HomeMy WebLinkAboutDSD-2024-066 - Enabling Four Units - OPA23/020/K/KA, ZBA23/035/K/KAXTc NEE
Staff Report
Development Services Department www.kitchener.ca
REPORT TO:
Planning and Strategic Initiatives Committee
DATE OF MEETING:
March 25, 2024
SUBMITTED BY:
Rosa Bustamante, Director of Planning and Housing Policy/City
Planner, 519-741-2200 ext. 7319
PREPARED BY:
Katie Anderl, Project Manager (Planning), 519-741-2200 ext. 7987
Gaurang Khandelwal, Planner (Policy), 519-741-2200 ext. 7611
Arwa Alzoor, Planner (Development), 519-741-2200 ext.7847
WARD(S) INVOLVED:
All
DATE OF REPORT:
March 12, 2024
REPORT NO.:
DSD -2024-066
SUBJECT:
Enabling Four Units OPA23/020/K/KA & ZBA23/035/K/KA
RECOMMENDATION:
That City -Initiated Official Plan Amendment OPA23/020/K/KA, for the purpose of
permitting up to 4 dwelling units on lots which permit a single detached dwelling,
semi-detached dwelling or street -townhouse dwelling, be adopted, in the form
shown in the Official Plan Amendment attached to Report DSD -2024-066 as
Attachment `A', and accordingly forwarded to the Region of Waterloo for approval;
and,
That City Initiated Zoning By-law Amendment Application ZBA23/035/K/KA to amend
Zoning By-law 85-1, be approved in the form shown in the "Proposed By-law"
attached to Report DSD -2024-066 as Attachment `B1'; and further,
That City Initiated Zoning By-law Amendment Application ZBA23/035/K/KA to amend
Zoning By-law 2019-051, be approved in the form shown in the "Proposed By-law"
attached to Report DSD -2024-066 as Attachment `132'.
REPORT HIGHLIGHTS:
The purpose of this report is to recommend changes to the City's Official Plan, Zoning
By-law 85-1 and Zoning By-law 2019-051 to enable up to four residential units on a lot
which currently permits a single detached dwelling, semi-detached dwelling or street -
townhouse dwelling.
On October 16, 2023, City Council directed staff to propose a zoning by-law
amendment to permit `as -of -right' permissions for up to four (4) residential units on a
property where zoning permits single detached, semi-detached or street townhouse
dwelling units on sufficient lot sizes by the end of March 2024.
*** This information is available in accessible formats upon request. ***
Please call 519-741-2345 or TTY 1-866-969-9994 for assistance.
Page 8 of 343
• The recommended amendments enable up to 4 additional units on approximately
41,450 lots as -of -right, representing 68% of all residential lots in Kitchener through
more permissive zoning rules.
• This report also includes an overview of next steps to support uptake and
implementation.
• Community engagement included a variety of in-person and virtual opportunities
including an online engagement page on Engage Kitchener, a virtual community
meeting, public open houses in three different locations, consultation with the
development industry through Kitchener Development Liaison Committee, and a
development industry workshop totaling nearly 2,000 individual interactions.
• This report supports the delivery of core services.
EXECUTIVE SUMMARY:
This report recommends Official Plan and Zoning By-law Amendments that will enable up
to four dwelling units on residential lots which currently permit single detached dwellings,
semi-detached dwellings and street -townhouse dwellings. Four units could include four
units in a principal dwelling, three units in a principal dwelling and one unit in an additional
dwelling (detached) or two units in a principal dwelling and two units in an additional
dwelling (detached) as depicted on Figure 1.
4 UNITS IN PRINCIPAL
3 UNITS IN PRINCIPAL
AND 1 UNIT IN DETACHED
Figure 1. Options of Four Dwelling Units on a Lot
2 UNITS IN PRINCIPAL
AND 2 UNITS IN DETACHED
The Enabling Four Units project helps to implement Kitchener's Municipal Housing Pledge
through gentle intensification of the `missing little' which is a subset of missing middle
housing including detached additional dwelling units and small multi-plexes which can be
integrated in existing and new neighbourhood contexts.
The proposed zoning regulations enable more units on more lots by:
• T increasing the number of units allowed on a lot from three (3) to four (4), and
• decreasing lot size and parking requirements from current regulations for 3 units,
with variation based on geography.
The Official Plan and Zoning By-law Amendments recommended in this report represent a
bold yet balanced approach which works with existing zoning regulations, lotting and built
form of neighbourhoods, while allowing for increases in density in areas with existing
infrastructure, services and community facilities.
Page 9 of 343
BACKGROUND:
The City's Strategic Plan, Official Plan, and Housing for All Strategy recognize the
importance of using a broad range of tools to advance critical housing objectives. The
Enabling Four Units project is a key action of the City's Housing Accelerator Fund
application and enabling additional units in existing low-density neighbourhoods will assist
the City in fast -tracking 1,200 additional housing units over the next three years. On
October 16, 2023, City Council directed staff to propose a zoning by-law amendment to
permit `as -of -right' permissions for up to four (4) residential units on a property where
zoning permits single detached, semi-detached or street townhouse dwelling units on
sufficient lot sizes.
This initiative is one of many considered, directed, and supported by Council since their
endorsement of Kitchener's Housing Pledge in March 2023. Kitchener's Municipal Housing
Pledge includes 11 strategies and actions to support the building of 35,000 more homes
by 2031. The Enabling Four Units project advances work on the following Municipal
Housing Pledge commitments:
• Item 1 - Updates to Kitchener's Official Plan and Zoning By-law to further enable an
increased supply of missing middle housing;
• Item 5 - Continued advancement of work on updates to land use and zoning within
Major Transit Station Areas;
• Item 7 - Continued work to implement the recommendations and action items from
Kitchener's Housing for All Strategy, specifically including those that enable an
increased housing supply or streamlining development approvals; and,
• Item 8 - Continued collaboration with the Waterloo Region Home Builders
Association and Kitchener Development Liaison Committee, and others, to identify
labour shortages and costs, material costs, infrastructure timing, economic market
conditions, and land supply and housing capacity.
The proposed amendments also align and act on direction from Regional Official Plan
Amendment number 6 (ROPA 6). This amendment was approved by Regional Council in
August 2022 and by the Province on April 11, 2023. ROPA 6 includes polices that seek to
increase housing choice, support the construction of a range and mix of housing, and
support intensification within the Urban Area through gentle density and missing middle
housing options. It defines missing middle housing as "multiple unit housing including, but
not limited to multiplexes, stacked townhouses, apartments, and other low-rise housing
options."
The Enabling Four Units project implements recommendations of the Enabling Missing
Middle and Affordable Housing Feasibility Study (MM+AH Study) completed in April 2023.
This study looked at ways to improve housing affordability, provide more diversity in the
housing types being built, and increase overall housing supply. The Enabling Four Units
recommendations align with key recommendations of the study by reducing parking
requirements, increasing density allowances and continued process improvements
through the development approval process.
Finally, this project builds on zoning bylaw amendments associated with Bill 23, More
Homes Built Faster Act changes to the Planning Act which required municipalities to
permit three (3) units as -of -right on lots with single detached dwellings, semi-detached
Page 10 of 343
dwellings and street fronting townhouse dwelling units. In June 2023, City Council
approved zoning amendments that allowed three (3) units as -of -right on over 28,500 lots.
This project expands upon these permissions as detailed in the following report.
REPORT:
Kitchener has a long-standing history of managing growth through the Growth
Management Strategy and Growth Management Plan, enabling housing supply through
the Official Plan (i.e., directing growth to intensification areas like the Urban Growth Center
and nodes as well as allowing a range of housing types in low-rise residential areas
throughout Kitchener) coupled with forward -thinking zoning. For example, since the mid-
1990s Kitchener has enabled 2 dwelling units (i.e., duplexes) on most residentially zoned
properties, and 3 dwelling units (triplexes) and backyard homes have been permitted on
many lots since 2021. This report makes recommendations to enable up to four dwelling
units on lots which currently permit single detached dwellings, semi-detached dwellings
and street townhouse dwellings, to allow more housing in new and existing residential
areas.
This report is structured to include the following sections:
• Why Four Units? - provides a brief overview of the focus of this project
• Financial Feasibility - summarizes MM+AH Study four -unit related findings
• Impact of Current & Proposed Zoning Rules — explores statistics about what is
currently permitted and potential impact of what is proposed
• Four Units in Other Cities - summarizes the approach of other municipalities
• Proposed Official Plan Amendment - provides an overview of the amendments
proposed to Kitchener's Official Plan
• Proposed Zoning By-law Amendments - details proposed zoning amendments
• Planning Analysis — analyses the proposed amendments with the current planning
framework
• What We Heard - summarizes feedback from community, industry, staff and
agencies, and our approach to addressing concerns
• Next Steps — describes subsequent work to support implementation
Why Four Units?
Kitchener is growing rapidly. To meet growing housing needs, growth is required in all
segments of the housing spectrum, from single detached dwellings to high-rise multiple
dwellings. This report considers enabling additional housing for the "missing little". The
MM+AH Study identified the "missing little" as an important housing typology, within the
housing continuum. As part of the Official Plan's urban structure, the majority of lots in
Kitchener are in Community Areas which are primarily low density and low rise, providing
a significant opportunity to add more dwelling units. The "missing little" includes small-
scale, infill housing that can be effectively integrated into neighbourhood contexts by
allowing more units to the primary dwelling often referred to as triplexes or fourplexes or in
additional dwelling units (ADUs) such as backyard homes (see Figure 2).
