Heritage evaluation

Custodian department obligations

The Treasury Board Policy on Management of Real Property states that departments must have FHBRO evaluate the buildings they administer or that they are planning to purchase that are 40 years of age or older, in order to determine their heritage character.1

In order to comply with this section of the policy, departments must submit all federal buildings that meet the "40 years of age or older" rule for heritage evaluation; departments may, however, make special evaluation requests for buildings that are less than 40 years old.2 It should be noted that this obligation does not extend to buildings administered by Crown corporations (e.g. Canada Post Corporation), archaeological resources or ruins.

Canada's national historic sites are not, themselves, subject to this obligation; however, all buildings 40 years of age or older located on national historic sites that belong to the federal government must be submitted to FHBRO for evaluation.

The purpose of the evaluation is to determine the heritage character of federal buildings, as well as their level of designation, either Classified, Recognized or not designated. In order to meet this policy requirement, departments should establish an evaluation plan that takes into account acquisitions, operations, maintenance and disposals. The real property inventory systems used by departments should enable them to readily identify buildings that require an evaluation.

Gulf of Georgia Cannery National Historic Site, Steveston, British Columbia
Gulf of Georgia Cannery National Historic Site, Steveston, British Columbia
The former Gulf of Georgia Cannery, built in 1894, is designated as a Classified federal heritage building because of its strong historical associations, its architectural design and its importance to the Steveston's waterfront. The building was directly associated with the fishing industry from 1894 through the 1970s. The former cannery serves as a symbol of the history of the west coast fishery.

Departments are encouraged to work with FHBRO to develop guidelines and annual plans that will help them determine the order in which their requests for evaluations should be submitted. If interventions are planned, it is very important to submit request for the evaluation of the affected buildings at the very beginning of the initial phase of the project.

The integrity of the evaluation process is ensured through the use of evaluation criteria that are recognized both nationally and internationally, in-depth research and an evaluation committee made up of experts from various disciplines, as well as representatives from the custodian department. The evaluation criteria used by FHBRO are based on a system developed by architectural historian, Dr. Harold Kalman, for Parks Canada and described in The Evaluation of Historic Buildings, published in 1980. The factors evaluated by FHBRO and their weighting have been fine-tuned over time and adjusted to take into account the federal context.3

Real property covered by the policy

Federal real property should be submitted to FHBRO for a heritage evaluation when it meets the following three conditions:

  • it is 40 years of age or older;
  • it is owned, or is being considered for purchase, by a federal department;
  • it meets the definition of "building", based on the following three criteria:
    1. it is capable of containing or sheltering human activities
    2. it has an interior space, an exterior shell and a roof
    3. and it is fixed in a permanent specific location

The heritage character of federal buildings is evaluated on the basis of the following factors:

  • Historical associations - thematic association, person/event and local development
  • Architecture - aesthetic design, functional design, craftsmanship and materials, designer
  • Environment - site, setting and landmark status.

To be designated a Classified federal heritage building, the highest level of designation reserved for the best examples of federal built heritage, a score of between 75 and 135 points (out of a total of 135) must be obtained.

For a building to be designated as a Recognized federal heritage building, the second level of designation for buildings that have significant heritage value, a score of between 50 and 74 points is required.

A building will not be designated if it scores below 50 points. There are no specific heritage obligations for these buildings, however, some of them may have specific significance to communities or interest groups, and these interests should always be taken into account in decision-making.

Steps in the process

The ruins of Thomas
The ruins of Thomas "Carbide" Wilson's phosphate fertilizer plant, Gatineau Park, Quebec
© C. Lefebvre, 2008
This structure has no roof and is therefore not considered to be a building.

FHBRO administers the heritage evaluation process, in accordance with the Policy on Management of Real Property and the guidelines set out in the Guide to the Management of Real Property.

