ACO (Architectural…

ACO (Architectural Conservancy Ontario) finds that the proposed PPS 2023 substantially weakens the policies in the existing PPS 2020 with respect to cultural heritage. As such, it would undermine a vital part of Ontario’s heritage protection regime.

Under the pillar, “Balance housing with resources” the proposal says that the proposed policies would, with respect to heritage resources, “Update the cultural heritage policies to align with Ontario Heritage Act (OHA) amendments through Bill 108 and Bill 23, with a focus on conserving protected heritage properties.”

The Planning Act, in section 2(d), identifies “the conservation of features of significant architectural, cultural, historical, archaeological or scientific interest” as one of the matters of provincial interest. The Minister and all planning authorities “shall have regard to” these matters in carrying out their responsibilities.

This raises an important question whether, as proposed, the severely curbed policies in section 4.6 of the PPS 2023 are aligned with the intent and spirit of the Planning Act, where the conservation of features of heritage interest are a “matter of provincial interest.”

Section 2 of the Planning Act also identifies other matters of provincial interest relevant to the conservation of cultural heritage and, more broadly, the retention and reuse of older buildings, including:
(g) minimization of waste; ...
(q) the promotion of development that is designed to be sustainable, to support public transit and to be oriented to pedestrians;
(r) the promotion of built form that (i) is well-designed, (ii) encourages a sense of place, and (iii) provides for public spaces that are of high quality, safe, accessible, attractive and vibrant; and
(s) the mitigation of greenhouse gas emissions and adaptation to a changing climate.