Proposed changes will bring…

Proposed changes will bring bulldozers to Ontario's heritage

First, the statement about what heritage will be protected is way too narrow. If left as proposed, i.e.
"2 (a) 4.6.1. Protected heritage property, which may contain built heritage resources or cultural heritage landscapes, shall be conserved"
the only property that will be protected is what is already protected. What is the point of stating a tautology?
I much preferred the original wording of 2.6.1 "Significant built heritage resources and significant cultural heritage landscapes shall be conserved"
because it acknowledged, as your proposed statement does, that not every heritage resource would be protected, while also setting out a criterion for what would be conserved.
The proposed change is especially worrisome in the wake of Bill 23 which will eliminate protection of most listed properties. For example, one rural municipality has 108 carefully researched and fully described properties on its Municipal Heritage Register of non-designated (listed) properties. But council has informed the Municipal Heritage Committee that council will designate, at most, two properties a year. Your proposed statement would mean at least 104 of these properties would be wide open for demolition in 2025.

The cynic in me wonders why the statement doesn't just say, Ontario's cultural heritage is not valued, and can be destroyed at will.
But I live in hope that someone does recognize the environmental, cultural, job-creation and economic value of cultural heritage properties, districts and landscapes.

If you won't change the wording on 4.6.1. to Significant built heritage resources and significant cultural heritage landscapes shall be conserved
Then please rewrite the definition of "protected heritage property" to be
• property designated under Part IV or VI of the Ontario Heritage Act;
• property subject to a notice of intention to designate in accordance with section 29(1.1) and subject to the limitations in section 29(1.2) of the Ontario Heritage Act;
• property included in an area designated as a heritage conservation district under Part V of the Ontario Heritage Act;
• property subject to a by-law designating an area as a heritage conservation study area in accordance with section 40.1(1) of the Ontario Heritage Act;
• non-designated property of cultural heritage value or interest recorded on the municipal register in accordance with section 27(3) of the Ontario Heritage Act;
• property subject to a heritage conservation easement or covenant under Part II or IV of the Ontario Heritage Act;
• property identified by a provincial ministry or a prescribed public body as a property having cultural heritage value or interest under Part III.1 of the Ontario Heritage Act and the heritage standards and guidelines;
• property with known archaeological resources in accordance with Part VI of the Ontario Heritage Act;
• property protected under federal heritage legislation; and
• UNESCO World Heritage Sites.

Secondly, the definition of adjacent lands is problematic. Limited adjacency to contiguous properties if much too narrow. It needs to be broadened to at least 60 metres from the subject property, and broader in specific circumstances, e.g. properties bordering canals like the Rideau or Trent.