Page 11 of 343
s
c�
C2
ca
"MISSING MIDDILP
n2
Rmrtihwses
A
Tryaleues
=d'i1a�ri tiPanrmnts
-d.851nropbpartmanM
Ganga Camvrpons
Gorden Suiln
8ec.?w®eck Tv.ms
E
Singles+
ADUs*
Towns
Towns
Plexes*
Low -Rise
Mid -Rise.
High -Rise
SngieUMachad
>9S�.a. fapanncs6
Semi Cl—hed
•'M15f�N4 i+TTif"
•1NiSSM/{I Fn1iF'
LOW DENSITY
HIGH DENSITY
s
c�
C2
ca
��
n2
Rmrtihwses
iTackmj Tans
Tryaleues
=d'i1a�ri tiPanrmnts
-d.851nropbpartmanM
Ganga Camvrpons
Gorden Suiln
8ec.?w®eck Tv.ms
5lucked Becbm6eck Tow..
Fpu�p+enm
Lancxay l±assir;
In9Y Tarns
char hluHl-Pla.osisd una
ec-. r ss. s... u......
•'M15f�N4 i+TTif"
•1NiSSM/{I Fn1iF'
Figure 2. `Missing Middle' and `Missing Little' Housing Types
Other small multiples including multiplexes with more than 4 units and various forms of
cluster townhouses are also important housing types within the community and are outside
the "missing little" building typology. Detailed consideration and zoning for larger missing
middle dwelling types was outside the scope of this project and will be evaluated prior to
establishing new enabling policies and associated zoning regulations. Concurrent and
future work which considers medium density and mid -rise housing forms include the
Official Plan Review and Growing Together.
The proposed regulations consider the typical low-rise residential lot sizes and
configurations, and the typical existing built form which exists on a majority of standard lots
in Kitchener. There will be unique situations which require site specific consideration
through planning processes, including minor variances. Where variances are proposed,
staff consider site and development characteristics to make recommendations to the
Committee of Adjustment. Staff will also monitor common variances to determine whether
variances which are frequently requested and typically supported can be recommended
for general change through annual Zoning By-law updates.
Financial Feasibility
A key element of the MM+AH Study was to help describe the reasons for recent
development patterns. Professional land economists on the consultant team tested the
financial viability of the full range of housing types from single detached to high rise, the
implications of ownership versus rental, and suburban versus central locations. The study
noted barriers for building missing middle and affordable housing, which are less
financially feasible than other housing types, including:
many missing middle forms are challenged by their poor financial attractiveness
compared to other housing types and other lower -risk investment opportunities (i.e.,
10 -year government bonds);
the analysis showed that while there were 5 profitable rental types (i.e., suburban
towns, 8-plex, low-rise in both central and suburban neighbourhoods, and ADUs),
all but the ADUs generated too small a profit to be viable; and,
parking costs are extremely impactful on development viability.
Key recommendations of the study addressed through this report include reducing parking
requirements, increasing density allowances, and continuing process improvements
through the development approval process.
Page 12 of 343
Impact of current and proposed zoning rules
Kitchener has approximately 62,000 lots with 110,000 dwelling units in total. About 96% of
the lots have a single detached, semi-detached, or street townhouse dwelling as the
principal dwelling type and about 90% of the lots have only one (1) dwelling unit.
Considering existing zoning regulations (minimum lot size and lot width only),
approximately 28,575 lots (46% of the lots in Kitchener) are currently eligible for a total of
3 units on a lot.
Figure 3 illustrates the total number of lots of each dwelling type. Single detached
dwellings represent about 80% of the residential lots in Kitchener and represent the
greatest opportunity for additional dwelling units. Street townhouses and semi-detached
dwellings together consist of about 16% of lots. Further analysis by dwelling type and lot
area and width is provided in Attachment F.
Street townhouses,
4.407.7%
Semis, 5,381, 9%
Other dwelling types,
2,313,4%
Singles, 50,091, 80%
Figure 3. Total number of lots in Kitchener by type of dwelling
Table 1 provides the number of building permits issued for additional dwelling units in the
last five years from 2019 to 2023 in Kitchener. The uptake of additional dwelling units in
Kitchener has been incremental, with triplexes and detached ADUs having relatively low
but growing numbers.
Table 1. Building permits issued for Additional Dwelling Units in Kitchener, 2019-2023
Year
Duplex
Triplex
ADU (Detached)
2019
212
6
-
2020
286
13
-
2021
383
10
5
2022
547
10
15
2023
688
29
27
Total
2116
68
47
Page 13 of 343
With the proposed zoning changes, it is estimated that approximately 41,450 lots in
Kitchener will become eligible (accounting for minimum lot size and lot width only) for up to
4 units as -of -right, representing 68% of all residential lots in Kitchener. An overall
comparison of the increase in number of units which will be eligible is provided in Table 2.
Nearly 80% of lots containing single detached dwellings will be eligible (approximately
11,937 more lots than today), and approximately 658 additional lots containing a semi-
detached dwelling and 281 lots containing street -townhouses will be eligible. It should be
noted that lots estimated to be eligible for up to 4 units may be subject to other
development constraints (as discussed later in this report) that may impact the uptake of
additional units. It is anticipated that the uptake will continue to be gradual, however, the
City will make efforts to reduce barriers through the subsequent implementation strategy to
support an increase in uptake.
Table 2. Comparison of Lots with Additional Units Enabled
Four Units in Other Cities
Many municipalities in Canada and internationally are facing housing shortages and have
taken the initiative to enable multiplex housing in low rise residential areas. Toronto,
Mississauga, and London have already implemented zoning changes to permit up to 4
units on a lot. Some other municipalities in Ontario such as Waterloo, Guelph and
Burlington are working towards enabling 4 units on a lot. A detailed comparative analysis
of the regulations in place in Toronto, Mississauga, London, Vancouver, Edmonton, and
Portland is included in Attachment E and a summary of the approach to key regulations is
provided in Table 3.
Table 3. A summary of 4 -unit permissions approved by other municipalities
Zoning rules
Lots with Single
Lots with Semi-
Lots with Street
Lot
units on a lot. Most permit up to 4 units in the principal
Detached
Detached
Townhouse
Total
Dwellings
Dwellings
Dwellings
Number of lots with up to
3 units permitted based
28,237 (56%)
207(4%)
131 (3%)
28,575 (48%)
on current regulations
Number of lots with up to
4 units permitted based
40,174 (80%)
865(16%)
412(9%)
41,451 (69%)
on proposed regulations
Additional lots that
11,937
658
281
12,876
permit up to 4 units
Four Units in Other Cities
Many municipalities in Canada and internationally are facing housing shortages and have
taken the initiative to enable multiplex housing in low rise residential areas. Toronto,
Mississauga, and London have already implemented zoning changes to permit up to 4
units on a lot. Some other municipalities in Ontario such as Waterloo, Guelph and
Burlington are working towards enabling 4 units on a lot. A detailed comparative analysis
of the regulations in place in Toronto, Mississauga, London, Vancouver, Edmonton, and
Portland is included in Attachment E and a summary of the approach to key regulations is
provided in Table 3.
Table 3. A summary of 4 -unit permissions approved by other municipalities
Zoning rules
Other municipalities' approach
4 Unit Configuration on a
Other cities have enabled different configurations of 4
Lot
units on a lot. Most permit up to 4 units in the principal
building. Other options include 3 units in the principal
building and one in the detached building, or 2 units in
both the principal building and the detached building.
Page 14 of 343
Minimum Lot Width
Minimum lot width is largely based on the underlying zone
and principal dwelling type. Although minimum lot width
requirements vary, it is generally in the 10 -metre range.
Minimum Lot Area
Some cities require a minimum lot area to achieve a
functional site of around 300 square meters. Some other
municipalities do not specify a minimum lot area but rely
on the underlying zone minimum.
4 Units in Principal Building
With the intention to maintain the neighborhood character,
most municipalities have enabled 4 units in the principal
dwelling with the addition or conversion regulated through
built form standards (coverage, height, setbacks). Most
municipalities exempt 4 -unit buildings from a floor space
ratio (FSR) regulation. Some also provide bonusing in
terms of additional coverage or FSR to accommodate
additional units.
4 Units on Lots with an
Approach varies among cities. Key observations:
Additional Detached
_ size of the detached building is restricted to be
Dwelling
subordinate to the principal building and mostly
regulated through lot coverage, proportion of the
principal building, up to a maximum specified size, or a
proportion of the rear yard area
- building height is restricted in relation to the principal
building, and in most cases limited to around 6 to 6.8
m, allowing a 2 -storey building
- for a one -storey building, setbacks from side and rear
lot lines are mostly 0.6 m with no openings allowed on
the fagade towards the lot line
- for a 2 -storey building, setbacks from side and rear lot
lines vary from 0.9 m to 1.5 m
- some have implemented a minimum separation
between the principal and the additional detached
dwelling which varies from 3 m to 6.1 m
Parking
Most municipalities have moved away from parking
minimums, particularly for additional units. Parking
regulations still apply where parking is provided.
