The Housing Tell: No Room for National Occupancy Standards

December 20, 2022
The Housing Tell - No Room for National Occupancy Standards - National Right to Housing Network“I know that there are occupancy standards for safety as well. But I feel like they’re being used as an excuse for a barrier more often than they’re being used to support safety. I think anyone who was asked, ‘what’s safer, being on the street with your children or being under-housed with your children?’ would agree being under-housed is safer.”  – Research Participant, July 2021
In 2019, Canada passed the National Housing Strategy Act, cementing the federal government’s legal obligation to progressively realize the human right to housing in all of its programs, policies, and budgetary decisions. That same year, the BC Society of Transition Houses completed a community needs assessment to identify barriers to housing for our member organizations. One of our key findings was that National Occupancy Standards are a significant barrier to securing safe and affordable housing for women and their families who have experienced violence or are at risk of experiencing violence.
This led us to ask: “What are the National Occupancy Standards?” The answer may come as a surprise to you.
This blog was written by BC Society of Transition Houses (BCSTH), a member-based, provincial umbrella organization that, through leadership, support and collaboration, enhances the continuum of services and strategies to respond to, prevent and end violence against women, children and youth. 

In the early 1990s, as the federal government divested from housing and transferred its housing responsibilities to the provinces and territories, the Canada Mortgage and Housing Corporation (CMHC) started to measure core housing needs. Core housing needs were meant to ensure that provincial housing providers were meeting the housing needs of their most vulnerable populations. A household was identified to be experiencing core housing need if they spent more than 30% of their income on housing, and/or lived in inadequate housing (i.e., in need of major repairs), or unsuitable housing (i.e., not enough rooms based on the family’s size and composition). National Occupancy Standards (NOS) became the measure of housing suitability; however, the NOS became a barrier to those desperately in need of affordable housing when used to match families to available social affordable housing.

So how did a set of guidelines meant to measure housing need and protect the right to housing become a barrier to housing? And how can we revamp these guidelines to meaningfully support the right to housing by ensuring access to housing that truly meet peoples’ needs?

Research led by BCSTH has identified policy changes that would immediately open the door to more housing options for those most in need. Read on to learn more.

What are the National Occupancy Standards?

Canada’s National Occupancy Standards, or the NOS, function in two ways.

  1. CMHC uses core housing need to determine who is in need of housing using the following three measurements:
    • Affordability, which means spending less than 30% of household income on housing;
    • Adequacy, which refers to the condition of the home, including assessing need for major repairs; and
    • Suitability, which refers to whether there are enough bedrooms for household members as per the NOS.

The NOS were adopted by many social housing providers across Canada in the 1990s to identify the right size of unit for housing applicants. The guidelines are as follows:

    • A maximum of two persons per bedroom.
    • Household members, of any age, living as part of a married or common-law couple share a bedroom with their spouse or common-law partner.
    • Parents in a one-parent family, of any age, have a separate bedroom.
    • Household members aged 18 or over have a separate bedroom – except those living as part of a married or common-law couple.
    • Household members under 18 years old of the same sex share a bedroom – except parents in a one-parent family and those living as part of a married or common-law couple.
    • Household members under 5 years old of the opposite sex share a bedroom if doing so would reduce the number of required bedrooms. This situation would arise only in households with an odd number of males under 18, an odd number of females under 18, and at least one female and one male under the age of 5.

2. The NOS are a helpful measure of core housing need that can be used to identify households who may benefit from more space but cannot afford to move. In theory, this should also lead to investments in social and affordable housing that would meet the needs of these families. However, after over three decades of under-investment in social and affordable housing, particularly at the federal level, the gap between the number of suitable units (according to the NOS) available and the number of families in need has only grown.

Given this gap, when housing providers use the NOS to match housing applicants to the appropriate unit size, these guidelines result in fewer families gaining access to limited social and affordable housing units. The result is that an increasing number of families face housing precarity, but not all families are affected equally. Women and children fleeing violence are especially vulnerable to precarious housing.

The Relationship between Violence and Housing Precarity

Women experiencing violence often have to make the difficult choice between housing and safety. A lack of affordable and appropriate housing has perpetuated a cycle of violence against women. Fleeing violence is the leading cause of homelessness for women. If women become homeless, they also experience disproportionate rates of violence in co-ed shelters and sleeping on the streets. In the absence of available housing, many women remain in violent households to avoid homelessness and new forms of violent victimization.

The stark reality for women fleeing violence is that Transition Houses and Second-Stage Housing are often full and there are not enough affordable long-term housing units available in the private rental market, social housing, or community housing stock. In just one day in BC in 2021, 109 women and their children were turned away from transition houses or their services, largely due to a lack of available space.

In BC, women make up 30% of the visible homeless population; however, the actual proportion of women experiencing homelessness is higher. Women are more likely to experience hidden homelessness which could look like living in cars or couch surfing with friends or family to avoid the violence that can be experienced when “sleeping rough” on the streets. For more information on this trend across Canada, check out the Pan-Canadian Women’s Housing and Homelessness Survey Report.

In this context it is critical that the safety and security of women and children fleeing violence is central to policies that dictate access to social and affordable housing. When the NOS are used to match families to available social and affordable housing, they close the door to this essential resource for far too many families. For example, according to the NOS, a woman with two children of different genders over the age of five will need a three-bedroom accommodation, as room sharing is not allowed among herself and her children. While three bedrooms is a reasonable amount of space for this family, the current occupancy standards become a significant barrier when we consider that, in much of Canada, a three-bedroom unit is hard to find and are very expensive when available.

Ongoing Research Related to the National Occupancy Standards

BCSTH leads and supports several research projects that explore the barriers to housing for women fleeing gender-based violence.

