As a member of a municipal…

ERO number

019-6196

Comment ID

80636

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Individual

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Comment

As a member of a municipal Heritage Preservation Panel, I want to vigorously object to
the following term of the proposed legislation:

[If removed from the register under any of the above three circumstances, the property cannot be relisted for a period of five years.]

In my estimation, this exemption from relisting for a period of five years, seems to reflect a superficial, fool-hardy, reckless, and thoughtless adaption of one of the terms of the United Kingdom's heritage legislation and procedures, the Certificate of Immunity provision.
[[ excerpt: Certificates of Immunity
A COI prevents a building from being listed for five years. It's a useful mechanism for ascertaining the listed status of a building and can help inform development proposals for a site.]] [[reference: Terms of a Certificate of Immunity: https://historicengland.org.uk/listing/apply-for-listing/]]

In my estimation, the proposed amendment to the OHA, appears to be a bastardization of the UK terms for issuing a Certificate of Immunity; this new OHA term potentially provides a ZERO-COST blanket amendment for developers to completely ignore community heritage preservation interests in tens of thousands of properties across the province of Ontario, and, without the benefit of the safeguards provided in the UK Certificate of Immunity procedures.

This new OHA term issues a carte blanche to developers, many of whom potentially represent offshore investors who likely, mainly have sanitized investment, financial concerns about returns of assets, do not know anything about the heritage and aesthetics of the communities where their projects will be sited, are blithely ignorant of how heritage structures can be conserved and incorporated into their projects, and have no loyalty or cultural affiliation with Canadian history or Canadian community values.
This amendment term of the OHA requires substantive revision to provide at a minimum, a limited, controlled exclusion, at the very least, in line with the UK Certificate of Immunity provisions. Contrary to the apparent underlying assumptions of this amendment term, Heritage Preservation is not antithetical to development, and, can be executed via well developed conservation plans that reflect the communities in which such projects will reside.