CBRM council agreed unanimously on Monday to apply for contribution funding under the federal government’s $4 billion Housing Accelerator Fund (HAF).
I missed the council meeting during which the application was discussed (I’d hoped to be able to watch it before press time, but the video has yet to be posted) so instead I watched a presentation on the “basic elements” of the fund by Elizabeth Tang of CMHC, which oversees it.
Tang explained that the goal of the fund, announced as part of the federal budget on 7 April 2022, is to increase the supply of housing across the country by at least 100,000 “net new permitted housing units” by 2026-2027 while also driving “transformational change” and “creating the conditions for more housing supply over the short and the longer term.”
The “objectives and priorities” of the program are represented in the graphic below:
Source: The National Housing Strategy
Applications open in summer 2023 (when in summer 2023 has apparently yet to be determined) and the application window will be narrow—just 45 days.
CBRM—as a local government with “delegated authority over land use planning and development approvals” and a population over 10,000—is eligible for funding under the Large/Urban stream.
The minimum requirements for applications, according to Tang’s presentation, are:
- Develop an action plan
- Commit to a housing growth target
- Complete/update housing needs assessment
- Submit periodic reports
The “Action Plan” must outline the specific steps the municipality will take to “grow the housing supply” and “speed up development approvals” and I would just like to go on record here as saying that I am skeptical about this focus on “speeding up development approvals.” I tend to agree with Tim Rees, who wrote in the Hamilton Spectator in November 2022 that the myth of “red tape” (the Ford government has actually appointed a minister of Red Tape Reduction) holding back the development of affordable housing is actually a “red herring”:
Ripping down our planning controls to allow developers to build what they want, where they want and when they want will simply allow housebuilders to do their worst. Building density without a plan is a recipe for disaster. And in this flawed trickle down theory of economics developers will not build affordable housing unless they have to. The industry uses endless ruses to avoid building affordable houses and it carefully manages supply to keep prices high.
Rather than being distracted by the delusions of red tape, it is important to remind ourselves that most of the rules and regulations that the building sector complain about are there to ensure residents, consumers and communities are protected from some the negative impacts and potentially harmful effects of the development industry. The rules and regulations have been carefully put in place over many years to protect the environment, our safety, our security and the quality of our neighbourhoods.
Okay, having got that out of my system, back to the Action Plan—it must be approved by council and include an attestation by the CAO that it is financially viable.
On Monday, on the advice of CBRM planning director Michael Ruus, council directed staff to produce and submit such an Action Plan and “any other required documentation” to CMHC as part of the municipality’s HAF application.
Growth targets
The plan must include a Housing Supply Growth Target—the municipality has to provide a projection (based on “reasonable assumptions”) of the number of housing units likely to be permitted between now and September 2026 without HAF funding and the number of units likely to be permitted with the funding. The second number is the Housing Supply Growth Target.
The two numbers can then be used to calculate the housing supply growth rate and (which must exceed 1.1%) and the housing supply growth rate increase (which must be a minimum of 10% over a three-year period).
Tang’s presentation gave the following sample figures:
Source: The National Housing Strategy
There are “additional targets” that can result in increased funding for projects:
Source: The National Housing Strategy
Tang says the “local definition” of “affordable housing” will be used and where there is no local definition, the provincial definition will apply. It will be important to nail down which provincial definition we’re talking about because, as I’ve reported previously, both the province and the CMHC pay lip service to the definition of affordable housing as “housing that is in good repair, suitable in size and costs no more than 30% of a household’s pre-tax or gross income” while funding projects that promise “affordable” units “at least 20% below market value.”
Tang explained the term “missing middle” refers to “ground-oriented” housing types situated between single-detached and mid-rise apartments that can provide “gentle density increases” within single-family neighborhoods. Examples include:
In its Action Plan, the CBRM has to provide a breakdown of its projected permitted housing units (with and without HAF) by type of housing. If its application is accepted, this breakdown will be used to determine the amount of funding to which it is entitled.
Base funding is estimated at $20,000 per unit.
Top-up funding (to incentivize certain types of housing) is estimated at between $7,000 and $15,000 per unit.
The affordable housing bonus is estimated at $19,000 per unit.
Needs assessment
As noted above, I missed Monday’s council meeting and am relying on Ruus’ written presentation in which he mentions the requirement for a Housing Needs Assessment but provides no further details. I have never heard tell of the CBRM creating such an assessment, although the Cape Breton Community Housing Association (CBCHA) and Affordable Housing and Homelessness Working Group (AHHWG) have certainly produced relevant research, like this 2019 “situational assessment” of “Affordable Housing in the Cape Breton Regional Municipality” which found that:
Over 8,000 households in the region have unaffordable housing (Statistics Canada, 2018a). Approximately 5,500 of these households are in core housing need (Statistics Canada, 2017d), which means that their housing is unaffordable, inadequate, and/or unsuitable, and they would need to spend more than 30% of their income to obtain a home meeting these standards (Statistics Canada, 2017g). Core housing need disproportionately impacts renters, seniors, women, and/or people with activity limitations in the CBRM (Canada Mortgage and Housing Corporation [CMHC], 2018c). In addition, 284 individuals were found to be experiencing homelessness in the CBRM (Roy & Bickerton, 2018, in progress).
I would think this group, which is expert on all issues related to the local housing market, would be an important resource for CBRM staff as they draft the municipality’s Needs Assessment (if not its Action Plan, although Ruus referenced only CBRM Forward in his written presentation).
Tang says the Needs Assessment does not have to be completed at the time of application but must be done by the summer/fall of 2025, meaning, after an applicant has been awarded funding.
Lucky 7
The third key element of the Action Plan is Initiatives. Municipalities applying under the Large/Urban stream must provide a minimum of seven initiatives and explain how each will increase the housing supply or speed approvals over the course of the program. The feds are also interested in any other expected outcomes that could drive “long-lasting, systemic changes” after the HAF program has run its course.
The initiatives should be new but Tang said if applicants are “struggling” to come up with seven new projects, CMHC might consider initiatives that are already underway, provided they started after 7 April 2022, when HAF was announced.
Permitted uses of HAF funds include:
- HAF Action Plans
- Affordable Housing
- Housing-Related Infrastructure
- Community-Related Infrastructure
Applicants are encouraged to assess their own “housing needs, challenges and opportunities” when developing their Action Plans, but to “spark ideas,” Tang shared some examples of initiatives like:
- promoting high-density development without the need for rezoning
- encouraging accessory dwelling units
- incorporating a climate adaptability plan into your official community plan
The list of initiatives Ruus presented to council looks like this:
The wording seems vague but according to the Post‘s coverage of the meeting, that’s on purpose: Ruus said they structured the Action Plan to “make sure it’s open to everyone” and that they were “not identifying any specific projects at this point.”
We’re just going through the selection process, if we are successful in the application, to partner within the development community to move forward on any strategic projects.
Councilors apparently raised questions about CBRM’s in-house capacity to manage such a program but Ruus’ report states:
The initiatives listed represent an ambitious goal to assist in facilitating housing development requiring commitment from Council and administration. Additional internal resources required for the implementation of these initiatives are proposed to be funded through the estimated HAF revenue.
And that’s where we stand, with staff preparing an application for submission at some point in summer 2023.
