For the purposes of our study, direct federal involvement in housing programs other than on-reserve First Nations housing can be divided into three main categories.

The first is federal programs designed to provide or encourage the creation of affordable rental housing. This encompasses both federally operated social housing programs and programs funded through cost-sharing agreements with provinces, the provision of rent supplements to tenants in private rental units and direct funding for the development of new rental housing units.

The second major category of federal activity is in the area of homeownership. Canada Mortgage and Housing Corporation (CMHC) plays an important role in providing mortgage insurance and regulating access to mortgages for homeownership and also in providing financial assistance to lower income homeowners for repairs and upkeep of existing homes.

A third category of activity is in the area of "homeless initiatives", providing funding for emergency shelters and facilitating research and community action to address homelessness.

What follows is a review of these categories of federal housing programs from the standpoint of women's homelessness.

The most direct role of the federal government with respect to housing and homelessness, and the one which has been the focus of most advocacy and commentary, is in the area of provision of assisted rental housing. Since the majority of low income women are tenants, it is clear that the issue of access to affordable rental housing is central to understanding and addressing women's homelessness.

From the 1950's, when it initiated the Regent Park development in Toronto, the federal government has played a leading role in funding and developing assisted rental housing. The significant expansion under the 1954 National Housing Act of the mandate of Canada Mortgage and Housing Corporation, formed originally as the Central Mortgage and Housing Corporation in 1946 to address the needs of returning war veterans, established the basis for an active and important federal role in the direct funding and administration of affordable rental housing.

By the 1970's the federal government was a key player in the Canadian housing system through major public housing initiatives and by 1993 was subsidizing 645,000 rental units across Canada in a wide variety of public housing, non-profit, co-operative and rent supplement units.

There are two primary aspects of federal involvement in assisted rental housing which need to be considered in assessing the impact of federal policies in this area on women's homelessness.

The first is the recent trend toward the withdrawal of funding and the reduction of allocations toward assisted rental housing. The most dramatic turning point was the announcement in 1993 that federal funding of social housing would be frozen and that except for on-reserve Aboriginal housing, there would be no new social housing units funded. But the reductions in federal allocations toward assisted housing actually began earlier, in the mid 1980's, with cuts in allocations to assisted rental housing. The period between 1990 to 1993 saw the most dramatic reductions in federal allocations to assisted housing, commencing with a 15% reduction in the 1990 budget.

The second, more neglected issue of importance to women is the design and structure of continued federal spending on assisted rental housing. While there has naturally been considerable focus on the withdrawal of funding, the federal government continues to spend about $2 billion a year to provide subsidy to over half a million households and has recently implemented dramatic changes in the administration and funding of assisted rental housing. A review of the impact of federal policies and programs on women's homelessness needs to consider not only whether the allocation of funds is adequate, and assess the impacts of reductions, but also whether current allocations are properly targeted and whether women most at risk of homelessness have equitable access to them.

i) The Withdrawal from Direct Federal Involvement in Developing and Administering Social Housing

The withdrawal of federal funding for new social housing, culminating in the 1993 freeze in federal contributions to social housing and the cancellation funding for any new social housing (except for on-reserve Aboriginal housing), is arguably the most significant development in federal housing policy in a generation. Prof. David Hulchanski has estimated that the effects of this federal withdrawal of funding, reducing expenditure on assisted rental housing from over 4% of GDP in the mid 1980's to under 3% in the late 1990's, amounts to the cumulative loss of about 325,000 assisted units. The loss of these units has implications not only for the availability of rental housing, but also for funding commitments to subsidies for lower income renters. Had expenditure on new social housing supply not been reduced and then terminated, the federal government would be providing an additional 1 billion dollars in subsidy to an additional 325,000 households.

It is important to recognize, in addition, that the federal cut-backs were followed by provincial cut-backs which were even more dramatic. In 1985, provinces spent over $1 billion in social housing programs, usually in matching funds in federal/provincial programs. By 1997, after the freeze on new federal programs, provincial spending had been cut back by over 90% to just over $100 million annually. Thus, in general terms, cut-backs in allocations to social housing in the last decade have meant a reduction of almost $2 billion a year in government spending on assisted rental housing.

