AMO's Compendium of Work on Housing and Homelessness
AMO has been actively involved in housing and homelessness advocacy for years, as Ontario’s 444 municipal governments are responsible for building strong, complete communities, of which housing – both home ownership and rentals – is a key component.
AMO Documents and Submissions
AMO has provided comments on the proposed 2023 Provincial Planning Statement, with a focus on areas of municipal interest. AMO’s comments cover proposed changes in the areas of Intensification, Affordability & Complete Communities, Employment Lands, Environment & Indigenous Relations, and Implementation Concerns. AMO looks forward to continuing to work with the government on efforts to build 1.5 million homes by 2031.
On May 20, the Association of Municipalities of Ontario (AMO) submitted comments in response to a series of ERO Postings around Bill 97. These comments discussed "renovictions" and own-use evictions, the potential for a balanced framework for rental replacement by-laws, and the importance of additional tenant protections and landlord rights. The AMO president also sent a joint letter with the ROMA Chair to Minister Clark thanking the province for the change to site plan control.
AMO delivered remarks to complement a written submission to the Standing Committee on Heritage, Infrastructure and Cultural Policy. The presentation covered AMO’s primary ideas with Bill 97, as well as the actions under the Housing Supply Action Plans being taken by the province in its effort to build 1.5 million homes by 2031.
AMO submitted key comments to the Ministry on the proposed Bill 97, Helping Homebuyers, Protecting Tenants Act, 2023. Topics included rental replacement by-laws, site plan control, fee refunds, and Ministers' Zoning Orders (MZOs) as found in Schedule 6, and the Provincial Land Development Facilitators section found in Schedule 4.
On May 3-4, 2023, AMO hosted the Ending Homelessness Symposium in Toronto, which brought together around 250 people including municipal elected officials and staff, Indigenous organizations and other sector partners. Sessions explored the various intersecting factors that cause and keep people homeless, as well as collaborative approaches needed to address these underlying factors. Key takeaways will be considered by AMO’s Task Forces and Board of Directors to inform ongoing advocacy positions and strategy.
AMO's Submission to the Ministry of Municipal Affairs and Housing on ERO 019-6847, Ontario Regulation 332/12 and Future Enhancements to the Qualification Program for Ontario's Building Practitioners May 3, 2023
AMO recently submitted comments to the Ministry of Municipal Affairs and Housing’s proposals on the Building Code, including freezing provincial fees, addressing development interest in unincorporated territory and identifying strategies to increase the number of qualified building officials.
The AMO President wrote to the federal Minister of Housing and Diversity, the Honourable Ahmed Hussen to discuss the housing priorities of Ontario and the potential of funding programs under the National Housing Strategy (NHS), including the Housing Accelerator Fund (HAF), to help meet the high degree of core housing needs Ontario experiences comparatively to other provinces and territories.
AMO's submission to the Ministry of Municipal Affairs and Housing’s consultation on municipal reporting on planning matters reflects the feedback of planning staff from the 29 largest and fastest-growing lower- and single-tier municipalities in southern Ontario. Municipalities agree that transparency, open data, and continuous improvement but in the current form, the proposed reporting regulation will tell an incomplete story. AMO recommends including data on affordable housing units and time.
AMO's Call to Action on Housing and Homelessness February 27, 2023
The provincial government’s assertion that the housing supply crisis can be solved by limiting municipal access to infrastructure financing, eliminating environmental protections or changes to municipal governance is unsound. Ontario has seen successive provincial governments favor income tax cuts over investments in people and downloading of expenditures on property taxpayers to conceal provincial underspending.
Hearing from municipal councils and members of the public in your communities will be a critical part of calling on the provincial government for action on housing and homelessness.
To support this effort, AMO is encouraging municipal governments and District Social Service Administration Boards to support the messages in AMO’s 2023 Pre-Budget Submission.
To help with this effort, municipalities, DSSABs, and municipal associations are asked to consider passing a Council resolution in advance of or close to the provincial budget, on March 23, 2023.
