It is unclear how the…

It is unclear how the proposed changes will help create more affordable or attainable housing. It is clear, however, that the changes threaten our heritage.

Threatening our heritage also threatens our existing affordable housing. As many historic homes have been subdivided into multiple living units, their demolition will eliminate much-needed housing.

The communities that are under- represented, such as 2SLGBTQIA+, Indigenous, Black, and new Canadians, will be only further under-represented if the "threshold" for designation is changed to requiring at least two criteria being met.

This will make it almost impossible to protect our more humble buildings and places, and would help strengthen the already powerful bias towards the rich, white, European sociocultural and historic voice.

The changes to listing properties on the Municipal Heritage Register will place undue pressure on municipal staff and volunteers, especially in smaller municipalities. It is unrealistic to require listed properties to be designated within two years of being listed on the Municipal Heritage Register.
This requirement will put historic properties at risk because municipalities may not be able to enact by-laws to protect them in time.

Historic buildings are great options for conversion to affordable housing. Located in older, established neighborhoods, these buildings are often near public transit and have amenities within walking distance. Many have already been converted to multiple units and offer more affordable housing options. Putting historic buildings at risk, then, also puts affordable housing options at risk.