Like changes in federal income support programs, which will be considered in Chapter Four, the federal withdrawal from funding of social housing in the mid-1990's involved not only reductions in allocations, but also involved major structural changes to the federal government's role in housing programs. As in the income support area, the structural changes put into effect along with the reduced spending have seriously undermined the ability of the federal government to protect fundamental rights of disadvantaged Canadians, particularly women, in the area of housing.

Historically, it has been the federal government that has taken the lead in developing and financing social housing, with provinces developing parallel or jointly funded programs during the 1970's and early 80's. In recent years, the federal government has "led" in the opposite direction, initiating a general government retreat from affordable rental housing programs.

The effects of government withdrawals from funding affordable rental housing are likely to be felt most dramatically by women. A loss of $2 billion annually in subsidies directed to lower income renting households is bound to have a disproportionate effect on women. Women-led households are more likely to be renters than men and women are more likely to be paying high percentages of their income toward rent. They are more likely than men to meet income qualifications for assisted housing and therefore more adversely affected by cuts to assisted housing. In 1997, 71% of single mothers in Canada were renters compared to 48% of single fathers and 22% of two spouse families with children. 60% of sole support mothers who rented paid more than 30% of income toward rent compared to 40% of sole support fathers and 29% two spouse families. 39% of households in core need in Canada are lone parents. While disparities between men and women are less dramatic among unattached individuals, it is certainly the case that unattached women are predominantly renters, have serious affordability problems and would therefore qualify for subsidized housing if it were available. 66% of unattached women under 65 were renters and 52% paid more than 30% of income toward rent. 51% of women over 65 years of age are renters and 62% of these renters spend more than 60% of income toward rent.

These statistics make it very clear that because women, both with and without children, are most likely to qualify for subsidized housing, they will be disproportionately affected by failures of governments to ensure the provision of affordable housing for those in need and disproportionately affected by reductions in the provision of housing subsidy to low income households.

A loss of 325,000 social housing units has not only meant the loss of an additional $1 billion that would have been committed in subsidy for the households occupying those units, it has also forced low income women to rely more extensively on existing and new private market rental units. The impact of reductions in social housing units must therefore be assessed in the context of changes in private market rental allocation. New private market rental supply has been largely limited to rented units in condominium developments in recent years. These developments have usually targeted two spouse, middle age households and often explicitly discriminate against women with children in "adult lifestyle" communities.

In addition, new marketing and management strategies in multi-residential private apartments in Canada have changed dramatically. During the times of low vacancy rates in the 1980's, and with the growth in the number of low income tenants and tenants relying on social assistance in the early 1990's, many private market landlords have tried to engage the more "upscale" rental market to avoid renting to low income families, particularly single mothers. Women with children have thus faced increasingly widespread discrimination in the private market, particularly on the basis of income level and family/marital status.

A study of single mothers who moved into private market apartments in Toronto in 1995 found that when low income single parents in Toronto rented apartments in 1995 (ie. moved within the year prior to the census) more than half had to pay rent that corresponds to the most expensive third of the market. Discriminatory barriers in the private market are particularly felt by young women, racialized women and single mothers. As was found by a human rights board of inquiry in Ontario:

Thus, it is clear that the reduction in federal allocations to subsidized rental housing of about a billion dollars annually has not only deprived many low income women of access to critical rental assistance, but has additionally made women more vulnerable to discriminatory marketing and allocation of private market rental housing.

In addition to cutting allocations to assisted housing, the federal government has also initiated a radical restructuring of social housing program delivery which has important implications for the allocation and administration of housing subsidies.

The new model for federal involvement in housing programs can best be understood by distinguishing three elements in the provision of affordable rental housing:

1) The "bricks and mortar" development of rental housing units;

2) The administration and management of non-profit housing; and

3) The provision of housing subsidy or shelter allowance to low income households.

Recent federal housing policy changes have been oriented toward separating out these three aspects of government involvement and redefining federal involvement in each.

