The Special Priority Policy
Victims of domestic abuse and trafficking are too materially deprived to contribute to the economy in a consistent and reliable way. Their inability to guarantee reliability in the workplace makes their income unreliable. This, in turn, makes victims of domestic abuse and / or trafficking unsuitable renters for the regular housing market.
Social Housing Programs
In Ontario, under the Housing Services Act, 2011 , the Special Priority Policy gives eligible survivors of abuse and trafficking priority access to Rent-Geared-to-Income assistance. This is intended to ensure that housing is not a barrier to leave a situation of abuse or trafficking.
Social housing programs are government-funded initiatives designed to provide affordable rental accommodation to low-income households. As part of Ontario’s initiative to realign local services, the province downloaded its social housing responsibilities, both administrative and financial, to its local municipalities. This legislation is housed in the Housing Services Act, 2011, (the “HSA”).
These municipalities are designated as Service Managers under the HSA. The Region is designated as a service manager under O. Reg. 367/11, Sched. 2, made under the Housing Services Act, 2011 (the “Regulation”). The County of Simcoe, (or the “Service Manager”), is the Service Manager charged with overseeing those housing projects in its territorial jurisdiction. The County of Simcoe has delegated some of its powers and responsibilities to the Barrie Municipal Non-Profit Housing Corporation (“BMNPHC”, or “Barrie Housing”, or the “Housing Provider”).
The Ontario Municipal Social Services Association (“OMSSA”) represents 47 CMSMs and DSSABs who are the designated Service Managers responsible for meeting objectives and targets relating to housing needs in their service area. The Corporation of the County of Simcoe acts as one of the 47 service managers in the province of Ontario. In that role, the County provides funding to privately-owned not-for-profit corporations under various provincial funding programs, including RGI.
The HSA governs housing subsidies, also known as rent-geared-to-income (“RGI”), in Ontario. Under the HSA, the Special Priority Policy gives eligible survivors of abuse and trafficking priority access to RGI (or “housing subsidy”) assistance. This is intended to ensure that housing is not a barrier to leave a situation of abuse or trafficking.
The only way a human being can contribute to the economy consistently is by having their basic human needs met consistently, not just for a few days each month. Basic human needs are unmet when a human being experiences prolonged periods of being too cold, too hot, too wet, too dirty, too sleep-derived or too hungry. Furthermore, when people experience any of these repeatedly or chronically, poor health outcomes compound. The root problem in the County of Simcoe is that vulnerable people, especially victims of domestic abuse and / or trafficking, cannot consistently and reliably contribute to the economy due to severe material deprivation caused from government discrimination at every level.
When we see barbaric acts done on civilians, there’s an element of hatred and cruelty in that person’s spirit that is scary. When someone can be cruel and enjoy materially depriving someone else, there’s something deeply wrong with that person.
An Increasing Risk of Abuse
Incidence of domestic abuse appears to worsen during periods of economic downturn. Unable to find affordable alternative housing arrangements, many women choose to stay in or return to an abusive situation rather than become homeless. A recent study has shown that the rate of women returning to their abusers increases during times of reduced affordable housing availability.
Continuing to live with an abuser puts both the woman and her children at risk. While some children display high levels of resilience, many children exposed to violence manifest symptoms of physical and psychological distress and trauma. Domestic violence commonly co-occurs with child abuse, meaning that children, along with their mothers, may be at risk of physical injury. Simply moving out of a domestic abuse situation may not be sufficient if a woman cannot find affordable and stable housing. (Pg.7)
Housing Statistics
According to the Canada Mortgage and Housing Corporation ("CMHC"), community housing is administered by roughly 3,000 housing providers across Canada. In 2021, there were 576,000 households in Canada living in social and affordable housing units, representing 3.8% of all households and 11.9% of renter households. A further 227,200 Canadian households were on the waitlist. (pg. 15)
3,000
housing providers across Canada
576,000
households in Canada are social or affordable housing units
227,200
additional social housing units were on the waitlist
Heat-Related Illness Will Exceed $3 Billion Per Year
Rising temperatures and an increase in the frequency and severity of heat waves have significant public health implications, increasing morbidity and mortality. For example, prolonged exposure to extreme heat can lead to dehydration, fatigue, and a spectrum of heat-related illnesses (HRI), including heat stroke. Extreme heat can also exacerbate pre-existing chronic conditions such as cardiovascular and respiratory disease while increasing susceptibility to infectious diseases.
