Comments for Environmental…

Comments for Environmental Registry of Ontario
Nov. 23, 2022
The Frontenac Heritage Foundation is a volunteer based not for profit organization which has been protecting built heritage in the Kingston region for fifty years. Our view is that if there was ever a downtown that should be protected, the built heritage in the first capital of Canada would be one to protect.
The Bill 23 changes to the OHA introduced are draconian, and brought to the fore by Michael Ford, the new ‘minister of heritage’, the Minister of Citizenship and Multiculturalism, who as it happens, is the nephew of the Premier.
From our review, the Foundation notes what appears to be a unilateral view that Schedule 6 of the proposed Bill 23 will fundamentally and negatively change heritage planning in this Province.
The November 10 Media Release from the Architectural Conservancy of Ontario (ACO) describes the Bill 23 changes to the OHA as dropping a bomb into the Province’s Heritage System, as shown at this link: https://acontario.ca/show_news.php?nid=80 As the ACO media release says, “Two of the (Bill 23) proposals stand out. Forcing communities to drop ‘listed’ properties from their heritage registers if they are not designated in two years and requiring that the standard for designation of properties be hiked from at least one of Ontario’s heritage criteria to two.” Both suggestions are needlessly onerous, and would force the re-think of hundreds of hours of analysis, by volunteers and staff, of properties on the municipal register.
The Community Heritage Ontario (CHO) umbrella group representing over 150 municipal heritage committees across the Province provided a ten-page analysis of the problems with the Bill 23. (https://uploads.documents.cimpress.io/v1/uploads/c8c1b9ea-de2f-4e1f-963…)
Virtually the only item that the CHO supports is how Schedule 6 would deal with the fact that the OHA is silent on amending heritage districts. While this might be viewed as a positive move, the FHF expresses reservations about how such an amendment may be abused – and this comes from a municipality where a 23-storey tower was endorsed by City Council within a stone’s throw of the NHS-designated City Hall. The Foundation has concerns about how such amendments to heritage districts might be abused within the Market Square HCD surrounding City Hall, which is being considered for expansion in a heritage sensitive downtown, the Barriefield Village, the oldest heritage district in the Province, as well as the 550-building district plan in the Old Sydenham area located next to our heritage-rich Queen’s University.
The Ontario Historic Society (since 1888) a not-for-profit charity, speaks on behalf of over 500 affiliated groups across the Province. They too, have made a submission to the Standing Committee on Heritage, Infrastructure and Cultural Policy, in which the economic importance of heritage designation is articulated, and that it is in the public interest to protect, preserve and maintain Ontario’s cemeteries.
It is a curious thing that the Ford Government has not figured out that the Heritage Act is as much to protect them as it is to protect our built treasures. (The same holds for conservation lands.) The OHA provides a guardrail for governments to claim they are protecting our built heritage interests. After years of delegating assorted wide-ranging powers to municipalities, the about face by the Ford Government is an affront to municipalities which have been carefully and diligently protecting built heritage by developing their municipal registers, continuing the listing and designation process reflected on their municipal registers, and implementing and updating heritage district plans.
The government's self narrative is that heritage designation is unpopular. Owners of our precious built heritage in Kingston take tremendous pride in their buildings as is evidenced by the Foundation’s annual awards ceremony which acknowledges owners and the trades people who take great pride in their properties.
The Frontenac Heritage Foundation therefore recommends that Schedule 6 of Bill 23 be deleted in its entirety from Bill 23.
Many thanks for your time and consideration.

Shirley Bailey, President, Frontenac Heritage Foundation