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Adding human rights to the discussion: London’s Draft Official Plan

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August 26, 2015
Gregg Barrett
Manager, Long-range Planning and Research
City of London
Via Email: gbarrett@london.ca

Dear Mr. Barrett,

As the City of London renews its Official Plan, I am writing to draw some human rights concerns to your attention and make recommendations to help the new plan include and welcome all residents in London’s communities.

Under Ontario’s Human Rights Code (the Code), municipalities are obligated to not discriminate based on protected Code grounds when providing or regulating housing and services among other areas.

The Government of Ontario recently emphasized these legal obligations in the 2014 Provincial Policy Statement (PPS): section 4.6 states that the PPS must be implemented in a manner that is consistent with the Code and the Charter of Rights and Freedoms (s. 4.6). The PPS also emphasizes:

  • the importance of:
    • accommodating an appropriate range and mix of residential (including second units, affordable housing and housing for older persons) and other uses to meet long-term needs (s. 1.1.1(b)), and  
    • identifying, preventing and removing land use barriers that restrict the full participation of people with disabilities and older persons in society (s. 1.1.1(f)).
  • the requirement to provide an appropriate range and mix of housing types and densities that
    (s. 1.4.3):
    • meets the need for housing that is affordable to low- and moderate-income households
    • meets the projected requirements of current and future residents
    • meets the social, health, well-being requirements of these residents, including special needs requirements.

The attached submission outlines our concerns, asks questions and makes recommendations on two key areas (housing and services) that will be directly affected by the new London Plan.

We welcome the opportunity to contribute our human rights expertise in this process, and invite you to contact Jacquelin Pegg, Inquiry Analyst, OHRC, at 416-326-9863, or Jacquelin.pegg@ohrc.on.ca if you would like more information.

Yours truly,
Ruth Goba, Hon. BA, LLB
Interim Chief Commissioner

cc: Mayor Matt Brown and Members of City Council