By mid-century, the cost of heat-related illness in Canada will likely be over $3 billion a year. The dangers of extreme heat for Canadians are further amplified by the fact that the vast majority of the population — over 70% as of 2020 — live in urban centres. Cities are often significantly warmer than surrounding rural areas. This temperature difference is due to urban heat islands — areas where natural vegetation and water bodies are replaced by buildings, asphalt, concrete roads, and other human-made structures. Urban heat islands absorb, rather than reflect, the sun’s heat, leading to significantly higher surface and overall ambient temperatures. (Pg. 12)
Social Housing & Heat-Related Mortality
Preparing community housing for extreme heat is thus imperative to reduce fatalities, increase livability, and ensure community housing tenants are well protected from this growing public health crisis. (Pg. 11)
The 2021 heat dome in British Columbia led to 619 heat-related deaths in a single week, 98% of which occurred inside peoples’ homes. Many of the deceased lived in “socially or materially deprived neighbourhoods’’ and “homes without adequate cooling systems.”
98%
of deaths occurred inside peoples’ homes
3.8%
of Canadians live in social and affordable housing
10%
of deaths occured in social and affordable housing (pg. 10)
Many public housing developments lack key infrastructure to protect residents from the changing and warming climate. For example, low-income individuals and those residing in public housing are less likely to have access to central air conditioning (or any type of AC) due to cost or lack of availability, increasing their risk of heat-related death. Given that increasing global temperatures in coming years are likely to exacerbate heat-related morbidity and mortality, the lack of access to central AC in much of public housing further increases risk of heat-related mortality among low income and vulnerable populations. Source
“We have a decades-long history of dealing with housing at the building level. But that’s where the thinking ends. We need to think about housing from a community context because that’s how it affects individuals’ lifestyles and behaviours, all of which are important for climate change.”
-Steve Mennill, Planning, housing finance and policy consultant & Previous Chief Climate Officer for the Canada Mortgage and Housing Corporation (CMHC) (pg. 15)
Discriminatory Housing Services
Section 48(2) of the HSA specifies that the service manager is to make RGI determinations in accordance with “the prescribed provincial priority rules” and the priority rules established by the service manager.
Municipal service managers lack the education, training and qualified skills to manage special priority policies and procedures. Current laws allow municipal service managers to discriminate, and Municipalities to empower them to do it, instead of stopping it. What Housing Services need to include is a trauma-informed model of care.
The lack of definition for Housing Services has allowed municipal service managers to interpret its meaning through prejudice biases when determining “deservability” of RGI assistance beneficiaries.
This includes decisions about the location and livability of households, as well as the length of time in which households are available to certain people based on personal characteristics.
BARRIE HOUSING EVICTIONS & DEATHS
July 2021 - September 2024
Cause of Vacancy data was not provided for all of 2020, January to April 2021, June 2023, November 2023 or June 2024 because Barrie Housing "can't find it", which is a breach of contract. Vacancy data for October to December 2024 did not exist at the time of this request.
BARRIE HOUSING TENANT TRANSFERS & RELOCATIONS
May 2021 - September 2024
This infographic shows tenant transfers, internal transfers and relocations (not including out-of-province relocations) data for the period of May 2021 to September 2024. Please note, this infographic does not include data for all of 2020, or data for the months of June 2021, November 2023, or June 2024 because Barrie Housing “can’t find it”.
LARGEST PROJECTS
SMALLEST PROJECTS
MOST MOVES
Moves are the combined number of transfers, internal transfers and relocations (not including out-of-province relocations).
This data tells us that tenants who live at the smallest projects have a significantly higher liklihood of having their request to transfer granted. One would think that the smallest projects would have the fewest moves but nope.
LEAST MOVES
Interestingly, Coulter Glen is Barrie Housing’s largest housing project of their 14 projects, with 125 households but in the last three years, no tenants relocated. Only one tenant was granted permission to transfer internally and only two tenants were granted permission to transfer externally.
Housing Remains a Barrier to Leave Domestic Abuse and / or Trafficking
Without trauma-informed training, Municipal Service Managers hold pejorative attitudes based on strongly held views about the appropriate capacities or limits of its below market-rate tenants, which is discrimination. This discrimination is motivated by an intentional desire to obstruct tenants’ potential, which perpetuates disadvantage among them. The actions of Municipal Service Managers in the County of Simcoe have perpetuated and promoted the view that its RGI tenants are less capable and less worthy of recognition and value as human beings and as members of Canadian society.
Since Municipal Service Managers don’t think vulnerable people deserve livable households, they’ve established substandard housing services and procedures for them.
