Basically, if you take Toronto as a whole then there aren't enough francophones. However, if you take different parts of Toronto, there would probably be several neighbourhoods that could rightfully be designated. I think it would be very important.
Furthermore, the Commissioner of Official Languages has no authority over consumers. I think she can only act regarding consumers and services. In the UFPBA, it appears that only the minister is responsible for the process of francization or the fostering of French. So we'll see. However, I think it would be important for the commissioner to be able to conduct investigations on her own initiative, and not only when she receives complaints. I don't know if it's in your proposals.