Thank you for the…

Thank you for the opportunity to comment on the proposed policies adapted from A Place to Grow and Provincial Policy Statement to form a new provincial planning policy instrument. Please see the attached PowerPoint presentation and report to Council, being RPT-0201-23, from the County of Brant for additional comments on the proposed Provincial Planning Statement (2023).

There are some changes to cultural heritage and archeology proposed in the Provincial Planning Statement (2023) not noted in the attached report to Council (RPT-0201-23), but that the County of Brant would like to make the provincial government aware of.

The County supports the conservation of heritage resources and landscapes and has been developing proactive strategies for the identification of properties and districts for evaluation under the Ontario Heritage Act. Identification, evaluation, and protection are equally important tools that work together to address matters of Provincial and municipal interest, and the proposed changes to the Provincial Planning Statement (2023) focus solely on “protected” heritage property. Municipally, there is an opportunity to leverage the development process in a proactive way for the purposes of identification and evaluation of cultural heritage resources that could translate into the adaptive reuse of heritage buildings. There should be clear opportunity for a municipality to identify and evaluate heritage resources during the development application process, which could be done within certain parameters to ensure the development application continues within the prescribed timelines. The County of Brant requests that the Province consider incentives at the Provincial level (similar to development charge waivers for additional residential units) for the adaptive reuse of a heritage building to be incorporated into the development or incentivizing moving buildings to an alterative site that will provide social benefits to the municipality. These opportunities would benefit both the applicant and municipality and be a responsible use of existing resources without the need for demolition.

Overall, the proposed policy changes create additional redundancies in the heritage conservation policy framework, undermining the work to identify and list properties and ultimately meet the matters of provincial interest in the Planning Act, and in particular the conservation of features of significant architectural, cultural, historical, archaeological, or scientific interest. There is no reference to the protection offered to “listed” properties in the proposed definition of a protected heritage property for the purposes of policy 4.6.1, essentially rendering the municipal listing process moot. Given the limited resources available for cultural heritage conservation in many municipalities, the County of Brant would support a simplified but multi-faceted approach to heritage conservation that incorporates opportunities to identify, evaluate, and protect built heritage resources in a timely and resource-effective manner. Consideration should be given to simplifying the processes of the Ontario Heritage Act and Building Code for the identification, evaluation, and protection of heritage resources and adaptive reuse of older buildings. Clear incentives should be provided for opportunities to adapt older buildings that have heritage potential as well as provide opportunities to be reused to support the community through additional housing units and amenities.

Should there be any questions about this submission, please do not hesitate to contact the County of Brant for assistance.