The Architectural…

The Architectural Conservancy, the North Waterloo Region Branch is one of fifteen branches in Ontario committed to preserving and reusing structures of cultural significance. We are opposed to the new Provincial Planning Statement for the following reasons:

It will weaken the protection of Ontario's heritage.

· It would limit protection of built heritage resources and cultural landscapes to only those already designated. (Section 4.6)

· Heritage resources which qualify for designation under the Ontario Heritage Act, but not already formally recognized by municipalities, risk demolition. Municipalities will not be able to protect the heritage value of a property when it is threatened by new development.

· Because this statement applies only to protected properties, municipalities will not be able to assess non-protected properties to see if the heritage attributes should be protected.

· The proposed Provincial Planning Statement undermines the Planning Act which clearly states "the conservation of features of significant architectural, cultural, historical, archaeological or scientific interest" is a matter of provincial interest.

· Policy 4.6.1 should be strengthened to say "Cultural heritage property, which may contain built heritage resources or cultural heritage landscapes, shall be conserved."
It will reduce the likelihood that existing buildings will be kept, maintained and reused, weakening Ontario's ability to reduce greenhouse gas emissions and fight climate change.

· Section 2.9 on “Energy Conservation, Air Quality and Climate Change” needs to specifically mention that maintaining, retrofitting and adaptively reusing existing buildings and structures is a good way to reduce greenhouse gas emissions and prepare for the impacts of a changing climate.

· Properties that currently meet the criteria for designation, which have not yet been designated, due to time and financial constraints, which were significant under the former PPs are no longer allowed to also be protected.

· There are 33,000 properties on municipal registries, which have some heritage potential, but have not been afforded full protection. If these are not designated by December 31,2024, they will have no protection. There is not enough time for municipal heritage committees to evaluate such a large number of properties and have them designated. Some municipal governments have no specialists who can evaluate the listed properties to see if they should be protected.

· Municipal heritage procedures have been in place for about 50 years and there have been extremely few cases where heritage properties put new development at risk. If a building with heritage value was in a location where development was planned, the development simply went around it. There are a number of cases in our region where the homes built in the late 1800s are still intact, with large subdivisions all around them. These properties have retained their heritage value and in addition are sold for large sums of money.