Submission to ERO Proposal…

Submission to ERO Proposal 019-6196

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

Bill 23 is a threat to heritage properties, due to removing listed properties from a municipality’s heritage register leaving them with no heritage status or protection.

We can have both new housing AND heritage properties.

A review of the proposed heritage changes suggests the intent to set up communities to fail in their efforts to protect heritage resources in the name of expediency, which this government has not effectively proven necessary.

The heightened urgency to implement these changes is troubling.

The proposed requirement to either designate or remove any heritage resource on a municipal heritage registry within two years and not re-instate it for at least five years ignores local heritage values, decades of volunteer work identifying and honouring historical and cultural properties, and the labour and cost implications for a small community. Designation entails consulting with numerous entities and conducting research. Based on a 60-day turnaround schedule for a building, the number of resources registered, and municipal staff size, two years may not be sufficient to complete the task.
The Minister of Citizenship and Multiculturalism's proposed override of a local municipal council's determination of heritage value or interest disregards the local context or point of view. Unexpected consequences will result from this strategy.

Similarly, how can one agree to support the creation of a regulatory authority to prescribe processes for municipalities to amend or repeal existing Heritage Conservation District (HCD) designation and HCD plan by-laws without knowing the specifics of the authority and processes?

We can all agree that additional housing is required, but the manner used by Bill 23 is controversial, unlikely to achieve its stated objectives, and likely to have unexpected consequences.

The haste of this Bill through the system, particularly when this timing coincided with the transition from old to new councils, has meant there has not been time to collect opinions from all impacted municipalities, organizations, and the public.

The best decisions are made when diverse perspectives and areas of expertise work together to solve a problem.

I recommend that these Heritage Act changes be scrapped or postponed and that the Ministry and municipalities take time to explore and develop more reasonable solutions to our shared housing difficulties and heritage interests.