RE. Proposed Changes to the…

RE. Proposed Changes to the Ontario Heritage Act and its regulations: Bill 23 (Schedule 6) - the Proposed More Homes Built Faster Act, 2022
I work as a consultant in the heritage field, and I am gravely concerned about these changes which will have a direct and negative impact on my work as a heritage professional. While these changes are billed to create jobs, you are not looking at those who's jobs are being threatened now as a result.

As a single mother who is doing her best to make ends meet, and who may be in need of affordable housing depending on how this proposed bill change affects my employment, I am not at all confident these OHA changes (or many of the other non-cultural heritage related changed) will help alleviate the intense, and immediate need for affordable housing now or even in the future.

I feel the heritage industry is a bit villified in the construction/building/development industry as an obstacle. I would like to ad my voice to the growing chorus that heritage conservation and housing development can be mutually beneficial. Reuse and adaptation of existing buildings and neighbourhoods, combined with well-designed and well-planned infill, can and will result in new homes for Ontarians. This tack will get MORE HOMES BUILT (or in these cases, REUSED) FASTER.

The heritage industry to which I belong, contributes to construction/building/development industry in a variety of ways including as tradespeople, engineers, architects, and planners. Heritage professionals have a unique understanding of the challenges and opportunities of working with older structures; but we have not been asked to join the conversation. We would very much welcome a seat at the table! We have solutions, ideas on ohow to create more housing.

MORE UNINTENDED/UNFORSEEN COST - Regarding person power needed to address these changes in the workforce in REALITY and in the trenches here, the proposed amendments would mean that non-designated properties currently included on a municipal register would have to be removed if council does not issue a notice of intention to designate (NOID) within two years of the amendments coming into force. It is not feasible to review all of these properties for designation within two years. To remove these properties from
consideration of future developments is a waste of all the time and money that was spent reviewing and compiling these registers.With the proposed removal of planning responsibility from many regional and county governments, our field will see a further reduction in professional capacity as well as existing technical studies (such as archaeological management plans) that are critical to heritage management in this province. This uncertainty in the process is not good for homebuilders, communities or heritage experts. In some cases, it will also result in increased costs to homebuilders and tax-payers.

UNDER-REPRESENTED (i.e., non-white) PEOPLE'S CULTURE IS BEING OVERLOOKED - increasing the threshold for listing and designation under Part IV of the Ontario Heritage Act will make it more difficult to address reconciliation as well as issues of equity, diversity and inclusion in the protection of cultural heritage resources in Ontario. There are many properties that reflect underrepresented groups that would no longer meet the criteria for designation under Section 29 Part IV. This will mean that the current inequity in the criteria will continue to assign more value to the contributions of architecture and well-documented histories rather than recognizing the diverse stories that make up Ontario’s history. Any revision to provincial criteria must ensure that underrepresented communities can still protect the cultural heritage resources that are important to them. This is a significant concern for me as many of my colleagues have been directly involved in efforts to rethink traditional understandings of heritage designations and listings.

Please, pump the breaks on this damaging bill. Lets get the people with real experience and expertise contributing to solutions here. Please listen. This is not the Ontario in which I want my kids and my family to live, work and play.