Thank you for the…

Thank you for the opportunity to comment on the changes proposed through Bill 23, and specifically Schedule 6. The County of Brant generally supports changes proposed to listed properties. Currently, the Act only prevents demolition and not alteration. Stronger protection measures are afforded for designated properties.

Accordingly, where properties warrant heritage protection they should be designated as opposed to listed. Requiring the listing of properties creates a simple but redundant process under the Ontario Heritage Act. Legally, an owner could potentially alter the façade of a listed property which would lessen its heritage value.

Requiring listing before designation creates an extra layer of work that is not helpful in municipalities with limited resources. Heritage is an important component of community character, one that is important to residents and professional, but is poised as barrier to development. When considering local heritage, building renovations are a very large component of the building industry and can be incentivized to encourage adaptive re-use of older buildings (regardless of their heritage status), ensuring that changes to the outside are sympathetic to the heritage value. Consider integrating a requirement into the Planning Act for municipalities to identify areas where properties and buildings of potential cultural heritage interest are located, essentially integrating 'listing' into the official plan of zoning by-law process and directly connects its policies for cultural heritage conservation to specific properties or areas that meet certain criteria (e.g. O.Reg. 9.06). This will also help integrate the heritage process more closely with applications under the planning act and building / demolition permits and add a level of transparency for property owners.

Please also see the attached report to Council, being RPT-0517-22 from the County of Brant for additional comments on the changes proposed through Bill 23. Should there be any questions about this submission, please do not hesitate to contact the County of Brant for assistance.