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HomeMy WebLinkAboutDSD-19-191 - A 2019-050 - 149-151 Ontario St N & 21 Weber St WStaff Report _x Development Services Department wwwkitchener.ca REPORT TO: Committee of Adjustment DATE OF MEETING: August 20, 2019 SUBMITTED BY: Juliane von Westerholt, Senior Planner - 519-741-2200 ext. 7157 PREPARED BY: Garett Stevenson, Planner— 519-741-2200 ext. 7070 WARD: 10 DATE OF REPORT: August 9, 2019 REPORT NUMBER: DSD -19-191 SUBJECT: Addendum to Report DSD -19-121 Application A2019-050 149-151 Ontario Street North & 21 Weber Street West Owners — Kiah Group Inc. Applicant — Scott Patterson, Labreche Patterson and Associates Inc. Approve with Conditions Subject Properties Background: On May 14, 2019 the Committee of Adjustment deferred Application A2019-050 for three months to allow for the appeal period for the new Zoning By-law (By-law 2019-051) to expire. By-law 2019-051 proposed changes to parking regulations, as well as the application of some non- residential zones, among others. By-law 2019-051 was approved by Kitchener City Council on Staff Report Development Services Department K"'""' NFR wwwki tchenr. ca April 29, 2019 and has been appealed. The application of new zones within the Urban Growth Centre has been deferred and will be addressed through a future zoning by-law amendment. Report: Since the May 14, 2019 Committee of Adjustment meeting, the building proposal has been changed such that the proposed dwelling units are now less than 51 square metres in size. The total required parking under Zoning By-law 85-1 is now 23 spaces. The application seeks a reduction from Section 6 of Zoning By-law 85-1 to permit a mixed use building with no minimum parking requirement, whereas the total parking requirement for the new building would be 23. Planning staff remain supportive of the requested parking reduction. Please see Report DSD -19- 121, dated May 14, 2019, for additional information and rationale. As the timing for the application of the new Urban Growth Centre zones is not known, Planning Staffs recommendation from Report DSD -19-121 has been revised to remove any reference to dates and transition regulations and policies. RECOMMENDATION: That Application A2019-050, requesting relief from Section 6 of Zoning By-law 85-1 to permit a mixed use building with no minimum parking requirement, be approved subject to the following conditions: That the Owner receive full site plan approval for a mixed use building, which includes the following bicycle parking configuration: A minimum one 1 Class A Bicycle Parking Stall for each dwelling unit. Each Class A Bicycle Parking Stall shall be a bicycle locker or an enclosed, secure area with controlled access in which a bicycle may be parked and secured for the long term in a stable position with at least one point of contact with the frame of the bicycle. ii. A minimum of 6 Class B Bicycle Parking Stalls. Class B Bicycle Parking Stalls shall be an area in which a bicycle may be parked and secured for the short term in a stable position with two points of contact with the frame of the bicycle. Garett Stevenson, B.E.S., MCIP, RPP Juliane von Westerholt, B.E.S., MCIP, RPP Planner Senior Planner Staff Report Development Services Department REPORT TO: DATE OF MEETING SUBMITTED BY: PREPARED BY: WARD: DATE OF REPORT: REPORT NUMBER: SUBJECT: Report: K_x wwwkitchener. ca Committee of Adjustment May 21, 2019 Juliane von Westerholt, Senior Planner - 519-741-2200 ext. 7157 Garett Stevenson, Planner— 519-741-2200 ext. 7070 10 May 14, 2019 DSD -19-121 Application A2019-050 149-151 Ontario Street North & 21 Weber Street West Owners — Kiah Group Inc., 1476795 Ontario Limited Applicant — Scott Patterson, Labreche Patterson and Associates Inc. Approve with Conditions Subject Properties On April 29, 2019, Kitchener City Council approved several sections of Stage 1 of the new zoning by-law, including new on-site parking regulations for properties within the Urban Growth Centre (UGC) zones. However, the UGC zones, Bonusing regulations in section 4.3, and the application of the zones to lands within the Downtown, were deferred. Staff Report Development Services Department K"'""' ' FR wwwki tchener. ca On May 13, 2019, the Planning and Strategic Initiatives Committee recommended approval of the UCG zones and Bonusing regulations, which will be considered at Kitchener City Council on May 27, 2019. Consideration of new UGC zoning for the subjects lands only was specifically deferred to a regularly scheduled Kitchener Council meeting on May 27, 2019 to allow time for the processing and consideration of this minor variance application, and to have the proposal be presented to Heritage Kitchener prior to new zoning being applied. A site plan application is anticipated in the coming days. Heritage Planning staff has received a draft Heritage Impact Assessment (HIA) dated February 2019 and revised March 18, 2019 prepared by Letourneau Heritage Consulting Inc., regarding a proposal to redevelop 149-151 Ontario Street North and 21 Weber Street West. The property municipally addressed 149-151 Ontario Street North contains a circa 1876 brick building originally constructed as semi-detached or "double house". The property is "listed" on the Municipal Heritage Register. 