A media toolkit has also been developed:
- News Release template
- Suggested text and graphics for social media posts
- Key Messages to use when writing to or meeting with local MPPs in advance of the provincial budget.
Building Ontario Together: AMO's 2023 Pre-Budget Submission February 13, 2023
AMO provided their 2023 Pre-Budget Submission to the Standing Committee on Finance and Economic Affairs. The submission addresses key insights into the issues of provincial underspending, as well as the projected $1 billion annual shortfall in light of the legislative changes brought on by Bill 23. It also calls on the provincial government to take immediate foundational actions towards ending homelessness in Ontario.
Sustaining and Growing the Supportive Housing System in Ontario January 30, 2023
AMO provided a submission to the provincial government about the need to grow the supportive housing system and make it more effective and efficient. This type of housing is an essential component of the housing continuum that meets the unique needs of people to maintain successful tenancies. Homelessness will not be addressed without more supportive housing units. Nor will we address the challenge of rising mental health and addictions that is taking a devasting toll on people and communities across Ontario. Vulnerable people, including seniors and persons with disabilities, rely on the system. There are too many individuals living in inadequate housing or shelters for long-stays without the supports that they need. This must change.
On December 22, 2022, AMO provided a series of submissions to various consultation postings from the Environmental Registry and Regulatory Registry of Ontario Postings regarding The More Homes Built Faster Act, 2022.
This single document covers 3 submissions sent for the following consultations:
ERO 019-6177: Review of A Place to Grow and Provincial Policy Statement
ERO 019-2927: Proposed Updates to the Regulation of Development for the Protection of People and Property from Natural Hazards in Ontario
ERO 019-6161: Conserving Ontario’s Natural Heritage
On December 9, 2022, AMO provided a series of submissions to various consultation postings from the Environmental Registry and Regulatory Registry of Ontario Postings regarding The More Homes Built Faster Act, 2022.
This single document covers 9 submissions sent for the following consultations:
- ERO 019-6196: Proposed Changes to the Ontario Heritage Act and its Regulations: Bill 23 (Schedule 6) – The Proposed More Homes Built Faster Act, 2022
- ERO 019-6172: Proposed Planning Act and Development Charges Act Changes: Providing Greater Cost Certainty for Municipal Development-related Charges
- ERO 019-6141: Legislative and regulatory proposals affecting conservation authorities (CAs) to support the Housing Supply Action Plan 3.0
- ERO 019-6163: Proposed Planning Act Changes (Schedule 9 of Bill 23 – the More Homes Built Faster Act, 2022)
- ERO 019-6197: Proposed Changes to Ontario Regulation 299/19: Additional Residential Units
- 22-MMAH017: Seeking Feedback on Municipal Rental Replacement By-Laws
- 22-MAG011: Proposed Amendments to the Ontario Land Tribunal Act, 2021
- ERO 019-6173: Proposed Amendment to O. Reg 232/18: Inclusionary Zoning
- 22-MMAH018: Seeking Input on Rent-to-Own Arrangements
The Association of Municipalities of Ontario was pleased to have the opportunity to submit AMO’s Submission to ERO 019-6216: Consultation on Proposed Amendments to the Greenbelt Plan to the Ministry of Municipal Affairs and Housing in response to ERO posting #019-6216.
The submission was also submitted through the ERO Posting webpage.
AMO was not provided an opportunity to present to the Legislature's Standing Committee on Heritage and Culture during its review of Bill 23. AMO was, however, invited by the Official Opposition to present its submission to interested members of the Legislature through a virtual meeting. The submission was also shared with all Members of Provincial Parliament (MPPs).
AMO recommended that the provincial government develop and implement a rental housing strategy as part of the Blueprint for Action: An Integrated Approach to Address the Housing Crisis.
This and other recommendations were provided to the Ministry of Municipal Affairs and Housing in the AMO submission titled "Increasing and Preserving Purpose-Built Rental Housing: The Need for an Ontario Strategy".
