November 22, 2022 SENT BY E…

November 22, 2022

SENT BY E-MAIL - paula.kulpa@ontario.ca
Paula Kulpa
Heritage Branch, Ministry of Citizenship and Multiculturalism
400 University Avenue, 5th Floor
Toronto, ON, M7A 2R9

Dear Paula Kulpa,

RE: Bill 23, More Homes Built Faster Act, 2022

Proposed Changes to the Ontario Heritage Act and its regulations: Bill 23 (Schedule 6) – the Proposed More Homes Built Faster Act, 2022
ERO Number: 019-6196

This letter summarizes the Town of Erin’s comments to the proposed legislative and regulatory amendments to the Ontario Heritage Act. We request that the Province consider our comments and the negative impact the proposed changes will pose to all municipalities, especially smaller rural municipalities.

New Requirements for Municipal Registers and the Inclusion of Non-Designated Properties on the Municipal Register
• The Town has no concerns with requiring municipalities to make an up-to-date version of the information on the municipal register available on municipal websites, given municipalities are given sufficient time to complete this task. Given the volume on listed projects and limited staffing within small municipalities, we would request the timeframe be amended from 6 months to 12 months.
• The Province is proposing to allow property owners to object to the inclusion of their non-designated property on the municipal register regardless of when it was added to the municipal register. If a non-designated property has existed on a municipal register for many years, we request that the property owner provide a Heritage Impact Assessment to remove the property from the municipal register.
• The Town is supportive of applicant-initiated removal from the municipal register within settlement areas, however does not support the automatic removal of non-designated properties from the register if they are not designated within 2-years of the amendment coming into force.

An Increase in the Threshold for Designation of Individual Properties and New Limitations on Designation for Properties Subject to Proposed Development
• The Town of Erin is predominately a rural agricultural community that strives to protect and preserve its cultural heritage. The Town is not supportive of losing buildings and structures with cultural heritage value or interest in its rural areas. As the goal of the proposed More Homes Built Faster Act is to reduce the barriers that slow down housing construction, it would be most appropriate to limit changes to areas identified for growth, as per the Growth Plan (i.e. Settlement Areas).
• The Town does not have the resources (either financial or staffing) to issue Notices of Intention to Designate, as notices require a Heritage Impact Assessment (HIA) to be completed. The Town does not have in-house expertise in heritage related matters, and therefore would be required to hire a heritage consultant to complete each HIA and assist with the designation process. Consider placing the onus on the property owner to provide a Heritage Impact Assessment to remove their property from the municipal register.
• In addition, the Town has been unsuccessful in finding heritage consultants who are able to complete a HIA within the current 60 day review period for requests to demolish structures that are currently listed within the Municipal Register. Increasing timelines would help municipalities to obtain a Heritage Impact Assessment on properties which have provided a Notice of Intention to Demolish.
• If permitting applicant-initiated removal from the Register, municipalities should be provided the ability to set minimum submission requirements to reduce for such an application, to reduce the financial burden placed on municipalities.

If you have any questions or concerns, please contact me by email (Jack.Krubnik@erin.ca) or by telephone (519.855.4407 Ext. 253).
Sincerely,

Jack Krubnik, MLA, OALA, MCIP, RPP
Director of Planning & Development
Town of Erin