Submission to the ERO…

Submission to the ERO regarding 019-6196

I am very concerned that the Ontario Heritage Act (OHA) is being significantly changed as part of Bill 23, the More Homes Built Faster Act, 2022. It is apparent that the provincial government does not value our built heritage and sees it as a barrier for building houses.

I agree that Ontario needs more housing but it should not be at the expense of our built heritage. My main concerns with the proposed legislation are:

1. There is no assurance that the proposed changes to the OHA will create any affordable housing.

2. It forces communities to remove properties from their heritage registers if they are not designated within a 2 year period. Based on the current legislation, most communities have many more listed rather than designated properties. Listing helps to protect heritage buildings because it requires a 60 day period of reflection if a demolition permit is requested. The designation process is much more complex and time consuming requiring significant effort on the part municipal planners. As a result, on average, only a few properties can be designated each year. This will force municipalities to cherry pick only a few properties that can be protected through designation during the proposed time period.

3. The requirement that a property must meet two of the legislated criteria for designation instead of one will challenge the protection of the more humble buildings and places associated with more marginalized groups such as Blacks and Indigenous Peoples.

4. This proposed legislation fails to recognize the sense of place that built heritage provides, and the contribution it makes to tourism and local businesses.