Questions for municipalities…

Questions for municipalities (City of Waterloo):
Q1. How many applications do you receive each year from municipally designated heritage properties that are primarily used for religious practices or Indigenous spiritual or religious practices requesting an alteration to identified heritage attributes connected to those practices?
A1. Average of 1 application

Q2. How long does it typically take to review such an application (in hours)? How long do you believe it would take under the revised process and requirements?
A2. Time varies based on scope of project. Since delegating approval authority to staff (as mentioned further below): minor alterations take 1-2 hours for review + 1-5 days for manager/director approval; major alterations take 2-3 hours inclusive of time meeting with heritage committee + 1-5 days for manager/director approval.
Under the revised process and requirements, it appears our influence over terms and conditions is limited, which would eliminate a component of the review. Time will still be needed to review the affidavit or sworn declaration to verify it meets the criteria as well as consult the Municipal Heritage Committee. This will likely be 1-2 hours for review + 1-5 days to confirm manager/director consent (i.e., similar to current process for applications proposing minor alterations).

Q3. What level of employee in your organization typically undertakes this work (e.g., administrative staff, management)?
A3. Senior- or junior-level planner

Additional comments:
City of Waterloo Heritage Planning staff, in consultation with the Municipal Heritage Committee, have some concerns with the proposed amendments to the Ontario Heritage Act. The main concern is that municipalities would be forced to consent without any terms or conditions where the proposed requirements are met, which leaves little to no control over things such as design, materials, construction methods, or other best practices to ensure the heritage resources are properly conserved. Furthermore, the criteria such as “heritage attributes to be altered are connected to religious practices” seems it may be quite subjective. If this was to proceed, we recommend providing more detailed criteria with examples to guide municipalities in their review of such applications.

Staff support the proposed regulation that “the alteration is not permitted to be an addition to the building”. Staff also recommend alterations not be permitted for other large-scale, major alterations. We believe the proposed amendments, if passed, should be limited to minor alterations and be defined with supporting examples for guidance to owners/municipalities of what types of alterations can/should benefit from this amended process.

The Heritage Permit process in Waterloo is quite efficient and streamlined, and we historically have had good relationships and meaningful engagement between applicants, owners, and the Municipal Heritage Committee. In June 2023, Waterloo City Council adopted a delegation by-law, granting the majority of heritage planning approvals to staff, which has significantly improved the processing of applications.