Heritage Centre Wellington…

Heritage Centre Wellington Advisory Committee

May 31, 2019

RE: ERO 019-0021 - Comments concerning Bill 108 - (Schedule 11) – the proposed More Homes, More Choice Act: Amendments to the Ontario Heritage Act R.S.O. 1990.

As members of the Heritage Centre Wellington Advisory Committee, we have reviewed the proposed More Homes, More Choices Act: Amendments to the Ontario Heritage Act and wish to provide the following comments.

-Heritage Centre Wellington endorses the comments submitted by Community Heritage Ontario to the ERO on May 27th, 2019.

We have concerns with the proposed changes that transfer the jurisdiction from the Conservation Review Board (CRB) to hear municipal level appeals (designation of bylaw repeals, amendments and alterations) to the Local Planning Appeals Tribunal (LAPT). We understand that instead of the CBR making recommendations, the LAPT will issue a final decision. Not only does this remove final authority from the municipality to protect heritage properties, but it may also mean there will be no way to guarantee LPAT members have enough knowledge of heritage conservation to evaluate heritage-based evidence.
- We believe that this amendment needs to be looked at in further detail to help alleviate this concern.

At the municipal level much of the data gathering about heritage resources is done by volunteers and a council appointed advisory committee. The amendments introducing deadlines for issuing notices, passing bylaws, listing properties, filing objections etc. could seriously hamper the ability of the municipality to undertake due diligence in evaluation and review.
- Consultation with municipalities in determining reasonable deadlines is essential to avoid heritage resources being lost to administrative expediency.

Furthermore, our Committee also believes that there has been no meaningful consultation to determine what the potential impacts of this legislation will have in our community and the decision making processes.
-Heritage Centre Wellington Committee requests that the passing of Bill 108 be delayed so that further consultation at both provincial and local levels can proceed.