As an emerging professional…

As an emerging professional who has studied and worked in the field of heritage conservation over the past decade, I respectfully submit my objection to the proposed changes to the Ontario Heritage Act as part of Bill 23. Amidst an inarguable housing crisis, I agree and support efforts towards creating affordable and safe housing options in communities across Ontario. However, I disagree with the posturing that the Ontario Heritage Act and the conservation of cultural heritage sites are actors perpetuating this crisis. Frankly, the proposed amendments will not create more affordable housing options for those that call Ontario home and they disregard and undermine representation of Ontario’s multicultural history and cultural heritage assets.

By requiring the removal of buildings listed on the Heritage Register after two years (if there is no ‘intent to designate’ issued), and the subsequent restriction of including properties formerly on the register for five years, Bill 23 removes an important tool for communities in identifying and protecting valuable cultural assets. The strict timelines proposed alongside the prescribed evaluation criteria for designating properties would impose an impractical and impossible workload for municipal workers. Further, requiring the of properties from the register and from consideration of future developments wastes the effort and work that municipal staff have previously spent reviewing and compiling registers that capture an area’s cultural significance. Bill 23 will wildly destabilize municipal registers whose contents will be defined by arbitrarily established 2 and 5-year cycles. Property will be added to the list, will come off due to a scarcity of municipal resources or absence of need, and then may return to the Register once the 5-year period has lapsed. The status of the province’s 31,000 non-designated properties will be ever-shifting, creating a murky set of requirements to property owners, like a game with a shifting rulebook. Further, currently there is a deadline for submitting objections to a property listing, the proposed amendment would permit objections to be filed at any time, even years later. The impact would destabilize the heritage listing and approval process, creating more backlog.

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.

As noted by the Ontario Association of Heritage Professionals (OAHP), when the Report of the Ontario Housing Affordability Task Force was released earlier this year, OAHP supported recommendation 4, “Permit “as of right” conversion of underutilized or redundant commercial properties to residential or mixed residential and commercial use”; however, there are significant barriers that inhibit the conversion of existing buildings in Ontario, such as building code limitations/requirements and a lack of skilled trades. Introducing policies to support reuse or repurposing of existing buildings and the removal of certain ‘new build’ requirements for existing buildings would lead to more housing faster. Addressing these barriers and providing incentives for the conversion and expansion of existing buildings as well as additional adaptive re-use training programs would increase the ability for the Province to provide affordable and sustainable housing. In the face of unprecedented and ever-worsening climate crisis, it is vital that the existing building stock and the embodied carbon of these materials be considered as part of our future. Heritage buildings and sites of cultural heritage significance can support intensification through building conversion and adaptation and allow for more homes to be constructed through infill projects.

I with many others urge the Province to ensure that the path forward in addressing the housing crisis is not at the expense of built heritage resources, cultural heritage landscapes, and archaeological resources.