Kitchener's approach to enabling 4 units and the proposed regulations considers other
municipalities' approach in relation to aspects such as configuration of 4 units, minimum
lot width and lot size for 4 units on a lot, and parking reductions. However, the proposed
regulations through this work are a `made in Kitchener, made for Kitchener' solution that is
both forward thinking and considerate of Kitchener's existing lot fabric and the zoning
permissions already in place. The proposed changes are responsible and will provide for
an increased housing supply while respecting neighbourhood characteristics that are
important to residents.
Page 15 of 343
Proposed Official Plan Amendments
In June 2023, the City amended the Official Plan to incorporate changes resulting from Bill
23, More Homes Built Faster Act. This Bill was enacted in response to the housing supply
crisis and the province's ambitious target to build 1.5 million homes within the next 10
years, and made changes to the Planning Act that, among other matters, broadened as -of -
right permissions for up to three units on a property for single detached dwellings, semi-
detached dwellings and street -fronting townhouses. These changes were incorporated
into the Official Plan through Official Plan Amendment #29 and included new housing
policy 4.C.1.23 which enabled up to two additional dwelling units (attached) or one
additional dwelling unit (attached) and one additional dwelling unit (detached) in
association with a single detached dwelling, semi-detached dwelling, or street -townhouse
dwelling.
The proposed Amendment to the 2014 Official Plan deletes policy 4.C.1.23 which currently
permits up to 3 units on a lot and specifies how the units may be arranged within buildings
(refer to Attachment A to this report). In replacement, the proposed policy will permit up to
4 units on a lot and continues to enable these units to be further regulated by the zoning
by-law which will specify lot sizes, setback requirements, parking, and other matters.
As articulated in the Planning Discussion that follows, staff is of the opinion that that
proposed Official Plan Amendment is consistent with and conforms to the Planning Act,
Provincial Policy Statement (2020), the Places to Grow Act (2005) and A Place to Grow:
Growth Plan for the Greater Golden Horseshoe (2020) and the Regional Official Plan
(2010, including ROPA #6), and represents good planning.
Proposed Zoning By-law Amendments
The proposed Zoning By-law Amendments make changes in four key regulation topics
that will enable up to four units `as -of -right' on significantly more lots than are currently
eligible. Changes are proposed for both By-law 85-1 and By-law 2019-051 and result in
consistent requirements between the by-laws. These four key regulation topics include:
• Parking
• Lot width and area
• Regulations for additional dwelling units (detached)
• Built form and site layout
Parking:
Parking was identified through the MM+AH study and through consultation with builders to
be one of the major drivers in cost and a barrier to providing additional dwelling units, both
in terms of land requirements and construction costs. Planning and Transportation
Services staff recommend that parking requirements be reduced for additional dwelling
units (attached and detached) dependant on geography. Table 4 summarizes the total
number of required parking spaces for four units.
Page 16 of 343
Table 4. Summary of proposed parking requirements for four units on a lot
Location
First unit
Additional
units
Total
Within 800 m of an ION station
0 to 1, depending
on the zone
0
0 to 1 space
Central neighbourhood area
1
1
2
All other areas
1
2
3
In addition to parking reductions, the proposed approach to parking includes the following
as further detailed in this section:
• Parking will continue to be permitted in tandem with maximum driveway widths in
the front yard to remain unchanged. To add more flexibility to parking
arrangements, the required setback to the first parking space is proposed to be
reduced to allow side-by-side required parking in the driveway.
• With no maximum parking limitation, rear yard parking may continue to be designed
in a parking lot format with 4 or more vehicles per existing rules for parking layout.
To support three parking spaces in the back, a less restrictive requirement is
introduced that balances a maximum width with landscaped amenity area.
• A new bicycle parking format is proposed for 3 and 4 units that supports active
transportation while providing flexibility for storage options.
Reduced parking requirements — The approach to parking rates recognizes that residents
living within 800 metres of a Major Transit Station and within the Central Neighbourhood
Area may not require dedicated parking spaces for all additional dwelling units because
the area is well served by light rail, frequent bus transit, and cycling infrastructure, and is
also very walkable. On the other hand, suburban areas of the city are more highly
dependent on private vehicle ownership as transit is less accessible, and distances to
destinations results in walking and cycling being less viable options. It is noted that as
densities in neighbourhoods increase, demand for transit will grow transit services and the
completion or upgrade of streets and active transportation networks will support active
transportation options.
Staff recommend that:
• no parking be required for an additional dwelling unit on any lands within 800
metres of a Light Rail Transit Station. The affected area is shown in Appendix E to
By-law 2019-051 and illustrated in Figure 4. The proposed parking rate will result in
0 or 1 spaces for the lot (0 spaces for any additional unit, plus 0 or 1 spaces for the
principal dwelling depending on the zoning category).
Page 17 of 343
®rs� �n1�RTl smao�n
� �n� ninwlf�Tl
Figure 4 - Properties within 800 metres of a Light Rail Transit (LRT) Station
• a rate of 0.3 parking spaces for an additional dwelling unit in the Central
Neighbourhood Area as defined in Appendix C to By-law 2019-051 and illustrated
in Figure 5. The proposed parking rate will result in 2 spaces for the lot (1 parking
space for any number of additional units plus 1 space for the principal dwelling).
Figure 5. Central Neighbourhood Area
• A parking rate of 0.6 spaces per additional dwelling unit in all other areas of the
city. The proposed parking rate will result in a maximum of 3 spaces being required
for the lot (up to 2 parking spaces for additional dwelling units, plus 1 space for the
principal dwelling).
Page 18 of 343
Note that parking calculations always round up to the nearest whole number (0.3 rounds
up to 1, 1.2 rounds up to 2). Further, in all cases, a property owner may provide additional
parking in accordance with the zoning by-law regulations for driveways and parking lots.
Where parking is provided staff have also considered alternatives to traditional parking in
driveways and private garages which make more efficient use of space including rear yard
parking areas, reductions in setbacks to parking and mechanical parking systems.
Driveway widening — Staff recommend that the current permissions for driveway widths
remain unchanged. Driveway widths are generally limited to about 50% of the lot width in
suburban areas, and 40% of lot width in the Central Neighbourhood Area. These
regulations were studied and implemented through the recent Comprehensive Review of
the Zoning By-law, to achieve a balance between parking demands, an attractive
streetscape and community characteristics. Limiting driveway widths helps to ensure that
a proportion of the front yard can be dedicated to green space, which is important to
facilitate infiltration of stormwater, as well as providing space for trees and landscaping
which contribute to an attractive streetscape. Wider driveways also reduce the space for
street trees, on -street parking, boulevard snow storage, and infrastructure such as hydro
transformers and hydrants. Through community consultation, staff heard that protection of
the urban forest and community characteristics, as well as availability of on -street parking
are priorities for residents.
Reductions to street line parking setback— Staff recommend reducing the minimum
setback from the street line to the first required parking space from 6.0 metres to 0.5
metres (the 6.0 metres setback to a garage will remain). Today, required parking spaces
are generally required to be setback 6.0 metres, except where parking is permitted in
tandem. This means that while a tandem parking arrangement may be closer to the street,
a non -tandem required parking space must be set back 6 metres. This requirement is
frequently the subject of minor variances. The proposed change would apply to parking
on all driveways, irrespective of the number of units, and will support a more efficient use
of lands by allowing vehicles to be parked generally side-by-side in the driveway, often in
front of the garage. Further, staff recommend amending regulations for driveway visibility
triangles, so that vehicles parked on driveways are not considered an obstruction to
visibility. Transportation Services staff are supportive of this change and recognize that
vehicles regularly park in driveways close to the street, which may encroach into the
visibility triangle of a neighbouring property.
Rear Yard Parking — Where 3 or 4 units are provided on a lot, staff propose that parking
regulations permit parking in rear yards. This can be desirable as it minimizes the need
for driveway widenings and reduces vehicle clutter in front yards. The recommended
zoning regulations would permit a driveway to be a maximum width of 8.0 metres in a rear
yard, which could accommodate 3 parking spaces. Four or more parking spaces in a rear
yard is defined as a parking lot, and the existing rules for small parking lots would apply
including visual barriers, a minimum aisle width and minimum setbacks. The
recommended additional permission for rear yard parking is balanced with proposed
zoning rules requiring a minimum rear yard landscaped area of 30%, to provide for private
amenity space, snow storage, and landscaping.
Page 19 of 343
Mechanical Parking Systems — Mechanical parking systems were explored through this
study to determine the appropriateness of integrating them into zoning regulations. Staff
do not recommend that a mechanical parking lift or stacking system be considered for
required parking for several reasons. First, it is difficult to ensure the ongoing maintenance
and operational viability for the parking space to remain accessible to owners and tenants
permanently. Stacking systems also present unique safety challenges that require training
to ensure proper use and safe operation. Rather than integrating mechanical parking
systems into the bylaw, staff took the approach of reduced parking requirements to
provide flexibility to property owners. Such systems may be installed within a private
garage to provide parking beyond the minimum zoning requirement. Staff do not
recommend that this additional space be counted towards required parking.
