Loss of heritage sites and…

Loss of heritage sites and demolition of older buildings means loss of jobs in the renovation and tourism industries, and loss of our sense of place. In addition, destroying older buildings releases embodied carbon and contributes to climate change.

Please reconsider the two year time limit after which properties would be removed from the Municipal Heritage Register. In addition, a proposed five-year ban on re-listing is punitive (Section 27.18.) Further, the two year timeline puts significant pressures on municipal staff to perform a task that would likely be impossible.

The Province should consider the role that the Ontario Heritage Trust can play in collecting and managing data about non-designated property included on Registers. Creating a publicly accessible Register that is posted to a municipal website takes time and resources. The Ontario Heritage Trust's Ontario Heritage Act Register of designated properties can be leveraged to serve as a shareable open dataset that municipalities can use to meet requirements for making information about designated properties publicly accessible on municipal websites.

One criteria is sufficient for designating a property. To quote an article regarding the proposed changes to the Regulation 9/06 designation requirements: “Here’s a better one: membership admission criteria for an orchestra. To join an orchestra you only need to play one instrument well, not all of them. Or this one… to be considered marginalized you only need to belong to one marginalized group, not all of them. To say you have to belong to two or more marginalized communities to be considered marginalized would verge on the absurd. Is it clear now why requiring two or more heritage criteria be met — to provide further “rigour” in designations, says the government — is such a bad idea?”

Thank you for your consideration.