1. The OHTK Infosheets are…

1. The OHTK Infosheets are not updated. Please identify when they will be updated as these are also important components of the OHTK and Ministry-related guidance.
2. The OHTK does not provide much information on the difference between condition and integrity and whether or not condition and integrity should be considered when determining whether or not long-term conservation is warranted. This is mentioned in the Parks Canada Standards and Guidelines and should reasonably be addressed in the OHTK (i.e. the evaluation and/or designation documents)
3. The OHTK should provide additional information on how to define "significant". I.e. is every resource that meets the OHTK criteria significant? The former definition of significant has been removed and should be addressed. It used to define significance as to whether or not it makes an important contribution to a people or place.
4. The OHTK offers little information on Indigenous consultation and should be addressed. Perhaps an additional OHTK document specifically on Indigenous affairs, history, and consultation is warranted.
5. The OHTK should identify specific examples of successful commemoration efforts which mitigate the loss of heritage resources.
6. The OHTK should provide additional guidance on the difference between design/physical value, historical/associative value and contextual value. Specifically, the OHTK states that "A property's cultural heritage value or interest is expressed through specific heritage attributes that are identified through the evaluation process.". Further that their merit will be based on whether or nit the physical features "currently exist". Therefore, the OHTK should be clear on what this means. This suggests that a property may be of historical/associative value, but that if the physical (tangible) elements have been removed, there may be nothing on the property to physically conserve. However, the property may still have historical/associative value that can be commemorated or recognized through other means.
7. The OHTK mentions "documentation" but does not identify it as a form of mitigation. The OHTK should be clear on what is defined as alternative development options (avoidance) and what is mitigation (to make less of an impact) such as commemoration, documentation or salvage
8. The OHTK addresses easements - but does not identify situations where easements may not be warranted. In some situations, the designation of a property under Part IV is sufficient. The OHTK makes it seem as if an added layer of protection (via an easement) is a best case scenario. It should be identified that easements are only appropriate for certain situations, and not others.
9. The OHTK could potentially provide additional information on the Building Code - there are many situations where considering whether or not a heritage building should be demolished is weighed against existing structural conditions and whether or not a building meets current code requirements.
10. The OHTK may consider providing a more clear definition of "alter" and "demolition". For example, can a person demolish an attached addition to a listed heritage building if it is argued as an "alteration"?
11. The OHTK notes that "using physical condition as a determining factor in whether or not to add a property to the ..register of a heritage property is not advised". This may be interpreted that condition should not be weighed in whether or not long-term conservation. This interpretation would directly go against the Parks Canada S&G which identifies that condition should always be determined in whether or not demolition should be considered.
12. "The ability of the structure to exist for the long term, and determining at what point repair and reconstruction erode the integrity of the heritage attributes, must be weighed against the cultural heritage value or interest held by the property." This statement should be further explored.