Bicycle Parking - To support parking reductions and active transportation, staff
recommend that bicycle parking be provided for all lots with 3 or 4 dwelling units. A new
class of bicycle parking is also recommended which will require secure and weather
protected bicycle storage areas, but without the specific criteria for access aisles,
overhead clearance and locking mechanisms which are required for commercial
developments and multiple dwellings, where more extensive bicycle storage rooms or
lockers may be required. Bicycle parking for additional dwelling units could be provided in
an alcove within the unit, in a shed, or in a private garage.
Lot Width and Area:
Through this report, staff recommends reducing minimum lot size requirements from
today's regulations, except where the base zone requires larger lot sizes in which case the
base zone rules will continue to prevail (e.g. RES -1 and RES -2 zones and corner lots).
Currently, a minimum lot width of 13.1 metres and a minimum lot area of 395 square
metres are required for a lot containing 2 additional dwelling units (attached) or any lot with
an additional dwelling unit (detached). The exception is where the zoning category
requires more, in which case the lot size of the base zone prevails. This currently makes
about 46% of lots in Kitchener eligible for additional units. These regulations were
developed when additional dwelling units (detached) were first introduced in 2021 and
were carried forward to regulations for 2 additional dwelling units (attached) in 2023 in
response to Bill 23 changes to the Planning Act.
The recommendations are informed by a lot size and built form analysis that takes into
consideration setbacks, driveway widths, and building coverage. The minimum lot size
requirements are largely driven by the amount of parking which may be required,
maximum permitted lot coverages, minimum recommended landscape areas and
recommended minimum separation distances between principal dwellings and detached
additional dwellings. Based on the analysis, staff recommend minimum lot size rules
based on geographic location summarized in Table 5.
Page 20 of 343
Table 5. Summary of required minimum lot width and area for four units on a lot
Location
1 ADU (attached)
2 or 3 ADUs
Detached
(attached)
Additional Dwelling
(1 or 2 units)
Within 800 m of
Base zone rules
Base zone rules
Base zone rules
an LRT station
apply
apply
apply
Central
Base zone rules
Base zone rules
Base zone rules
Neighbourhood
apply
apply
apply
Area
All other areas
Base zone rules
10.5 m min. lot
10.5 m min. lot
apply
width, 360m2 min. lot
width, 360m2 min. lot
areal
area'
Except where the base zone requires larger lot sizes in which case the base zone rules will
continue to prevail (e.g. RES -1 and RES -2 zones, and corner lots)
A single detached, semi-detached or street townhouse dwelling with one additional
dwelling unit (attached) continues to be permitted in accordance with the base zone rules
regardless of lot size. This is consistent with the current approach and applies across the
city.
Within 800 metres of a Light Rail Transit Station and in the Central Neighbourhood Area,
the base zone rules for lot size are proposed to apply to additional dwelling units (attached
or detached) as the proposed total number of required parking spaces is lower and less lot
width and area are required to accommodate parking and driveways, therefore providing
additional opportunity to accommodate units on smaller lots. Staff is of the opinion that in
the Central Neighbourhood Area and within 800 metres of an LRT station, additional
dwellings attached and additional dwellings detached can be accommodated on any size
lot, subject to the regulations for setbacks, building separation, landscaping, as less
parking is required to be accommodated.
Outside of the Central Neighbourhood Area and farther from LRT stations, staff
recommend a minimum lot width of 10.5 m and a minimum lot area of 360 m2 for detached
additional dwellings and where there are three or four units on a lot. New subdivisions, in
particular, tend to have the most restrictive building orientation, with narrow lots where the
principal dwelling is built to the required yards. Parking areas are often limited to a private
garage in front of the dwelling, and driveway widths have already been maximized. Such
areas are less well served by transit and are less walkable, generating a higher demand
for off-street parking, and therefore more parking must be accommodated on-site.
The proposed regulations were developed based on a lot analysis (refer to Figure 6)
considering a typical suburban lot which has maximized useable space. The proposed
minimum lot width of 10.5 m allows a single car garage, and a double car driveway to
accommodate for the 3 required parking spaces. Alternatively, the lot width can
Page 21 of 343
accommodate a 2.6 -metre -wide single car driveway located between the principal dwelling
and the interior side lot line, to accommodate parking on the driveway in tandem, or
leading to a parking area in the rear yard. Staff is of the opinion that a minimum lot area of
360 m2 is sufficient to accommodate an additional dwelling (detached) or where there are
2 or 3 additional units (attached) to provide for parking in the rear yard or an additional
dwelling (detached) in the rear yard, together with private amenity space for residents. The
diagrams demonstrate that the required site functions, setbacks and separations work on
a lot of the recommended minimum area.
Staff recommend that these regulations apply equally to semi-detached dwellings and
street -townhouse dwellings as these will also require, in most cases, double car width
driveways, landscaping, and distance separations, and 1.1 m unobstructed walkways.
The recommended lot sizes are generally consistent with other municipalities that regulate
lot size, and are a useful metric to property owners and investors seeking to understand
whether additional units may be feasible in consideration of other regulations.
Figure 6. Lot analysis for a suburban built form with detached and attached ADUs
Omm rule.,..
Arnily,6far. 1rrtareaof360 m2 ADUDetached ADUAftadhed
Min Lot Area m2 3W 360
i� E �anxnttarEANo Lot dePtir(m) 34.29 34.29
8 AMEtaTrarACE Min tat. Width m) 10.5 10.5
I IMw aI Min Front yard sethck (m) 4.5 45
Garage from yard lmj 6 6
Min lntedor 51 do yard setback lml 1.2 1.2
ME
rsss TwW Min Re M Yard Setback lml 75 75
E'Lt CoverageU3% 48%~rCr Building Area (w2) 144 171.71
IMIN BOA) IOlSTANCE SEpARATbN I Mae Building Height (ml 11 11
Max 0 of storeys 3 3
ADU detached Max size 13% 0%
ADU detached Area im2l 45.77 0.00
AREA WITH THE SA M
VVSEPARATION EPA—KNREaVIREMENT
6 N �€ I tor_ACMeenNc u�7H
,:.� `I sErancK rsecuinnays
—E - EUENS,ME=CNArycPE `al,I, wAeTQyy,uEGHPNIGAL
I aguIrMENT neW aiHER I Equll'raE=NtPWOr—
j E=aTRucrpNS Must oes_"CAnN8 MusT
N iHl6 sloE eE Ory Srys $IDE
np
1 OrrB
00 eluo �,T 00
-t t •-11
\,Rq.—NN. \\ // \ / � mlN
E m \ / IMIN mm] E \ /
E
m X =a100m - 1 0 /X§2 X e aat00m
-11 j tp 1 na � l M113'-1
1,
10500 mm 10500 mm
[34's7 104'd9
Min Lot Arra of 360 m2 and Lot Width of 10.6 m fvlin Lot Area of 360 m2 and Lot Width of 10.5 m
etac ADU ttac e
In all cases, other zoning regulations such as minimum setbacks, maximum lot coverage,
minimum landscaping requirements, regulations related to the additional dwelling
(detached), and a 1.1 m unobstructed walkway to principal entrances (for emergency
Page 22 of 343
access purposes) will also apply and may restrict some lots from particular dwelling forms
or site layouts.
The proposed lot size will enable additional units on approximately 12,875 more lots than
today. Buildings will continue to be subject to other zoning regulations including maximum
lot coverage and setbacks, as well as the Ontario Building Code, which may further restrict
building sizes and separation distances between buildings. It is important to note that
despite a lot meeting minimum lot size requirements, it may not be feasible for all unit
configurations to fit on all lots. Grading conditions and individual site constraints such as
easements, retaining walls, infiltrations galleries, or public utilities in rear or side yards may
further restrict the ability to develop additional units.
Regulations for Additional Dwelling Units (Detached):
Additional dwelling units (detached) or backyard homes provide another option for
property owners wishing to increase the number of dwellings on a lot. This type of
dwelling has been allowed since 2021, permitting 1 storey buildings with 1 unit on lots
having a minimum lot area of 395 m2 and a minimum lot width of 13.1 m. Staff have
undertaken a review of the regulations for additional dwelling units (detached) and
recommend changes in a few key areas to help support this housing option:
• Minimum building separation
• Permissions for 2 units in a detached dwelling
• Increasing building height
• Exterior side yard permissions
Minimum building separation —As discussed in previous sections, staff recommend
reductions to lot size and parking to enable additional dwellings on more lots. As built form
on a lot becomes denser, achieving a minimum separation between principal dwellings
and detached tiny homes may become more difficult — however it is important that space
is provided for private amenity areas. As such, staff recommends a minimum separation
distance between a principal dwelling and a detached additional dwelling. This space
ensures that there can be windows and doors on facing elevations of buildings, and
private amenity space is provided in the rear yard. In addition to the building separation, a
30% rear yard landscape area is recommended, which ensures that the combination of
buildings, driveways and parking continues to allow for adequate green and amenity
spaces.
Permissions for 2 units in a detached dwelling - Staff also recommend permitting up to two
dwelling units in an additional dwelling (detached). Such units could be located side-by-
side, back-to-back or one above the other. An additional dwelling (detached) whether it
contains one or two dwelling units will be permitted to have a maximum building footprint
of 80 square metres and cannot exceed 15% of the lot area.
