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Federal Heritage Buildings Review Office

Processes

Intervention Review

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.

Why must departments consult conservation experts?

Heritage conservation is a field that requires a knowledge of theory (charters, conservation philosophy, and concepts of value and authenticity), technical matters (traditional types of construction and craftsmanship, building pathology, structural systems, etc.) and regulatory frameworks (applicable standards, compensation measures, etc.), among things. Heritage conservation experts will also be familiar with the recommended approaches to preservation, rehabilitation and restoration, as defined by the Standards and Guidelines for the Conservation of Historic Places in Canada.

Whom should departments consult?

Qualified heritage conservation professionals, include architectural historians, conservation architects and engineers, landscape architects, and archaeologists. In some instances, it may be necessary to call in professionals who have expertise in specialized areas (for example, seismic engineers), or non-professionals, such as trades people, who specialize in masonry conservation or restoration work (who have expertise, for example, in the restoration of stained-glass or specific interior finishes). Each project has its own specificities that determine which types of experts need to be consulted. As the practice of conservation is not regulated in Canada, it is necessary to seek professionals who have specific training in the appropriate area. In the absence of recognized training, experts should demonstrate that they have worked on similar projects and are recognized by their peers for their conservation expertise.

FHBRO may provide conservation advice to departments that request it, in particular on how to interpret Heritage Character Statements and the Standards and Guidelines, in the context of a proposed intervention. FHBRO may also help departments identify conservation resources, whether within the federal government or in the private sector.

When should the departments seek conservation advice?

Conservation expertise can be put to effective use at every stage of a project, from the strategic planning phase through the various design phases (concept design, design development, etc.), up to and during construction. Conservation experts should be involved at the earliest possible stage of project planning.

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

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.

Information to be Included with a Review of Intervention Request

  • Basic information about the building, such as its name and address.
  • Project contacts.
  • The purpose of the project, in the form of a short description of the proposed intervention and the reasons for it (change of use, new operational requirements, upgrades to meet code requirements, correction of a technical problem, etc.) and how the heritage character of the building will be protected.
  • Scope of work, which should describe the various elements of the project (foundations, exterior, roof, envelope, windows, interior, mechanicals, etc.), and how the affected character-defining elements described in the Heritage Character Statement will be preserved, or what mitigating measures are being considered.
  • Sufficient documentation (photographs and plans) to enable FHBRO to prepare the Review of Intervention report, whose purpose is to analyze the impact of the planned project on the heritage character of the building. Photographs may be used to illustrate why the work is required (a picture is worth a thousand words). Drawings (plans, elevations, details), as well as specifications, may also be required to clearly explain the work being proposed.

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.

Federal heritage buildings may also be designated as national historic sites, or may be situated within one. When a department considers intervening on a building with more than one designation, all the heritage values should be taken into consideration. Departments can consult Parks Canada, through FHBRO, for advice on how to address such situations, and to obtain information about the reasons for the national historic site designation. Although the policy does not set out specific obligations regarding national historic sites, their heritage value should be protected just as in the case of federal heritage buildings.

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

Machine Shop (Buildings #1 and #2) Bear Creek Compound, Bear Creek (Yukon) Machine Shop (Buildings #1 and #2), Bear Creek Compound, Bear Creek (Yukon)
© KNHS, 1988
The Machine Shop, constructed in 1924, is a Recognized federal heritage building. As a key structure for the mining operations of the Bear Creek service facility and the largest building on the site, the Machine Shop is one of the best illustrations of the facility's association with the corporate phase of the Yukon's gold mining history. The Machine Shop, the most dominant building on the site due to its sheer scale, reinforces the industrial character of this complex. This large structure, with its unusual front elevation, is a conspicuous and memorable landmark.

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.




Preservation

The action or process of protecting, maintaining and/or stabilizing the existing materials, form and integrity of a historic place, or of an individual component, while protecting its heritage value.

Hardware Centre Block, Parliament Hill Ottawa, Ontario Hardware Centre Block, Parliament Hill Ottawa, Ontario
© C. Lefebvre, 1995
The first step in preserving architectural metals is to identify the type of metal. Before cleaning, it is important to determine if cleaning is appropriate for the particular metal: removing the patina if it is a character-defining finish of the metal or if it provides a protective coating is not recommended. If cleaning is appropriate, testing is recommended to ensure that the gentlest method is used.

Rehabilitation

The action or process of making possible a continuing or compatible contemporary use for a historic place, or of an individual component, through repair, alterations and/or additions, while protecting its heritage value.

Disinfection Building Grosse-Île, Quebec Disinfection Building Grosse-Île, Quebec
© Parks Canada; J.P. Jérôme, 1997
This building is part of Grosse Île and the Irish Memorial National Historic Site. Located in the middle of the St. Lawrence River, Grosse Île was a quarantine station for the Port of Quebec from 1832 to 1937. At the time, the island was the main point of entry for immigrants coming to Canada. The building's rehabilitation involved stabilizing the structure, upgrading it to current standards and preserving as many of the original features as possible. The building is used mainly to house interpretive installations and washroom facilities.

Restoration

The action or process of accurately revealing, recovering or representing the state of a historic place, or of an individual component, as it appeared at a particular period in its history, while protecting its heritage value.

Vaux Wall Parliament Hill, Ottawa, Ontario Vaux Wall, Parliament Hill, Ottawa, Ontario
© María Inés Subercaseaux, 1996
Recreating a missing feature must be based on physical or documentary evidence. For the reconstruction of this rosette, the expertise of masonry restoration specialists (conservation architect, sculptor, etc.) was required.


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.