21 Weber Street West contains a commercial building built circa 1957. While 21 Weber Street West does not have heritage status, it is by definition located adjacent to the Civic Centre Neighbourhood Heritage Conservation District (across Weber Street West). ZIN, 11111411111 `��✓� 111111��111111111 Q 11111411113 lot' ����,�� 1111111y11�i�]7ltlit lob ���J �9f9� ,:1a�lti�lllilii i l � '����1111ii111i111Ul1y +i111111l111111111i1t t � � i1I11311,111111t Al I slog l so am Existing Buildings, 21 Weber Street and 149-151 Weber Street W I G - The development proposal, as currently conceived, retains the existing listed cultural heritage resource at 149-151 Ontario Street North and proposes demolition of 21 Weber Street West. A new 21 storey building would be built above, and around, the existing semi-detached dwelling. The developer has requested relief from Section 6 of Zoning By-law 85-1 to permit a mixed use building with no minimum parking requirement, which is consistent with the parking regulations (Section 5 of the new zoning by-law) approved for the UGC zones by Kitchener City Council. The Staff Report Development Services Department K"'""' NFR wwwki tchenr. ca minor variance is required in order to meet transition policies in the new zoning by-law, such that the development would only have to comply with the current zoning regulations (Zoning By-law 85-1). Planning Comments: The subject lands are designed as City Centre District within the Urban Growth Centre (Downtown) Intensification Area. The lands are currently zoned as Office District Zone (D-4) in the current zoning by-law, and proposed to be zoned as UGC -1 with Site Specific Provision (1) in the new Zoning By-law. A site inspection as conducted on May 13, 2019. In considering the four tests for minor variances as outlined in Section 45(1) of the Planning Act, R.S.O., 1990 Chap. P. 13, as amended, Planning staff offers the following comments. 1. General Intent of the Official Plan The Downtown will be planned to increase residential development, to conserve our cultural heritage resources and ensure new development and redevelopment is sensitive to, enhances and reflects our past, and o create and maintain a cycling and pedestrian -friendly and walkable Urban Growth Centre (Downtown). All development or redevelopment in the Downtown will have regard for the contribution to the public realm through the design of public, semi-public and private spaces and buildings. Pedestrian, cycling, and rapid and public transit modes of transportation will be given the priority over vehicular circulation and accommodation within the overall transportation system. The proposed building will not have any required on-site vehicle parking. Planning staff is recommending that the bicycle parking requirements from the new zoning by-law be required to be shown on the final site plan as a condition of approval for the minor variance application to support cycling as an active transportation option for the residents of the building. Active Transportation policies in the Official Plan allow the City to require new multi -unit residential to provide secure bicycle parking. The lands are designated as City Centre. The City Centre District is the heart of the Downtown and focuses around the original commercial area of King Street. This City Centre District is also characterized by several large office developments and by lot sizes and assemblies of lot sizes conducive to future large scale developments. One of the predominate uses in the district includes multiple residential and mixed use developments. Pedestrian -friendly developments are encouraged on the side streets and public lanes as well as King Street to maintain the district's pedestrian appeal and to maximize the points of attraction and to minimize walking distances. The podium of the proposed building will be positioned close to the Weber and Ontario streetlines, and with ground floor elevations are proposed to include large openings with vision glass allowing public view of the front and sides of the heritage resource. An evaluation of significant cultural heritage resources is undertaken in the UGC. Such evaluation includes the identification of specific heritage attributes which will be referenced and guide the review and approval of plans for heritage conservation, adaptive reuse, new development and infrastructure works. The developer completed an HIA which has concluded that the existing semi-detached dwelling at 149-151 should be retained and incorporated into a new development. Staff Deport Development Services Department 1 wR wwwki tchener. c a A high quality of urban design for buildings, building elevations, building massing, storefronts, store signs, patios, streetscapes and public spaces are required in order to enhance street life and create local pride and interest as well as tourism interest. Planning Staff has been advised that