On May 19th, 2022, AMO’s Executive Director, Brian Rosborough, presented to the House of Commons’ Standing Committee on Human Resources, Skills and Social Development and the Status of Persons with Disabilities (HUMA) study on the Housing Accelerator Fund.
We emphasized that housing is a complex issue and not one that municipal governments can solve on their own, but rather through solutions that involve a variety of actions from all orders of government and the development industry.
We noted that the measures and investments in Budget 2022, including the Housing Accelerator Fund, are welcome and that the Housing Accelerator Fund has great potential to help get housing built faster through direct and flexible investments that allow municipalities to tackle the most serious local barriers to supply.
We also expressed concern that while all municipalities can benefit from these investments, flexibility and a recognition of the unique needs of smaller, rural, and northern communities are key to meaningful local solutions.
Housing affordability is one of the greatest challenges facing our province and, indeed, the country, and AMO is committed to continuing its work on this issue with the provincial and federal governments.
The Association of Municipalities of Ontario (AMO) submitted comments on the various consultations related to the More Homes for Everyone Plan and Bill 109 – More Homes for Everyone Act, 2022. As part of AMO’s submission, we encouraged the province to carefully consider comments from other municipal associations and our member municipal governments who have provided more specific feedback based on their local circumstances. We look forward to continuing to work with the province and other critical partners on advancing housing affordability in Ontario.
The Association of Municipalities of Ontario (AMO) took the opportunity to speak with the Standing Committee on the Legislative Assembly on Bill 109, the More Homes for Everyone Act, 2022. Housing has become a top-of-mind issue, regardless of whether it is an urban city or small, rural, northern and remote community. These challenges will not be solved by one-size-fits-all solution. Many of the changes that Bill 109 makes to the Planning Act give municipal governments more responsibility, transfer risk, and create a more punitive planning system that will likely have unintended consequences and may not achieve the desired outcomes. The Bill was passed by the legislature without any amendments and received Royal Assent.
The Association of Municipalities of Ontario (AMO) was pleased to have the opportunity to submit a response to the Ministry of Municipal Affairs and Housing regarding the Proposed amendments to Ontario Regulation Numbers 82/98 under the Development Charges Act, 1997 (22-MMAH008) and Ontario Regulation Numbers 509/20 under the Planning Act (22-MMAH009) on April 6th, 2022.
AMO has provided the province with our response to the Province’s Housing Affordability Task Force Report. AMO encourages the provincial government to find ways to address the housing crisis in Ontario in a way that requires all three orders of government and private, non-profit, and co-operative housing sectors (collectively referred to as “development sector”) to work collectively to improve affordability, diversify the housing mix, and increase supply. AMO urges the Ministry to carefully consider the recommendations put forward in AMO’s Blueprint as opposed to relying heavily on the Housing Affordability Task Force Report.
Ontario is facing a housing affordability and supply crisis. "A Blueprint for Action: An Integrated Approach to Address the Ontario Housing Crisis" builds on AMO’s longstanding positions and advocacy around housing. The Blueprint takes a principle-based approach and outlines nearly 90 recommendations on how to guide action and build a strong housing sector. It provides a new starting point for ongoing collaboration and collective work by all levels of government and the development sector to make a meaningful difference in Ontario communities. The Blueprint calls for a new collective mindset and transformative change to address the systemic issues around housing affordability over the long term. AMO stands ready to work together with the province, federal government, and development sector to meet the long-term housing affordability needs of all Ontarians.
Ending Homelessness December 8, 2021
There are a range of actions that can be taken by all orders of government to prevent and break the cycle of homelessness. AMO is inviting the provincial government to build on the productive work to date with AMO, municipalities, and District Social Service Administration Boards. The next step needed is to come together to jointly co-design and implement a plan of action to end homelessness in Ontario. AMO has developed and provided a proposal to the province, with five recommended foundational steps and twenty-three recommended actions.
Fixing the Housing Affordability Crisis August 14, 2019
This submission provided initial input into the provincial government’s Housing Supply Action Plan. Positions have since been updated in AMO’s Blueprint, however this document is still posted for archival purposes.