The following is provided on…

The following is provided on behalf of Community Heritage Ontario (CHO), the province-wide, non-profit umbrella organization of municipally appointed heritage committees (MHC). There are currently over 150 MHCs in the Province comprised of more than one thousand volunteers responsible for providing advice and recommendations to Councils on local heritage matters.

The following is a summary of key concerns. The Attachment provided is the official response from CHO to the proposed changes to the Ontario Heritage Act as addressed in Schedule 6 of Bill 23 (also included are comments on changes proposed in Schedule 9 - Planning Act which may also have an impact on the conservation of cultural heritage resources).

Concerns:
General Comments
• Overall, the previous and proposed changes to the Ontario Heritage Act have made this a very complex and difficult to understand piece of legislation especially given the reliance on volunteer members of the community to implement it in many parts of the province.
• The time period allotted for review of the current changes and the timing of the release of the proposed legislation has been extremely challenging and should be extended to allow proper consultation.
• The conservation of heritage resources is not an impediment to expanding the supply of housing in the province; in fact, there are numerous examples where the conservation of heritage resources has resulted in an increase in the supply of housing.
• The effect of a number of the proposed changes would in effect impede the protection of Ontario’s cultural heritage resources.

Ontario Heritage Act
• The ability to allow property owners of all existing listed properties to object years after they have been listed in the heritage Register
• The removal of all existing listed properties from the Register after two years from proclamation if they have not been designated and not allowing them to be re-listed for an additional five years
• Unspecified evaluation criteria for including a property on the Register, and
• Increasing the threshold criteria for evaluation for individual property designation and for creating heritage conservation districts.

Planning Act
• Removal of Site Plan Control for developments with less than 10 residential units
• Limit site plan control by removing the ability for municipalities to regulate exterior architectural details and landscape design
• No longer require public meetings for plans of subdivision

As noted, our concerns, perceived implications and recommendations are provided in the attached document from CHO.

Thank you for taking our comments into consideration as you review the proposed legislation as we are extremely concerned regarding the potential impact on the conservation of Ontario's cultural heritage resources.