“Given that Canada has a substantial shortage of three-bedroom and larger homes, and the need for our cities to densify, BCH’s prioritization of small, low-rise homes is a peculiar choice,” Moffatt wrote in his analysis.

Missing pieces on innovation and regulation

While BCH promotes modern construction methods, it excludes funding for research and development. The framework explicitly states the program “will only consider investments to the extent that they support its core mandate of directly increasing the amount of affordable housing.”

This creates what Moffatt calls a “valley of death” for emerging technologies. Beyond cost concerns, the framework ignores a harder problem: “zoning and building codes often make the most promising innovations illegal to build.”

One area that works

The framework does offer clarity where it matters most—affordability. “Housing is affordable when rents are no more than 30 per cent of before-tax income (based on median household income of an area),” the framework states, providing income-based tranches that Moffatt called “exceptionally detailed and common-sense.”

Yet affordability clarity cannot mask broader concerns. Tim Richter from the Canadian Alliance to End Homelessness warned that without clear federal objectives, “federal dollars [will be] spread a mile wide and an inch deep, and housing affordability and homelessness will not improve.”