Intervention review

• Custodian department obligations
• Steps in the process
• Standards and guidelines
• Checklist

Custodian department obligations

The Treasury Board Policy on Management of Real Property states that the departments must respect and conserve the heritage character of federal buildings under their administration throughout their lifecyle.¹

Once the evaluation process has been completed and a building has been designated, the custodian department must develop management and planning processes that ensure the protection of its heritage character.

More specifically, the Guide to the Management of Real Property² states that departments must:

• Seek FHBRO's advice before undertaking interventions, including ones related to maintenance or changes of use, to Classified federal heritage buildings that could affect the building's heritage character, as defined in the Heritage Character Statement.
• For alterations, changes of use or other interventions to Recognized federal heritage buildings that could affect heritage character, departments must obtain appropriate conservation advice. This advice can be obtained from a private or public sector conservation expert.

Every year, FHBRO receives a large number of requests from departments for advice and recommendations about interventions to federal heritage buildings. The proposed interventions are extremely varied, ranging from the straightforward repair of character-defining elements, to the partial demolition of a portion of a building. In order to systematize its approach to such requests, FHBRO introduced a process called the Review of Intervention³. The purpose of a Review of Intervention is to assess the impact of the proposed intervention on the building's heritage character and, where appropriate, recommend mitigation measures.

"An intervention is any action, other than demolition or destruction, that results in a physical change to an element of a historic place."

Definition from the Standards and Guidelines for the Conservation of Historic Places in Canada.

Steps in the process

The Review of Intervention process includes the following steps:

1. Information to be included with a Review of Intervention request
2. Preparation of the Review of Intervention report

1 Information to be included with a Review of Intervention request

FHBRO encourages custodian departments to inform it as early as possible of any planned interventions to Classified federal heritage buildings. Initial contact may be made as soon as a project begins to take shape, whether at the planning or concept stage. For complex projects, it may be appropriate to submit a request for a Review of Intervention at each significant stage of the project.

When a request is received, FHBRO determines whether a Review of Intervention report is required.

• If the proposed intervention is minor and unlikely to have a significant impact on the heritage character of the building, a short note is sent to the department (by e-mail) to confirm that it is not necessary for FHBRO to prepare a Review of Intervention report.
• If the work requires a Review of Intervention, FHBRO advises the department.
• If the Review of Intervention request concerns a very prominent federal heritage building, such as a building on Parliament Hill, and the proposed work is likely to have a major impact on its heritage character, FHBRO may decide to conduct a formal review in which the advice and recommendations of the FHBC are sought.

An effective Review of Intervention request will demonstrate that:

• the heritage value and character-defining elements set out in the Heritage Character Statement were taken into consideration in developing the project and, where applicable, that mitigating measures to protect them are planned;
• the approach to the intervention was guided by the Standards and Guidelines for the Conservation of Historic Places in Canada;
• heritage conservation experts were consulted as the project was developed.

The request for a Review of Intervention, together with the required documentation, should be sent by e-mail⁴ or regular mail to the FHBRO Registrar. FHBRO then forwards these documents to a reviewer who will prepare the Review of Intervention report. The reviewer may contact the project contact for further details about the project, if required.

Note: Each department should establish an appropriate internal process for the submission of requests for Reviews of Intervention. For some departments, it may be appropriate to submit all requests via their departmental FHBRO representative. For others, it may be preferable for the project managers to contact FHBRO directly.

2 Preparation of the Review of Intervention report 

A special service agreement is in place with the Heritage Conservation Directorate, within Public Works and Government Services Canada (PWGSC-HCD), who are the federal government's heritage conservation experts. The Heritage Conservation Directorate provides FHBRO with technical advice, as required, and prepares the Review of Intervention reports. Their analysis and recommendations are based on the following reference documents:

• The Heritage Character Statement for the building⁵
• The Standards and Guidelines for the Conservation of Historic Places in Canada

It is important to note that the purpose of the Review of Intervention report is not to corroborate proposed technical solutions. Rather, its purpose is to consider whether a building's heritage character, as defined in the Heritage Character Statement, will be protected and whether the project complies with the conservation practice defined in the Standards and Guidelines for the Conservation of Historic Places in Canada. The reviewer may nonetheless comment on technical solutions that appear inappropriate for ensuring the building's integrity, or that of its component elements.

