As a member of a municipal…

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

[Increasing the standard for including a non-designated property on a municipal register by requiring that the property meet prescribed criteria. MCM is proposing to have the criteria currently included in O. Reg. 9/06 (Criteria for determining cultural heritage value or interest) apply to non-designated properties included on the municipal register and is proposing that the property must meet one or more of the criteria to be included, which would be facilitated through a regulatory change. MCM is further proposing that this requirement would apply only to those non-designated properties added to the municipal register on or after the date the legislative and regulatory amendments come into force.]

I strongly recommend that the Ministry immediately conduct indepth international comparative research of 21st Century Heritage Preservation standards
( such as the UK 2008 Conservation Principles, Policies and Guidance), and issue a report to inform this legislation and the public; In the interim, no further regulations should be issued concerning this term of the OHA.

First, in my opinion, the current two tiered identification of 'designated' and 'listing-non-designated' represents a historical Canadian simplification of the complex UK heritage regulations which includes designated infrastructure as well as three tiers of nationally listed properties, as well as locally listed properties, all of which receive some degree of protection and conservation management.

In fact, it seems likely that many Ontario heritage properties, whether identified provincially or merely listed by a municipality, may be eligible for National Canadian Heritage Designation; But, based on the paucity of Ontario properties in the National Register of Historic Places, it seems very little effort has been expended to ensure that our provinces historical properties are added to the national register. For instance, I am aware of a property, the original Bank of Canada building in Toronto, which likely would qualify, but, I found the required procedure too onerous to undertake myself, as a private citizen.

If the Ministry chooses to update the OHA terms at this time, in 2022, changes SHOULD reflect 'best in class' international heritage preservation standards, including but not limited to the following four factors :

a)applying a more nuanced and expansive definition of eligibility criteria as per:

<< i)the UK 2008 Conservation PPG
[excerpt: People value historic places in many different ways; 'Conservation Principles' shows how they can be grouped into four categories:

Evidential value: the potential of a place to yield evidence about past human activity.

Historical value: the ways in which past people, events and aspects of life can be connected through a place to the present - it tends to be illustrative or associative.

Aesthetic value: the ways in which people draw sensory and intellectual stimulation from a place.

Communal value: the meanings of a place for the people who relate to it, or for whom it figures in their collective experience or memory.]

AND,
ii) with consideration of the ICOMOS ISC20C framework for 20th century modernist heritage.
[reference: https://isc20c.icomos.org/education_items/the-twentieth-century-histori…;

ALSO,
b) giving consideration of the resource limitations of Canadian/ Provincial/Municipal Heritage experts and community resources available to support and propose heritage conservation plans in the context of multi-million dollar development projects.

c)expanding and refining the scope and number of heritage asset categories--
per the UK example.

FOLLOW-UP STUDY:
Overall, my impression is that the current updates represent a slipshod effort to blindly shoe horn development projects in the guise of a 'housing' crisis , with scant consideration of the need to thoughtfully and objectively update the province's current heritage preservation regime to 21st century standards.