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OMA Submission on Bill 23
"More Homes Built Faster Act", 2022
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The OMA calls on the Ministry of Citizenship and Multiculturalism and the government for legislation that ensures Ontario’s irreplaceable heritage is protected. The OMA calls to maintain all possible protections for heritage assets, including through the Ontario Heritage Act, and calls for support of heritage designation with broad applicability for the stewardship of valuable heritage assets and museums across the province. The OMA discourages proposed changes to existing protections (listing and designation under the Ontario Heritage Act and the Standards and Guidelines for Heritage Properties) as these changes may put at risk museums and the important places that are part of the heritage of diverse communities across Ontario.
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Background
On October 25, 2022, the Honourable Steve Clark, Minister of Municipal Affairs and Housing, introduced Bill 23, the More Homes Built Faster Act, 2022. In his address to the Legislature, he stated that the report of the Ontario Housing Affordability Task Force serves as the Province’s “long-term housing road map for the future.”
Bill 23 would alter multiple pieces of Provincial legislation, including the Ontario Heritage Act, Conservation Authorities Act and Planning Act and Development Charges Act, among others.
Ontario Heritage Act
Schedule 6 to Bill 23 includes amendments to the Ontario Heritage Act (OHA). As indicated in the Environmental Registry of Ontario (ERO) posting, changes are proposed to regulations under the Act, including:
1. Municipal Heritage Designations
- Requiring non-designated properties on/added to municipal registers be designated within two years or removed from the register, after which a property could not be re-listed in five years
- Increasing the threshold by requiring that a property meet two or more of the criteria prescribed in regulation for designation [O. Reg. 9/06]
2. Heritage Conservation Districts (HCD)
- Requiring municipalities to apply prescribed criteria to determine a HCD’s cultural heritage value or interest, and is proposing that the HCD must meet two or more of the criteria in order to be designated
Read more about the proposed changes to the Ontario Heritage Act: https://ero.ontario.ca/notice/019-6196 |
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Conservation Authorities Act
Schedule 2 to Bill 23, includes amendments to the Conservation Authorities Act. As indicated in the Environmental Registry of Ontario (ERO) posting, changes are proposed to regulations under the Act, including:
- Setting fees for programs through regulations instead of allowing conservation authorities to establish them and authorizing the Minister to direct an authority not to change fees
- Placing restrictions on the content of programs and services, prohibiting those related to reviewing and commenting on a development application
- Removing the consideration of pollution mitigation or land conservation and instead focusing on natural hazards such as flooding and erosion
Read more about the proposed changes to the Conservation Authorities Act: https://ero.ontario.ca/notice/019-6141 |
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Planning Act and Development Charges Act
Schedule 9 to Bill 23, includes amendments to the Planning Act. As indicated in the Environmental Registry of Ontario (ERO) posting, changes are proposed to regulations under the Act. Read more HERE: https://ero.ontario.ca/notice/019-6172 |
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OMA's Submission on Bill 23
- The Ontario Museum Association will submit comments to the Environmental Registry of Ontario via consultation portal by Dec. 9, 2022. Read OMA's submission HERE: https://members.museumsontario.ca/sites/default/files/Ontario_Museum_Association_submission_ERO_019-6196_Dec_8_2022.pdf
- OMA's submission will be forwarded directly to Minister Neil Lumsden, Ministry of Tourism, Culture and Sport and Minister Michael Ford, Ministry of Citizenship and Multiculturalism
- The OMA will continue to share relevant information with members on potential impact.
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Make your voices heard!
The abovementioned changes will come into force on proclamation, anticipated to be January 1, 2023. Bill 23 has had Second Reading and is currently at the “committee stage” (Standing Committee on Heritage, Infrastructure and Cultural Policy).
The committee considers the bill in more detail and holds public hearings on it. The committee will also consider both government and opposition proposals for changes/amendments to the bill as part of what is called “clause-by-clause” review.
1. Make a submission through Environmental Registry of Ontario (ERO)
- The proposed changes to the Ontario Heritage Act and its regulations have been posted on the ERO HERE: https://ero.ontario.ca/notice/019-6196.
- Submit comments or documents by clicking on the “Submit a Comment” button
- You can also submit comments on other related postings and/or provide your comments directly to the Ministry at paula.kulpa@ontario.ca
- The deadline for comments has been extended to December 9, 2022
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Make your voices heard!
