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FHT Submission to City of Fredericton re:Municipal Plan Review

City of Fredericton
Development Services Department

Attention: Mr. Bill DeGrace
Manager, Heritage & Cultural Affairs Division

City Hall, 397 Queen Street
P O Box 130
Fredericton N B E3B 4Y7

Dear Mr. DeGrace,

This submission is in response to the Capital City Municipal Plan Review 2003, CulturalSection (Section 3.11). While it is appreciated that a number of heritage planning issues are worthy of discussion, this submission will deal almost exclusively with the issue of "The Tool of Heritage Designation" [pp 40-41 of Technical Background Report].

Heritage designation (of individual buildings, streetscapes and/or neighbourhoods) is seen as one of the most tangible and most effective means of promoting and realizing heritage preservation and has been a policy of many jurisdictions since the late 1960's.

While Fredericton has a heritage preservation area (St. Anne's Point Heritage Preservation Area), it encompasses a relatively small component (approximately 340 properties out of the nearly 1400 properties included in the city's Municipal Heritage Inventory) of our built heritage. As a result, many properties that may be worthy of designation are subject to real and potential degradation or loss due to either unsympathetic renovation or actual demolition.

Since the inception of the St. Anne's Point Heritage Preservation Area in 1984 (more than 20 years ago) it has undergone only one expansion, in 1997. While the current Capital City Municipal City Plan (December, 1991) identified 9 potential heritage preservation areas for study [see Attachment 1], only 2 of those areas (or parts of them) have received municipal heritage designation. (While Historic Marysville has been declared a National Historic District, that designation carries no conditions restricting demolition or inappropriate renovation of properties therein and does not fall under the jurisdiction of the City of Fredericton with respect to heritage.) Draft/proposed revisions to the Capital City Municipal Plan suggest 8 "Proposed Study Areas, Heritage Designation" [see Schedule "A", Attachment 2], which is for the most part simply a slight reconfiguration of the areas identified in the 1991 Municipal Plan.

Fredericton Heritage Trust (FHT) appreciates that the "boundaries" suggested by the shading of these proposed study areas are not necessarily "set in stone" and may vary somewhat when the actual study/inventory occurs, however it is our firm belief that an entirely different configuration is warranted for those areas adjacent York Street. In the course of public concern associated with the announcement of the proposed demolition of York House (former Fredericton High School No.1, located on the westerly side of York St., between Brunswick and George), it was realized that the portion of York St. starting at the St. John River/City Hall end, and extending almost to Dundonald St. contains a multitude of heritage buildings representative of a cross-section of Fredericton's past. These buildings encompass civic/government (City Hall, Justice Building), commercial (most of the buildings between Queen and George - in both commercial buildings and in former residential buildings), industrial (Hartt Shoe, Chestnut Canoe), transportation (York St. Train Station), religious (Brunswick St. Baptist Church, St. Paul's United Church), institutional ( York House/former Fredericton High) as well as many fine residential properties. We believe that a more formal, concerted emphasis should be placed on recognizing, preserving and promoting this area, which FHT has identified as "the York St. Historic Corridor", which might be considered second in importance only to Queen St. as the most continuous and divergent heritage streetscape in Fredericton.

It is therefore urged that the "Proposed Study Areas, Heritage Designation" as contained in the Capital City Municipal Plan Review 2003, be modified/revised to recognize York St., from the St. John River to Dundonald St. as a "proposed study area". [See "Revised Proposed Study Areas, Heritage Designation", Attachment 3]. Recognition of "the York St. Historic Corridor" has the benefit of bridging/incorporating elements of 4 of the 5 "proposed study areas" previously identified in the draft plan, as well as including both sides of the York St. streetscape, rather than splitting it down the middle and possibly having "unregulated" unsympathetic design on one side compromise the historic integrity of the other. (As a general principle, FHT believes that the centre lines of streets should not be used as "boundaries" for proposed Heritage Preservation Areas, as 2 adjacent areas on opposite sides of a street might not receive designation at the same time [as happened at George St., resulting in an "unfortunate" renovation to the Roberts/Limerick House at 734 George]. The preference would be to use rear property boundaries to separate study/preservation areas from each other and/or other adjacent areas.) Further to this recommendation that centerlines of streets not be used as boundaries, it is urged that the boundaries of the other study areas be modified to follow rear property boundaries as much as possible. [See Attachment 3]

Identification of "Proposed Study Areas for Heritage Designation" is one matter, but to actuallycarry through with the studies (within a reasonable timeframe), and to actually designate additional properties/areas, is quite another matter. As indicated earlier, a heritage preservation area comprising of only approximately 340 properties (and some of those properties not of "legitimate heritage vintage or detail") is not very significant when considered over the 20 year time frame. Whether areas/properties ultimately receive heritage designation status or not, the inventory/research processes should be an ongoing activity so that particular buildings/neighbourhoods don't "slip through the cracks of bureaucracy" and be unsympathetically renovated or demolished before their heritage value has had a chance to be reviewed/established. Research after the fact will do nothing to bring heritage resources back from the wrecker's grave. It is hereby recommended that any pre 1914 structure seeking a demolition permit require a review of its heritage value, according to Preservation Review Board guidelines and procedures.

