Cultural heritage landscapes, part two… or a matter of significance

Thursday, June 21, 2018
by Dan Schneider

The Provincial Policy Statement, 2014 says:

2.6.1  Significant built heritage resources and significant cultural heritage landscapes shall be conserved.

Last time we looked at the evolution of the definition of cultural heritage landscapes, now in its third iteration. We did not look at the meaning of “significant.”

The word "significant" with a purble background and black border

The PPS currently defines “significant” as:

e) in regard to cultural heritage [i.e. built heritage resources and CHLs] and archaeology, resources that have been determined to have cultural heritage value or interest for the important contribution they make to our understanding of the history of a place, an event, or a people.

Criteria for determining significance for the resources identified in sections (c)-(e) are recommended by the Province, but municipal approaches that achieve or exceed the same objective may also be used.

While some significant resources may already be identified and inventoried by official sources, the significance of others can only be determined after evaluation. 

Supposedly this rather cumbersome definition is to help distinguish your run-of-the-mill, nothing-special-about-it cultural heritage landscape from … a significant cultural heritage landscape that would trigger policy 2.6.1. Does it?

I’ll happily wager a keg of the good stuff that you can’t explain the difference. As suggested in an earlier post[1], I believe there is no coherent distinction between the two. So why bother with the modifier?

An image of tree tops and sky with the words "National Trusts of Australia Register of Significant Trees"

“Significant” is used elsewhere in the PPS, primarily in the natural heritage policies.[2] Take wetlands and ANSIs (areas of natural and scientific interest) — there significant means provincially significant as identified by the Ministry of Natural Resources using “evaluation procedures”, i.e. criteria, established by the province. For woodlands significant means ecologically important woodlands to be identified using criteria established by MNR. Clearly, there are plenty of Ontario wetlands and woodlands out there that would not qualify as “significant.”

To keep things more-or-less consistent, the Ministry of Municipal Affairs, in drafting the PPS, no doubt required that a similar bar be set for our cultural heritage (which, is it fair to say, they didn’t really understand?). And so we got: Significant built heritage resources and cultural heritage landscapes are those “determined to have cultural heritage value or interest…” as identified using “criteria for determining significance … recommended by the Province.”

Fine. The criteria mentioned would presumably be those in O. Reg 9/06 (“Criteria For Determining Cultural Heritage Value Or Interest”) and O. Reg. 10/06 (“Criteria For Determining Cultural Heritage Value Or Interest Of Provincial Significance”) under the Ontario Heritage Act.

The thing is, “built heritage resources” and “cultural heritage landscapes”— defined in the PPS as having “cultural heritage value or interest” identified “by a community” — have already been through an evaluation process, using the O. Reg criteria or something comparable. You could say they have “significance” built into them.

Put another way, significance to a community is intrinsic to the concept of cultural heritage. While there are varying degrees or levels of significance — local, regional, provincial, and so on — there’s no escaping that a cultural heritage resource that is not significant is not, to all intents and purposes (or at least those of the PPS), a cultural heritage resource.

Significant cultural heritage landscapes, as used in the PPS, is therefore a tautology. Like saying a new innovation or a necessary requirement, “significant” really adds nothing.

An image of the words "Please Prepay in Advance" on a sticker

Whew. As advertised this post was supposed to be about what the Ontario Municipal Board, now Local Planning Appeal Tribunal, has had to say about CHLs. That will have to wait. For now, given the complicated and quirky PPS definitions for significant CHLs — to say nothing of the not-so-black-and-white meaning of the “shall be conserved” part of the policy — we can sympathize with the poor municipal council or appeal tribunal that has to make sense of it all. Not to mention affected landowners.


Notes

Note 1: See OHA+M from January 2016: “‘Cultural heritage’ and the fuss with definitions”.

Note 2: The natural heritage policies are in section 2.1 of the Provincial Policy Statement. Note, by the way, that in the policies for agricultural resources a different terminology is used. Instead of “significant”, “primeagricultural areas are to be protected. (Prime cultural heritage landscapes, anyone?)