Guide to the Preparation of Commemorative Integrity Statements

Guideline No. 5 - Frequently Asked Questions

1. How does a national historic site get designated?

A national historic site is a place that has been designated to be of national historic interest or significance by the Minister responsible for the Historic Sites and Monuments Act . The Minister usually acts on the advice of the Historic Sites and Monuments Board of Canada. This advice is typically communicated to the Minister in the form of recommendations in the HSMBC's minutes.

However, over the years there have been a number of other ways in which national historic sites have been designated:

  • places set aside under Part II of the National Parks Act (now section 42 of the Canada National Parks Act ) are national historic sites. Many of these have also been recommended for designation by the HSMBC.
  • places declared to be national historic sites in a formal Parliamentary statement by the Minister responsible for the Historic Sites and Monuments Act . An example of this is the designation of the S.S. Keno which was also subsequently recommended by the HSMBC.
  • places explicitly referred to as national historic sites in legal agreements signed by the Minister responsible for the Historic Sites and Monuments Act . Included in this category are places like Marconi NHSC.
  • places formally dedicated as national historic sites by the Prime Minister. Laurier House NHSC in Ottawa is an example in this category.

Acquisition of property using the Historic Sites and Monuments Act as the authority is not sufficient justification for the property to be included in the list of national historic sites. Parks Canada has acquired property for locating cairns for plaques, for operational purposes and for other program needs - none of which, on its own, is sufficient justification for including the property in the list of national historic sites.

2. What's the difference between ‘commemorative integrity' and a ‘Commemorative Integrity Statement (CIS)'?

‘Commemorative integrity' refers to the condition of a national historic site and describes a state of health and wholeness. A ‘CIS' is a document outlining what is meant by commemorative integrity for a particular national historic site. See Guideline No. 1 - Glossary .

3. Can a CIS be done for more than one site at a time?

As a general rule, each national historic site should have its own CIS. However, when the HSMBC designation is such that two or more national historic sites constitute a "whole" for the purposes of commemoration, a CIS for the group may be warranted.

For example, the CIS for Prince of Wales Fort NHSC includes Sloops Cove NHSC and Cape Merry NHSC, which, although separately designated, were considered by the HSMBC as a whole. When multiple national historic sites are included in a single CIS, it should be clear what the Statement of Commemorative Intent and Designated Place are for each designated site.

In some cases, the CISs for several sites have been included in a single volume. For example, the CISs for Port-Royal, Fort Anne, Grand-Pré, and Fort Edward were produced and approved in a single package.

4. To what extent should third parties be involved in the development of the CIS?

In cases where a national historic site is owned or operated by a third party, representatives of this group play an essential role in achieving commemorative integrity for the site. In their capacity as owner or as site operator, they are responsible for the management and operation of the site and for the preparation of a CIS.

In cases where the site is owned and operated by Parks Canada, community representatives and other stakeholders should be included in the development of the CIS to build understanding of commemorative integrity for the site, to enhance shared stewardship and to ensure broader input into the Resources, Values and Messages Not Related to the Reasons for Designation section of the CIS.

5. Can submission reports be used in preparing a CIS?

A submission report (formerly known as an agenda paper) is any research document prepared for the HSMBC's consideration. Over the years these have been prepared by HSMBC members, by third parties, and by Parks Canada staff. These documents are input to the HSMBC rather than an expression of the HSMBC's opinion.

Submission reports and agenda papers are not to be used directly in preparing a description of the Designated Place or the Statement of Commemorative Intent, except where the HSMBC's minutes make explicit reference to specific content in these documents. In preparing a CIS, probably the most important use of these documents is in providing historical information on the site.

6. Does the Statement of Commemorative Intent determine the size of the Designated Place?

No. The Designated Place is the place that has been designated by the Minister. For example, Hay River Mission Sites is a national historic site because of its close association with a critical period in Dene/Euro-Canadian relations, but the Designated Place consists of St. Peter's Anglican Church, St. Anne's Roman Catholic Church and Rectory, and the two church cemeteries with their numerous spirit houses.