The evaluation process consists of the following steps:

  1. Submission of a request for an evaluation
  2. Documents to be provided with a request for an evaluation
  3. Determination of the type of evaluation required
  4. Preparation of a research report
  5. Evaluation meeting
  6. Recommendation for designation

1 Submission of a request for an evaluation

Main Greenhouse Range (Building 50), Central Experimental Farm, National Historic Site, Ottawa, Ontario
Main Greenhouse Range (Building 50), Central Experimental Farm, National Historic Site, Ottawa, Ontario
© C. Lefebvre, 2008
These greenhouses are considered to be buildings, since they accommodate research activities, have walls and a roof and are fixed in a specific location.

Requests for an evaluation of one or more buildings located on a site must be made using the Preliminary Information Sheet that can be obtained from the FHBRO Registrar.

One information sheet per building must be completed. If the evaluation application is complex (addressing several buildings located on one or more sites, for example), it is recommended that the Registrar be contacted for guidance on how to prepare the evaluation request.

The completed Preliminary Information Sheet should be mailed to the Registrar, and must include a printed and electronic version of all required documentation, including photographs and plans.

Documents to be provided with a request for an evaluation

An introductory letter explaining the context for the evaluation request, for example, whether an intervention (alteration, disposal or demolition) to the building is planned, together with a schedule for the intervention, is required so that FHBRO can determine evaluation priorities.

A Preliminary Information Sheet must be completed for each building submitted, including secondary buildings. This form asks for essential information about the building and its history, and it is very important that it be completed as accurately as possible. It is especially important to provide good recent photographs of the building, plans and any other available information (historical report, report on building condition, etc.).

2 Determination of the type of evaluation required

Alexander Graham Bell Museum, National Historic Site Baddeck, Nova Scotia
Alexander Graham Bell Museum, National Historic Site, Baddeck, Nova Scotia
The Alexander Graham Bell Museum, built in 1954-56, is designated as a Recognized federal heritage building. Built specifically to hold Alexander Graham Bell artifacts, the museum consists of an attractive A-frame structure and a large column-free interior space. The rock-faced sandstone exterior walls, patterned, coloured slate flooring, laminated wood beams at the roof and redwood fittings and furnishings give the building's modern design its rustic character.

FHBRO uses one of three evaluation methods, depending on the nature of the building submitted. It is FHBRO's responsibility to determine which of these methods is most appropriate for the building.

Formal evaluation is used for buildings that may potentially be designated as federal heritage buildings. This type of evaluation requires the preparation of a research report and an evaluation meeting involving the full FHBC. Nine to twelve months are required to complete this type of evaluation, given the research and analysis that must be completed prior to the evaluation meeting. FHBRO therefore recommends submitting evaluation applications at least twelve months in advance of the date when the result is required.

Benchmark evaluation is used for buildings that are likely to score close to 50 points, which is what is required for a designation. This type of evaluation requires the preparation of a short research report that includes comparative examples. A score is proposed to the custodian department by an evaluation sub-committee consisting of an historian and a conservation architect. The custodian department has one month to either accept the proposed score or challenge it, in which case it may ask for a formal re-evaluation of the building. The benchmark evaluation process takes up to nine months to complete.

Screening is used for buildings that appear not to merit designation, on the basis of having little or no chance of receiving a final score greater than 49 points. This type of evaluation is performed by a sub-committee that includes the FHBRO Manager, an historian and a conservation architect, using documentation submitted by the federal department or agency. No additional research is carried out. This review may take up to four months to complete. The custodian department may comment on, or suggest modifications to the score recommended by FHBRO. It may also request a benchmark or even a formal re-evaluation.

3 Preparation of a research report

For formal and benchmark evaluations, a research report must be prepared to serve as a reference document during the evaluation. Parks Canada's Cultural Sciences Branch prepares the research reports.

The custodian department may help Parks Canada's historians by making available all of its documentation about the history of the building being evaluated. The types of information used by historians include historical and recent plans; photographs from different time periods; written documents; and statements from members of the community where the building is located. Where possible, the historian may visit the building being evaluated.

