Architectural Conservancy…

Architectural Conservancy Ontario (ACO) is the largest heritage advocacy organization in Ontario with 17 branches across the province. Our objective is to promote the identification, conservation and reuse of buildings, structures, districts and landscapes of cultural heritage significance. Under our Keep, Fix and Reuse slogan, we advocate for socially and environmentally sustainable solutions for Ontario’s older building stock.

ACO welcomes the opportunity to comment on the Province’s proposed amendments to the Ontario Heritage Act (OHA) and O.Reg. 385/21 with respect to certain alteration requests, which are intended to allow religious organizations and Indigenous communities or organizations to move forward with their proposed alterations.

We have several concerns:

1. The MCM ERO posted proposal does not justify why these amendments are necessary. Separate provisions for religious buildings, which weaken the OHA, are not required. Simply stating that the proposal would reduce application requirements and shorten decision making timelines is not adequate and will likely be ineffective, as explained below. Whatever issues the proposal is attempting to respond to would be better addressed in appropriate guidance material, using the existing Places of Worship guide.

2. The proposal posted on the Environmental Registry of Ontario does not contain the draft wording for the proposed amendments to the OHA nor the O. Reg. 385/21, so ACO requests that MCM provide sufficient time for municipalities and organizations such as ACO, Community Heritage Ontario, Ontario Professional Planners Institute, and the Ontario Association of Heritage Professionals to comment on such draft wording.

3. Many religious organizations do not have the financial resources to build their own religious buildings and, as a result, they use spaces such as community halls or gymnasiums for a place of worship. Would this type of facility, with heritage attributes designated under Part IV of the OHA, qualify as a religious building? Clarification is needed.