The following is a summary…

The following is a summary of the comments made on behalf of The Governing Council of the University of Toronto (“the University”), please review our attached letter for further details:

• The University is supportive of the Minister’s proposed amendment to increase the threshold for designation by requiring that a property meet two or more of the criteria prescribed under Ontario Regulation 9/06. However, given the breath of the criteria as drafted, this amendment alone will not be sufficient to remove barriers while ensuring the continued protection of heritage resource. Further amendments to O. Reg. 9/06 are required to insert a standard of significance when considering each of the criteria for determining cultural heritage value or interest, and an objecting definition of “significant” should be added to the PPS that provides a measurable standard. Proposed amendments are included in the attached letter.

• Increasing the standards for listing a property on a municipal register by requiring that the property meet one or more of the prescribed criteria may have the result of effectively removing the distinction between listing and designation. Any prescribed criteria for listing a property must ensure that the merits of designation are not pre-determined, as there is no appeal of a heritage listing.

• While the University is supportive of imposing timelines for a municipality to designate a listed property and preventing a municipality from designating a property that has not already been listed, the University is concerned that the proposed changes will have the unintended consequence of ultimately encouraging an increase in designations prior to the expiry of the two-year limitation period, particularly if the criteria for designation are not further refined. The University requests that provisions be added to allow the potential for the two-year time period for designation be extended upon the agreement of both the municipality and the owner.

• The University is supportive of increasing rigor in the process of identifying and protecting heritage conservation districts, ensuring they are not used to freeze a community in a moment of time and restrict future investment and intensification. However, the economic needs of communities, such as the current housing crisis, and the needs of area institutions and significant employers must be given priority consideration before redevelopment is discouraged through HCD designation. Care must also be taken to not use HCDs as a tool for regulating standards of development that are properly prescribed by the municipal zoning bylaw.