Comment
Ontario Heritage Toolkit: Your Community, Your Heritage, Your Committee
• Section 2.3.4 notes that a municipal heritage committee may consider seeking support from private or service sectors for special projects in the form of donations of services, supplies and project-specific funding. Could additional advice be provided regarding seeking additional funding for heritage projects?
• Section 3.3 notes that “… in larger municipalities, the MHC may be assigned to a particular department such as Planning or the Clerk’s Office. The department should identify which of its resources the MHC should reasonably expect, e.g., a staff liaison, photocopying, meeting space, translation services, refreshments, letterhead, records management, typing, etc.”. Can the OHT provide additional guidance on generally accepted processes and standards for municipal heritage committees?
Ontario Heritage Toolkit: Heritage Property Evaluation
• Section 3.1 notes that for properties designated under Part IV, the municipal register must include a legal description of the property, the name and address of the owner, and a statement explaining the cultural heritage value or interest of the property and a description of the heritage attributes of the property. Are online registers required to include the owner information for designated properties under Part IV? Or can that information be included in an internal version of the Heritage Register?
• In Section 3.2, clear guidance should be given on how municipalities should prioritize properties that are listed and manage change for listed properties and how to deal with miscommunication about the value of a listed property.
• In Section 5.0, more guidance should be given related to a property meeting some criteria, but it is not worthy of designation (it meets the criteria of having associative or historical value, but little or no physical and design value or contextual value). Additionally, can you provide guidance for municipalities in identifying recognition of properties outside of Part IV designation?
• Section 5.1: Can heritage attributes that have been recently lost be identified as heritage attributes in the by-law if the intent is to restore them, or does the by-law need to be amended following the restoration of the attributes?
• Section 5.7.1: Can more clarification be added to “representative” as this is an incredibly broad criterion as a portrayal or symbol could be applied to a very run-of-the-mill property.
• Section 5.6.2 could clarify how a property would “exemplify” an association with a theme, event, belief, person, organization or institution” and whether this would need to be physically exemplified vs. an intangible attribute of the property.
• Criterion 2.ii: Can this criterion be specifically focus on archaeological value? It is difficult to determine whether information discovered as part of the research for a property contributes a greater understanding of the community apart from archaeological evidence not visible on the property itself. It would be beneficial for municipalities if this criterion were narrowed to only archaeological evidence.
• Criterion 2.iii: The explanation as written indicates that an architect, artist, builder, designer, or theorist would need to be significant to a community because they made a strong, noticeable, or influential contribution. This should be clarified as the architect etc. may have only built one property that is not well-known within the community however is extremely influential or well-known within the province or outside of the community.
• Criterion 3.i: “To meet this criterion the property needs to be in an area that has a definable character, and it is desirable to maintain the character”. This description assumes that a heritage property within an extremely changed landscape cannot be a landmark within that landscape unless it has a desirable and definable character.
Ontario Heritage Toolkit: Designating Heritage Properties
• Section 3.1 should address the real pressures municipalities face as part of applications under the Planning Act to identify and conserve heritage properties as part of that process, in addition to noting properties of cultural heritage value or interest are usually identified by municipal heritage committees, or through a local community process such as an inventory of cultural resources, a municipal cultural planning process, or a community planning study.
• While noting that many listed properties on a Heritage Register are eventually recommended, for designation Section 3.1 should clarify that the intent of listing on a municipal heritage register is to provide the 60-day period for demolition applications. Indicating that the properties are eventually recommended for designation demonstrates the disconnect between listing as an interim measure and having properties being “only” listed vs. designated.
• Section 4.2 identifies that under the Ontario Heritage Act, designation of a heritage property applies to real property — the land itself and the buildings and structures on it. In some cases, only a portion of a property may be considered to have cultural heritage value or interest, not the entire property. It is recommended that the term “structures” be replaced with “additional features” to not exclude non-structure attributes (i.e., natural features).
• Section 5 identifies that “[i]f a property is important for its architectural design or original details, and that design is irreparably changed, it loses its heritage value and its integrity”. This description should include non-built features that have been identified as heritage attributes.
Ontario Heritage Toolkit: Heritage Conservation Districts
• Section 1.2 should include sustainability and climate change as an integral element to heritage conservation by way of Heritage Conservation District designation.
• Section 2.1 notes that there is no formal process for requesting to designate an HCD but should include examples of best practices in the province for this process and what has been successful in the past.
Ontario Heritage Toolkit: Places of Worship
• Section 2.0 notes that it is common to find heritage places of worship at the centre of a village, town, or urban community, identified as local landmarks. This should be expanded to reference churches within rural communities as well.
• Additional guidance should be provided within Section 2.4 to provide examples of a statement of significance that includes identified interior attributes but also identifies what is characterized as chattel? Would a pew affixed to the floor be “affixed” if removing them would cause damage to original floors?
• Section 2.5 indicates that “Municipalities should consult with the property owner on the evaluation and resulting statement of cultural heritage value or interest to determine the heritage attributes that require protection, as well as the most appropriate protective mechanism.” Is this referencing alternative ways to protect the property outside of Part IV designation?
• Section 3.7 - Heritage conservation easements should include additional guidance on when municipalities should request heritage conservation easements with property owners would be beneficial, with examples.
• Section 4.1 - Preventive conservation and maintenance should include Terms of Reference or additional guidance for conservation plans, which would be beneficial to ensure more consistency across Ontario municipalities.
• In Section 4.1, guidance on environmental sustainability should include reference to solar panels etc. in terms of balancing priorities.
• Section 4.2. needs to be consistent with the amended Ontario Heritage Act language regarding determining whether something is alteration vs. demolition.
• Section 4.3 regarding additional consideration for exterior alterations or demolitions requires additional clarification regarding fixtures vs. chattel if pulpit is identified as being potentially identified as an attribute. Would a pulpit have to be affixed to be identified or could it be a moveable pulpit identified if significant?
• Section 4.6: Could additional guidance be provided regarding development adjacent to Places of Worship?
• Section 7.1 provides examples under “Contextual Value” including historic and current landscaping (significant trees, garden walls, decorative fencing). These are describing physical attributes of the property and may be better described by identifying how those landscape features are understood within the surrounding context vs. in and of themselves.
Submitted June 28, 2021 1:56 PM
Comment on
Updates to the Ontario Heritage Toolkit
ERO number
019-2770
Comment ID
57967
Commenting on behalf of
Comment status