Preliminary findings from our research on the experience of Black, Indigenous, and Women of Colour (BIWOC) in the Lower Mainland exemplifies how the NOS exacerbates discrimination based on race, gender, and being a single mom. Several respondents discussed that being a single mom was looked upon poorly by landlords as it raised concerns about whether they would be able to meet rent each month. One woman extended this issue by explaining how her landlords assumed that she would bring violence and noise to the home as a Black woman with a Black family. This same respondent also shared that, due to affordability, in the coming month she and her children would be returning to live with her abusive partner.

The Keys to Home Project is working to build capacity in the anti-violence sector to provide long-term housing options for women who have experienced violence. Due to the ongoing housing crisis, many anti-violence organizations have been expanding their mandates to include Second Stage or long-term housing for their communities. Building capacity for anti-violence organizations to provide housing will result in trauma-informed and women-centred housing options that are mindful of the barriers women who have experienced violence face when seeking housing, such as the NOS.

The Women Centered Housing & Design Project discusses that while it is important to relax the requirements around the NOS, it is also vital to focus on building and designing suitable and culturally appropriate long-term housing. Developing such housing should be through an intersectional women-centred lens by amplifying women’s voices on what is suitable and appropriate for them. Currently, the NOS makes the suitability of housing for families, including a woman and her children, dependent merely on the number of bedrooms. However, this project found that there are other housing design opportunities and priorities leading to suitable and appropriate housing for women and their children after violence. These include the safety and security of long-term housing, designing efficient floor plans with built-in and adaptable features, providing on-site spaces and services that can be an alternative to a lack of in-unit spaces (e.g., bookable working space), locating women-centred housing in areas with easy access to important services such as childcare, healthcare, and transportation, and providing on-site spaces for services where possible (e.g., daycare in the building).

And lastly, the Finding Rooms for Families project pinpoints several barriers women fleeing violence face in relation to the NOS. In the summer of 2021, we interviewed eleven women who had experienced NOS as a barrier to housing and in our most recent set of interviews in the summer of 2022 we spoke with six women living in Vancouver, British Columbia, and Toronto, Ontario (where NOS are not used). The women we spoke with shared the precarious situations that they faced without affordable housing and the role that NOS played in limiting their choices. A major issue is the multi-year long waitlists for suitable units leaving women in precarious situations. Families often face tough decisions to qualify for subsidized housing that result in separation. One respondent’s mother had to leave their household so the respondent and her daughter could move into a 2-bedroom subsidized unit. This resulted in their family being responsible for two rents, created additional difficulties with childcare, and led to unnecessary family separation. As the respondent noted, she had previously lived with her mother in a two-bedroom and wanted to continue to live with her. The location of affordable social housing, along with waitlists, means that some women must relocate to new neighbourhoods where they may not have social relationships or community, and must find new services, like doctors and schools for their children. A respondent in this study spoke about how she only attained a unit in her preferred neighbourhood because she worked with her support worker to challenge the NOS, otherwise she would have had to move to a different city where she had no familiar resources or connections. These stories help shed light on the hardship that families face due to NOS.

Policy Recommendations and Conclusion

While our research is ongoing, the objective of the National Occupancy Standards should be to satisfy the spatial needs of families while ensuring an efficient allocation of available social housing units. We recommend that the NOS be revised at the federal level so that they can be used as an advocacy tool for families seeking housing. This would entail focusing on the rights of families to choose housing that meets their needs, rather than standards being externally imposed on people applying to social affordable housing.  

Furthermore, in order to fully realize the right to housing in Canada, immediate and comprehensive policy actions are needed to increase access to affordable and adequate housing for all. Canada’s housing crisis disproportionately affects vulnerable populations, including women and their children who have experienced violence. Although women who have experienced violence face many barriers to accessing housing throughout Canada, the continued use of the NOS creates an unnecessary barrier, specifically for single mothers and women fleeing violence who look to social, affordable, and co-op housing as a resource and place of safety. While many causes of housing precarity faced by women are systemic, there are key policies as well as housing design considerations that can be changed in order to limit the barriers to housing for women who have experienced violence.

We have identified six key recommendations to support access to housing for women who have experienced violence and other disproportionally affected groups, in alignment with the progressive realization of the right to housing:

  1. Educate housing providers and organizations on the potential consequences of strict adherence to the NOS;
  2. Improve housing suitability guidelines and ensure they are rights-based and inclusive of the diverse needs of families;
  3. Prioritize building affordable housing for families;
  4. Increase capacity in the anti-violence sector through adequate funding and resources to provide women-centered, violence- and trauma-informed long-term housing;
  5. Re-evaluate Canada’s approach to occupancy standards to focus on what the housing sector should do to provide appropriate and suitable housing rather than applying eligibility criteria to vulnerable populations;
  6. Provide design guidelines to build appropriate long-term housing for women and their children after violence to increase the availability and supply of suitable units. 

In order to achieve the right to housing in Canada, the voices of those with lived experience of homelessness or inadequate housing should inform national housing policy. In fact, this is a legal imperative under international human rights law and Canada’s National Housing Strategy Act

Those disproportionately affected by the NOS have voiced that housing eligibility and occupancy standards must be revised to uphold the rights of families to choose housing that fits their needs. Housing justice means choice and self-determination for communities in need.

All this to say, there’s no room to ignore families’ need for more flexible occupancy standards; Canada’s National Occupancy Standards need a rights-based overhaul.

***

“Finding Rooms for Families” research is funded by the CMHC-SSHRC-funded Balanced Supply of Housing Node based at UBC’s Housing Research Collaborative.

The Housing Tell is a blog series which platforms noteworthy perspectives, solutions, and ideas from across Canada’s right to housing movement.

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