Comment
I have had time to review only two of the six documents in the too short time frame provided.
I will submit detailed comments separately (typos, suggested additions, deletions, questions of clarification etc)
The following are general comments applicable to more than one of the documents/guides.
1. Nowhere is it specified exactly how one goes about ensuring an archaeological assessment is completed, when one has good evidence to suggest archaeological remains or artefacts are onsite. Questions like Who does one contact? How? Is there a timeframe?
This should be added to all relevant guides, e.g. Designating Heritage Properties
2. There should be a separate section on the Ontario Heritage Trust Register added to all applicable guides. This would repeat, but clarify, information from the OHT website https://www.heritagetrust.on.ca/en/index.php/pages/tools/ontario-herita…
The Trust website is confusing. On the one hand, under Role of Municipalities, it says designation bylaws, notices and other legal documents are to be sent to the Trust as part of the designation process. But under Types of Records, it lists only decisions, designations, repeals, etc. making me think only the final documents need to be sent (not the notices of the documents to come) This should be clarified in the Toolkit.
As currently written, the Guides contain numerous passing references to the need to send information to the Ontario Heritage Trust, but don't specify precisely how, when, what form.
3. Designating Heritage Properties misses the very important point that permission of the property owner is not required to designate or list a property.
Guides should also cite Provincial Policy Statement 2.6.1. "Significant built heritage resources and significant cultural heritage landscapes shall be conserved."
And they should cite the landmark precedent-setting case Tremblay vs Lakeshore, https://www.clo-ocol.gc.ca/en/language-rights/court-decisions/tremblay-…
4. The Designating Heritage Properties Guide misses the VERY important second part of OHA 35.3 that council can require repairs and enforce maintenance standards
35.3 (b) require property that has been designated under section 29 or 34.5 and that does not comply with the standards to be repaired and maintained to conform with the standards. 2005, c. 6, s. 27
5. Guides should state ALL the ways municipalities can provide support for the conservation of designated properties, not merely property tax relief. They should guide readers to more information, i.e. relieve 10-40% of the owner's property taxes, provide loans or grants for repairs or restoration.
Submitted July 2, 2021 8:54 PM
Comment on
Updates to the Ontario Heritage Toolkit
ERO number
019-2770
Comment ID
58105
Commenting on behalf of
Comment status