and other amendments to other Acts

The Canadian Mental Health Association, Ontario (CMHA, Ontario) welcomes the opportunity to make a submission to the Standing Committee on Social Justice regarding Bill 140, The Housing Services Act, 2010.

CMHA, Ontario is a provincial association committed to improving services and support for individuals with mental illness and their families, and to the promotion of mental health for all.

The relationship between housing and health is strong. Stable and affordable housing is essential for maintaining positive mental health. Social housing, in particular, can make the difference between being housing and living on the streets. The following suggested amendments will direct how the Act can be strengthened to provide better supports for all tenants.

Issue: Rental subsidy policies administered by two different social programs need to be aligned to avoid penalizing social housing tenants on social assistance who earn an income.


  • Amend Part VII Section 80 (2) to provide for regulations that align municipal/provincial rent subsidy rules to avoid rapid and steep rent hikes.

Issue: The Housing Services Act should mandate the creation of an independent panel to consider these disputes.


  • A new subsection should be added to section 80 that provides for the creation of an independent panel.

Issue: Inclusionary zoning is absent in the new Housing Services Act.


  • Add inclusionary housing legislation in the Housing Services Act. One of the fastest and fairest ways to create stable, equitably accessible, affordable housing is to ensure that the Planning Act gives allow municipalities the authority to introduce inclusionary housing policies.

Issue: The proposed legislation has the potential to create enhanced access to social housing to persons with mental health issues by identifying or clarifying the role that housing supports take in this new legislation.

There are a significant number of persons with mental health issues that live in social housing. Many of them require outside supports to living independently. However, there is no mention of supportive or supported housing anywhere in the Act. Likewise, there are no provisions under the current legislation to address the support needs of tenants with mental health issues who live in social housing units. However, the language in proposed legislation suggests that a broader use of social housing that includes supports within housing will be included in the housing services act 2010.

There needs to be clarity around the role of supports within housing and supported housing providers in the new housing services act, 2010.

  • Part I a) Purpose of the Act: to provide for community based planning and delivery of housing and homelessness services. Homelessness services are currently under the preview of supportive housing providers under the auspices of the Ministry of Health and Long-Term Care.
  • Part II, Section 4 (1) “That there be a system of housing and homelessness services” b) addresses the need to first house individuals and families in order to address other challenges they” and e) provides for partnerships between different levels of government and others in the community.


  • If it is the intention of the proposed legislation that supports in housing have a role in the new Housing Services Act then “supportive housing” and/or “supported housing” as distinct housing category(s), and detailed provisions for administering this type of housing, needs to be included in Part II, Section 4 of Bill 140.

Issue: The Ministries responsible for housing and homelessness plans need to be identified and the role of each Ministry in the proposed partnerships need to be clarified.


  • Amend Section 5 (2) to include the name of the particular provincial ministers, such as the Minister of Health and Long Term Care, who have until now had sole responsibility for administration of homelessness programs.

Issue: Special needs housing needs to identify specific tenant populations.


  • Amend Section 40 to identify the specific support needs and what population these supports are intended for.
  • If persons with mental illness are deemed to a special needs population, amend Section 40 to include the addition of a supportive housing administrator, with the expertise required by the community mental health sector.

With the above amendments, Bill 140 can be the framework that creates a broader more inclusive system for all vulnerable populations in Ontario. CMHA Ontario would be pleased to speak to you further as you move forward with creating an affordable housing strategy.

CMHA Ontario welcomes the opportunity to discuss these matters further.

Please contact

Michelle Gold
Senior Director of Planning and Policy

Pam Lahey
Planning and Policy Analyst

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