The Review of Intervention report consists of the following sections:

1. Basic information
2. Reference materials consulted
3. Description of the proposed work and the reason for the intervention
4. The impact on heritage value and character-defining elements (in the form of comments)
5. Recommendations

Once the Review of Intervention report has been approved by the Manager of FHBRO, it is sent by email to the project contact within the custodian department. The original signed version of the cover letter and paper copy of the report are then sent by mail.

In the case of formal reviews, another step is required to ensure an even more thorough and authoritative process. In such cases, the FHBC⁶ is invited to provide recommendations to FHBRO on the proposed intervention. The Manager of FHBRO organizes a meeting of the committee, at which the custodian department is asked to present the project. The committee members then make recommendations to FHBRO, which forwards the final recommendations in writing to the custodian department.

The time required to process a Review of Intervention request (from the time the documents are received until the final report is sent out) is between three and four weeks. FHBRO does everything possible to respond more quickly to urgent requests. In the case of formal reviews, the timeframe is generally six to eight weeks.

Follow-up Reviews of Intervention are often required to review responses to the recommendations of an initial report (this is nearly always the case for complex projects or projects with several phases). In such cases, the Review of Intervention report will clearly indicate this to the applicant (in the recommendations section), specifying what information or other reference documents should be submitted to FHBRO.

The Standards and Guidelines for the Conservation of Historic Places in Canada

It is up to custodian departments, whose decisions have an impact on federal heritage buildings, to ensure that their interventions respect the heritage value and character-defining elements identified in an evaluation.

In order to help departments meet their obligations with respect to federal heritage buildings, FHBRO adopted the Standards and Guidelines for the Conservation of Historic Places in Canada immediately upon their publication in 2003. The Standards and Guidelines, like the FHBRO Code of Practice used before it, are based on internationally recognized conservation principles. They help foster informed decision-making with respect to the planning and use of historic places, and help to ensure that appropriate interventions are undertaken that preserve heritage character.

FHBRO bases all of its Reviews of Intervention on the conservation approach set out in the Standards and Guidelines. It is therefore essential that custodian departments ask consultants working on projects involving federal heritage buildings to use the Standards and Guidelines.

Treatment types

The Standards and Guidelines identify three types of conservation treatments: preservation, rehabilitation and restoration. The choice of treatment depends on the principal goals of the project and the heritage value of the place.

The Standards

The Standards are a set of fundamental conservation principles, based on international charters and best practices in Canada. There are nine standards applicable to all types of projects, three additional standards for rehabilitation projects and two additional standards for restoration projects.

The Guidelines

The Guidelines provide practical advice for decision-making when undertaking interventions that may have an impact on character-defining elements that contribute to the heritage value of a building. The Guidelines are presented in a format that provides recommended and non-recommended actions and are structured according to the order of magnitude of the intervention, from minor actions to major interventions. The Guidelines do not provide technical advice and do not replace conservation advice provided by experts.

Checklist

• Did the department submit to FHBRO all planned interventions that are likely to affect the heritage character of the Classified federal heritage buildings that it administers?
• Did the department seek appropriate conservation advice regarding all interventions that are likely to affect the heritage character of the Recognized federal heritage buildings that it administers?
• Was the Heritage Character Statement distributed to those who are likely to intervene on a federal heritage building (managers, maintenance staff, occupants, consultants)?
• Do they understand the meaning and scope of the Heritage Character Statement? For example, have they taken FHBRO training?
• Did the department give a copy of the Standards and Guidelines for the Conservation of Historic Places in Canada to all employees, consultants or others involved in interventions to federal heritage buildings?

Footnotes

¹ Treasury Board Policy on Management of Real Property, s. 6.1.9.

² Guide to the Management of Real Property, s. 6.6.5. The Guide also refers to archaeological resources, which are also heritage resources and should be taken into account when undertaking interventions to federal heritage buildings.

³ This process is not employed for disposals, which are subject to a separate process - see the next section.

⁴ An electronic version of the reference documents may be sent to the FHBRO Registrar provided that it does not exceed 5 megabytes. Larger documents must be sent in print or electronic format on a CD, by mail.

⁵ If the building is also a national historic site, then the review will also take into consideration the Comemorative Integrity Statement.

⁶ The composition of the FHBC is the same for both heritage evaluations and formal reviews.