With respect to funding of new housing supply, budget allocations introduced on December 10, 2001, for financial assistance toward affordable rental housing supply, represented the first such expenditure since the 1993 elimination of funding for new social housing. Prior to the budget announcement, agreements were reached with the provinces for a framework for the new supply initiative, under which the federal government will provide an average of $25,000 per new unit of rental housing, subject to an equal contribution from the province.

It is clear from the new framework agreement with the provinces that the federal government is no longer interested in tying money for housing development to long term commitments to fund and oversee social housing programs or the provision of housing subsidy. The federal government has agreed to spend $680 million over five years to build 80,000 new units of rental housing. There is no allocation of federal funds for housing subsidy. Indeed, noticeably absent from the agreements being negotiated with the provinces are the types of preconditions that existed in earlier programs, ensuring that a minimum proportion of units will be allocated to core need households and that a certain amount of subsidy would be provided to needy households. In other words, funding for supply has been divested from commitment to provide rent subsidies. Affordability, has come to mean only that funded units should be "modest in size and amenities."

Women with children are concerned that the unit size of new rental supply will in fact be too small in terms of the number of bedrooms. Within both the private and social housing sectors, there is an acute shortage of two and three bedroom units for women with children. Since the proposed federal grant is based on a flat amount per unit, independent of unit size, developers will likely be inclined to build small units rather than the two, three and four bedroom units that women with children so desperately need.

It is also of concern to women that the new supply initiatives in the private market are not linked to any initiatives addressing widespread discrimination that prevents women from accessing the more affordable units. Important regulatory legislation such as rent control and rental housing stock protection is being rolled back in many provinces, so there is little assurance that new rental supply will remain affordable or will even remain as rental accommodation.

Since 1993, the federal government has also been actively devolving the administration of social housing to provinces which, in turn, have been downloading to municipalities. The sole exception to this devolution is unilaterally federal funded co-operatives, for which the federal government has agreed to maintain responsibility, and which are responsible for their own administration pursuant to operating agreements with CMHC.

Under "Social Housing Agreements" with the provinces, the federal government hands over the administration and financial responsibility of federally funded social housing to the provinces. The federal government has agreed to continue to provide the existing level of funding for administration, as long as provinces agree to assume all of CMHC's financial obligations, to abide by existing operating agreements and to redirect any savings into "low income" housing.

While in theory the Social Housing Agreements and the continued application of existing operating agreements could have been used to ensure that housing is administered appropriately and allocated fairly to those in need, in fact, the Social Housing Agreements do little to ensure appropriate allocation and at any rate, in practice, there is little that CMHC can do to monitor and enforce compliance with the terms of the Social Housing Agreement or with existing operating agreements.

Under the Social Housing Agreements with the provinces, CMHC requires that the proportion of units which were allocated as subsidized units under existing operating agreements will continue to be targeted to households below Housing Income Limits established by CMHC. A significant concern from the standpoint of women's homelessness, however, is that this so-called "targeting" does not actually identify those most in need or at highest risk of homelessness. Housing Income Limits for targeted units are determined under the agreements on the basis of CMHC's survey of "median market rent". Any household which would be required to pay more than 30% of income to cover the median rent is considered a "targeted household."

The "Housing Income Limits" do not effectively target those who are most in need. In Toronto, where median rents of two bedroom apartments are now in excess of $1,000/month, a two person household with an income of $41,000 would qualify as a "targeted" household. The average single mother in Toronto has an income of about half of this amount, and a single mother on social assistance receives an income of less than one quarter of this amount. With lengthy waiting lists for subsidy effectively excluding young women with children, newcomers and other women at high risk of homelessness, the impact of high income limits for subsidy is simply to lengthen waiting lists and to deny access to subsidy for women at greatest risk of homelessness.