As a result, housing remains a barrier to victims of domestic abuse and trafficking.
An Order to Transfer Control
The only way this discrimination and human rights mega-problem can be remedied is by allowing people with the proper education and training to manage the livelihoods of RGI tenants living in subsidized households. This means that an order to transfer the control, functions, and supervision of certain portions of the Public Administration of the Special Priority Policy in the HSA, to the Department of Public Safety and Emergency Preparedness Act is needed.
4.2 The Minister is responsible for exercising leadership at the national level relating to public safety and emergency.
Climate change has caused severe economic downturn, putting low-income vulnerable population groups in a state of emergency because they cannot afford food and shelter. Their hardships are further perpetuated by discrimination of Regional Service Managers who’ve been handed way too much authority over an entire population group’s livelihoods. An immediate emergency response needs to be issued.
Purpose
The purpose of the Special Priority Policy is to make sure that victims of abuse and trafficking can survive independently, away from their abusers. Therefore, even if policies are made to protect vulnerable peoples from Regional Service Managers, no policies exist to protect them from starvation. Starvation is just as important as housing and therefore, starvation is also a barrier for victims of abuse and trafficking to leave unsafe situations. Starving slowly is torturous and that’s why the Special Priority Policy must also be extended to include Housing and Food. Furthermore, due to the substandard service of care provided by Regional Service Providers to date, a Standard of Household Food Security must also be established and defined under the law to avoid the inevitable attempts by Municipal Service Managers and its Agents that will surely be made to pervert the law.
Enforcement
This legislation also needs to be policed and criminally enforceable by the Department of National Defence. The police need to have jurisdiction over decisions that determine the safety of victims of domestic abuse and trafficking. This includes determining the neighbourhoods victims are “housed” in. Currently, social housing providers in the County of Simcoe place survivors of sex-trafficking in neighbourhoods with known high rates of rape, abduction, trafficking, and drug use. Furthermore, despite letters of support from detectives, the County of Simcoe's social housing providers will not move survivors of sex-trafficking into safer neighbourhoods, despite the increased risk of repeat domestic violence and abuse. The ‘Standard of Housing Service’ definition requires a comprehensive re-write that includes safeguards to protect vulnerable persons with Special Priority Status from Regional Service Managers and Agents.
Livable households should be defined using section 15 of the Charter of Rights and Freedoms’ human dignity test.
The Special Priority Policy needs built-in safeguards to protect low-income population groups from discriminatory governments.
The Special Priority Policy needs to be extended to encompass Food and Housing; not just Housing.
Quality Assurances
There needs to be a revision to the Special Priority Policy that re-defines Housing Services. This revised definition must include:
Affordable
The term “affordable” needs to be revised to a term that realizes costs of living when determining rent calculations. The current method of determining affordability does not consider any living expenses of victims of domestic abuse or trafficking.
Chest Freezer
RGI households need to include a chest freezer that reflects the correct number of persons living in the household, which is determined by the number of bedrooms in the household.
Wash Machine
Access to clean clothes must become a human dignity right. Currently, not only can social housing tenants not afford to wash their clothes, there’s not enough functioning laundry machines available in public housing complexes for all tenants to wash their dirty laundry even if they could afford it.
Air Conditioning
Extreme heat is increasing and this heat significantly impacts the suitability and liveability of subsidized households. Air conditioning in the summer months is just as essential to survival as heat is during the winter months.
Internet Access
Victims of abuse or trafficking cannot afford internet when they first leave an unsafe situation and require provisions to make it affordable.
Sheltered Refrigerated Mailbox Clusters
Sheltered refrigerated mailbox clusters will allow a city-wide population group to receive on-going, fresh food deliveries until they’re capable of entering the workforce.
Responsibilities
Department of National Defence
1. Public Safety Canada
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Emergency Management and Programs Branch
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Responsible for the oversight of emergency program roll-outs
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2. Public Health Agency of Canada
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Emergency Management Branch
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Health Promotion and Chronic Disease Prevention Branch
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Housing and Home Care Services Branch
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Responsible for establishing the health care priorities and mandates for Housing and Home Care Services providers
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Data, Surveillance and Foresight Branch
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Shall house the population health information data and be responsible for monitoring the health of municipality populations and reporting data to the Food Systems Planning Office (Information Sharing Agreements required).
