From Heritage Grey Highlands…

From Heritage Grey Highlands (HGH), a sub-committee of the Museum & Heritage Advisory Council, Municipality of Grey Highlands (MGH):
https://www.greyhighlands.ca/en/visit-and-explore/heritage-grey-highlan…

• Our committee agrees with all the comments and concerns as submitted on behalf of all municipal heritage committees (MHCs) by the Community Heritage Ontario board. Thus, we strongly urge you to seriously reconsider accepting the proposals that CHO has identified as posing a profoundly negative impact on the ability of any MHC in the province to continue the valuable work of heritage preservation not just for now but for a sustainable future.
• The greenest buildings on the planet are already built. Repurposing and/or retrofitting them is far more economically and environmentally responsible than permitting destruction of solid and often valuable heritage structures to enable replacement by “affordable” housing built using inferior (and likely imported) materials.

Being an MHC in a largely rural community where most heritage research and other committee work is done by volunteers with very little access to staff assistance, many of the currently proposed changes would have a disastrous effect on our previous efforts and would impede our future ability to identify or protect local cultural heritage resources (until now, the stated intention of the Ontario Heritage Act.) In rural Ontario there is no shortage of land for development. To us, the threats of bill 23 to greenbelt and heritage is a dangerous step that will in no way help to provide more housing.

RE The ability to allow property owners of all existing listed properties to object years after they have been listed in the heritage register:
• It is already understood, and precedents exist for repealing a designation or listing should a property owner have a compelling reason. Therefore, this proposal seems unnecessary and provides an open invitation for property owners to make unfounded or egregious objections.
• In our case, every single property on the MGH register was designated or listed with the express permission of the owner. With this as municipal policy, we foresee no need for the above proposal.

RE Greater evaluation criteria for including a property as listed on the Register:
• For clarity and consistency, we agree with CHO that the regulation should establish an easily understood minimum criteria for required information.
• Having said that, the criteria for added information required to justify a listing should neither be onerous nor as explicit as what is required for designation.
• Rather than the proposal to demand designation or removal, it would be fairer to ask that registers be updated to include more information for older listings having just a name and address so that they would match new listings that adhere to new guidelines.
 
RE The removal of all existing listed properties from the register after two years from proclamation if they have not been designated, and not allowing them to be re-listed for an additional five years:
• This would have a destructively negative impact on most MHCs!!
• Removing all listed properties from a register would destroy years of work by heritage committees and drastically reduce the local visibility of valued heritage.
• Designation is complex. It takes time for all the conditions to be met. It may be costly. It means work for the volunteer committee, for council, and for staff.
• Listing is faster and simpler, even with a requirement for more justification of attributes.
• The many listed buildings that are cemeteries, churches, museums, municipal buildings, are in no danger of demolition.
• Most other listed buildings are proudly maintained by the owners and do not merit the added complications of enforced designation.
• Listed buildings help educate the public about local history and heritage.
• Listing draws attention to businesses operating in a heritage building.
• Many property owners who are proud of having their heritage building listed to the register would be far less comfortable with the added restrictions of designation.

RE Increasing the threshold criteria for evaluation for individual property designation:
• Increasing the threshold for listing and designation under Part IV of the Ontario Heritage Act would once again focus attention on mansions and halls constructed by our colonial forebears and may disqualify simpler, locally valued buildings in small towns.
• Many of the rustic and simple remains of Black or Indigenous communities could not qualify as having more than one value as outlined under the OHA.
• In effect, this proposal would make it more difficult to address reconciliation as well as issues of equity, diversity, and inclusion in the protection of cultural heritage resources in Ontario – an odd move with heritage now under the ministry of multiculturalism.
• Here is a Grey Highlands example of a building that by all rights should be designated but under Bill 23 would no longer qualify. It is a simple, very ordinary two-storey brick house constructed 1880s. It is in poor repair and has none of the distinctly interesting woodwork or brickwork that qualifies other local buildings of that era as having design value. It is situated on a hilltop at the edge of a hamlet on a well-travelled county road, but it is totally screened from view by a tall thick hedge, so not a recognizable landmark. The only way to even see the building is to turn onto the short dead-end street at the western side of the property. That is where also largely obscured from public view there is a large blue & silver federal plaque identifying this as the long-time home of Agnes McPhail, first female MP elected in 1921. So associative value is the only justifiable attribute. But for women everywhere, it’s a an important heritage site.

While all of us greatly appreciate the current need for more affordable housing, I truly believe that Bill 23 proposed removal of current protections for heritage buildings endangers the efforts of heritage committees everywhere. Long-term there will be irreparable harm and, in all probability, none of these measures will help achieve the stated short-term goal.