•In general, the use of…

•In general, the use of examples or pointing to example projects/reports/policies would be useful, i.e. pg. 8 specific examples of land use planning and development approvals tools that have been used, p. 29 in the first paragraph of section 4.3. Identifying Cultural Heritage different mechanisms used by municipalities are mentioned but there are no references to examples, and pg. 46 examples of different measures used for the conservation/preservation in place of archaeological resources would be super helpful.

•The language used throughout the guide is quite technical and may not be accessible to the general public or those without a working knowledge of heritage conservation and its guiding legislation, processes and terminology, e.g. a definition of the range of approval authorities would be helpful.

•It is unclear who the target audience is for this revised guide.

•Pg. 9 - Renewable Energy Approvals - Is the MTCS still working under the guidelines in Cultural Heritage Resources: An Information Bulletin for Projects Subject to Ontario Regulation 359/09 - Renewable Energy Approvals? If so, it would be useful to reference the guide in this section.

•Pg. 26 - "It must be noted that there are differences between these Standards and Guidelines and Ontario's heritage polices. Where this is the case, Ontario's legislation, and policies and guidelines issued under this authority, take precedence." Can you please provide examples?

•Section 4.4 makes reference to the checklist, which includes consideration for properties "within the watershed of a Canadian Heritage River." Can the MTCS provide guidance as to how this should be addressed in an HIA?

•Pg. 36 – Reference is made to the fact that it is illegal to knowingly disturb an archaeological site without a licence and it would be helpful to elaborate in a fully detailed way here and/or elsewhere in the guide on what may be considered illegal disturbance.

•Pg. 49 - In terms of adjacent lands, an example of a more complex scenario (i.e. if there is an additional easement beyond the public right-of-way (i.e. utility easement)) would be useful.

•Section 8.0 – It would be very helpful to explain all types of assessment reports that may be required to be completed as a result of development and site alteration applications, including EAs. A clear statement of the names of these reports (Cultural Heritage Assessment Report vs. Built Heritage and Cultural Heritage Landscape Assessment, Cultural Heritage Evaluation Report, Heritage Impact Assessment, Conservation Plan, Documentation & Salvage Report) and an explanation as to when they should be completed, what their purpose is and what content they should contain would be very helpful in ensuring that a consistent system of reporting and documentation is undertaken across the province.

•Pg. 56 – The last bullet in the list of documentation to be provided in a CHER states “either a draft statement of cultural heritage value when it is found or a rationale if a property is found not to have cultural heritage value or interest.” As heritage consultants, we use relevant evidence and significant experience evaluating cultural heritage resources using the criteria outlined in O. Reg. 9/06 of the OHA to reach conclusions on whether a property is found to have CHVI.

•Pg. 57 – the second paragraph discussing HIAs states that they are usually undertaken as part of the required supporting material for a complete application under the Planning Act. We would suggest this statement needs revision/needs to be broader as HIA are undertaken when there is the potential of a development activity impacting a cultural heritage resource and this could occur through activities related to many pieces of legislation such as the EA Act, REA Act, Aggregate Resources Act, Forest Management Guidelines, etc.

•Section 8.9, which focuses on impact assessment, only looks at negative impacts, while the possibility of positive impacts are not addressed. In ARA’s experience, some projects may have positive impacts. For instance, the removal of a 1960s utility building along a riverscape would enhance a view, or the assessment of buildings not yet examined as part of a municipality's municipal heritage register may add to the understanding of a community.

•Section 8.10 on Mitigation or Avoidance bluntly states that "commemoration and/or interpretation signage are not mitigation strategies." However, in some instances, these as well as documentation and salvage, may be viable considerations after Council has approved the Heritage Impact Assessment. How should commemoration/interpretation be addressed in an HIA?

[Original Comment ID: 211342]