Other places associated with Dene/Euro-Canadian relations in Hay River Mission are not part of the Designated Place. In cases where the team preparing the CIS feels that the Designated Place or Statement of Commemorative Intent (as described in HSMBC documents) needs to be changed, the matter should be discussed with the National Office as part of the review prior to preparing the CIS.

7. How much latitude is there in "interpreting" a HSMBC recommendation for purposes of determining Designated Place?

The HSMBC's recommendation means what it says. The HSMBC has also approved guidelines for interpreting Designated Place from old HSMBC minutes (see Guideline No. 7). These guidelines, which will be expanded in the next few years, explain how minutes should be used.

There is no flexibility in interpreting recommendations beyond what the minute itself says, in the context of the approved HSMBC guidelines. In cases where the minute is not explicit and the guidelines cannot be applied, the question of Designated Place must be referred back to the HSMBC.

8. What is the relationship between a national historic site and the Designated Place? Are they the same?

The formal meaning of national historic site is identical to Designated Place, i.e., it refers to "historic place" as defined in the Historic Sites and Monuments Act . National historic site is also sometimes used to describe the administered entity, which may contain all or part of the Designated Place.

For example, in common usage Fort Walsh NHSC is used to describe the property Parks Canada administers at Fort Walsh. The Designated Place is considerably smaller than the administered property. Ryan Premises NHSC is also used to describe the property Parks Canada administers but in this case it is smaller than the Designated Place.

9. Should the CIS be done for the Designated Place or for the administered entity?

A CIS should encompass the larger of the two. If the Designated Place is larger than the administered entity, such as at Ryan Premises NHSC, the CIS should deal with the administered entity plus those parts of the Designated Place which extend beyond the administered boundaries. If the administered property is larger than the Designated Place, which is the more usual situation, then the CIS should deal with the administered entity.

There are a few instances where the administered entity is so large and complex it overwhelms the Designated Place. Where this occurs, the CIS may deal with an area smaller than the administered entity but encompassing at least the whole of the Designated Place. In all cases, the whole of the Designated Place must be included in the CIS.

10. Who determines Designated Place and commemorative intent? What role do stakeholders have in preparing the description of Designated Place and the Statement of Commemorative Intent?

Designated Place and commemorative intent are established by the Minister as specified in the Historic Sites and Monuments Act , usually on the advice of the HSMBC.

Owners of national historic sites and other stakeholders are often intensely interested in what was designated and the reasons for the site's designation. However, stakeholder input into this decision-making process takes place before sites are designated - when the site is submitted (usually by the owner or with the owner's consent) or when the submission report/agenda paper is prepared (sometimes in consultation with stakeholders, especially Aboriginal peoples and cultural communities).

If owners or stakeholders have changes to suggest in the description of Designated Place or Statement of Commemorative Intent, the alterations need to be recommended by the HSMBC and approved by the Minister before they can be integrated into the CIS. See also Guideline No. 3, section 3.4.

11. Where persons and/or events are commemorated at national historic sites, are these designations part of the commemorative intent for the site?

Persons, events and other designations can be part of the commemorative intent for a site if the HSMBC minute indicates this. For example, the place where Treaty No. 1 was made (an event which occurred at Lower Fort Garry) is part of the commemorative intent for the site because this event was identified in the HSMBC minutes as a reason for designation for Lower Fort Garry.

Where an event is associated with a place which has been designated as a national historic site, that event is not automatically part of the commemorative intent. For example, Dr. Frédérick Montizambert is a national historic person (designated 1998) because the reformed quarantine system, based on his work at Grosse-Ile, ushered in a new era of efficiency, effectiveness and comfort. The HSMBC recommended Dr. Montizambert be commemorated by a plaque at Grosse-Ile and the Irish Memorial.

