Synthesis of Provincial Requirements

Local Housing and Homelessness Plans should serve local needs, but must also meet specific provincial requirements. These are set in the Housing Services Act (HSA), regulations under that Act, and the Ontario Housing Policy Statement (OHPS). While the Long-Term Affordable Housing Strategy (LTAHS) helps set the context, it does not create requirements for Service Managers.

This document provides an integrated summary of the provincial requirements. More itemized requirements are provided in the following documents:

The provincial requirements for local housing and homelessness plans in the HSA, the Regulations and the OHPS can be grouped into five categories:

  1. Overarching requirements.
  2. Principles and approaches.
  3. Content requirements, i.e. what approaches and programs in local plans are to address the needs. These include general requirements and more specific ones.
  4. Monitoring and accountability.
  5. Process requirements in preparing the local plan.

Overarching Requirements

Each Service Manager must have a plan to address both housing and homelessness, in place by January 1, 2014, covering at least a ten-year period. (Service Manager refers to the legal entity, i.e. the municipality or DSSAB, not the responsible senior manager or department.)

The plan must “address the matters of provincial interest” set out in the HSA and be “consistent with” the OHPS. These matters are included in the remainder of this summary.

Principles and Approaches

Provincial requirements point to a set of principles that apply. Some are specified and others are implicit, but all point to comprehensive, integrated policy-making at the local level.

Strategic planning – Provincial policies and requirements point toward a comprehensive approach to planning on a longer-term basis. The LTAHS calls on Service Managers to “establish the local vision for housing” and “develop and implement local housing and homelessness plans within the broader provincial framework.” The process, under the HSA, is to include a needs assessment and stakeholder consultations, as noted previously. The plan should address a spectrum of housing, as noted below, and is to be “coordinated and integrated with all municipalities in the service area” (OHPS). The content of the plan is to span from objectives to implementation steps to monitoring and reporting. The plan is to include “objectives and targets relating to housing needs”; and it is to set out implementation steps (referred to as “measures”) to meet the objectives and targets (HSA). See the related OMSSAbulletin on Local Housing and Homelessness Plans as strategic planning.

Intersection with related policy spheres – Plans are to address relations of affordable housing and homelessness to other policy spheres – two most noteworthy. The requirements for housing needs assessments (above) and for the role of market housing (below) imply a relation to urban planning and the Planning Act. Inclusion of housing-related supports for homeless people, abused women, and others point to a relationship to supportive housing and targeted services, currently under the ministries of Community and Social Services and of Health and Long Term Care, and their regional bodies and funded agencies. There are no specific requirements on how the Service Manager should achieve these linkages.

Other substantive policies – There are four priority polices set out in LTAHS that Service Managers will need to incorporate into their plans which are awaiting provincial direction. These include the consolidation of homeless programs, RGI calculation changes, performance measurement and reporting. Consolidation continues to be developed and is on plan to be in place January 2013. The RGI calculation changes and the local performance m,easures continue to be developed with input from the sector. Section 22 of the HSA, covering Service Manager reporting, and Section 168, covering Ministerial reporting, were not proclaimed on January 1, 2012. It is assumed that these sections will be proclaimed once local performance measures are in place.

Content Requirements

  • A needs assessment must be carried out as part of preparing the plan. This arises from the requirement that “an assessment of current and future housing needs within the service manager’s service area” (HSA) be included in (be part of) the plan.

Process Requirements

Several provincial requirements relate to the process to prepare the plan. Highlights are:

  • The Service Manager must conduct consultations. “In the course of preparing its housing and homelessness plan, a service manager shall consult with the public and the prescribed persons” (HSA). The Service Manager is to develop its plan “in consultation with a broad range of local stakeholders” (OHPS).
  • Within the requirement for consultation with a broad range of local stakeholders, three specific points are relevant, although Service Managers have wide discretion on how to address these. Service managers are to ensure that the plans “reflect the active engagement of non-profit housing corporations and non-profit housing co-operatives in current and future needs planning”. The broad range of local stakeholders is to include “those who have experienced homelessness”. (OHPS) The requirement that the plan be “coordinated and integrated with all municipalities in the service area” implies a need for the Service Manager to consult with other (e.g. local or separated) municipalities where applicable, and a reciprocal responsibility on the part of those municipalities.
  • The plan must be adopted by the municipal council of the Service Manager. It is up to the Service Manager to determine whether preliminary Council approval is needed before the plan is submitted for the required Ministerial review process.
  • The plan is subject to review by the Ministry of Municipal Affairs and Housing prior to final approval by the Service Manager. The HSA refers to this as consulting with the Minister. This must be done with at least 90 days provided for Ministerial review. As well, “before approving the plan, the Service Manager shall consider any comments the Minister provides” (HSA). It is up to each Service Manager to determine what timelines they need to meet internally in order to meet these provincial timing requirements.
  • The Service Manager must also provide the Ministry copy of the final approved plan.
  • The plan must set in motion a process of monitoring and reporting on indicators (metrics) relevant to housing and homelessness.
  • The Service Manager must review its plan at least every five years “and amend it as the Service Manager considers necessary or advisable” (HSA). The Service Manager must provide the Ministry a written report on the results of the review “without delay” (HSA), but the formal Ministerial review requirements apply only if the plan is amended.
  • A Service Manager may amend its approved plan in conjunction with the five-year review or at any other time. Much the same process requirements apply to any such amendment as applied to the original plan.