Increasing building height - Staff recommend permitting a height of 6.0 metres for an
additional dwelling (detached) where the principal dwelling has a height greater than 9.1
metres whereas today's maximum height is 4.5 metres. This provides additional flexibility
Page 23 of 343
to provide one larger unit, two units, or dwelling unit(s) above parking. This will allow a
raised bungalow, or a 1.5 storey design where a second floor is incorporated into the
roofline, and will provide for a design that incorporates a garage. An increase in height
would only be permitted where the principal dwelling is 9.1 metres in height (2 storeys) to
i!
O
Figure 7. Examples of additional dwellings (detached) that could be built with a 6 m
height (sources: www.familyhomel,)Ians.com and www.architecturaldesigns.com)
ensure that the additional dwelling (detached) remains subordinate to the principal
dwelling, and fits into the neighbourhood context. Examples of detached additional
dwellings with a 6 -metre height are depicted in Figure 7. Where an increased height is
permitted, staff recommend a setback of 0.9 metres which will provide additional space for
maintenance of eaves and walls.
Exterior side yard permissions - Staff further recommend that an additional unit (detached)
be permitted to locate in an exterior side yard, provided it is setback in accordance with
the regulations for the principal dwelling. This will help to make more efficient use of land,
especially where there is a wide exterior side yard. Staff is of the opinion that it is
appropriate for an additional dwelling (detached) to be designed to front the street
however it should not be severed from the principal dwelling.
Built Form and Site Layout:
Through an evaluation of built form and site layout considerations, staff are recommending
the followings changes to zoning regulations that are proposed to apply to three or four
unit scenarios:
• Increasing the number of doors permitted on a street line fagade
• Adding a front and rear yard minimum landscaped area requirement
• Adding an unobstructed walkway requirement for attached units
Number of Doors on a Street Line FaQade - As a result of Bill 23 Planning Act changes,
the City no longer can require site plan approval and therefore review building elevations
for matters of design. Some zoning regulations were established for small multiples in
2023 to regulate openings on front elevations. Zoning currently limits the number of
pedestrian entrances to one for each street line fagade. The purpose of this regulation
was to avoid elevations where several doors all faced the street, resulting in a less
desirable street facing fagade, and to ensure that dwellings with additional units blended
Page 24 of 343
into streets which were predominately single detached dwellings. However, staff have
heard through consultation that this regulation has presented issues to builders from an
interior layout perspective. Staff is of the opinion that to support additional units within the
principal dwelling, it is appropriate to allow up to two pedestrian doors to face each street,
and to allow more doors, provided they are perpendicular to the street (e.g. located on the
side wall of a porch). Further, staff is of the opinion that dwellings with more than one unit
are desirable in all neighbourhoods, and it is not necessary to camouflage this fact.
Front and Rear Yard Landscape Requirements - Staff recommend minimum front and rear
yard landscape requirements be added to all lots containing 3 or 4 dwelling units. As
density increases, the proportion of the lot covered by buildings and parking may also
increase and it is important to ensure that greenspace, landscaping and private amenity
spaces are preserved. Staff recommend that 20% of the front yard, between the building
and street line, be reserved for landscaping (excluding walkways, patios, and other hard
surfaces). This ensures space for stormwater infiltration, trees and vegetation, and
contributes to a positive streetscape experience. Staff further recommend that 30% of the
rear yard, between the principal dwelling and the rear lot line be reserved for landscaping
including both green spaces and private amenity spaces (such as patios, decks,
playgrounds etc.). Rear yard landscape can include hard surface amenity areas but
excludes buildings such as sheds and additional dwelling units (detached), and parking.
Through the analysis, staff is of the opinion that the targeted front and rear yard landscape
requirement will provide more functional landscaped area because it excludes the side
yards which are typically narrow with limited amenity function.
Unobstructed Walkway - Increases in the number of dwelling units may make it more
difficult for emergency services staff to access the principal entrances of units in an
emergency. Regulations for additional dwelling units (detached) require a 1.1 metre
unobstructed walkway to each principal entrance of the backyard home. In consultation
with building and fire staff, it is recommended that this requirement is added to additional
dwelling units (attached) where there are three or four dwellings on a lot, and the units do
not have their primary entrance facing a street (i.e., if doors are accessed from an interior
side or rear yard). This will ensure that there is a dedicated and clear path of travel to
these units for emergency services staff. A new definition is also recommended to be
added for unobstructed walkway to help provide clarity for implementation.
Other Proposed Zoning Changes:
Together with the above noted changes, staff are also recommending:
• minor changes to definitions, and introduction of new definitions resulting from the
proposed changes.
• clarification regarding the types of home businesses permitted in dwellings with
additional dwelling units.
• multiple dwellings with a maximum of 4 units is deleted from the RES -4 land use,
as the new regulations allow up to 4 units on a lot with a single detached dwelling,
semi-detached dwelling or street -townhouse dwelling, and are subject to more
permissive regulations.
Page 25 of 343
A detailed overview of proposed Zoning By-law Amendments and rationale may be found
in Attachments C1 and C2. As discussed in the Planning Analysis below staff is of the
opinion that the proposed amendments to Zoning By-law 85-1 and Zoning By-law 2019-
051 are consistent with and conform to the Planning Act, Provincial Policy Statement
(2020), the Places to Grow Act (2005) and A Place to Grow: Growth Plan for the Greater
Golden Horseshoe (2020) and the Regional Official Plan (2010, including ROPA #6), the
Official Plan and represent good planning.
Plannina Analvsis
The Official Plan and Zoning By-law Amendments proposed through this report have
regard for matters of Provincial interest under the Planning Act, are consistent with the
Provincial Policy Statement, conform with, or do not conflict with A Place to Grow: Growth
Plan and the Region of Waterloo Official Plan, and represent good planning.
Planning Act, R.S.O. 1990, c. P.13 25.
Section 2 of the Planning Act establishes matters of provincial interest and states that the
Minister, the council of a municipality, a local board, a planning board, and the Tribunal, in
carrying out their responsibilities under this Act, shall have regard to, among other matters,
matters of provincial interest.
Planning staff is of the opinion that the proposed amendments have regard for the matters
of Provincial interest outlined in section 2 of the Planning Act. By directing growth,
development, and intensification within built-up areas with appropriate regulations, the
proposed amendments:
• Protect ecological systems, agricultural resources, and conserve and manage
natural resources,
• Have regard for the supply, efficient use and conservation of energy and water,
• Have regard for the adequate provision and efficient use of communication,
transportation, sewage and water services and waste management systems, and
the minimization of waste as growth is directed to areas where the infrastructure
required to accommodate the additional growth already exists, minimizing the need
to add new infrastructure.
• Have regard for the protection of the financial and economic well-being of the
Province and of the City of Kitchener by enabling growth that makes efficient use of
existing infrastructure and reducing the need for capital investments in growth
where infrastructure does not currently exist. In doing so, the proposed
amendments also have regard for the orderly development of safe and healthy
communities.
• Have regard for the adequate provision of a full range of housing opportunities
through the implementation of zoning regulations that enable the `missing little'
building typologies on more lands.
• Promote development that is designed to be sustainable, climate resilient and
supportive of public transit and active transportation.
The Ministry of Municipal Affairs and Housing is proposing an integrated province -wide
land use planning policy document, potentially replacing the Provincial Policy Statement
Page 26 of 343
and A Place to Grow: Growth Plan for the Greater Golden Horseshoe, with a singular
Provincial Planning Statement (PPS) which is in draft form and not in effect at the time this
report was prepared.
Provincial Policy Statement, 2020
The Provincial Policy Statement (PPS) provides policy direction on matters of provincial
interest related to land use planning and development. Section 3(5) of the Planning Act
requires that a decision of the council of a municipality shall be consistent with the policy
statements that are in effect on the date of the decision and shall conform with the
provincial plans that are in effect on that date or shall not conflict with them, as the case
may be.
The PPS promotes the integration of land use planning, growth management, transit -
supportive development, intensification, and infrastructure planning to achieve cost-
effective development patterns, optimization of transit investments, and standards to
minimize land consumption and servicing costs. Efficient development and land use
patterns are promoted, as well as accommodating an appropriate mix of affordable and
market-based residential dwelling types with other land uses, while supporting the
environment, public health, and safety. Additionally, healthy, livable and safe communities
are supported through efficient development patterns, planning for a full range and mix of
housing, commercial, employment, institutional and community infrastructure.
Policy 1.1.1 speaks to the ways in which healthy, liveable and safe communities are
sustained, including: promoting efficient development and land use patterns which sustain
the financial well-being of the Province and municipalities over the long term,
accommodating an appropriate affordable and market-based range and mix of residential
types; and promoting the integration of land use planning, growth management, and
transit -supportive development. Further, healthy, liveable, and safe communities are also
sustained by intensification and infrastructure planning that achieves cost-effective
development patterns, optimizes transit investments, and minimizes land consumption and
servicing costs.
Policy 1.1.3.3 promotes transit -supportive development, accommodating a significant
supply and range of housing options through intensification and redevelopment where this
can be accommodated considering existing building stock or areas and the availability of
suitable existing or planned infrastructure and public service facilities required to
accommodate projected needs.
Policy 1.1.3.4 promotes development standards that facilitate intensification,
redevelopment and compact form, while avoiding or mitigating risks to public health and
safety.