There is some justification, in our view, for the federal government divesting responsibility for the administration of housing programs to other actors and to focus on continuing its most critical role of providing subsidies to households in need. Yet there seems to have been little attempt in the restructuring of federal assisted housing programs to ensure that these housing subsidies would benefit those most in need. While $2 billion a year allocated to 640,000 households for housing subsidy is arguably insufficient, it is still a significant expenditure. There is virtually no monitoring of who gets the benefit of these subsidies nor any consideration of how different allocation systems may affect women and other groups at risk of homelessness. As in the structural changes to federal transfer payments for social assistance, the move is in the direction of transferring funding with "fewer strings attached." Unfortunately, some of the strings that have been removed were designed to ensure that those most in need, who are disproportionately women, get the benefit of federal expenditure.

With new federal expenditure on supply now separated from federal commitments of rent subsidies, the federal government's $2 billion expenditure on housing subsidies is really more akin to a shelter allowance. The difference between this program and shelter allowance programs in most other developed countries, is that in Canada the subsidy is limited to a designated number of social housing or private market (rent supplement) units. Rather than targeting the subsidy to the most needy households, CMHC leaves it up to either individual housing providers or municipal, or provincial authorities to decide how determine which households, out of a vast number of tenant households falling below the relatively high income limits, will receive this critical assistance.

Under this "unit" based shelter subsidy system, many women who most need a housing subsidy will not receive it simply because they do not have access to a subsidized unit. In some cases, tenant selection may be based on discriminatory considerations. CERA and other organizations assisting women access housing across Canada receive frequent reports of discrimination in the allocation of social housing units. There are usually no internal monitoring or complaints procedures for human rights violations within social housing and no such mechanisms are required under the Social Housing Agreement.

Women with disabilities face particular hurdles, as social housing providers often take the position that since they have allocated particular units as accessible, they are absolved of the responsibilities applied to private landlords to take action to accommodate disabilities on a more individualized basis. There has been no leadership from the federal government to encourage those who are allocating federal housing subsidies to address important issues of access and discrimination in tenant selection practices within the social housing sector.

Of even greater concern than individualized discriminatory practices, however, are systemic issues related to the allocation of subsidized units. In recent years, housing authorities in a number of provinces and municipalities have changed from a needs-based allocation to a chronological waiting list system. In Ontario, new legislation actually requires that subsidized housing be allocated on the basis of chronological priority. The effect of the change to a chronological allocation system, without any attempt to more accurately target lower income applicants, has been catastrophic for many of the most disadvantaged women.

Waiting lists for one, two and three bedroom units required by women with children are extremely long, ranging from several months to 20 years depending on unit size and location. This means that young women with children and newly arrived immigrant women - those at greatest risk of homelessness - have virtually no access to federally funded rent subsidies. By the time they qualify under a chronological system, they will have already survived the years in which they are at greatest risk of homelessness. In the rental market as a whole, approximately one in ten affordable two bedroom apartments are occupied by households in which the oldest parent is under 24 - predominantly young single mothers. Yet social housing providers with a waiting list in excess of eight years for two bedroom units will rent no subsidized apartments to members of this group. Similarly, in Toronto, newcomers (immigrating within the previous year) rent one in five of apartments which turn over in the rental market as a whole, but rarely, if ever, get access to subsidized housing through the waiting list system.

Large families are particularly disadvantaged in trying to access subsidized units. Restrictions on family size in relation to the number of bedrooms are applied in subsidized units to disqualify larger families, even though such restrictions have been held to be discriminatory when applied by private landlords. Women with larger families are required to apply only for larger units that are difficult to obtain and may be disqualified altogether from eligibility for subsidy by their family size if there are no subsidized units large enough. Clearly many women most vulnerable to homelessness are being deprived even of a "fair share" of subsidized units.

In the context of its historical evolution, as a way to ensure that federally assisted housing provided rental housing at affordable rents, the linking of federal housing subsidy to social housing programs makes sense. Extending subsidies to rent supplement units in the private market in order to increase the number of subsidized households also majes a certain amount of sense. Yet in light of the systemic impact of relying on unit allocation to provide rent subsidy, we believe it is time to consider a more broadly based portable shelter allowance tied to household need rather than to designated units.

It does not make sense, in our view, to place the administration of what amounts to a critical form of supplementary income for low income households, a benefit which for many women may mean the difference between homelessness and housing, in the hands of a variety of housing providers, to be allocated on the basis of a range of tenant selection practices. It is particularly discriminatory to restrict this benefit to those who make it to the top of lengthy waiting lists.