due to the position and size of the building proposed to be retained, underground parking is not easily achieved. At grade and above grade parking within the new portions of the proposed building could only be located along the Ontario and Weber streetlines, resulting in blank facade walls and non-active uses at grade. By eliminating the requirement for parking, large portions of the podium of the proposed building could feature vision glass to ensure that components of the heritage resource that is being retained can be viewed from the public realm. An additional stepback beyond the podium is proposed for the tower, setting the mass from Weber Street to transition from the lower rise buildings on the opposite side of the street. The proposed minor variance also conforms to Sustainable Development policies in the Official Plan which encourage redevelopment to strive to be increasingly sustainable by encouraging and supporting compact development and efficient built form and transit -supportive development and redevelopment and the greater use of other active modes of transportation such as cycling and walking. Based on the foregoing, Planning Staff is of the opinion that the requested minor variance meets the general intent of the Official Plan. 2. General Intent of the Zoning By-law The current Zoning By-law was first approved in 1985 and has been updated and amended over time. A new zoning by-law is required to implement the City's 2014 Official Plan. During this time of transition, there are some sections of the Zoning By-law that do not align with the direction of the 2014 Official Plan, including on-site parking regulations. As outlined in Staff Report DSD - 19 -049, which was presented to the Planning and Strategic Initiatives Committee on April 15, 2019 along with the first stage of the new zoning by-law, "the new approach to on-site parking regulations involves some big moves, such as minimum bike parking, no minimum automobile parking requirements in the Urban Growth Centre, lower minimum automobile parking requirements for most uses, updated shared parking, and EV -ready spaces... The approach to Parking regulations conforms to the Official Plan policies; including those for active transportation, transportation demand management, intensification, urban design, the environment, and others. This is consistent with the provincial and regional policies on transportation and intensification." As part of the review of the on-site parking regulations in the new Zoning By-law, comprehensive research was undertaken by the City as well as consultants retained by the City. The City retained Paradigm Transportation Solutions Limited to complete a report titled Comprehensive Review of Off -Street Parking & Loading Regulations. The recommendations of this report were utilized in developing some of the on-site parking rates. At the conclusion of that review, inconsideration of the planned function of the UGC, Planning staff, with the support of Transportation staff, recommended that there be no minimum parking requirements in the UGC for multiple dwelling, among some other non-residential uses. This approach would permit the market to determine the parking demand for a development. The current Zoning By-law also contemplates parking reductions in the Downtown. While the final size of the dwelling units is not yet determined for this project, should the development Staff Report Development Services Department K"'""' NFR wwwki tchenr. ca proceed with units that are less than 51 square metres in size, the total parking requirement for the new building would be 23. At the time of the submission of the minor variance application, 36 of the proposed 126 units were below 51 square metres in size, resulting in a parking requirement of 87 spaces. The current zoning by-law also provides on-site parking exemptions for existing floor area and existing lots. While the current zoning by-law does not contemplate full parking exemptions for new multiple residential dwellings, there are exemptions for certain uses, as well as exemptions for new uses within existing buildings (at the time of the by-law being approved) in the "D" zones. Based on the foregoing, Planning Staff is of the opinion that the requested minor variance meets the general intent of the Zoning By-law. 3. Is the Variance Minor? The requested parking reduction is minor. Recent and ongoing investments and improvements to active and public transportation modes in the Downtown provides greater support to alternative modes of transportation. Private carshare and ride hailing services are available in the Downtown, as well as other areas throughout the City. Additionally, should a resident or visitor to the proposed building require vehicle parking, there are publically and privately owned parking lots and garages that could fulfil the demand, in the same way that current residents and employees in the Downtown without a provided parking space have met their needs. 