HomeMy WebLinkAboutDSD-2025-313 - Proposed Repeal and Replacement of Chapter 643
Development Services Department www.kitchener.ca
REPORT TO: Heritage Kitchener
DATE OF MEETING: November 4, 2025
SUBMITTED BY: Garett Stevenson, Director of Development and Housing Approvals,
519-783-8922
PREPARED BY: Victoria Grohn, Heritage Planner, 519-783-8912
WARD(S) INVOLVED: All
DATE OF REPORT: August 5, 2025
REPORT NO.: DSD-2025-313
SUBJECT: Proposed Repeal and Replacement of Chapter 642 of the City of
Kitchener Municipal Code Regarding Delegated Approval Authority
for Heritage Permit Applications
RECOMMENDATION:
That the draft by-law attached as A to report # DSD-2025-313 be enacted
to repeal and replace Chapter 642 of the City of Kitchener Municipal Code regarding
delegation of the power to consent to alterations to property designated under Part
IV and Part V of the Ontario Heritage Act.
REPORT HIGHLIGHTS:
The purpose of this report is to repeal and replace Chapter 642 of the City of
consent to alterations to property designated under Part IV and Part V of the Ontario
Heritage Act.
The key finding of this report is
delegated approval authority to Staff given changes to the Ontario Heritage Act and an
increase in the number of Part IV designated properties across the City.
There are no financial implications.
Community engagement included consultation with the Heritage Kitchener committee.
This report supports the delivery of core services.
EXECUTIVE SUMMARY:
The Ontario Heritage Act permits municipal councils to delegate its consent or approval
authority to staff for proposed alterations to designated heritage property. Kitchener City
Council enacted By-law 2009-089 to delegate its approval authority for certain classes of
alterations to Heritage Planning staff. Between 2018 and 2019, Heritage Planning staff
proposed amendments to the Delegated Approval Authority by-law to improve processes
related to the issuance of heritage permits. However, the Council at the time did not
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support the changes proposed by staff. In 2023, amendments to the Ontario Heritage Act
came into effect and altered how properties are identified and conserved by municipalities.
properties on municipal heritage registers. In light of these changes, amendments to the
Delegated Approval Authority by-
warranted. The changes proposed by Heritage Planning staff expand the delegated
approval authority to apply to both Part IV and Part V designated properties in effort to
further streamline the heritage permit process and optimize Heritage Kitchener and
Council meeting time to focus on more strategic and pressing heritage matters across the
City. The City of Kitchener is proud to be a provincial leader in accelerating housing
planning timelines and streamlined approvals to get homes built faster.
BACKGROUND:
In April 2005, the Ontario Heritage Act was amended to permit a municipal council to
delegate its consent or approval authority for proposed alterations to designated heritage
property. The objective of delegating approval authority is primarily to streamline the
approval process for alterations, and to eliminate routine and administrative matters from
heritage committee and council agendas. This typically includes applications compliant
with recognized conservation practices and existing heritage policies and guidelines.
In 2009, Kitchener City Council enacted By-law 2009-089 delegating its approval for
certain classes of alterations to Heritage Planning staff. The provisions of the by-law were
subsequently incorporated into Chapter 642 of the City of Kitchener Municipal Code
Heritage Property Consent Alterations (see Attachment B). Chapter 642 of the Municipal
Code outlines the circumstances and criteria to be used when qualifying a heritage permit
application to be processed through delegated approval.
In 2015, City Council directed Heritage Planning staff to examine heritage best practice
measures in Ontario and to identify priority measures for implementation in Kitchener.
Following discussion with Heritage Kitchener, one priority included improving processes
related to the issuance of heritage permits. This included giving consideration to reviewing
delegated approval authority for heritage permits and an
Municipal Code to provide greater opportunity for heritage permits to be issued through
delegated approval, when appropriate to do so.
In 2018, Heritage Planning staff presented a discussion paper on the issue to the Heritage
Kitchener committee, and at the time the committee expressed general support for
considering an all alterations approach, whereby Council delegates approval authority to
City staff for all alterations conditional on staff and the Committee Chair agreeing to
process the application through delegated approval.