Allocating subsidy on the basis of waiting lists rather than providing it based on need means that many women who are in need of short term financial help to avoid homelessness receive no benefit from the assisted housing program when they are at greatest risk of homelessness.

Shelter allowances have been a fundamental component of the recommendations of virtually all recent reports on homelessness in Canada. Yet for some reason, they have not received the same attention as supply oriented solutions within the advocacy community, and even remain controversial in some quarters. However, national shelter allowance programs are an essential component of the housing strategies of most other developed countries. In our view, it is time to give this option renewed consideration and serious support.

1) We recommend that a portable shelter subsidy be allocated as a direct cash transfer or tax credit based on established eligibility criteria to all qualified households. This would remove the administration and allocation of subsidy from the housing provider and eliminate the discriminatory consequences of lengthy waiting lists and other restrictions in social housing. Eligibility for subsidy would be determined by need rather than by whether women get access to social housing units.

2) We recommend that the federal government and the provinces develop methods of collecting complete information about the demographic and income characteristics of households securing access to assisted housing and that allocation of assisted housing be revised in order to ensure equitable representation of young women, larger families, newcomers and other groups at risk of homelessness.

3) Funding for new rental housing supply should be made conditional on non-discriminatory rental practices and on ensuring that the stock will remain affordable rental in the future.

What was not pointed out was that women have largely been denied the benefit of any of these initiatives. In 1976 41% of single parents owned their own homes. By 1997 this had decreased to only 30%. Home ownership has become less accessible for sole support parents during years in which more and more households were becoming owners. While 4 out of 5 two parent families with children own homes, less than one in three single mothers does. The disparity cannot simply be explained by the fact that single mothers "cannot afford" home ownership. They are prevented from purchasing homes, even where ownership would be more affordable than renting an apartment.

With decreasing interest rates and increasing rents, homeownership could be a more affordable and desirable housing option for an increasing number of low income households, particularly single mothers. A single mother in Halifax, for example, could purchase a semi-detached two or three bedroom semi-detached house in Dartmouth for approximately $60,000 or a detached house for about $80,000. If she purchased an $80,000 house, with 5% down payment she would require a mortgage of $76,000. At an interest rate of 7.25%, this would cost about $590 per month (amortized over 25 years and locked in for 5 years). It is difficult, if not impossible, to find a two bedroom apartment for less than $600 in Halifax.

However, CMHC will not provide mortgage insurance unless the purchaser has an income, in this example, of $21,240. Such a requirement disqualifies the majority of single mothers renting apartments, even though they may have been paying more than $600/month in rent without defaulting.

In more rural environments, of course, there is often no choice but to own one's own home. Denying women access to mortgages in these circumstances forces them to choose between homelessness and leaving their communities for a city or town in which there is rental stock.

While ownership may not be a viable option for many low income women, single mothers in particular would gain significantly from increased access to mortgages and home ownership. Benefits include building up equity and credit, not having to be concerned about children's noise disturbing other tenants, having an outside play area where one can supervise children, having access to better serviced communities, etc.

Recent data from the Statistics Canada's survey of financial security shows an increasing gap in income and wealth between owners and renters in Canada. Homeowners' wealth increased from 29 times that of renters in 1984 to 70 times that of renters in 1999. While home owners income increased by $2,100 (5%), renters' incomes decreased by $600 (-3%). Despite their greater need, however, renters tend to derive fewer benefits from federal government expenditure than do home owners. Tax expenditures such as the income tax exemption for Registered Retirement Savings applied to first time home purchase, the capital gains exemption for primary residences (approximately $1.5 billion) and the GST rebate on new housing ($595 million) add up to more than the federal government spends on subsidies for renters. Indeed, a recent Cambridge University study of Canadian housing policy concluded that "the actual expenditure costs of private renting is more expensive than owner-occupation so that there is quite a significant advantage to owner-occupation."