It is the understanding of FHT that a "scheduling/prioritizing process" for research/inventory of properties in the various "proposed study areas" has been in preparation by the City as of June 2004 (subsequent to City denial of formal request by the Queen Square Neighbourhood Association for inclusion in the St. Anne's Point Heritage Preservation Area), but there had not been a consensus or sense of priority on what area(s) to start with first. It would be a sad commentary if such a stasis were to persist, leading to the thought that there might be no real interest on the part of the City to seriously partake in the process, but to date, FHT has not been informed by the City of the proposed scheduling. If the City is looking for input on this matter, there are several "yardsticks" that might be appropriate, such as:

1. Study/designate the area(s) with the largest number of (perceived/actual) heritage properties.
2. Study the area(s) perceived to be under the greatest threat (from development, neglect or unsympathetic renovation).
3. Study/designate the area(s) where the residents/property owners show the most interest for inclusion in a heritage preservation area.

If the map of "Revised Proposed Study Areas, Heritage Designation [Attachment 3] is adopted/referenced, there would be a total of 6 "study areas", 3 in Fredericton South, 2 in Fredericton North and 1 in Marysville. It should not be difficult for at least one, if not two study areas to be "evaluated" each year, taking a maximum of 6 years and as few as 3 years to complete. In terms of the order/sequence in which the areas could/should be "evaluated", one possible scenario is that:

• the "York St. Historic Corridor" be done first (as it has one of the largest and most diverse range of heritage property types and is also coming under heavy developmental pressure);
• the St. Mary's Ferry neighbourhood be done second (it is the smallest of the areas but also contains some of the oldest properties in Fredericton, and one of the most significant buildings in the area -at the corner of Union and St. Mary's - has been under threat of demolition for several years to make way for trucks right-turning from Union onto St. Mary's heading north);
• the balance of the Queen Square Neighbourhood Association area (east Town Plat) be done third (while it is a relatively stable, mostly residential location, a large number of property owners have been eager to be included in the St. Anne's Point Heritage Preservation Area for several years, and it would be a serious mistake to continue to snub people willing to participate, particularly when residents of other Proposed Study Areas appear less inclined to do so);
• the section of South Devon to be done fourth (while the existing Union St. Secondary Plan addresses some of the concerns of part of this area, development pressures are mounting, and the sites of many previous commercial/industrial activities - primarily adjacent water courses/rail lines may not have been sufficiently researched/documented);
• the west Town Plat be done fifth (this primarily residential area has benefited from recent City measures to prevent lot consolidation for the purpose of large-scale multi-unit residential construction, yet a large number of heritage buildings remain unprotected from unsympathetic renovation, while an increasing number a residents appear in favour of consideration for heritage designation status);
• Historic Marysville to be done sixth (while the National Historic District designation does not include design guidelines or Preservation Review Board -type approval, and the Marysville Heritage Committee and area residents do not seem inclined to pursue municipal heritage designation status, the heritage resources of Marysville are much too important to go without a well-documented municipal assessment).

It is emphasized that the discussion immediately above only suggests one of many potential scenarios with respect to a "scheduling/prioritizing process" for areas already identified by the City as Proposed Study Areas for Heritage Designation, and does not in any way suggest that other areas of the city are not worthy of similar consideration. However, the "bottom line" remains that most of these identified areas have been "on the books" for almost 15 years and have seen little serious action on the part of the City. If the City hopes to retain credibility in the realm of heritage preservation, it must address this issue (and these areas) immediately.

It has been suggested by City staff that part of the reason for (apparent) City inaction on the issue of expanded heritage designation/heritage inventory has been a lack of City resources in terms of personnel and finances. While these are certainly considerations, the argument could be made that many other City departments and initiatives do not seem to have gone lacking to the same extent. In the past, Fredericton Heritage Trust has "informally" (verbally) suggested some possible means of being of assistance to the City/Preservation Review Board in this matter, and will reiterate this offer here, as well as offer the following other suggestions:

• Fredericton Heritage Trust is prepared to offer ongoing feedback/commentary on proposed City initiatives with respect to all aspects of Heritage Designation, but particularly so in terms of the Revised Proposed Study Areas, Heritage Designation [Attachment 3] and to liaise with the various neighbourhood associations/local heritage groups to encourage acceptance of heritage designation.
• Fredericton Heritage Trust is prepared to investigate/encourage "partnerships" between the City and other entities (such as the History Departments of the University of New Brunswick and St. Thomas University, and the Faculty of Architecture and Planning of Dalhousie University, Halifax) to enable staff/student participation in various aspects of heritage resource research/documentation.
• Fredericton Heritage Trust is prepared to offer ongoing feedback/commentary on the implementation of possible City proffered "incentives" for designated heritage property owners.
• Fredericton Heritage Trust suggests that in order to provide adequate (financial) resources to ongoing/future heritage (designation) initiatives, the City should earmark specific budgets for specific tasks, and create a "heritage nest egg" as necessary with a percentage of monies derived from the issue of building permits issued for properties located in the existing St. Anne's Point Heritage Preservation Area and in those areas identified in Attachment 3 as Revised Proposed Study Areas, Heritage Designation.

Fredericton Heritage Trust looks forward to receiving your response to this submission with the expectation that the valuable, but often underappreciated heritage assets of our wonderful city may benefit from the recommendations here-in.

Sincerely,

Ian Robertson,
President, Fredericton Heritage Trust

cc. Office of the City Clerk

Preservation Review Board
Queen's Square Neighbourhood Association
Carleton St. Neighbourhood Association|
West Plat Neighbourhood Association
St. Mary's Neighbourhood Association
South Devon Neighbourhood Association
Marysville Heritage Committee