In 2019, a new Heritage Kitchener committee was appointed and delegated approval was
discussed. There was mixed support from the committee on the proposed changes. Some
committee members expressed continued support for making changes if efficiencies in
processing times and customer service would result. Other committee members
expressed reservation with providing more delegated approval authority to staff and
questioned if there was a need to amend the current provisions. Heritage Planning staff
recommended minor amendment
Code, and in particular to the criteria for the review of applications made for Part V
designated property. The Heritage Kitchener committee at the time was supportive of this
recommendation, but it was not approved at City Council.
Starting in 2020, through our Development Services review (DSR), the City has eliminated
unnecessary steps and optimized processes to support housing delivery. The DSR looked
interact and made improvements resulting in
clearer accountability, stronger collaboration, and ultimately a better customer experience.
A key takeaway from the DSR was a staff commitment to continue to focus on process
improvements that strengthen the Citlining and
reducing the time for development application review. The proposed amended delegated
approvals to staff processes build on this work. In January 2023, amendments to the
Ontario Heritage Act came into effect through Bill 23, the More Homes Built Faster Act.
The key goals of this legislation are to increase housing supply, promote affordability, and
streamline development through a reduction of red tape and bureaucracy in the planning
and approval process.
Bill 23 altered how heritage properties are identified and conserved by municipalities. One
properties on the Municipal Heritage Register to be evaluated to determine if they meet
the criteria for heritage designation. Bill 200, the Homeowners Protection Act, 2024
extended the time municipalities must designate properties listed on their municipal
heritage registers to January 1, 2027. Since these changes have come into effect,
Heritage Planning staff has reviewed 94 properties. Of these properties, 35 are currently
undergoing the designation process at various stages of completion and 45 have been
fully designated under Part IV of the Ontario Heritage Act. The remaining properties
reviewed were determined that no action should be taken at this time. As such, there are
currently 139 Part IV designated properties across the City.
The recent amendments to the Ontario Heritage Act warrant another review of Chapter
improve productivity and
optimize time for Heritage Planning staff, the Heritage Kitchener committee and Council.
REPORT:
Purpose and Current Scope of Delegated Approval Authority
applications is generally regarded as a customer service measure. Delegated Approval
Authority (DAA) can reduce the timelines for granting heritage approval from 6-8 weeks
down to approximately 10 days and provides more efficient use of time and resources
toward Heritage Kitchener committee and Council priorities.
The current DAA by-law extends to alteration applications made under Part IV or Part V of
the Ontario Heritage Act (OHA) but does not include applications for demolition.
Part IV Designated Property
-law, staff may consent to a heritage permit application
(after consulting with Heritage Kitchener) if:
Heritage Kitchener recommends approval (with or without conditions); and
The conditions are either the same as those recommended by Heritage Planning
staff or are conditions that Heritage Planning staff agree to.
Part V Designated Property
For properties designated under Part V of the Ontario Heritage Act (OHA), heritage
approval through DAA may be granted in two scenarios:
Scenario 1: Direct Staff Approval
Heritage Planning staff may approve the application without referring it to Heritage
Kitchener, provided that:
The application does not meet specific criteria that would require committee review;
and
Staff consults with the HCD representative that sits on Heritage Kitchener, or with
the Chair if no representative is available.
Scenario 2: Committee Recommendation
If the application is referred to Heritage Kitchener, and the committee recommends
approval, then:
Staff may grant final approval under DAA, following the same process used for Part
IV designated properties.
Heritage Permit Applications
In practice, the application of DAA for Part IV and Part V properties is working well. While
many heritage permit applications can be processed through DAA under the current
framework and permissions, there have been instances when alteration applications in
compliance with recognized conservation practices have not been able to be approved
directly by staff due to the existing criteria as it is written in the current by-law. Additionally,
applications for alterations to Part IV properties are approved through DAA after
consultation with the Heritage Kitchener committee, in most instances. Further, the
majority of heritage permit applications received for Part V properties are granted approval
by Heritage planning staff through DAA without having to consult with Heritage Kitchener.