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3. Public Service and Procurement Canada
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Canada Post
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Refrigerated Mailbox Registry
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4. Ministry of the Solicitor General
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Department of Justice (promotes respect for rights and freedoms)
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Public Safety, Defence and Immigration Portfolio
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Responsible for measuring and monitoring municipal Housing and Home Care Services’ demand and supply in Canada
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Responsible for the administration of subsidized housing applications and on-going occupancies for persons with Special Priority Status
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Food Systems Planning Office
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Responsible for establishing foodshed cultivation plans and policies for Canadian municipalities (establish a National Food Systems Plan)
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Responsible for managing the Special Priority Policy
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Shall work with (assign) regional police departments the task of placing tenants with Special Priority Status in subsidized housing (chooses the physical location of where tenants live)
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Procedures
Department of National Defence
1. The Food Systems Planning Office
The Food Systems Planning Office ("FSPO") shall be a new federal branch responsible for planning and executing a National Food Systems Plan ("NFSP"). The NFSP shall be comprised of a Master Municipal Food Systems Plan ("MMFSP") for each Canadian municipality.
Population housing and food needs will be assessed and prescribed by the Public Health Agency of Canada. The physical locations of the NFSP’s infrastructure properties will be mandated by the Minister of the department of Public Safety and Emergency Preparedness, whose powers shall precede the powers of municipalities because municipalities have demonstrated for generations that they do not consider the basic human rights and freedoms of vulnerable population groups despite the evidence they’ve been provided.
2. Measurement & Monitoring
To know if a person’s basic human needs are being met, their income and living expenses must be known. To know a whole population group’s income, the data for all social assistance benefits must be known. Furthermore, the Government of Canada shall know exactly how much each low-income Canadian is costing tax payers.
Therefore, population health information data will be used to determine population health status. Information Sharing Agreements (ISA) shall be created with:
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Employment & Social Development Canada.
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The Canada Revenue Agency (to crossmatch addresses of vulnerable people to addresses of high income earners to ensure no one is taking advantage of the subsidy).
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The Ministry of Health & Long-Term Care (Health insurance and dental: Healthy Smiles).
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The Canadian Mortgage and Housing Corporation.
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The Ontario Electricity Support Program ("OESP"), which is currently administered through the Ontario Energy Board. Social Service workers co-ordinate this.
The Public Health Agency of Canada will assess, determine and mandate a Supreme Federal Housing Infrastructure Standard that certifies a livable household.
3. Population Health Needs Assessment
The Public Safety, Defence and Immigration Portfolio shall determine the Housing and Home Care Services, and the Food Services supply and demand needs for each municipality in Canada, and adhere to the Supreme Federal Housing Infrastructure Standard that certifies a livable household.
4. Determining Infrastructure Capacity Needs
Once the supply and demand needs are identified, the Agriculture and Agri-Food Canada ("AAFC") shall work with Housing, Infrastructure and Communities Canada, and Environment, Climate Change Canada, and Transport Canada and NAV CANADA to determine infrastructure capacity requirements needed to supply the demand.
5. Planning
Once the total infrastructure capacity requirements are determined, a regional Food Systems Plan will be created, which will be called the Municipal Master Food Systems Plan ("MMFSP"). Municipal FSPO’s will submit their MMFSP to the federal NFSO for approval. The MMFSP will not unreasonably impede pre-existing Official Plans, or infrastructure projects.
A location and criteria standards criteria shall be established for MMFSPs. Failure to comply will result in criminal charges because this plan is a Public Safety and Emergency Preparedness Response.
Once a MMFSP has been approved, municipalities shall be mandated to revise their Official Plan to ensure that their municipality’s vulnerable people are being taken care of for the first time in over a century.
Neighbourhoods of Subsidized Households
A safeguard to ensure that tenants with Special Priority Status have Lived Experiences of feeling safe in their own home, a Special Priority Housing Placement Policy Statement will set strict and enforceable criteria. Failure to comply shall be a criminal offence.
Subsidized households shall be mandated to the following rules:
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Not be located in neighbourhoods that exceed a specified violent crime rate.
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Be located in proximity for a collocation of mandated Essential Services Providers, which shall be within 100 meters of the main building. Essential Service Providers include mandated health care, home care and social care services.
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Several designated male-free properties shall be established for tenants who;
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Say this is the only property type she feels safe in, or
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Penalties for tenants who break rules are required, but eviction should be the absolute last penalty, after many attempts to heal the victim of domestic abuse or trafficking have first been made. Attempts made must be documented and referenced in the eviction notice, and accessible in the event that a tenant appeals eviction. Documented infractions will allow the tenant to defend themselves in court if the accusations lack merit.