I have issues with some of…

I have issues with some of the amended land use policies proposed in this Statement as they apply to heritage properties in the Province. Along with amendments to the Heritage Act in Bill 23, these put a significant number of heritage properties under risk and make it much more difficult for municipal heritage planners to effectively do their jobs. Under this "use it or lose it" approach many listed properties on heritage registers will be struck from the list by January 1, 2025, and cannot be re-instated within 5 years. In the attendant scramble to officially designate individual properties of major historical and architectural importance within the next two years, it's logical to conclude that many significant structures will fall through the cracks and miss this deadline, resulting in a loss of many irreplaceable heritage buildings to new development.

Some of the proposed language in the new PPS seems to continue the erosion of protections for heritage properties found in Bill 23. “Significant built heritage resources and significant cultural landscapes” is gone, replaced with “protected heritage property which may contain heritage resources...shall be conserved”. Protected heritage property is defined as property designated either individually or as part of a HCD. So, going forward, properties that are under consideration for designation, listed properties, and properties that are designated as a result of a demolition or development application will not be included in this new PPS as they were before. This again has the effect of removing protections for certain types of properties.
The definition of ‘adjacency’ is also changed. A more restrictive meaning of “contiguous” means that there may be no more latitude for Official Plans definitions that go beyond strict contiguity. This is a potential problem.

Also, the recommendation that “proactive strategies for the identification of property evaluation under the OHA” be undertaken is not clear. The intent of this phrase should be clarified.