4 Evaluation meeting

Government of Canada Building Grand Falls, New Brunswick
Government of Canada Building Grand Falls, New Brunswick
© PWGSC, 1999
This Recognized federal heritage building, constructed in 1958-59, is associated with the expansion of federal government services in the post-Second World War period. It is designed in the modern aesthetic, and is one of the largest federal buildings in the region. The Government of Canada Building reinforces the urban character of the town centre of Grand Falls.

In the case of a formal evaluation, FHBRO organizes an evaluation meeting to which the FHBC is invited. The research report is used as a starting point for discussion, but the points of view of all committee members are taken into account. The custodian department can name up to three representatives to the FHBC. It is highly recommended that at least one of these representatives be familiar with the building under consideration, as well as with the community in which it is located.4 Departmental observers from regional offices are also sometimes invited to participate at meetings, in particular when environmental criteria are being considered. The meeting is chaired by the Manager of FHBRO, who ensures that all decisions reflect a consensus view.

Once the evaluation has been completed, FHBRO prepares a Building Evaluation Record with the final score for each criterion, the total points obtained and the committee's designation recommendation: not designated, Recognized or Classified. This is signed by the Manager of FHBRO and constitutes the official result of the evaluation. Once finalized, it is sent to the custodian department.

The minutes of the evaluation meeting are also submitted to FHBC members for comments in the weeks following the meeting. These minutes are one of the main sources of information, together with the Building Evaluation Record and the research report, used in the preparation of a Heritage Character Statement, if the building has been recommended for designation.

5 Recommendation for designation

At the end of the evaluation process, some buildings are recommended for designation. It is important to note that the FHBC does not itself designate buildings, but recommends designation to the Minister of the Environment.

A list of proposed designations is submitted to the Minister at the end of each fiscal year for approval. Once such approval has been received from the Minister, the designated buildings are listed on the Directory of Federal Heritage Designations and on the Canadian Register of Historic Places.

The Heritage Character Statement

Clock Tower Old Port of Montreal, Montreal, Quebec
Clock Tower, Old Port of Montreal, Montreal, Quebec
© C. Lefebvre, 1996
The Clock Tower, built in1919-22, has been designated a Classified federal heritage building because it is an eloquent symbol of the importance of the Port of Montreal in the history of transportation in Canada. Its aesthetic significance resides in its elegant silhouette, the excellence of its composition, and in the judicious choice of decorative elements in the Beaux-Arts style. The design of the tower integrates in an ingenious manner its role as a memorial, commemorating the courage of the seamen of the Merchant Marines who perished in the First World War, with its role as a clock tower and curtain wall to conceal grain sheds and conveyors, which were eventually demolished in the 1970s. The Clock Tower is a major landmark in Montreal.

The policy requires that departments protect the heritage character of the designated buildings they administer. In order to do this, they must understand and respect this heritage character in all planning and intervention-related activities. The Heritage Character Statement was developed by FHBRO to explain the reasons for the designation and what it is about the building that makes it significant (the heritage character). This statement reflects the results of the evaluation process and is based primarily on the Building Evaluation Record and the minutes of the evaluation meeting. It is a short document of two to three pages that includes the following sections:5

  • General Information provides users with basic information about the building, including the FHBRO and Directory of Federal Real Property numbers.
  • Description of Historic Place answers the question: What does the designation apply to, and what does it include? This section describes the designated building in general terms and specifies what is being designated.
  • Heritage Value answers the question: Why is the building important or significant? This section is directly related to the evaluation criteria. It discusses the historical (thematic, person/event, local development), architectural (aesthetic design, functional design, craftsmanship and materials) and environmental (site, settings, landmark) significance of the building identified during the evaluation process.
  • Character-Defining Elements answers the question: What are the key elements or features of the building that must be protected in order to preserve its heritage value? This section briefly describes the tangible features of the building that carry or express its value or significance. These may include formal elements (volume, elements of its composition, etc.), materials and craftsmanship, spatial configurations, finishes, and ornamental details, among other things.

