I agree with the comments…

I agree with the comments made by the Ontario Association of Heritage Professionals (OAHP) regarding the proposed changes to the Ontario Heritage Act.
I would like to see the commenting period be extended to allow for consultation with a wider span of stakeholders and requests that the OAHP be added as a stakeholder and consulted on all forthcoming guidelines and regulations.
1. Provincial Direction - ● remove the forthcoming regulation and replace it with a guidance document based on best practice including Parks Canada, ​Standards & Guidelines for the Conservation of Historic Places in Canada​ and the Burra Charter.
2. "Listing" on the Register ● the province should introduce a time limit on the property owner’s ability to object to the listing of a non-designated property on a municipal Register to thirty (30) days following notification.
● the listing and objection processes should be set out through guidance documents, not through regulation.
3. Designation by-laws● Base the forthcoming regulation on best practice in Canada including:
○ Canadian Register of Historic Places - Writing Statements of Significance
https://www.historicplaces.ca/…/sos_guide_final_e_new_desig…
○ A Guide to Working with the Federal Heritage Buildings Review Office
https://www.historicplaces.ca/…/fhbro_manual_parks%20canada…
4. Timelines for Designation under Part IV● heritage stakeholders including municipalities, public and private sector heritage planners and OAHP should be consulted in the drafting of the regulation with the intent of reaching a consensus.
5. Streamlined Appeals ● The CRB, in its current form, should be maintained and that municipal council authority over Part IV designations and alterations be continued.
● If this is not feasible, it is important that LPAT limit its review of Part IV designations and alterations to matters of process and procedure rather than subject matter pertaining to heritage value.
● If this is not feasible, it is paramount that LPAT members hearing heritage appeals meet the CAHP definition of Heritage Professional. In no circumstance, should a non-heritage professional make a binding decision regarding the identification of heritage value or conservation of heritage properties.
7. Demolition -Appeals relating to alterations and demolitions of Part IV properties will now be appealable to the LPAT rather than the CRB. Please see comments under Section 5.0 for recommendations relating to the CRB ad LPAT.
8. Provide enhanced ministry guidance on cultural heritage landscapes - Though this is a non-legislative change and technically not part of the EBR posting guidance around CHLs, particularly their conservation and protection is required and appreciated.