Thank you for the…

Thank you for the opportunity to submit comments.
I have tremendous concerns about the proposed changes in Bill 23 More Homes Built Faster Act 2022 to the Heritage Act because the result of these changes will be the loss of many properties with features that have heritage value.
Increasing the threshold for obtaining a designation will deter people who are even slightly hesitant about undertaking designation. Many people are already reluctant to apply for heritage designation for their property due to the restrictions and anticipated cost associated with designation. Many properties that merit designation are being lost each year under the Heritage Act without any changes. It stands to reason that many more will be lost if the rules for qualifying for heritage designation are made more difficult.
Imposing a two year timeline on the properties on the municipal heritage register will also result in many more properties being lost. It will also tend to deter municipalities from maintaining complete and thorough heritage registries, particularly in the smaller municipalities that have very limited budget and staff allocated to work on the heritage registry and designation work. In smaller municipalities, undertaking the process of creating a heritage registry can take years of effort. This work relies entirely a very small number of people, or in some municipalities, due to these limitations, the work to create a heritage registry has involved the assistance of members of the municipal Heritage Advisory Committee, who do the work on a volunteer basis.
In light of these limitations, it is completely unrealistic to demand that every eligible property achieves heritage designation within two years otherwise they are to be removed from the registry. The reality is that years of work, in some cases hundreds of hours by volunteers that has gone into documenting heritage properties will be completely wasted. With these changes, all of the work that has been will be wiped out, with the exception of those few properties that successfully apply and achieve heritage designation within two years - if they meet the higher standard that is being proposed.
It is very difficult to imagine a better, or more effective way to completely frustrate municipal staff who work on heritage and at the same time discourage members of the public from volunteering their time to assist with Heritage Advisory Committees. And if that happens it is easy to see that the Heritage Act will have no meaning and heritage will no longer be a consideration in the development process.

While it is important to address the need for more homes in Ontario that are affordable, it is more than a little far-fetched to propose that the demolition of structures with heritage value will do much, or anything to achieve that goal. Many people who live in Ontario (or will move here over the next 20 or 30 years) require affordable homes, but at the same time, people also want to feel like they are part of a community. There are many things that make communities enjoyable places to live. One feature is a community's unique charm and beauty. The architectural heritage of a community is a huge contributor to what makes communities distinct from each other. The architectural heritage and other heritage features need to be preserved and protected because this helps to protect more than just the history of and it contributes to the unique identity of a community. These features are often part of what provides a draw for tourism in communities. Tourism is an important economic driver for many communities in Ontario. If the architectural and other heritage features are lost, it will not be nearly as interesting to travel and explore Ontario. Communities will lose their uniqueness. When communities all look the same, the result will be that people will choose to travel elsewhere instead of vacationing and traveling around Ontario.
It takes some creativity and effort, and sometimes extra cost, but preserving the heritage features of communities is important. While it appears The Housing Affordabilty Task Force does not attribute much value to heritage as it appears in the report with quotation marks, the report also states that the amount of land available for residential development is not the cause of the lack of affordable homes. Their assessment was there is plenty of land available to build affordable homes. It does not require opening up the Greenbelt or taking away the powers of Conservation Authorities or these proposed changes to the Heritage Act to build affordable housing. It requires funding, some targets and it requires cooperation between municipal, provincial and federal governments.