2. To your local MPP and Ministers:
- Forward the OMA submission and your comments to your local MPP (see example message below)
- cc Minister Neil Lumsden, Ministry of Tourism, Culture and Sport (email: ) and Minister Michael Ford, Ministry of Citizenship and Multiculturalism (email: )
- cc the OMA (email: community@museumsontario.ca)
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Example Email to MPP:
Dear MPP (Last Name),
I am writing to share a submission prepared by the Ontario Museum Association about proposed changes to the Ontario Heritage Act under Bill 23, More Homes Built Faster Act, 2022. This submission expresses our sector position discouraging proposed changes to existing protections (listing and designation under the Ontario Heritage Act and the Standards and Guidelines for Heritage Properties) as these changes may put at risk museums and the important places that are part of the heritage of diverse communities across Ontario.
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The Ontario Heritage Trust hosts the Ontario Heritage Act Register:
The OHA Register features a searchable database that provides information about properties in Ontario that have been designated using the Ontario Heritage Act.
If you have questions or cannot locate the information you are looking for, email or call the Provincial Heritage Registrar at registrar@heritagetrust.on.ca or 437-246-9092.
The OMA encourages museums to check the status of places that matter to them
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| Partner Organization Responses |
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| Please see below for the submissions, comments, and actions taken by a number of the OMA's partner organizations: |
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Architectural Conservancy Ontario (ACO)"For no good reason Bill 23’s proposals will wreak havoc with Ontario’s heritage system. Tens of thousands of heritage places will lose what little protection they currently have. Municipalities will be intimidated and overwhelmed by a confusing and incoherent array of onerous new restraints and requirements. Decades of work will be compromised and future efforts to keep, fix, and reuse the best of our past will be stymied." Read ACO's submission HERE.Watch ACO's press conference at Queen's Park HERE.Sign ACO's petition HERE.
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Ontario Archaeological Society (OAS)"We note the limited mention (or omissions) of Indigenous, Black, Franco-Ontarian, and 2SLGBTQIA+ peoples in this proposed bill, as if these changes have no implications for them. Ontario is comprised of the traditional territories of the First Nations, Métis, Inuit, and Non-status traditional land stewards...Powers to exempt provincial properties from all or parts of the Standards and Guidelines for Conservation of Provincial Heritage Properties may also remove an important trigger for archaeological assessments on these properties..." Read the OAS' statement HERE.
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Ontario Historical Society (OHS)
"The OHS does not oppose the building of affordable homes for Ontarians. However, the OHS believes those homes should not be built on the graves of our ancestors. To protect all cemeteries and burial sites, the OHS asks this committee to vote, recommending that the Government of Ontario register/license all unregistered cemeteries in the Province of Ontario."
Read OHS's submission HERE.
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Canadian Association of Heritage Professionals (CAHP)“This will mean that the current inequity in the criteria will continue to assign more value to the contributions of architecture and well-documented histories rather than recognizing the diverse stories that make up Ontario’s history. Any revision to provincial criteria must ensure that underrepresented communities can still protect the cultural heritage resources that are important to them. This is a significant concern for our membership as many of our members have been directly involved in efforts to rethink traditional understandings of heritage designations and listings.” Read the CAHP's submission HERE.
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Ontario Nonprofit Network (ONN)"While Bill 23 may seem like the right fix right now, many of its proposed changes will have long-term negative economic, environmental, and social impacts on Ontario’s communities. The proposed changes will not solve our province’s challenges, rather they will deepen the housing affordability crisis, create irreversible harm to our environment, and further damage community well-being." Read ONN's submission HERE.
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More partner organizations:
Association of Municipalities of Ontario - submission on Bill 23 HERE.
Conservation Ontario - submission on Bill 23 HERE.
Parks and Recreation Ontario - submission on Bill 23 HERE. |
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Ontario Museum Association
Monday-Friday, 9:00am - 5:00pm
Toll-free in ON: 1-866-662-8672
Phone: 416-348-8672 |
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| As an organization of provincial scope, the Ontario Museum Association recognizes that its members and community live and work on the lands and territories of Indigenous peoples. Toronto, where the OMA offices are located, is the territory of the Mississaugas of the Credit, Haudenosaunee and the Huron Wendat. We wish to express our gratitude for the resources we are using and pay respect to the rich and ongoing Indigenous history of what is now Ontario and Canada. |
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