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Main Street East HCD Studyshould focus on protecting Main Street East

The Town Planning staff’s decision to extend the Main Street East Heritage Conservation Study map into the downtown area was met with criticism after the first Public Information Centre (PIC). It was fueled by concerns over the lack of notice regarding this decision without prior consultation, particularly with the downtown business community as is required by Town’s Official Plan.

In response, Planning staff issued an Update Report to Council, accompanied by a presentation delivered by Town’s Planning Director at the last Committee of the Whole meeting on December 20th. Among the “issues” addressed in this Update Report were “misinformation” spread by the public and the “lack of trust” from the community.

During the discussions around this Report, Councillor Lianne Vardy pointed out that bashing resident concerns is not a good (nor professional) way to build a positive relationship with the community.

From the items called “misinformation” listed in the Update Report, there are references to the SaveMainStreet joint delegation to Council with the Grimsby Historical Society in 2020, and the three phase approach that was proposed to protect the heritage features of Grimsby’s entire Main Street.

Planning staff seem to have been inconvenienced by that, having to answer residents who question the inclusion of downtown areas in a study that was directed to cover Main Street East. The argument issued by staff was that a three-phase approach was not valid, since no direction was given by Council following our delegation’s presentation.

While it is true that Council received our delegation with no direction for staff, the “three-phase approach” did not come as a surprise to any members of the Council nor the Planning Department at the time.

Consideration of three Main Street segments was not something that originated with our delegation. These segments have long been recognized by the community as distinct areas historically, even if they belong to the same 10-kilometer-long historic street. Given the importance of Main Street in defining the character of the town, a discussion with former resident members of the Heritage Advisory Committee, local historians, or a visit to the Grimsby Historic Society’s Archives could have cleared staff’s confusion and maybe establish a higher level of community trust.

However, an official direction was given by Council after our delegation in 2020: prioritizing the protection of Main Street East.

Another item on the list of “misinformation” presented to Council at the December 20th meeting was the proposed study area from the Heritage Grimsby Advisory Committee (HGAC).

The HGAC study area proposed was very much in line with the direction from Council to protect Main Street East, the motion’s intent being to encompass all Main Street East fronting properties. There are several overlapping Cultural Heritage Landscapes extending to the eastern border of Grimsby which are threatened by development pressures. It is unclear why their proper assessment under a Heritage Conservation District Study has been a problem for this Planning Department so far.

Contrary to staff’s repeated statements that a heritage professional was not involved in the GHAC’s decision of the study area, the Ministry’s Heritage Tool Kit clearly has no requirement for any Planning Department’s input into decisions around a study area’s boundaries. The Ministry document indicates that Municipal Heritage Committee (MHC) guidance is sufficient when it states that “following consultation with the Municipal Heritage Committee (where appointed), it is up to council to decide whether to proceed with the designation of the area as a HCD”, and that “where a MHC exists, the act requires that council consult with the committee about any area being considered as a heritage conservation study area”.

The biggest issue has yet to be clarified at all. Why has the whole Downtown “village” and commercial core now been added to a Main Street East HCD study?

The Planning director mentioned that criteria from Step 6 of the Ministry’s Heritage Toolkit - Delineation of the Boundary of a HCD was used to delineate the study area presented at the PIC on October 20th. This step from the Toolkit recommends consideration of four categories of criteria for a HCD boundary delineation: Historic factors, Visual factors, Physical features and Legal or Planning factors.

If these delineation criteria were used to determine the study area presented at the PIC (as suggested in Planning’s presentation), we seriously question the accuracy of the research that led to the amalgamation of two areas which are obviously very different historically, visually, physically and from a planning perspective - quite contrary to the Ministry’s recommendations.

As Councillor Dorothy Bothwell argued, it is hard to believe that the consultants needed to add the downtown area to create a “defensible boundary for the HCD” when there is already a wealth of heritage features on Main Street East.

Councillor Bothwell also expressed concerns about foreseeable planning implications on Main Street East caused by the new direction:

“The downtown is identified to do intensification and for great change and for huge infill. It’s just totally different ballparks and I’m just worried that what we’re doing is we’re going to lose one of those ball games because we’re watering it down and one of them is going to become a priority. When you look at downtown, it needs its own - definitely. But what we have got to focus on right now, is the protection of managing the change within the area that’s at greatest risk, which is our Main Street East, which is a totally different zoning designation with huge setbacks, totally different from downtown. It’s apples and oranges.”

These concerns are very real since any resulting HCD Plan from this study will have stated goals that take into consideration existing planning policies of all areas within the final HCD boundary. It doesn’t take a heritage specialist to confirm that the focus on maintaining the character of Main Street East as a distinctive area will be forever lost in this mix.

The answer from the Planning Director that “downtown is intrinsically linked with the evolution of Main Street East” does not hold water from a historic district perspective. The Main Street East area evolved differently from the entire Grimsby township and the original 2020 request to Council provided a specific boundary defined from an understanding of how Main Street East developed. If the argument provided by staff will be used to justify the creation of “a defensible boundary”, the whole HCD Plan could miserably fail in any possible future challenges.

According to the RFP document for this study, it is not up to staff to decide anything about this HCD Study or eventual HCD Plan. In the end, it will be Council’s job to decide after they receive the Town’s consultant’s independent report.

Public engagement in the study process will start this month. We couldn’t agree more with the Town’s Planning Director’s statement that “we need to move forward in a constructive, productive way”.

The real question becomes - Which way?

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