Listing Multiple Properties on Toronto’s Heritage Register using Historic Context Statements

The City of Toronto (the “City”) is recommending a city-wide approach to the identification and listing of multiple properties for inclusion on the City’s Heritage Register. The approach builds on the City’s evolving and strategic use of Historic Context Statements to guide the identification of cultural heritage resources. The proposed process, methodology and recommended properties for listings were brought to the Toronto Preservation Board (“TPB”) on November 30, 2020. The TPB recommended that the revised reports be adopted by the Toronto and East York Community Council on December 2, 2020 and City Council on December 16, 2020 (here). City Council has since adopted the proposals without amendment (here).

Current Process

Currently, city heritage staff undertake heritage surveys in tandem with planning studies to identify properties of potential heritage value. The staff then recommend that an area be studied further or receive immediate protection. Because this approach only conducts heritage surveys where a planning study is already prioritized (in areas with high growth potential), the City claims that this will make the listing process more effective.

Proposed Process

City Council mandated City Planning to launch the Toronto Heritage Survey in 2019. The goal was to create a city-wide strategy that constitutes good planning, operational efficiency and greater predictability by creating a systematic study throughout the City, rather than listing on a case-by-case basis. The Survey results are used to provide an understanding of the historical evolution of the City and its neighbourhoods. The register is publicly accessible online with advanced search functions (register search).

The Survey identifies sites with cultural heritage value according to a defined list of criteria. The first phase of the process focused on building resources and testing models prior to reporting back to Council. Planning Studies and Heritage Surveys were done for Midtown (King-Spadina); College Street (Huron to Bathurst); and Broadview Avenue (Danforth to O’Connor) identifying approximately 1500 properties as having potential heritage value.

City Council recently reviewed and adopted the following new studies that collectively list approximately 966 new properties:


Area Recommended Listings
Danforth Avenue Planning Study Danforth Avenue (Coxwell Avenue to Victoria Park Avenue) and Dawes Road 165 properties
King-Parliament Secondary Plan Review Area


North side of Queen Street East, between Jarvis Street and River Street 257 properties
Forest Hill Village Urban Design Guidelines Study Area


Four corners of Spadina Road and Lonsdale Avenue 16 properties
Ossington Avenue Planning Study Area


Ossington Avenue (Queen Street West to Dundas Street West) 38 properties
Queen Street West Planning Study West, Queen West and Parkdale Main Street Areas 325 properties
Dundas Street West and Roncesvalles Avenue Built Form Study Area


Dundas Street West and Roncesvalles Avenue 162 properties
Cabbagetown Southwest Heritage Conservation District Study Outside the original study, Berkeley Street

9 properties

All properties have been reviewed to confirm their cultural heritage value in consideration of the Ontario Heritage Act (the “Act”), Ontario Regulation 9/06 and Toronto’s Official Plan requirements for listing.

An owner who intends to demolish a non-designated but listed property, must notify the City within 60 days of their intention to demolish a structure. The owner will have to submit plans, as determined by City Council, for review by Heritage Planning. City Council then has a fixed period of time to decide whether the property meets the designation criteria under the Act and if it does, to issue a notice of intention to designate the property. The owner can reject the notice of intention by serving the clerk a notice of objection within 30 days.

Proposed Methodology

Under the Ontario Heritage Act, the City’s Register may contain property that has not been designated where the council of the municipality believes the property to be of cultural heritage value or interest. The Official Plan requires that the proposed properties be identified and evaluated to determine their cultural heritage value or interest. These cultural heritage values include design or physical value, historical or associative value and contextual value.

The City is now focusing on contextual value rather than historical and associative value as historical and associative value are not visually evident without an extensive evaluation process.

Two proposed methodologies are being discussed, both taking a contextual approach that will work together:

  1. Historic Context Statements – this method is based on prevailing building types and common descriptions of each building type. It is similar to what has been used in the past but consolidates shared features and removes reference to terms more often used for designations under Part IV of the Ontario Heritage Act (e. a legal description of the property; name of the owner; and a statement explaining the cultural heritage value); and
  1. Descriptive Listings – this method is an abbreviated version of the past approach and will be used where a Historic Context Statement has not been defined or where a property’s heritage value relates primarily to its design, physical, historical or associative values.

Davies Howe LLP would be happy to discuss this new Heritage Listing Process with you further.