Grosse-Ile was designated in part to commemorate the role played by the island from 1832 to 1937 as the quarantine station for the port of Quebec, for years the principal point of entry for immigrants to Canada. No reference was made to Dr. Montizambert in the minutes recommending Grosse-Ile and the Irish Memorial as a site of national historic significance.

Accordingly, the Statement of Commemorative Intent for Grosse-Ile and the Irish Memorial NHSC would not include any reference to Dr. Montizambert as part of the reasons for its designation. However, the CIS should contain a reference to the other designation(s) in the section entitled "Historical and Geographical Context", as well as at the end of the section containing the Statement of Commemorative Intent.

Following the Statement of Commemorative Intent, there should be a statement such as: While not part of the commemorative intent for Grosse-Ile and the Irish Memorial NHSC, Dr. Frédérick Montizambert is a national historic person and is commemorated by an HSMBC plaque at the site.

12. Can the Designated Place be changed if part of it is destroyed?

Because the Designated Place refers to the place designated by the Minister of Canadian Heritage on the recommendation of the HSMBC, it can only be changed by the Minister.

In instances where the resources which are part of the Designated Place have been destroyed or diminished in value, reconsideration by the HSMBC may result in a recommendation to the Minister to amend the designation. Similarly, new research or the discovery of new resources may warrant a reconsideration by the HSMBC of commemorative intent or Designated Place.

13. In some cases, a national historic site may be part of another larger national historic site. Province House NHSC in Charlottetown, which also forms part of Great George Street NHSC in Charlottetown, is a good example of this. What impact does this situation have on the Statement of Commemorative Intent and the description of Designated Place for each site?

In both cases, the Statement of Commemorative Intent and Designated Place would be derived in the same manner as for other national historic sites. The only time when a Statement of Commemorative Intent would contain a reference to the other national historic site would be when the HSMBC recommendation states that being part of that other national historic site constitutes a reason for designation. However, immediately following the Statement of Commemorative Intent, there should be a statement such as the following:

"Province House NHSC forms a part of Great George Street NHSC, which was designated for its ... in 1966," or conversely, "It should be noted that Great George Street NHSC contains Province House NHSC, which was designated because of its ... in 1990."

14. How are commemorative intent and Designated Place described in recommendations to the Minister?

The system changed in June 1999. Commemorative intent and the extent of Designated Place are now clearly stated in the HSMBC recommendation to the Minister.

15. In those rare cases where a national historic site designation was revoked, and the site was subsequently re-designated, what use can be made of the HSMBC recommendation(s) and plaque text(s) that preceded the de-designation?

A revocation rescinds all previous recommendations. If these sites are later brought forward for reconsideration and subsequently recommended by the HSMBC, the Statement of Commemorative Intent and Designated Place should be drawn from minutes and plaque texts relating only to the later recommendation(s).

16. Is there any difference in the use of HSMBC recommendations where the site was recommended for both its historic and architectural significance, just for its historic significance or just for its architectural significance?

Before 1957, the HSMBC's recommendations for national significance relate exclusively to a site's national historic significance. Beginning in 1957, there may also be reference to a site's architectural importance.

Recommendations in the 1960s, 1970s and 1980s contained references to a site's national significance for historic and architectural reasons, just for historic reasons or sometimes just for architectural reasons.

Where a site is designated for its architectural significance, the Statement of Commemorative Intent normally contains a statement relating to the site's architecture. By the same token, the Statement of Commemorative Intent for a site designated for its historic significance typically contains a statement relating to the site's history. Sites designated for both historic and architectural significance usually contain at least two statements (one relating to history and one to architecture) in the Statement of Commemorative Intent.

By 1998, because there is nothing in the Historic Sites and Monuments Act referring specifically to national architectural significance, the HSMBC's recommendations had reverted once again to being for national historic significance. However, the reasons for designation are clearly articulated and may include references to architecture.

17. How should "oral traditions" be treated in a CIS, as a cultural resource or as a significant value?

A cultural resource is a human work, or a place which gives evidence of human activity or has spiritual or cultural meaning, and which has been determined to have historic value. Generally speaking, the term cultural resource refers to a physical resource. Non-physical or intangible heritage, such as oral traditions, folklore, beliefs (sacred and secular), customs, and language is not normally described in a CIS as a cultural resource but as a value of the site.

