I would like to express my…

I would like to express my strong opposition to certain proposals in Bill 23, the More Homes Built Faster Act. These proposals will have an extremely negative impact on our community’s ability to protect its cultural heritage resources. My concerns are outlined below.

Heritage Registers

Heritage registers are internationally-recognised tools to protect cultural heritage resources. Toronto’s heritage register has been in existence for decades and contains many thousands of properties considered to possess cultural heritage value. Thousands of hours of research by volunteers and staff were involved in adding properties to the register. Currently, the City is conducting a City-wide heritage survey to ensure that properties with heritage value are identified on the register. This will enable better response to development proposals when heritage resources are involved.

I am extremely concerned about the proposal that all properties on the heritage register that are not designated under Parts IV or V of the Ontario Heritage Act, (that is, listed, but not designated) will be dropped from the register after two years unless they are officially designated within that period. Currently, an owner of a listed property is not subject to any restrictions except for having to give 60 days notice of intent to demolish the property. This time period can give city staff time to evaluate the heritage value of the property and to recommend designation of the property if warranted. This proposed change is a complete disaster for the heritage register and for the protection of heritage properties.

The proposal that once a property is dropped from the heritage register, five years must elapse before it can be considered for re-addition to the register, is frankly baffling and can only be seen as damaging to heritage preservation efforts.

Designation Criteria

Although not addressed directly in the Act, the Ministry proposes that a property must meet two, instead of one, of the criteria for designation. This would make it more difficult to protect heritage properties. At present, obviously-significant heritage properties can qualify for designation based on only one criterion. The proposal to require meeting two or more criteria makes no sense and will disqualify properties worthy of designation. Importantly, properties that may not be architecturally significant, but have strong associations with local communities, may no longer qualify for designation. This goes against current government policy to afford more recognition to marginalized and minority communities.

Conclusions and Recommendations

I conclude that Bill 23, in its current form, presents a significant threat to our cultural heritage resources – both now and in the future. At the same time, the I do not understand how the proposed legislation will result in a significant increase in affordable housing. Housing and heritage are not mutually exclusive as can be illustrated by numerous examples of re-purposed industrial and commercial buildings. Heritage is also an important factor in improving a community’s “liveability”.

I recommend further discussion with heritage advocates and professionals to mitigate the potential harm of this legislation. To this end, I recommend a further extension of the time period allowed for review of the proposed changes.