Each building recommended for designation as a federal heritage building receives a Heritage Character Statement, prepared by FHBRO, which is sent to the custodian department for review and approval before being finalized.6 The final statement is translated and made available in both official languages.

Each designated building has its own Heritage Character Statement, which may be obtained from the departmental FHBRO representative, or from the FHBRO Registrar.

It is important that everyone involved in interventions to federal heritage buildings has access to their Heritage Character Statements. This includes building managers and maintenance staff, occupants or new owners, and any consultants working on proposed interventions.

For Canada's national historic sites, the Commemorative Integrity Statement plays a role that is equivalent to that played by the Heritage Character Statement for federal heritage buildings: it sets out the reasons for the designation, the values associated with the site, and those elements or characteristics of the site that need to be protected or conserved.

For the departments

The Heritage Character Statement is the best tool available to ensure that the heritage character of the federal heritage buildings they administer is preserved. The Heritage Character Statement can guide the preparation of conservation and maintenance plans, to ensure appropriate stewardship of the building. It can also be used in conjunction with the Standards and Guidelines for the Conservation of Historic Places in Canada to plan interventions in a manner that respects the heritage character of the building.


The Heritage Character Statement is the primary reference document used to carry out a Review of Intervention for a designated building. The Heritage Character Statement allows FHBRO to measure the impact of proposed work on the building's heritage value and character-defining elements.

Federal Building, detail of main entrance, Winnipeg, Manitoba
Federal Building, detail of main entrance, Winnipeg, Manitoba
The stepped massing, flat walls and stylized decoration clustered around the entrance and first floor windows are elements that characterize the Federal Building as an example of "Classical Moderne" architecture.
Granary, detail of fresco Manoir Papineau, National Historic Site, Montebello, Quebec
Granary, detail of fresco, Manoir Papineau National Historic Site, Montebello, Quebec
© C. Lefebvre, 2008
The Granary is directly associated with politician Louis- Joseph Papineau (1786-1871), the first French-Canadian nationalist leader and seigneur of La Petite-Nation, and with Napoléon Bourassa (1827-1916), an architect and painter who used the upper floor studio during the summers of 1858 to 1871. Testimony to the time Napoléon Bourassa spent in the upstairs studio, are the frescoes ornamenting the ceiling.

Air Terminal Building HALB09A FOX-M Station, Hall Beach, Nunavut
Air Terminal Building, HALB09A FOX-M Station, Hall Beach, Nunavut
© Canada, DND, ISC86-753
The Air Terminal Building, constructed in 1960 on the airfield sector of the FOX-M station of the former Distant Early Warning (DEW) Line, is designated a Classified federal heritage building. The building is associated with the continental air-defence programs of the Cold War. As part of one of four main stations constructed for the DEW Line, the Air Terminal Building was part of a joint American-Canadian effort to monitor Arctic airspace through an innovative radar and radio system designed to provide advance warning to North American military authorities of a possible air attack from the Soviet Union.


  • Does the department have an up-to-date inventory of all federal buildings that it administers?
  • Has the department had all buildings 40 years of age or older evaluated?
  • Does the department have in its possession all Heritage Character Statements for its designated buildings (Classified or Recognized)?
  • Has the Heritage Character Statement for each designated building been given to everyone likely to carry out work on these buildings (managers, maintenance staff, occupants, consultants)?
  • Do these people understand the meaning and scope of the Heritage Character Statement? For example, have they taken FHBRO training?


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

2 The 40-year point provides a degree of perspective on the building's history; it is also a stage in a building's life cycle at which signifcant reinvestment decisions must often be made.

3 Information taken from the FHBRO Code of Practice, published in 1996, p. 12.

4 It is essential that departmental representatives receive training on FHBRO's evaluation process before participating as evaluators on the FHBC.

5 Heritage Character Statements written before 2002 were structured somewhat differently.

6 In rare cases, there is only one Heritage Character Statement for a group of buildings.

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