Policy 1.4.3 promotes providing an appropriate range and mix of housing, supports all
types of housing options and residential intensification (in accordance with 1.1.3.3),
promotes densities for new housing that efficiently uses land, resources, infrastructure and
public service facilities, which supports the use of active transportation and public transit,
and supports development standards which minimize the cost of housing and which
promotes compact form while maintaining public health and safety.
Page 27 of 343
Policies of section 2.6 speak to protection of cultural heritage resources
The proposed amendments will enable additional dwelling units on existing residential
lands. This enables additional housing choice within established residential areas and
makes efficient use of existing lands and building stock, infrastructure and services. The
recommended geography -based parking reductions support more efficient use of land and
support the use of public transit and active transportation options. Existing cultural
heritage protection measures, including individual and district designations under the
Ontario Heritage Act continue to apply, and regulations and by-laws which may require
heritage permits continue to apply. Staff is of the opinion that the proposed amendments
are consistent with the Provincial Policy Statement.
A Place to Grow: Growth Plan for the Greater Golden Horseshoe, 2020 (Growth
Plan)
The Growth Plan supports the development of complete and compact communities that
are designed to support healthy and active living, make efficient use of land and
infrastructure, provide for a range and mix of housing types, jobs, and services, at
densities and in locations which support transit viability and active transportation. The
Growth Plan recognizes that many communities are facing issues of housing affordability,
which are being driven primarily by sustained population growth and factors such as a lack
of housing supply with record low vacancy rates. To address this challenge, policies of the
Growth Plan provide direction to plan for a range and mix of housing options, including
additional residential units, in particular, higher density housing options that can
accommodate a range of household sizes in locations that can provide access to transit
and other amenities. The Growth Plan places strong emphasis on optimizing the use of
the existing urban land supply and supports an intensification -first approach to
development and city -building, one which focuses on making better use of existing
infrastructure and public service facilities, and less on continuously expanding the urban
area.
The Growth Plan requires that municipalities achieve minimum density requirements to
meet growth forecasts. Planned growth is directed to settlement areas, and as outlined in
section 2.2.1 c) to delineated built up areas, locations with existing or planning transit and
public services facilities (such as police and fire protection, schools, community centres,
parks, etc.). City-wide and geography specific density targets are provided by the Region
of Waterloo. Housing Policies in section 2.2.6.1(a) state that municipalities will support
housing choice through the achievement of the minimum intensification and targets in this
plan by identifying a diverse range and mix of housing options and densities which shall be
implemented through zoning by-laws. The proposed amendments will help to achieve
intensification and density targets to achieve the Growth Plan population forecasts.
Section 2.2.1.4 states that complete communities will feature a diverse mix of land uses;
improve social equity and overall quality of life for people of all ages, abilities, and
incomes; provide a diverse range and mix of housing options, including additional
residential units and affordable housing, to accommodate people at all stages of life, and
to accommodate the needs of all household sizes and incomes; expand convenient
access to a range of transportation options, including options for active transportation and
public service facilities; provide for a more compact built form and a vibrant public realm;
Page 28 of 343
and, mitigate and adapt to the impacts of a changing climate, improve resilience and
reduce greenhouse gas emissions, and contribute to environmental sustainability.
Policy 2.2.2.3 states that "all municipalities will develop a strategy to achieve the minimum
intensification target and intensification throughout delineated built-up areas, which will:
a) identify strategic growth areas to support achievement of the intensification target
and recognize them as a key focus for development;
b) identify the appropriate type and scale of development in strategic growth areas
and transition of built form to adjacent areas;
c) encourage intensification generally throughout the delineated built up area;
d) ensure lands are zoned and development is designed in a manner that supports the
achievement of complete communities;
e) prioritize planning and investment in infrastructure and public service facilities that
will support intensification; and
f) be implemented through official plan policies and designations, updated zoning and
other supporting documents."
Policy 2.2.6.1 (a) states that municipalities will "support housing choice through the
achievement of the minimum intensification and density targets in this plan by identifying a
diverse range and mix of housing options and densities, including additional residential
units and affordable housing to meet projected needs of current and future residents."
Further, Policy 2.2.6.1 b) and e) require municipalities to implement policy 2.2.6.1 a)
though official plan policies and zoning by-laws.
Policy 2.2.6.2 requires municipalities to support the achievement of complete communities
by planning for and accommodating growth in order to achieve intensification targets, by
considering a range and mix of housing options and densities, and planning to diversify
overall housing stock.
Policy 2.2.7 states that "New development taking place in designated greenfield areas will
be planned, designated, zoned and designed in a manner that:
a) supports the achievement of complete communities;
b) supports active transportation, and
c) encourages the integration and sustained viability of transit services."
The proposed amendments support gentle intensification in both the Built -Up Area and
Designated Greenfield Area. The proposed amendments support a more compact built
form and enable a more diverse mix of housing options, thereby supporting the
development of complete communities. The proposed amendments will help make
efficient use of land, infrastructure, parks, roads, trails, and transit. Planning staff is of the
opinion that the application conforms to the Growth Plan.
Page 29 of 343
Regional Official Plan, 2010 (ROP)
Urban Area policies of the ROP identify that the focus of the Region's future growth will be
within the Urban Area. Through ROP Amendment 6 the Region has set a minimum target
that 60% of new growth will occur within the delineated Built -Up Area. The ROP promotes
an intensification -first approach to development that focuses on making better use of
existing infrastructure and public service facilities, and on protecting the region's valuable
water, agricultural and natural heritage systems.
Policies 2.B.1.1 supports intensification within the Urban Area through gentle density and
missing middle housing options.
Policy 2.C.2 directs municipalities to develop official plan policies and implementing zoning
by-laws that, among other matters, promotes a more compact built form that enables a
modal shift to most trips being made by walking, cycling and rolling, contributing to the
creation of 15 -minute neighbourhoods, provides a diverse mix and range of housing
options, including additional residential units and affordable housing.
Policy 2.D.5 requires area municipalities to establish policies in their official plans and
implementing zoning by-laws to permit missing middle housing on residential lots located
within an Urban Area.
Policy 3.A.2 requires area municipalities, in collaboration with the Region, to plan for a
diverse range and mix of housing options with an overall target of a minimum of 30% of
new ownership and rental housing being affordable to low- and moderate -income
households. The range and mix of housing options provided will vary in terms of form,
tenure, density, and number of bedrooms to accommodate the needs of all sizes,
incomes, and ages of households.
Policy 3.A.20 states "The Region encourages the area municipalities to apply alternative
development standards as -of -right to help streamline the development of affordable
housing provided health, safety, servicing, and other reasonable standards or criteria can
be met. Examples of such alternative development standards may include, but are not
limited to, reduced parking standards, setbacks and road allowances."
The Region acknowledges that while strategic growth areas (such as Major Transit Station
Areas) will play the primary role in achieving the intensification targets, intensification will
also occur more broadly within existing neighbourhoods through gentle density. The ROP
envisions this transition to occur gradually over time as new opportunities arise for infill,
redevelopment, additional residential units, new missing middle housing options,
development of vacant and/or underutilized lots, and the expansion or conversion of
existing buildings.
Regional policies require the City to plan for a range of housing in terms of form, tenure,
density and affordability to satisfy the various physical, social, economic and personal
support needs of current and future residents. The proposed amendments enable missing
middle housing, with as -of -right reductions to parking throughout the urban area. Regional
staff have indicated that they have no objections to the proposed amendments
(Attachment `H'). Planning staff are of the opinion that the application conforms to the
Regional Official Plan.
Page 30 of 343
Kitchener Official Plan (2014)
The City of Kitchener Official Plan (2014) provides the long-term land use vision for
Kitchener. The vision is further articulated and implemented through the guiding principles,
goals, objectives, and policies which are set out in the Plan.
Complete Communitv
The vision articulated in the Official Plan is to build an innovative, vibrant, attractive, safe,
complete and healthy community contributing to an exceptional quality of life. A complete
community creates and provides access to a mix of land uses including a full range and
mix of housing. Planning for a complete community will aid in reducing the cost of
infrastructure and servicing, encourage the use of public transit and active modes of
transportation, promote social interaction, and foster a sense of community. The proposed
amendments enable additional housing options within the community.
Housina Policies
Housing Policies of the Official Plan seek to provide for an appropriate range, variety and
mix of housing types and styles, densities, tenure, and affordability to satisfy the varying
housing needs of the Kitchener community through all stages of life. Objectives speak to
the preference for a land use pattern that accommodates a range of housing types across
the city as a whole and within neighbourhoods. The City encourages intensification and
redevelopment including adaptive re -use and infill including additional dwelling units
attached and detached in order to respond to changing housing needs and as a cost-
effective means to reduce infrastructure and servicing costs by minimizing land
consumption and making better use of existing community infrastructure.
Policy 4.C.1.9 requires that residential intensification and/or redevelopment within existing
neighbourhoods be designed to respect existing character. Community character refers to
pockets of the urban fabric with distinctive physical attributes and includes scale of the
built environment and development patterns which can be regulated through zoning.
Other components of community character such as architectural vernacular cannot be
regulated by zoning.
Policy 4.C.1.12 indicates that the City favours a land use pattern which mixes and
disperses a full range of housing types and styles both across the city as a whole and
within neighbourhoods.