The following are specific examples of heritage permit applications processed in the last
few years where staff believe the existing by-law has limited the opportunity to further
streamline the heritage approval process for designated property owners:
Application Year 2021
HPA-2021-IV-007 (23 Roland Street)
In this example, an application was made to remove and reconstruct the rear porch and
balcony, based on evidence found in a historic photograph. The property is designated
under Part IV of the OHA and located within the Victoria Park Area Heritage Conservation
District (VPAHCD). Typically, applications for porch repairs and replacements in the
VPAHCD are processed through DAA. However, given that this particular property is also
designated under Part IV of the OHA, the proposal was required to be reviewed and
considered by Heritage Kitchener as per the DAA by-law. The application was approved
unanimously at Heritage Kitchener and the application was further processed by staff
through DAA.
Application Year 2023
HPA-2023-IV-020 (307 Queen Street South)
In this example, an application was made to replace a portion of the roof on the property
addressed as 307 Queen Street South. The designating by-law for this property identifies
the exterior façade of each elevation, including the roof lines of the 1879 and 1893
buildings as well as the façade and roof line of the Queen Street elevation of the 1919
building as heritage attributes. The portion of the roof replaced as part of this application is
not original to the building and not visible from the street. However, given that this is a Part
IV designated property, the application was required to be reviewed and considered by
Heritage Kitchener as per the DAA by-law. The application was approved unanimously at
Heritage Kitchener and the application was further processed through DAA.
Application Year 2025
HPA-2025-V-014 (59 Park Street)
In this example, an application was made to demolish a non-original attached garage and
non-original shed on the property addressed as 59 Park Street. The property is located
cultural
heritage value or significance. Given that this application contemplated the removal of a
building or structure within the VPAHCD, the application required review and consideration
by Heritage Kitchener. The application was approved unanimously at Heritage Kitchener
and the application was required to go to Council for final approval.
Reasons for Undertaking Review
Municipal Heritage Register Review Project
Following the 2023-2024 amendments to the Ontario Heritage Act (OHA), the City must
re-evaluate all properties listed on the Municipal Heritage Register (MHR) by January 1,
2027. Properties not designated by this deadline will be removed from the MHR and
cannot be re-listed for five (5) years. This review remains a key priority for Heritage
Planning staff.
Since the amendments came into effect, the City has designated 45 properties, with an
additional 34 undergoing the designation process at various stages. Under the current
DAA By-law, all heritage permit applications for these Part IV properties must be reviewed
by Heritage Kitchener and, in some cases, Council; a process that typically takes 6-8
weeks. While the full impact on staff workload is not yet known, it is anticipated that
continued reliance on the current DAA process will significantly increase demands on
report preparation by Heritage Planning staff and committee agendas, regardless of
application complexity or compliance.
Changes to the Ontario Heritage Act Extension of Timelines
Recent amendments to the OHA introduced new time limits for individual property
designations, alterations to designated properties, and changes within heritage
conservation districts. These timelines govern when applications must be deemed
complete, when Council must make decisions, and when Notices of Intention to Designate
must be issued. Currently, extending these timelines requires Heritage Kitchener review
and Council approval. Proposed changes to the DAA By-law would allow Heritage
Planning staff to manage extensions directly with property owners, streamlining processes
and reducing the number of items requiring Heritage Kitchener committee and Council
consideration.
Impacts on Public Perception
The heritage permit process under Parts IV and V of the OHA is often perceived as time-
consuming, which can discourage property owners from supporting designation due to
procedural delays. The proposed amendments to the DAA By-law aim to streamline
approvals by expanding staff authority to process a broader range of applications, thereby
reducing administrative burden for designated property owners.
Proposed Changes to Delegated Approval Authority By-law
To address the changes to the OHA regarding the MHR review and extension of timelines,
as well as improve public perception around designated heritage properties, Heritage
Planning staff propose the following amendments to the DAA by-law. The purpose of
these amendments is to improve efficiencies around the processing of heritage permit
applications and allow Council and committee agendas to focus on more complex or
strategic heritage planning matters.
