In general, the revisions…

In general, the revisions are good, in particular the following:

1) The areas that pertain to indigenous heritage demonstrate a stronger commitment to the rights of indigenous people;

2) The inclusion of cultural heritage landscapes, heretofore not afforded protection; and

3) The definition of heritage attributes is the notion that "the principal features or elements that contribute to a protected heritage property’s cultural heritage value or interest..." must be retained. Attributes may include the property’s built, constructed, or manufactured elements, as well as natural landforms, vegetation, water features, and its visual setting (including e.g. significant views or vistas to or from a protected heritage property).

RECOMMENDATIONS

We know from practical experience that cultural heritage and indigenous concerns have often been put by the wayside when development pressures are deemed more important. We have statements in various municipal plans that put aside heritage when requirements of density and development needs are shown to be important. For that reason, I am concerned that the wording of the document has retained the use of the notion of "market" to guide provincial policy. The revised changes have added the words "market-forces" and "market demand" in several places.

So, I recommend that the wording be changed to something more analytical, e.g., supply/demand analysis. I would feel more comfortable knowing that the demand is a real one before having indigenous landscapes and cultural heritage irreversably destroyed or seriously affected. This concern is reflected in a flurry of condominium development where I live in Kitchener/Waterloo where heritage has been put at risk. Will the tall towers that are flooding the urban centre eventually become dark towers? When that happens, we will have seen many low-income residents displaced in favour of development skeletons in the sky.

Also, there is a weakening in the following, where the word "shall" is replaced by "should":

1.1.3.6 New development taking place in designated growth areas should occur adjacent to the existing built-up area and should have a compact form, mix of uses and densities that allow for the efficient use of land, infrastructure and public service facilities.

1.1.3.7 that Planning authorities should establish and implement phasing policies to ensure:

a] specified targets for intensification and redevelopment are achieved prior to, or concurrent with, new development within designated growth areas; and

b] the orderly progression of development within designated growth areas and the timely provision of the infrastructure and public service facilities required to meet current and projected needs.

1.6.7.2 Efficient use should be made of existing and planned infrastructure, including through the use of transportation demand management strategies, where feasible.

Overall the changes are good but there are sufficient development pressures that negatively affect heritage without the changes that I have noted which would accelerate the loss of significant cultural heritage that we all enjoy.