In accordance with policy 4.C.1.13., the City will work with the development industry and
other community members to identify and encourage innovative housing types and
designs in the city where such innovation would be compatible with surrounding land uses,
support the development of complete communities, provide accessible and affordable
housing to residents, be transit -supportive and/or transit -oriented. The proposed
regulations are more flexible and provide opportunities for creativity in providing more
dwelling units in a compact and efficient way that will support transit, affordability, variety
and choice, while also being compatible with existing neighbourhoods.
Policy 4.C.1.23 for additional dwelling units attached and detached is proposed to be
amended to permit up to 4 dwellings on a lot.
Page 31 of 343
Proposed changes to zoning regulations continue to align with policy 4.C.1.23 for
additional dwellings (detached). In accordance with this policy the additional dwelling
(detached) should be subordinate to the main dwelling on the lot; integrated into its
surroundings with negligible visual impact to the streetscape; compatible in design and
scale with the built form on the lot and the surrounding residential neighbourhood in terms
of massing, height and visual appearance; the site layout should consider other
requirements including servicing, pedestrian and vehicular access, stormwater
management, grading and drainage, tree preservation, and provision of amenity areas,
landscaped buffers and visual screening; and up to one parking space may be required for
each additional dwelling unit.
The proposed zoning regulations permit additional dwelling units attached and detached,
subject to regulations for setback, height, and parking. Regulations require and protect
front yard and rear yard landscaped areas, provide for a built form, including height and
setbacks, that aligns with existing built form. Driveway widths continue to be limited to
preserve boulevard trees and on -street parking. Rear yard parking lots must be setback
and screened from neighbouring dwellings. Backyard homes will continue to be
subordinate to the principal dwelling, while allowing for modest increases in height that will
allow additional flexibility and floor space.
Natural and Human -Made Hazards
Official Plan policies direct development away from areas with natural or human -made
hazards including flooding hazards, and human -made hazards. Polices and zoning
regulations which restrict residential uses in certain areas will continue to apply and may
restrict additional dwelling units on affected lands or may require additional study or
mitigation.
Natural Heritage and Environmental Management
Policies of the Official Plan protect and conserve the natural heritage system. Policies,
associated processes and implementing zoning regulations which protect the Natural
Heritage System are not impacted by the proposed regulations and development will not
be permitted in such areas.
Energy Conservation, Air Quality and Waste Reduction
Policies of the Official Plan support development which conserves energy, reduces waste,
and minimize adverse impact to air quality. Permitting additional dwelling units promotes a
compact urban from, maximizes the use of existing infrastructure, supports the adaptive
reuse of buildings, and the reduction in parking promotes the use of transit, walking and
cycling, supporting reduced levels of private automobile ownership and associated
emissions.
Urban Design
Neighbourhood design policies of the Official Plan promote development and
redevelopment in existing neighbourhoods that is compatible with the existing
neighbourhood, which achieves walkability, variety, placemaking, conservation,
connectivity, is transit supportive and safe. The proposed regulations permit additional
Page 32 of 343
dwelling units attached and detached, subject to regulations for setback, height, and
parking. Regulations require and protect front yard and rear yard landscaped areas,
provide for a built form, including height and setbacks, that aligns with established
neighbourhood regulations intended to preserve streetscape characteristics. Parking in
front yards continues to be limited to current standards to help preserve boulevard trees
front yard landscaped areas and on -street parking. Rear yard parking lots must be
setback and screened from neighbouring dwellings. Backyard homes will continue to be
subordinate to the principal dwelling, while allowing for modest increases in height that will
allow additional flexibility and floor space. Staff is of the opinion that additional dwelling
units in existing neighbourhoods are compatible with existing residential development.
Cultural Heritage Resources
Policies of the Official Plan seek to conserve the City's cultural heritage resources using
provisions of the Ontario Heritage Act and other legislation. Cultural heritage resources
within Kitchener include identified Cultural Heritage Landscapes, as well as designated
Heritage Conservation Districts and individually designated properties. Once properties
are designated under the Ontario Heritage Act, the City is enabled to manage physical
alterations to the cultural heritage resources as a means of protection. The principal
mechanism of management is the Heritage Permit Application process, which allows the
municipality to review site-specific applications and determine if proposed changes will
affect identified heritage attributes or the cultural heritage value or significance of a
property. This process will apply equally to development or redevelopment for additional
dwelling units as it would for any other development proposal, whether that be renovations
to an existing building, or construction of an addition or an accessory structure. The
demolition of designated heritage buildings is not supported by the City. If a property is not
designated but is within a Cultural Heritage Landscape, a Heritage Permit Application is
not required but additional heritage studies or consideration in design and impact may be
requested.
Transportation
The City's Official Plan contains policies to develop, support, and maintain a complete,
convenient, accessible, and integrated transportation system that incorporates active
transportation, public transit, and accommodates vehicular traffic. Regarding alternate
modes of transportation, objectives of the Official Plan include promoting land use
planning and development that is integrated and conducive to the efficient and effective
operation of public transit and encourages increased ridership of the public transit system.
The City shall promote and encourage walking and cycling as safe and convenient modes
of transportation. The proposed amendments seek to reduce parking requirements in
certain geographies which have good access to public transit (including bus, i -express bus
and light rail transit), have good access to on and off-street cycling networks, the micro -
mobility system (e.g., Neuron e -scooters), and are walkable. Proposed regulations
associated with parking are discussed in the preceding sections of this report.
Servicing and Utilities
The objectives of the Official Plan are to provide infrastructure, municipal services and
utilities in a coordinated, efficient and cost-effective manner to meet the City's current and
projected needs; to maximize the use of existing municipal services and utilities before
Page 33 of 343
consideration is given to extending and/or developing new municipal services; and, to
promote cost-effective development patterns and standards to assist in minimizing
servicing costs.
Permitting additional units in existing built-up areas help to make efficient use of existing
infrastructure including sanitary sewer, water services, storm water infrastructure, and
utilities including hydro, gas and communications infrastructure. As site development
intensifies, individual property owners will be required to make arrangements with service
providers, including the City of Kitchener, to ensure that site services are appropriately
sized for the increase in units. Where upsizing of services is required, this will be a cost to
the developer, but should be considered an investment in the property, which will permit
additional density.
Utility providers including Enova and Kitchener Utilities have provided input to the
proposed changes that will enable additional density. Staff expect that uptake and
construction of additional units will be gradual, and it is unlikely that all lots on a street will
convert from 1 -unit dwellings to 4 -unit dwellings concurrently. This will allow time for
ongoing assessment and monitoring of infrastructure to understand when and where
improvements may be required. It is reasonable to assume that over time, existing excess
system capacity will be used up and improvements may be required.
The City is currently preparing an Integrated Sanitary Master Plan. This plan is reviewing
existing conditions and evaluating planned growth and servicing needs and is expected to
be completed by Q2 of 2024. The Master Plan will identify recommended projects to
address current and future sanitary servicing needs of the community based on the
existing condition of sanitary infrastructure as well as current and future capacity needs.
Recommended projects will be prioritized based on factors including infrastructure life
expectancy, as well as other criteria. Areas of constraint may be identified through this
work, and it is possible that further recommendations which limit development, including
but not limited to development of additional dwelling units, may be necessary in certain
areas, until infrastructure can be rehabilitated or replaced to increase existing capacity.
Staff is of the opinion that the proposed Official Plan Amendment and Zoning By-law
Amendments are consistent with and conform to the Planning Act, Provincial Policy
Statement (2020), the Places to Grow Act (2005) and A Place to Grow: Growth Plan for
the Greater Golden Horseshoe (2020), the Regional Official Plan (2010) and the Kitchener
Official Plan (2014) and represent good planning.
What We Heard from the Community
Through community engagement, staff heard from a range of community members,
including property owners, residents (including renters), builders, designers, and investors.
A summary of community engagement is provided in this report while more detailed
information on the community engagement strategy and feedback are included in
Attachments G1 to G4.
The community engagement strategy included variety of online and in-person
opportunities for community members to provide input, as summarized in Figure 8.
Overall, the team recorded nearly 2,000 individual interactions ranging from visits to the
Page 34 of 343
Engage Kitchener project page, to attendance at one of the in-person open houses, and
one-on-one discussions with staff on the phone or at city hall.
WHAT 1 E HEAR _
Engage Kitchener Enabling Four Units webpage
• 1393 visits, 145 subscribers and 30 surveys completed
Virtual Community Meeting (January 17, 2024)
• 30 participants and 185 views of the recording
Three (3) public Open Houses totaling approximately 150 attendees:
• January 25, 2024, at the Kitchener 1vlarket,
• January 23, 2024, at the Stanley Park Community Centre, and
• January 31; 2024, at the Forest Heights Community Centre
Written Comments
• 40 emails
Development Industry Workshop (January 31, 2024)
• 20 participants
Kitchener Development Liaison Committee on January 19, 2424 and
February 23; 2024
• 11 participants
Figure
Figure 8. A Summary of engagement opportunities.
In evaluating feedback, staff observed that many community members support gentle
density on existing residential lots. We heard this is an important way to help respond to
the housing crisis. Community members identified the following benefits of allowing
additional dwelling units:
• Enabling more housing in neighbourhoods;
• Supporting financial feasibility of home ownership,
• Supporting multi -generational housing,
• Environmental responsibility — making use of existing infrastructure, services and
transit,
• Shifting transportation modes away from personal vehicle ownership; and,
• Creating neighbourhoods with densities that will support stores and businesses.
