Attached, please find the…

Attached, please find the response from the Ontario Association of Heritage Professionals. Below is a summary of OAHP's comments:

Proclamation Date
OAHP requests that the proclamation for the regulation be moved to July 1, 2021 to allow municipalities and their staff more time to prepare.

Affordable Housing
OAHP recommends that the Ministry of Heritage, Sport, Tourism and Culture Industries incorporate the connection between heritage buildings and affordable housing in the revised Ontario Heritage Toolkit. Donovan Rypkema’s Measuring Economics Impacts of Historic Preservation can be accessed at:
https://www.achp.gov/sites/default/files/guidance/2018-06/Economic%20Im…

Principle 1.
OAHP requests that the word “should” be replaced with “shall” to be consistent with the direction of the Province in Policy 2.6.1 of the Provincial Policy Statement (2020).

Principle 2.
OAHP requests that the wording of the proposed regulation be consistent with the language in existing legislation and that the language “Significant built heritage resources and significant cultural heritage landscapes shall be conserved” from the Provincial Policy Statement (2020) be adopted as a principle for the Ontario Heritage Act.

Adaptive Reuse Definition.
OAHP requests that the definition of ‘adaptive reuse’ be revised to “the alteration of a property of cultural heritage value or interest to fit new uses or circumstances while retaining the cultural heritage value or interest and the heritage attributes of the property”.

Prescribed exceptions s. 29 (1.2) of the Act.
OAHP requests that the 90 day timeline to issue a Notice of Intention to Designate be increased, or that an additional exemption be included that provides municipalities more time to address requirements for peer review.

Designation by municipal by-law, requirements.
OAHP requests further guidance from the Ministry of Heritage, Sport, Tourism and Culture Industries on how to briefly explain how each heritage attribute contributes to the cultural heritage value or interest of a property. OAHP suggests this could be provided in the revised Ontario Heritage Toolkit.

Prescribed information and material.
OAHP requests that the requirements for complete application also be applied to properties designated under Part V of the Ontario Heritage Act. OAHP suggests wording be revised to “on the next day that is not a Saturday, Sunday, or a holiday.”

Council consents to application under s. 34 of the Act.
OAHP requests clarification on the wording of this section. Are non-heritage buildings/structures exempted from this provision or does the removal of any building/ structure including non-heritage buildings/structures require Council approval?

Record of Decision.
OAHP requests revising this provision to be within 20 days after notice of appeal is given. This would be consistent with the requirements of an appeal pursuant to the Planning Act but still provide the information in a timely manner.

Ontario Heritage Toolkit.
OAHP requests:

Updated process flowcharts. These are useful tools in implementing the processes affected by these amendments and regulations.

Interpretation and commentary from the Ministry of Heritage, Sport, Tourism and Culture Industries on the distinction between “alteration” and “demolition or removal” of a heritage attribute. OAHP believes this will be critical to implement the amendments to the Ontario Heritage Act.