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A Brief to the Minister of Municipal Affairs and Housing Appendix A: How the Social Housing Reform Act is (not) Working for Housing Co-ops This appendix in pdf format (includes all four appendices) In this appendix, co-op housing staff give their own accounts of the damaging effect of the Social Housing Reform Act on co-op communities. The comments are drawn from interviews with experienced staff working in several service areas across the province. The Act is burying co-ops in paperwork “I’ve worked in the co-op for fourteen years and there has never been as much work as there is now.” “We have 33 downloaded units and 18 federal units. The people living in the federal units are not any worse off due to lack of paperwork.” “Our co-op has eight units covered by our service manager and eighty-six federal units. More administrative time is spent on the city units than on the federal units. Two meetings a month are entirely or mainly to do with those units.” “There is a huge administrative burden imposed by the new RGI rules, particularly surrounding the proposed decision, opportunity to comment and then the appeal period. The reality is that members have always had the opportunity to comment. They would just come in and talk to us.” “The system is overladen with regulations. We’re all audited, so why not include information in the annual audit – just once a year. We believe in accountability and a province-wide system, but there has to be more autonomy for housing providers.” “We’ve created a paperwork monster. Paper costs and copying costs are higher and the time spent filing has increased considerably. Is this where we want to be putting our energies in managing housing? Is the extra paperwork leading to the goal of housing people in a positive environment?`` “The rules and regulations are so complex it is very difficult to administer and then to explain to our volunteer board members. It has created the requirement for internal review committees which is an administrative nightmare. Co-ops already have built-in mechanisms to deal with member grievances, regardless of the issue causing the grievance.” “Most of our time is spent doing paperwork, and not a single extra unit has been built or a single extra person housed. We got CMHC seed funding last year to look at building more units, but who has time to work on that?” “The Social Housing Reform Act has killed a lot of trees what with the by-laws that needed to be amended, not to mention all the new forms that now have to be used. It seems there is a form for everything you need to do. Before the SHRA it was a lot simpler to get the work done.” “The administrative burden associated with the administration of the waiting list is horrific. It takes much more time to fill units than before, so we sometimes suffer vacancy loss.” “We had to purchase an expensive software upgrade last summer just to cope with all of the rule changes.” “The additional layer of paper when sending out notices of housing charge re-calculation, because of the opportunity to comment and internal review rules, is unnecessary. As long as I have been working in this business [16 years] I have always offered members and applicants an opportunity to question information. This has always worked very well. If I was unable to satisfy them, they could appeal to the board. This year we used the new process when we did our annual review. No one responded with a "comment" or requested an internal review. However, the same percentage of members did call staff and ask for a chance to review the calculation. All have been satisfied. I feel that this process was devised to solve a problem that doesn't exist.”
“There are no allowances for members who have lived in the community for a long time paying market to qualify for subsidy if they lose their jobs.” “There are many different interpretations of the regulations. It was bad enough when we got six different interpretations from six regional offices; now we have to deal with thirty different interpretations from different service managers.” “Because some of the rules for RGI members have been tightened up [for example, occupancy standards, delivery of notices] it creates even more of a difference in the way market members and RGI members are treated. I have always felt that even though there are inevitably some differences, we should try to minimize them and treat all members as equitably as possible. The SHRA has made it harder to do that.” “Market rent households with a change in circumstances are being forced to move. We need to give them a higher ranking on the waiting list to recognize their contributions to the co-op. We should use the date of occupancy to determine RGI eligibility, especially for seniors.” “People’s circumstances change, but the regulations don’t take into account the needs of members. If a person has been on RGI and gets a full time job, after a year they no longer qualify for RGI. People working on contract often don’t have them renewed and that can lead to an economic eviction. There is no net gain – just a punitive approach towards the member and the co-op [which takes on the costs of a move-out.]” “Some units need a recalculation every month due to changes in income. It’s impossible to use the required waiting periods and notification periods and still keep peoples’ housing charges current with their ability to pay.” “The accountability required of members is so much greater. There is much more responsibility on members to supply information and the time frames for people to get information to you are very inflexible.” “The deadlines for appeals are unfair to both the members and the co-op in some cases. With 261 units in our co-op, there are a lot of changes to housing charges each month. We need more flexibility.” “For members who have been living in the co-op for years and suddenly experience a loss of income, security of tenure is jeopardized because they need to apply externally for subsidy. A couple who have just retired and cannot pay market housing charges are having to move because they cannot afford to stay.”