4. Is the Variance Appropriate? The requested variance is appropriate. By eliminating the requirement for on-site parking, a residential intensification can occur on an irregular shaped lot that features an existing cultural heritage feature that is being retained. Eliminating the need for an at or above grade parking structure in the podium will result in a building base that features active uses at grade with a high percentage of vision glass, allowing view of the sides of the heritage feature from the public realm. The minor variance is required to have full compliance with Zoning By-law 85-1 in order for the development to proceed independent of the application of the new UGC zones. Building Comments: The Building Division has no objections to the proposed variance provided a building permit for the 21 storey apartment building is obtained prior to construction. Please contact the Building Division @ 519-741-2433 with any questions. Transportation Comments: Transportation Services can support a `zero' parking rate for the proposed application based on the fact that both Planning and Transportation Services staff supported and recommended a `zero' parking rate (no minimum spaces) for multiple residential buildings within the Urban Growth Centre (Downtown) through the Comprehensive Review of the Zoning By-law. Heritage Comments: The property municipally addressed as 149-151 Ontario Street North is a listed property on the Municipal Heritage Register, and the property municipally addressed as 21 Weber Street North is adjacent to the Civic Centre Neighbourhood Heritage Conservation District. The larger development proposal on the subject properties contemplates the retention of the existing front portion of 149-151 Ontario Street North in situ. The proposed minor variance to request relief for 0 (zero) parking spaces would help facilitate the retention of the heritage building, and as such Heritage Planning staff has no concerns. Staff Deport Development Services Department Engineering Comments: Engineering staff has no objections to the proposed variance. Operations Comments: Operations staff has no objections to the proposed variance. Environmental Planning Comments: Environmental Planning staff has no objections to the proposed variance. RECOMMENDATION: 1 wR wwwki tchener. c a That Application A2019-050, requesting relief from Section 6 of Zoning By-law 85-1 to permit a mixed use building with no minimum parking requirement, be approved subject to the following conditions: That the Owner submit a complete site plan application under Zoning By-law 85-1 and comply with all transition policies of Section 18 of the new zoning by-law. 2. That the Owner receive full site plan approval by May 21, 2021, for a mixed use building, which includes the following bicycle parking configuration: A minimum one 1 Class A Bicycle Parking Stall for each dwelling unit. Each Class A Bicycle Parking Stall shall be a bicycle locker or an enclosed, secure area with controlled access in which a bicycle may be parked and secured for the long term in a stable position with at least one point of contact with the frame of the bicycle. ii. A minimum of 6 Class B Bicycle Parking Stalls. Class B Bicycle Parking Stalls shall be an area in which a bicycle may be parked and secured for the short term in a stable position with two points of contact with the frame of the bicycle. Garett Stevenson, B.E.S., MCIP, RPP Juliane von Westerholt, B.E.S., MCIP, RPP Planner Senior Planner Region of Waterloo May 03, 2019 Holly Dyson City of Kitchener 200 King Street West P.O. Box 1118 Kitchener, ON N2G 4G7 Dear Ms. Dyson: PLANNING, DEVELOPMENT AND LEGISLATIVE SERVICES 150 Frederick Street, Sth Floor Kitchener ON N2G 4A Canada Telephone: 519-575-4400 TTY: 519-575-4608 Fax: 519-575-4449 www. reg i o n ofwate r l o o. ca File No.: D20-20/VAR KIT GEN (2) 06 BENTON/Frederick Victoria Business Centre (15) 08 WEBER KIT, Kiah Group Inc. Re: Committee of Adjustment Meeting on May 21, 2019, City of Kitchener Regional staff have reviewed the following Committee of Adjustment applications and have following comments: 1. SG 2019-009 — 760 Commonwealth Crescent — No Concerns. 2. SG 2019-010 — 907 Frederick Street — There are no concerns to the sign variance for the sign mounted on the building, mentioned in the application. However, it is noted that there is another ground mounted business sign which is encroaching into Victoria Street right-of-way. The owner should confirm if there is an existing encroachment agreement in place. If not, the same would be required with the Region. 3. SG 2019-011 — 524 Belmont Avenue West— No Concerns. 4. A 2019-039 — 121 Arrowhead Crescent — No Concerns. 5. A 2019-040 — 18 Rosedale Avenue — No Concerns. 6. A 2019-041 — 555 King Street East — No Concerns. 7. A 2019-042 — 244-260 Shoemaker Street—No Concerns. 8. A 2019-043 — 170 Rivertrail Avenue — No Concerns. 9. A 2019-044 — 109 North Hill Place — No Concerns. 10.A 2019-045 — 52 South Drive — No Concerns. 11.A 2019-046 — 18 Guelph Street — No Concerns. 12.A 2019-047 — 945 Robert Ferrie Drive — No Concerns. 13.A 2019-048 — 28 Stirling Avenue South— No Concerns. 14.A 2019-049 — 101-115 Margaret Avenue — No Concerns. 