Transparency, Targets, and Family Housing: Strengthening Bill C-20

Mike Moffatt's testimony to the Canadian House of Commons Standing Committee on Human Resources.

This morning, the House of Commons Standing Committee on Human Resources, Skills and Social Development and the Status of Persons with Disabilities (HUMA) is holding a meeting on Bill C-20, An Act respecting the establishment of Build Canada Homes. MMI’s Mike Moffatt is one of the witnesses. Below are his planned opening remarks, which emphasize the need for more transparency, key performance indicators, and accountability measures in the implementation of Build Canada Homes. As well, Mike plans to use the opportunity to emphasize the need for housing that meets the needs of families of all shapes and sizes.

First, I would like to congratulate the federal government on its recent agreements with the province of Ontario to provide a full HST rebate on homes under $1 million and to cut development charges by up to half. The combined impact of these moves will cut the cost of new homes by 15-20 percent, make new homes competitive with resale homes, increasing housing starts. Since these are temporary measures, the Missing Middle Initiative encourages all governments to use this time to extend them to other provinces and enact further reforms to drive down the cost of building new homes.

Earlier this year, the CMHC released projections showing that housing starts will fall in each of the next three years. The HST and DC reforms will help reverse that trend, but they are insufficient to reach the government’s 500,000 annual housing start target. We would encourage the federal government to take further action, such as implementing the MURB reforms promised during the 2025 election. We would also encourage the government to develop a goal, not just a target, to address the middle-class housing crisis.

I am here to discuss Bill C-20 and Build Canada Homes, which can be an important piece of achieving the government’s housing target. We believe there is merit to BCH’s approach of using federal land to build housing that the market would not, while simultaneously using government procurement as a tool to drive innovation.

The Missing Middle, however, has significant concerns around implementation and transparency. BCH lacks a clear goal, lacks targets, and lacks key performance indicators and accountability measures. The public has not been told how many homes the program will complete, what types of homes, what the rents and prices will be, or over what time frame. I can’t tell you five years from now whether BCH was working, as there is no benchmark for success. That is a problem.

Our team is also concerned about the lack of transparency regarding the unit mix to be created and that those homes will not meet the needs of larger families.

In 2021, there were roughly 300,000 households in Canada with five or more persons who rented their homes. Over half of this group lived in unsuitably small housing, according to the federal government’s National Occupancy Standard. And of those approximately 150,000 families living in unsuitable housing, 78% needed a home that has four or more bedrooms to meet the federal government’s own standard. Despite this, we do not know what proportion of homes built by BCH will be large enough to suit these families. But what we do know is concerning.

In BCH’s Investment Policy Framework, project proponents are encouraged to “leverage the [CMHC’s] Housing Design Catalogue” in their proposals. However, in that design catalogue for Ontario, only 1 of the 21 units has four bedrooms, with 16 having two bedrooms or fewer. This leaves us concerned that BCH will build few homes that are suitable for larger families, as BCH is encouraging the creation of smaller homes. We would encourage the government to provide greater transparency regarding the type and size of the units to be created, and to not forget that households come in all shapes and sizes, including multigenerational families.

Thank you for your time.