However, where a site designation makes specific reference to intangibles as a resource, these should be treated as cultural resources in the CIS. When a site is designated because of its association with a particular group and that group wishes to record a non-physical expression as a cultural resource, it should be recorded as a cultural resource in the CIS.

18. Can trees and plants be evaluated as cultural resources?

Trees and plants can be evaluated as cultural resources where they have historic value. For example, a Culturally Modified Tree or CMT (a tree that has been altered, often by native people as part of their traditional use of the forest) would be a cultural resource if it were deemed to have historic value.

The tulip tree at Woodside NHSC has been deemed to have historic value (and thus evaluated as a cultural resource) due to the direct references made by Mackenzie King concerning the important association of the tree to his father who planted it. The Woodside CIS includes it as a resource directly related to the reasons for designation as a national historic site because of its direct association with Mackenzie King.

On the other hand, a red oak tree which existed during Macdonald's tenure at Bellevue House in Kingston has not been documented as having the same direct association with Macdonald. If the team preparing the Bellevue House CIS considered it to have historic value it would be a resource not related to the reasons for designation as a national historic site. Section 1.1.7 of the CRM Policy provides guidance on how to consider natural resources.

19. Are the records associated with cultural resources (for example, archaeological records, records of building interventions, artifact records) also cultural resources?

No, they are not automatically cultural resources. Section 1.3.3 of the CRM Policy states that "information about cultural resources will be recorded and those records will be maintained for the future. Parks Canada will maintain up-to-date inventories and records on its cultural resources. Dossiers will contain basic data and related documentation, including the results of research and evaluation, records of decision and actions taken. Heritage recording will be carried out on cultural resources of national historic significance."

While these records are an integral part of understanding the resource, their association with a cultural resource does not automatically make them cultural resources. Records associated with cultural resources are not considered to be cultural resources unless the records themselves have been evaluated and determined to have historic value. If the record is important for its information value only (i.e. not for its physical form), it is not a cultural resource.

20. How do we treat viewscapes or viewsheds?

A viewscape or viewshed is normally considered to be a value associated with a resource or resources.

21. Is a cultural landscape a cultural resource?

The use of the word cultural juxtaposed to landscape has caused confusion as to whether it is a cultural resource. A cultural landscape is like any other resource - it should be evaluated. If a cultural landscape has historic value then it is a cultural resource.

22. Should moveable cultural resources which do not belong to the owner of the national historic site be included as part of the CIS? For example, should archival material relating to the site's commemorative intent be included as part of the CIS even though the material is housed in the National Archives?

The concept of commemorative integrity and the CIS were developed primarily to assist managers/owners in managing the cultural resources located at national historic sites.

In most cases the cultural resources, whether directly related to the reasons for designation as a national historic site or not, will be part of the administered entity or located at the site. There may be some instances where the CIS should include additional cultural resources which are beyond the administered entity, for example where resources directly related to the reasons for designation are under the custody of the owner of the site but are in storage at another location.

In each case, the CIS should not only identify the resource, but also the historic values and specific objectives which the owner/manager of the site is responsible for achieving.

23. In determining if something is a cultural resource and, if so, whether it is directly related to the reasons for designation as a national historic site, how is resource evaluation affected when the HSMBC has singled out specific features as being nationally significant (e.g., specific structures at the Sault Ste. Marie Canal or the Hay River Mission Sites)?

In most cases the HSMBC has not provided specific direction as to which cultural resources are of national historic significance. However, there are some instances, for example with certain canals, where the HSMBC clearly considered the resources associated with a site and indicated which in situ resources were considered to be of national historic significance.

For sites where this has been done, we must respect the recommendation of the HSMBC, given its authority under the Historic Sites and Monuments Act , and not expand on the list of in situ resources directly related to the reasons for designation.

