Some of these changes like…

Some of these changes like being able to amend an HCD plan and applying regulation 9/06 to listing of properties is positive. Unfortunately there are more negatives in this bill. The time limits applied to listed properties is especially unfortunate given the amount of work over decades that municipalities have put into compiling their heritage registers. Listing is a non-resource intensive way for communities to flag properties of potential heritage value and interest without proceeding through the intensive process of designation. There is no restriction applied to owners of listed properties beyond needing to provide notice of intention to demolish. In many small communities where not much development occurs, this protection for demolition is often considered enough protection especially where the municipality may not have staff equipped to handle heritage permits if the properties were designated. Listed properties can be radically altered to accommodate new construction and housing so long as demolition isn't undertaken. The proposed 90 timeline associated with planning events provides clarity around how such properties should be dealt with in the event of planning applications. The requirement to have all listed properties either be designated or removed from registers within two years makes no sense and is an affront to the heritage conservation efforts of communities across the province. Municipalities are not sufficiently resourced to designate the likely thousands of properties on registers within two years, though municipalities may try to advance designation for many which would only result in more restrictions on these properties than had they been left solely as listed properties. At the very least, the two year timeline should not be retroactive to already listed properties. Also concerning is the requirement for a property to meet two or more criteria under regulation 9/06 for designation. Many sites associated with BIPOC communities do not contain grand architecture, but nevertheless have very important historical and value for those communities. By requiring two criteria the province will be taking heritage conservation efforts back to a focus of purely architectural preservation associated with primarily white Ontarians rather than heritage conservation, which includes the places of importance to BIPOC Ontarians. Lastly, the notion that heritage conservation somehow hinders new home construction is false. There are countless examples of adaptive reuse of heritage buildings to accommodate new homes that were once factories, warehouses, and schools. The conservation of these existing structures is more sustainable, provides jobs for specialized labour, and often results in the kind of missing-middle housing that would have been less likely if the existing building were torn down. In the same way that existing single detached, semi, and row housing of all ages provides opportunities for intensification without demolition, so to do our protected heritage properties. I would strongly encourage the province to take more time to consult with municipalities, BIPOC communities, and other stakeholders before passing Bill 23.