15.A 2019-050 — 149-151 Ontario Street North / 21 Weber Street West: There are no concerns to the minor variance application. However, the owner is advised Document Number: 2997610 Page 1 of 2 that any development application on the above development would require dedicated road widening of approximately 3.0 metre along the entire property frontage along Weber Street (RR #08). 16.A 2019-051 — 25 Vanier Drive — No Concerns. Please be advised that any development on the subject lands is subject to the provisions of the Regional Development Charge By-law 14-046 or any successor thereof and may require payment of Regional Development Charges for these developments prior to the issuance of a building permit. The comments contained in this letter pertain to the Application numbers listed. If a site is subject to more than one application, additional comments may apply. Please forward any decisions on the above mentioned Application numbers to the undersigned. Yours Truly, Joginder Bhatia Transportation Planner (519) 575-4500 Ext 3867 Grand River Conservation Authority Resource Management Division Andrew Herreman, Resource Planning Technician 400 Clyde Road, P.O. Box 729 Cambridge, Ontario N 1 R 5W6 Phone: (519) 621-2761 ext. 2228 E-mail: aherreman(u-)grandriver.ca PLAN REVIEW REPORT: City of Kitchener Holly Dyson DATE: May 13, 2019 YOUR FILE: See below RE: Applications for Minor Variance: SG 2019-009 760 Commonwealth Crescent SG 2019-010 907 Frederick Street, Units 3-5 SG 2019-011 524 Belmont Avenue West A 2019-038 128 Mill Street A 2019-039 121 Arrowhead Crescent A 2019-040 18 Rosedale Avenue A 2019-041 555 King Street East A 2019-042 244 and 260 Shoemaker Street A 2019-043 170 Rivertrail Place A 2019-044 107-109 North Hill Place A 2019-045 52 South Drive A 2019-046 18 Guelph Street A 2019-047 945 Robert Ferrie Drive A 2019-048 28 Stirling Avenue South A 2019-049 101-115 Margaret Avenue A 2019-050 149-151 Ontario Street North/21 Weber Street West A 2019-051 25 Vanier Drive Applications for Consent: B 2019-014 128 Mill Street B 2019-015 23-25 Wendy Crescent B 2019-016 52 Wilhelm Street B 2019-017 177 Fifth Avenue B 2019-018 69 Amherst Drive/118 Doon Valley Drive B 2019-020 28 Burgetz Avenue B 2019-021 20-24 Breithaupt Street B 2019-022 20-24 Breithaupt Street B 2019-023 26, 43, 47, 53, 55 Wellington Avenue North, 2, 12 Moore Avenue, 20-24 Breithaupt Street GRCA COMMENT*: The above noted applications are located outside the Grand River Conservation Authority areas of interest. As such, we will not undertake a review of the applications and plan review fees will not be required. If you have any questions, or require additional information, please contact me. 'These comments are respectfully submitted as advice and reflect resource concerns within the scope and mandate of the Page 1 of 2 Grand River Conservation Authority Sincerely, Andrew Herreman, CPT Resource Planning Technician Grand River Conservation Authority 'These comments are respectfully submitted as advice and reflect resource concerns within the scope and mandate of the Page 2 of 2 Grand River Conservation Authority. Shuh Cline & Grossman LLP Barristers and Solicitors Frederick J. Shuh, B.A., LL.B. - 17 Weber Street West Also of New York State Bar Kitchener, Ontario N2H 3Y9 William C. Cline, LL.B- Telephone (519) 578-9010 Mark S. Grossman, B.A., LL.B. Facsimile (519) 578-1590 Gretchen T. Reitzel, B.A. (Hoes.) J.D. Samantha S. Ahn, B.A., M.A., J.D. Please Refer To: Samantha S. Ahn 519-578-9010 east. 240 sahn@shuhlaw.com May 17, 2019 DELIVERED BY EMAIL to Dianna. Saunderson@Kitchener.ca AND BY HAND Committee of Adjustment Office of the City Clerk Kitchener City Hall 200 King Street West 2nd Floor Kitchener, ON N2G 4G7 Dear Sir or Madam: Re: Committee of Adjustment — Hearing May 21, 2019 Objection to Application # A 2019-0 5 0 149-151 Ontario Street North / 21 Weber Street West I am the solicitor for the owners of the property located at 17 Weber Street West, Kitchener which is immediately adjacent to all the applicant's property in the Application. My clients have used their property 17 Weber Street West as law office for 30 years staring in 1989. My clients have a number of concerns regarding this Application to permit a very large scale, high density 21 Storey residential development with zero (0) parking on the immediate adjacent land located at 149-151 Ontario Street North and 21 Weber Street West. Our clients only received notice of this Application on May 6, 2019. My clients were not consulted about this Applicant or the applicant's development. They received some information in a newspaper article published this month. This application should be deferred until my clients have obtained professional planning advice. Our clients will then be able to meet with the applicant and City staff regarding this Application. Shuh Cline & Grossman LLP Barristers and Solicitors We submit that this Application does not meet the legal tests for approval by the Committee of Adjustment under Section 45 of the Planning Act. 1 _ This Application is not minor in nature. The Application seeks the total elimination of the requirement for 87 off-street parking spaces and reduced to zero (0) parking spaces for a 21 -storey residential development. There has been no appropriate consideration of the significant and negative impacts this complete elimination of parking requirements on existing properties adjoining to this development. There will be very significant problems with illegal parking on my clients' property and traffic congestion if this Application is granted. There will also be significant problems with access to my clients' property due to congestion and illegal parking. My clients have many elderly and limited mobility persons needing to attend their law office. 