Delegation of Consent to Alterations on Part IV and Part V Applications
Heritage Planning staff recommend that Part IV and Part V properties be treated
consistently under the DAA by-law. Most designating by-laws and HCD Plans clearly
identify attributes contributing to cultural heritage value, allowing staff to assess
compliance with proposed alterations. However, under the current DAA framework, even
fully compliant applications for Part IV properties require review by Heritage Kitchener and,
in some cases, Council.
Minor alterations, such as the construction or removal of detached accessory structures
under 15 square metres (161 square feet) which are not identified as heritage attributes,
are examples of applications staff proposes to be processed through DAA, aligning with
building permit exemptions. Larger structures or those with heritage value would continue
to require Heritage Kitchener review.
approval authority to staff for all alterations, except in defined cases. Below are the
instances in which DAA would not apply:
(a) The removal of heritage attributes as identified in a designating by-law, Heritage
Conservation District Plan, or by Heritage Planning staff as having cultural heritage
value;
(b) The construction of a new single storey detached accessory building on the
property if the entire footprint is greater than 15 square metres (161 square feet);
(c) The removal of a single storey detached accessory building if the entire footprint is
greater than 15 square metres (161 square feet) and is identified as a heritage
attribute in the designating by-law, Heritage Conservation District Plan, or by
Heritage Planning staff as having cultural heritage value;
(d) Alterations that would have significant impact on the cultural heritage value of the
property as identified in the designating by-law, the Heritage Conservation District
Plan, or by Heritage Planning staff as having cultural heritage value; and
(e) The application is highly complex, including situations in which a heritage impact
assessment, conservation plan, or other heritage-related study is required to be
submitted.
A clause will remain allowing staff to refer any application to Heritage Kitchener and
Council at their discretion.
The purpose of the amendments to the DAA by-
role in reviewing heritage permit application
to more pressing and larger heritage planning matters (ex. Kitchener 2051, designation of
properties on the inventory).
Municipal Examples of Delegated Approval Authority
Several Ontario municipalities have implemented DAA by-laws, including the surrounding
municipalities of Waterloo, Cambridge, and Guelph. Many of these municipalities define
scenarios where staff may approve heritage permit applications without municipal heritage
committee or Council review. Inclusion-based lists, which specify permitted alterations,
can create ambiguity when certain types of work are not explicitly identified. An
exclusions-based approach provides greater clarity by outlining when DAA does not apply.
The proposed amendment-law are informed by the model used in
the Town of Oakville.
Heritage Planning Staff Recommendations and Conclusion
In alignment with changes to provincial legislation, optimizing Heritage Kitchener and
Council time on heritage planning matters, and creating greater efficiencies to the heritage
permitting process, Heritage Planning staff recommend the following:
Expanding delegated approval authority to staff for all alterations to Part IV and Part
V properties, except in defined circumstances, ensuring consistent treatment across
properties;
Utilizing an exclusions-based framework to reduce ambiguity and improve clarity
around when delegated approval authority does not apply;
Authorizing staff to manage extensions to statutory timelines directly with property
owners, reducing the need for Heritage Kitchener and Council involvement; and
enactment of the draft by-law included as Attachment A to this report.
The changes being recommended should improve customer service by further
streamlining the approval process for alteration applications that are consistent with
heritage policy and good conservation practices. Applications that will
STRATEGIC PLAN ALIGNMENT:
This report supports the delivery of core services.
FINANCIAL IMPLICATIONS:
Capital Budget The recommendation has no impact on the Capital Budget.
Operating Budget The recommendation has no impact on the Operating Budget.
COMMUNITY ENGAGEMENT:
INFORM
of the Heritage Kitchener committee meeting.
CONSULT Heritage Kitchener has been consulted regarding the proposed amendments
to the Delegated Approval Authority By-law.
PREVIOUS REPORTS/AUTHORITIES:
DTS-09-087 Delegation of Council Approval for Alteration Applications
DSD-19-273 Amendment to Chapter 642 of the Municipal Code Regarding
Delegated Approval Authority
Ontario Heritage Act
REVIEWED BY: Sandro Bassanese, Manager of Site Plan
APPROVED BY: Justin Readman, General Manager, Development Services
ATTACHMENTS:
Attachment A Draft Delegated Approval Authority By-law
Attachment B