I write on behalf of the…

I write on behalf of the Port Hope Branch of the Architectural Conservancy of Ontario (ACO) in support of the position taken by the ACO provincial branch, regarding Bill 23, Section 6. We, too, are very concerned that the proposed changes to the Ontario Heritage Act in Bill 23 will adversely affect the ability of the people of Ontario to protect their heritage properties and landscapes.

Particularly concerning are the proposals in the Bill which prescribe processes for municipalities to amend and repeal existing Heritage Conservation Districts, and which change the protocol for protecting provincially designated properties of heritage value. Equally worrying are the proposals to raise the threshold for Municipal designations and to completely modify the listing process, which will mean that protecting currently non-designated heritage assets throughout Ontario, going forward, will be even more difficult. Yet, according to ACOntario, heritage-protected buildings make up such a small percentage of the Ontario building stock that none of these changes will help solve the housing crisis.

Heritage Conservation Districts in Ontario require considerable research, and each district is defined by its heritage unity and cohesion. This integrity could, however, become much more difficult to preserve, if the proposal regarding the amendment or repeal of a Conservation District is being made, as stated in the Bill, simply “to better facilitate development.”

The Province should be setting a high standard when it comes to protecting, conserving
and maintaining cultural heritage resources in its ownership. Instead, the proposals in Bill 23 stipulate that provincial designations may be revised or set aside. This makes us fear that many provincially designated properties such as the 19th century village of Wesleyville in the Municipality of Port Hope could be lost. For Port Hope, such a loss would be heartbreaking, as many Port Hope citizens have devoted money, time and effort towards the site’s preservation and restoration.

As far as municipal designations are concerned, the Bill’s proposal to require that a property meet two or more of the criteria prescribed in regulation rather than one will mean that a number of simple/local heritage resources that help tell the story of one of our diverse communities could no longer qualify for designation. For example, under the proposed new criteria, a cultural area such as Reggae Lane in Toronto would no longer be eligible for protection..

The current listing process was designed to allow Municipalities to recognize properties of heritage value before all of the criteria-based research for designation had been completed, and listing has become a transparent and educational planning tool. The proposal in Bill 23 requiring that all of the research for designation be completed in order for a property to be listed is excessive, especially when a second proposal requires that the listed properties must be de-listed from the register after only two years and not be re-listed until after 5 years. Compiling and analyzing the information required for designation is a meticulous and time-consuming task, usually done by volunteers but often requiring costly expert advice. For most municipalities ear-marking resources for what would become such a limited purpose, will be challenging, leaving a significant number of currently non-designated heritage properties unprotected.

It does seem that the provincial government believes that heritage is “in the way.” Yet, heritage conservation plays a crucial role in a community’s economic development, by enhancing the community’s quality of life, strengthening its distinctiveness, stimulating revitalization and attracting film-making and tourist dollars. Heritage Conservation also helps protect the environment not only through restoration and adaptive reuse rather than demolition and new builds, but also through the protection of old forests and cultural heritage landscapes such as Wesleyville or Walker Farm in Caledon.

Our heritage inspires, enlightens, and enriches us. Heritage Conservation should not be viewed as being in the way. It should be perceived as a way of life that benefits us all.