Homeowners also have increased access to the informal economy (heating with wood, repairing things yourself, etc.). Support programs for women homeowners could assist women to take advantage of these, as well as of CMHC's various renovation and repair programs.

CMHC targets its homeowner assistance programs such as the Residential Rehabilitation Assistance Program (RRAP), the Emergency Repair Program (ERP), and the Home Adaptation for Seniors' Independence (HASI) to low income households. Reviews of the recipients of benefits of these programs show that single mother homeowners are somewhat more likely to need repairs than couples and therefore, presumably, to benefit from the program. In rural areas, this type of assistance may actually be more important to low income households that assisted rental programs. The western side of Newfoundland is one such area. The Stephenville Regional Office reports that at the present time there are 846 households who are on the waiting list for funds from the Home Repair Program (HRP) and an Urgent Response Program (URP). It is anticipated that 280 households will receive assistance through this Program during the current fiscal year. There are only 68 households who are on the waiting list for one of the 370 social housing units.

However, because women are dramatically under-represented among homeowners in general, the vast majority of single mothers will not benefit from these programs because they are unable to access credit for home ownership in the first place.

1. CMHC's restrictions on mortgage insurance should be removed and regulation of banks should ensure that women and low income households are provided with alternative ways of demonstrating credit worthiness.
2. Banks should be required to provide detailed information about the income and household characteristics of those provided with mortgages, and be required to develop special programs to provide mortgages to low income households
3. Programs should be initiated to provide protection to low income home buyers from interest rate fluctuations.
4. While programs designed to assist homeowners with repairs would be valuable programs for low income women homeowners, these programs need to be linked with major initiatives to provide access to home ownership for single mothers and low income women.
5. Tax expenditures such as the capital gains tax exemption for primary residence available to home owners should be matched by a shelter allowance for low income renters so that federal program and tax expenditures are fairer to women.

In December 1999 the federal government launched its Homelessness Initiative committing $753 million to address homelessness across Canada over three years. Approximately 7% of this money (or $59 million) has been earmarked for homelessness related projects under the Urban Aboriginal Strategy. Close to 36% of the money has been earmarked for the CMHC Residential Rehabilitation Assistance Program (RRAP) and about 5% of the budget has been earmarked for the Shelter Enhancement Program - to enhance and create shelter and second stage housing for victims of family violence. The bulk of the budget, just over 40% or $305 million, is targeted for the Supporting Communities Partnership Initiative (SCPI).

80% of SCPI funds have been earmarked for 10 Canadian cities "with a documented significant absolute homeless problem". The remaining 20% is directed toward approximately 50 smaller communities that can also demonstrate a homelessness problem. The federal government provides 50% of the funds for each city or local project and the other 50% can be cash or in-kind contributions from a provincial or municipal government, private or voluntary sector or other source available to the community.

The Homelessness Initiative as a whole has been predominantly focused on "absolute" or street homelessness and on short-term solutions aimed at enhanced services and increased emergency housing supply. While this focus is important in addressing the emergency housing needs of women, we believe there must be an equal emphasis on addressing the systemic causes of homelessness.

Some of the SCPI projects do include initiatives that attempt to address systemic issues related to homelessness, but it is unclear the extent to which women's issues will be addressed. The Secretariat has included in its research agenda an examination of the structural/systemic issues in Canada that contribute to homelessness but has not identified women as a group requiring particular attention within this (or other) research areas. The Secretariat's budget has been almost fully allocated and no monies have been earmarked for a consideration of or action on women's homelessness. As these projects are just underway in many cases, it is too early to determine their efficacy in assisting low income women in meeting their housing needs.

1) The Homelessness Secretariat should consider setting as a priority the funding of community based initiatives that address the systemic causes and diversity of women's experiences of homelessness.

2) The Homelessness Secretariat could facilitate the establishment of a vehicle, such as a national network, to facilitate communication and collaboration between women's groups across Canada on issues related to women's housing and homelessness. A national network would assist in linking local community activism to systemic issues that are often national or international in scope. It might also assist in ensuring issues related to women's housing and homelessness are securely placed on political, economic and social policy agendas.