2. This Application does not support an appropriate development of the land. This is a very large scale, high density 21 storey residential development with zero (0) parking. The size of this developer's lot is small. We understand the developer's proposal does not comply with the current D-4 Zone and further, would not fully comply with the new proposed CRoZBy Zoning By-law. 3. We submit the Application does not maintain the intent and purpose of the official plan in a proper or reasonable fashion; 4. We submit the Application does not maintain the intent and purpose of the zoning by- law. The zoning by-law clearly created the requirement for large scale residential developments to have significant off-street parking. We understand that there are also requirements under the proposed new by-law that this development may not comply with. 5. This development has proceeded without any notice or consultation with my clients as the adjoining landowners. 6, The proposed 21 storey tower will block daylight and result in very significant shadowing of my clients' building. This is of great concern arising from the plan for the proposed 21 storey tower. 7, The developer's daylighting opinion mistakenly understates the impact and, in fact, does not refer to my clients' property. 8. There is no restriction on windows facing our clients' property. There should be no windows facing my client's property, similar to the building at 32 Duke Street West facing to the rear of my clients' property. The negative impact on the privacy and the business of my clients would be significant if windows from the 21 -storey tower face my clients' property. My clients are retaining professional Planners to obtain proper planning advice regarding the development at 149-151 Ontario Street North and 21 Weber Street West with zero (0) parking. Shuh Cline & Grossman LLP Barristers and Solicitors We ask that the Application be denied or, alternatively, be deferred until we have been able to obtain proper planning advice and my client's planners have been able to consult with City staff and the applicant. Yours very truly, Shuh Cline & Grossman LLP U Samantha S. Ahn SSA/ Dianna Saunderson From: Sent: "atay,ay P, P P: P To: Dianna Saunderson Subject: FW; Comment for Committee of Adjustment regarding A 2019-050: 149-151 Ontario St N / 21 Weber St W Greetings, Dianna, Holly has directed me to you. Can you please confirm receipt and forward this message to the Committee of Adjustment adjudicators? Thank you, From: Sent: May 18, 2019 3:06 PM To: holly.dyson@kitchener.ca Cc: Subject: Comment for Committee of Adjustment regarding A 2019-050: 149-151Ontario St N / 21 Weber St W Greetings, Holly. Can you please confirm receipt and forward this message to the Committee of Adjustment adjudicators? Thank you, Greetings, Adjudicators, In the case of 149-151 Ontario St N/21 Weber St W, I believe it necessary to either conform to a single zoning bylaw or conform to both the new and old simultaneously, in their respective entireties. I believe that straddling the benefits of two bylaws and ignoring even some of the associated requirements is not a legitimate option. Because a bylaw aims to protect all affected parties, picking and choosing among bylaw provisions can strip neighbours of the protections they are due. Thus, the least restrictive test for the minor variance application is to determine if the application can be considered minor under the complete set of requirements of at least one of Bylaw 85-1 or CRoZBy. Under 85-1, the proposed build, in its draft form, would require 87 spaces. The proposed variance is a reduction of 87 parking spaces or 100% of the requirement. This cannot be considered minor. Under CRoZBy, the parking requirement would not be at issue. But a variance for additional height would be required. The height limit, under CRoZBy, is 12 storeys or 125 feet. The proposed build is 21 storeys and over 226 feet. That constitutes a 75% increase in storeys and an 81% increase in height. This, too, cannot be considered minor. Therefore, under either bylaw, the proposed variance cannot be deemed minor. I appreciate that the proposal and staff report are forward thinking, anticipating and encouraging a shift toward active transportation. Nonetheless, we must operate under rule of law. Please rule that the decision isnot minor and cannot be approved by the Committee of Adjustment. Virus -free. www.avq.com 2