The Canadian Association of…

The Canadian Association of Heritage Professionals (CAHP) in partnership with its Ontario Chapter, OAHP, respectfully submits the following comments related to ‘Opportunities to increase missing middle housing and gentle density’, as part of the Ontario’s More Homes for Everyone Plan. Our organization represents more than 400 heritage professionals living and working in the province of Ontario, the majority of whom are actively involved in countless development projects. Our response is based on a survey to our membership, who were unanimous in noting that the Housing Task Force Report recommendations will have a direct impact on their work as heritage professionals.

As an organization, we welcome the Province’s commitment to addressing the current housing crisis and we also look forward to more information on the work that the Minister and cabinet are doing to address affordable housing. We also welcome the staged approach to implementing the majority of recommendations of the Task Force. This will offer an opportunity for additional consultation with stakeholders, which has yet to be undertaken with any heritage stakeholders including the Architectural Conservancy of Ontario, Community Heritage Ontario, or our Ontario members represented by OAHP.

Meeting the targets of More Homes for Everyone will require creative solutions. We believe that CAHP could bring the perspective of professionals with expertise in using existing buildings to the Working Group’s deliberations as a means of providing more affordable housing. It is also important to include existing buildings in these discussions because of their role in building sustainable and healthy communities. CAHP is prepared to play an active role in the Working Group and would like to formally request to become a member.

According to the 2022 Report from the federal Net-Zero Advisory Board, over two thirds of existing houses in Canada will still be there in 2050. As a result, we believe that heritage conservation has to be part of the discussion when exploring how to create gentle density in neighborhoods.

We urge the Province to ensure that the path forward to addressing the housing crisis not be forged at the expense of built heritage resources, cultural heritage landscapes, and archaeological resources. Cultural Heritage can be an integral component in the creation of affordable housing and healthy, sustainable neighborhoods.

Current barriers inhibit the re-use of existing and heritage buildings in Ontario. Addressing these barriers and providing incentives for the conversion and expansion of existing buildings would increase the ability for the Province to provide affordable and sustainable housing.
New construction and reuse often get treated the same way in the development permitting process. Introducing policies to support reuse or repurposing of existing buildings and the removal of certain ‘new build’ requirements for existing buildings would lead to more housing faster.

The Task Force Report Recommendation 4: Permit “as of right” conversion of underutilized or redundant commercial properties to residential or mixed residential and commercial use offers one possible solution, but a blunt change to “as of right” may unintentionally lead to destruction of urban fabric. CAHP believes there is a way to achieve a balance.

CAHP and OHAP are not opposed to gentle density in existing neighbourhoods as long as it continues to respect the existing properties. We are concerned that the “as of right” residential housing up to four units and up to four storeys on a single residential lot will lead to a huge economic incentive for developers to demolish existing two-story buildings and we would encourage avoidance of zoning tools that incentivize the removal of existing building stock, which would have a detrimental effect on mature neighbourhoods, the environment, and affordability.

We would support tools that encourage subdivision of single unit homes into multi-family buildings and give credits for the reuse of existing buildings and materials or incorporating established heritage buildings into new developments.

Finally, in response to Question 3, we are pleased to submit the attached examples of the successful reuse and conversion of existing buildings for housing, submitted to us by our membership, as innovative approaches to land use planning and community building. We would also reiterate that CAHP members are willing to provide their expertise and further insight on supporting gentle density within the heritage framework by participating in the Working Group.

Thank you for the opportunity to provide you with our input.