24. Can in situ resources outside the Designated Place be considered as resources directly related to the reasons for designation as a national historic site?

In situ resources outside the Designated Place but within the administered property can be identified as directly related to the reasons for designation as a national historic site provided they relate directly to commemorative intent. In situ resources outside the administered property cannot be evaluated as directly related to the reasons for designation as a national historic site. Otherwise, the designation of a single site because of its association with the War of 1812, for example, would result in an impossible situation where all resources, regardless of location, associated with the War of 1812, would be considered as resources directly related to the reasons for designation.

There are some cases where the HSMBC has referred to in situ resources outside the Designated Place as contributing to the national significance of a site. For example, the Designated Place for the Ruin of St. Raphael's Church is the ruin but the HSMBC's recommendations also make reference to the importance of its ecclesiastical precinct as contributing to the significance of the ruin. In instances such as this, the resources specifically referred to by the HSMBC will be considered as directly related to the reasons for designation.

In cases where the HSMBC has identified the resources that are nationally significant or which contribute directly to national significance, only those resources are evaluated as directly related to the reasons for designation as a national historic site. Anything not mentioned is not directly related to the reasons for designation as a national historic site.

25. Can we use the following criterion, "the original material, form and functional design qualities are safeguarded", as an objective?

Only if historic value (including historic value not related to national significance) resides exclusively in the original, which is exceedingly rare.

26. Should HSMBC plaques be treated as resources not related to the reasons for designation as a national historic site?

Section 2.2 of the CRM Policy states that "ministerial plaques and monuments will be managed in accordance with this policy." This includes appropriate maintenance and conservation procedures as well as appropriate storage once a plaque is no longer suitable for display.

There may be instances where a plaque does not need to be treated as a cultural resource.

For example:
  • when it was not erected (or erected and replaced within 5 years) because of errors in the plaque text;
  • when it was vandalized beyond repair and was replaced by a plaque of the same style with the same text.
27. Shouldn't "antiques" be evaluated as cultural resources?

If "antiques" have historic value they should be evaluated as cultural resources. Historic value is not derived through age alone but through attributes which can be either physical or associative.

For example, the tea service used by Mackenzie King when he lived at Laurier House would be considered a resource directly related to the reasons for designation because of its association with King. A physically identical tea service acquired through an antiques dealer to be used as part of a display at Laurier House will have monetary value. However, to be evaluated as a cultural resource it must also have historic value.

28. What about "collections" which are housed at various historic sites; should they be evaluated as "collections" or as individual objects?

In general, objects should be evaluated on an individual basis as objects, not as collections. However, there are some collections, such as the Webster Collection at Fort Beauséjour, which may be deemed to have historic value as collections. In these cases, the objects may have historic value individually as well as having value from being part of a collection.

29. What obligations relative to Federal Heritage Buildings should be identified in the CIS?

Classified or Recognized Federal Heritage Buildings are buildings administered by the federal government which have been evaluated and designated because of their significant heritage values. The Federal Heritage Buildings Review Office (FHBRO) has its own criteria for determining whether a building merits designation and a Code of Practice to guide treatment of these buildings. The Heritage Character Statement identifies what qualities led to the designation of the building and provides some guidance on how to protect the building's heritage character.

The site's management plan should account for all the management policies under which decisions about a site are made and is the appropriate place for discussion of obligations under the Treasury Board Heritage Buildings Policy. The CRM Policy requires that cultural resources (all classified or recognized Federal Heritage Buildings are cultural resources) must be safeguarded and their historic value(s) communicated.

Because the criteria for recognition under FHBRO may be unrelated to the reasons for designation, the Heritage Character Statement and Code of Practice per se should not be cited in the CIS. The CIS gives guidance on managing a site based on commemorative integrity and the CRM Policy . Values cited in the Heritage Character Statement which do not relate to commemorative intent should, however, be acknowledged as values not directly related to the reasons for designation in the CIS, as should the FHBRO designation itself.