“Our whole area was underfunded when co-ops were first developed. Not having benchmarks means that we have to follow the old funding model and we simply are not getting enough money.” “Although the Act was passed and implemented years ago, co-ops have still not received the new funding model and associated benchmarks. This has created unnecessary and undue financial pressures on our provincial co-ops as the service manager is unwilling to negotiate budgets until the benchmarks are released. An integral part of the legislation, the benchmarks, is missing and co-ops are being hurt.” “Because of financial shortfalls, co-ops are using reserves as cash flow instead of making monthly contributions. Sometimes their contributions are put in as much as six months after year end.” “Our co-ops are experiencing substantially higher vacancy rates because of the centralized waiting list process. We used to ensure that the top five people on each of our waiting lists had received an orientation, had met with the membership selection committee and had confirmed their interest so that when a notice to vacate was received, we simply had to do the credit and landlord checks which were done within a day, and then we could offer the unit. Now, under the new legislation, the waiting list changes daily so we can only check it once we have received the notice to vacate. Then we have to arrange for everything to be done only to learn that several other projects have also contacted the same applicant, who does not necessarily tell us that right away, and we spin our wheels only to have the applicant choose another location and we must start again. Our vacancy losses are increasing because the time to fill a unit has increased.”
“The SHRA sets out so many different rules for our RGI members that do not apply to our market paying members, that a noticeable split has been created within the community. This is not productive especially in co-ops where we try to treat all members equally.” “It is possible for co-ops with high turnover to end up with a high percentage of victims of violence, and no means of providing support to them.” “There is a need for transitional housing. We want to help people, but co-ops don’t have the ability to provide the support that is needed by many people. Ideally, the rules should be changed so that we can take every other person one from priority list. As it stands, there is no chance of being housed from the chronological list.” “In principle, I think the idea of a centralized waiting list is a good one, but it takes away any flexibility. I have always been very strict about following waiting list protocol as I think our responsibility is to treat applicants fairly always. We have a wheelchair accessible unit available due to the death of a member. I have called all eight applicants on our Housing Connections list and none are prepared to take the apartment. I want to start calling neighbouring co-ops to ask for names from their lists, call rehab centres and disabled advocacy groups -- but no, I'm not allowed to do that. I have to wait for Housing Connections to perform a larger search on their system and try to come up with more names. The problem is that they can't do this today, it will be at least two days till I get it. And, I'm not convinced that these people will be any more suitable since they haven't applied for this building or even this neighbourhood. We may very well incur another month vacancy loss.” “Because of a shortage of available housing, the only way to get housed quickly is to get special priority. We’ve seen several examples of SPP [Special Priority Policy] status being given too freely” “The amount of paperwork required to administer the waiting list has tripled. The waiting list is needier, and often filled with people who don’t really want to be housed in a co-op.”
“Many service managers are taking on a much more significant role than anticipated in the Act. Instead of acting as funders, they are getting involved in areas of day to day administrative decisions.” “Some service managers are less skilled than others. What do we do when a service manager is misbehaving or not doing their jobs properly? There is nobody to appeal to. Some get very defensive when problems are raised. Providers have to be careful for fear of retribution.” “The Province still needs a housing bureaucracy to supervise all of the little bureaucracies and those little bureaucracies are often micro-managing housing providers. The goal is supposed to be accountability, but we’ve lost sight of that with too much detail. The SHRA needs to change to move service manager requirements towards ensuring that the funding agreement is being fulfilled.” “The Act has regulated so much of a co-op's operations, right down to member selection, that our volunteers are feeling that they no longer have a useful, valid purpose. They feel that they have become bureaucrats mandated to administer the government's agenda instead of community-based volunteers.” “Agreements that co-ops have signed with the service manager raise issues of board responsibility and often conflict with other legal requirements. Autonomy is being sucked out of the system. Providers are in constant legal jeopardy.” “The requirement to participate in Social Housing Services Corporation reserve pool takes away our autonomy over investment decisions.” |