As a long-serving volunteer…

As a long-serving volunteer member of a municipal heritage advisory committee, I support many of the proposed changes to the Ontario Heritage Act, although I would like to express some concerns regarding a few of the proposed amendments. I feel that several of the proposed amendments will negatively impact the review process for Listed and Designated heritage properties, and as a result may result in the inadvertent and irretrievable loss of built and cultural heritage assets in our communities. There does not seem to have been a proactive consultation process in regards to developing the proposed changes within the heritage community, nor have there been, to the best of my knowledge, circulated guidance documents in order to help prepare staff, heritage committee members, and local history support organizations in respect to working with the new proposed regulations. This should be done well in advance of rolling out the changes to ensure that we are collectively well-prepared to manage the new requirements from the outset.

I also strongly feel that a significant weakness of the LPAT appeal board is the lack of a heritage professional familiar with heritage related matters. If we collectively view our built and cultural heritage as significant assets in our communities and in the province, it would seem most appropriate to have a voice at LPAT that can weigh in with full understanding of heritage matters, with personal heritage expertise in conservation, and with full knowledge of the heritage planning processes. As LPAT currently lacks this guidance, LPAT is not capable of fully understand the nuances of working with heritage applications, in my opinion.

My concerns are as follows:

2. Mandatory content for designation by-laws

- Land Registry Offices have varying capacities and accessibility to documents, which might provide difficulties in accommodating this requirement, and as such may create additional workflow challenges, which should be considered in points 3 & 4 (below).

3. Events which would trigger the new 90-day timeline for issuing a notice of intention to designate and exceptions to when the timeline would apply

- The 90-day timeline is restrictive, and provides too many variables to be practically workable. Preference would be set times frames of a longer duration for points 3 & 4, such as 120-day timeline for Part 3, and 160-day timeline for Part 4.

4. Exceptions to the new 120-day timeline to pass a designation by-law after a notice to designate has been issued

-We would prefer to see a longer timeline. See above.

5. Minimum requirements for complete applications for alteration or demolition of heritage properties

-We would also prefer to see the 60-day timeline extended to a 90-day timeline to allow for appropriate internal and external consultation and response.

9. Transition provisions

-Strong consideration should be given, considering the ongoing pandemic and existing staff challenges with accessibility to informational resources and repositories, to extending the implementation date for one year, coming into effect in fall 2021.

Thank you.