Staff also heard a range of concerns. Some community members believe that enabling 4
units does not go far enough, while others have concerns that allowing additional density
will have an impact on the elements of neighbourhoods that they value.
Page 35 of 343
A summary of the concerns we heard from the community along with a commentary on how
staff addressed or considered these concerns is provided in Table 6.
Table 6. Summary of Community Member Concerns and Staff Responses
Concerns by theme
Staff response
Parking. Concerns about how
Staff propose a geography -based approach to support
parking will be accommodated
reduction in parking minimums as detailed in the zoning
on-site and challenges with
section of this report. Staff recognize that some
respect to increased demand
homeowners and developers may opt to provide more
for on -street parking.
parking on-site than required. In such cases, parking will
be subject to regulations including those for parking lots
and maximum driveway widths.
On -street parking is intended to be for short-term use and
not permanent storage of personal vehicles. On -street
parking in Kitchener is enforceable under the City of
Kitchener Traffic and Parking By-law and the Region of
Waterloo Traffic and Parking By-law. On -street parking is
permitted up to 3 consecutive hours during the day unless
there is a sign posted that says otherwise. Overnight
parking exemption is required in the winter.
In the long-term, Kitchener could consider an on -street
parking permit system to offer long-term parking storage
on -street. On -street parking permit system generally
services specific residential areas where driveways
and/or garages are not common and on -street parking is
the only reasonable option. At this time, staff do not
recommend pursuing this option, due to the costs to
residents, staff time to administer and reduced access for
short-term parking needs.
Trees and amenity space.
The proposed zoning regulations seek to achieve a
Concerns were identified about
balance between enabling increased housing supply and
impacts to the urban forest,
protecting and preserving landscaped areas, private
reductions to landscaped green
amenity space and street trees, and specifically include:
space, and lack of private
minimum landscaped areas, setbacks to buildings
amenity space.
and parking lots, and maintaining maximum driveway
widths to accommodate amenity areas and space for
tree planting both on private lots and within
boulevards;
• proposing minimum separation distances between
principal buildings and detached additional dwellings
Page 36 of 343
Page 37 of 343
to accommodate outdoor amenity areas in rear yards;
and,
• minimum lot sizes and lot widths were evaluated to
ensure that lots are sufficiently sized to support
density increases while still providing adequate
greenspace.
Additional comments with respect to the urban forest is
provided in the following section of this report.
Impacts to neighbouring
Staff recommends a 6 -metre height for detached
properties. Concerns with
additional dwellings to allow a raised bungalow style
overlook and shadows on
dwelling or a 1.5 storey design where a second floor is
neighbour's yards from
incorporated into the roofline for flexibility to provide one
detached additional dwellings
large unit, two units, or dwelling unit(s) above parking
because of added height and
spaces. An increased height is proposed only where the
being too close to property
principal dwelling is 9.1 metres in height (2 storeys) to
lines.
ensure that the additional dwelling (detached) remains
subordinate to the principal dwelling, and fits into the
context of the neighbourhood.
The additional 1.5 metres in height will not have a
substantial impact on shadowing of neighbouring
properties. Where a detached additional dwelling is 4.5
metres high or less, a 0.6 metre setback continues to
apply. A higher detached additional dwelling is subject to
a 0.9 metre setback, which will help to reduce the impact
of shadows.
Overlook was also raised as a concern by property
owners. Openings in detached additional dwellings are
regulated by the Ontario Building Code which restricts the
percentage of openings on facades close to other
buildings and to property lines. A building located less
than 1.2 metres is not permitted to have unprotected
openings, and as the building is set farther back the
number of openings may increase. These Building Code
restrictions limit opportunity for windows and overlook into
neighbouring yards and private spaces.
Site functionality. Concerns
Staff recognizes the need and value of functional
were raised that as densities
properties and how it may impact quality of life for
and the number of units
residents. The proposed zoning balances the site
increased, lots would no longer
functionality elements with the intent of allowing gentle
be functional and able to
density through additional units on more properties across
provide for parking, living
Kitchener. The proposed zoning considers parking
minimums, impacts on tree canopy, landscaped and
Page 37 of 343
space, outdoor spaces,
amenity area, and walkway accesses. The proposed
services, etc.
zoning regulations work together to ensure that lots will
be large enough to accommodate additional density
together with other necessary site functions, while also
considering the public realm, streetscape and
environment. Some lots will be too small to
accommodate certain built forms and where regulations
cannot be met, increases in the number of units may not
always be possible. Further, staff conducted an analysis
to assess site functionality elements where up to 4 units
may be permitted. As a result, staff has proposed a
minimum lot area of 360 m2 and a minimum lot width of
10.5 m in suburban neighbourhoods to further facilitate
site functionality in these neighbourhoods due to the
higher parking requirement (3 spaces).
Streetscape. Community
Staff has not proposed changes to the fundamental
members raised concerns
zoning regulations that respect neighbourhood
about impact to existing
characteristics and streetscape such as minimum lot
characteristics of
area, lot width, lot coverage, height of principal dwelling,
neighbourhood and
setbacks, driveway and garage widths. The proposed
streetscape.
amendments seek to strike a balance between
accommodating new housing units and maintaining those
elements of a neighbourhood that can be regulated
through zoning regulations such as setbacks, height and
lot size.
Short-term rentals. There were
The intention of the proposed changes is to enable
concerns that the additional
additional dwelling units in more residential
dwelling units may be used for
neighbourhoods. Additional dwelling units may be a
short term rental purposes and
source of additional income for property owners, whether
may not help tackle the housing
used for traditional rental or short-term rental. Short term
crisis.
rentals are not regulated within the current Zoning By-law
framework and the City is undertaking a separate body of
work to assess and regulate short-term rental housing.
Minor variances. Concerns that
The proposed zoning regulations will enable more
despite the proposed zoning
dwelling units on more lots and are designed to be flexible
regulations, there will continue
to allow for creativity in design, while setting boundaries
to be applications for minor
for matters which are important to protect. The
variances.
recommended zoning may not work for all lots and all
circumstances, and variances remain a Planning Act tool
to consider small adjustments to zoning where tests can
be met. Staff will continue to monitor requested variances
and will consider further updates to the zoning by-law
where variances are frequently requested and supported.
Page 38 of 343
Develoament industry feedback
We also heard from those involved with development of these units as property owners,
investors, builders, designers, and contractors. The following are the key themes raised
by those in the development industry and staff's response.
Lot width and Lot area. The current minimum lot width and minimum lot area requirements
for additional dwelling units was requested to be reduced to make it easier to develop
additional units on more lots.
Staff evaluated the request to reduce lot width and lot area requirements and have
proposed a geographical approach to expand where additional dwelling units could be
developed. Today 2 additional units or a detached dwelling unit requires a minimum lot
width of 13.1 m and an area of 395 m2, or the zone minimum if it is greater. Staff are
proposing to only require the base zone minimum for lots within 800 metres of an LRT
station or which are located within the Central Neighbourhood Area. Outside of 800
metres from an LRT station or the Central Neighbourhood Area, a minimum lot width of
10.5 m and lot area of 360 m2 (or the zone minimum, if greater) is recommended for lots
containing 2 or 3 additional units, or a detached additional dwelling. Further discussion is
included in preceding sections of this report.
Parking. The removal of parking regulations and bicycle parking requirements for
additional dwelling units can make it easier to develop additional units removing cost and
spatial barriers.
Staff evaluated parking requirements and, to strike a balance, have proposed a
geographical approach to parking regulations with reduced parking rates as detailed in this
report. While bicycle parking is proposed, the new bicycle parking class reduces design
and cost barriers. Staff's recommendation is intended to recognize the importance of
addressing parking demand while supporting additional units and active transportation.
Building height. An increase in the allowable height for detached additional dwellings to
7.5 m was requested to accommodate units over garages and two-storey dwellings.
Staff evaluated the request to increase the building height for detached additional
dwellings from 4.5 m to 7.5 m. A proposed 6.0 m height limit (to mid -point of the roof) is
recommended where the principal dwelling is higher than 9.1 metres. This limit allows for
raised basements, a unit over parking integrated into the roofline or two units with the
upper storey integrated into the roofline. This approach is intended to allow some
additional height, where prevailing built form is generally higher, while limiting privacy and
shadow concerns and providing flexibility.
Application process. The development industry expressed concerns about processes and
timelines for application review.
In response, staff will evaluate ways to streamline the zoning review and building permit
processes. The proposed zoning changes also enable more units on more lots without
necessitating minor variance applications to expedite timelines. This report further outlines
next steps to support uptake of these units after a Council decision has been made.
Page 39 of 343
Based on input from the development industry workshop and the comprehensive planning
analysis conducted, as well as feedback from the public, staff has carefully considered
various regulatory adjustments aimed at facilitating the development of additional dwelling
units while addressing community concerns.
What We Heard from Staff and Agencies
The consultation with staff and agencies was a collaborative process. It included an email
circulation with the opportunity to provide feedback and comments, a post -circulation
meeting, and small, focused group meetings. The post -circulation meeting provided an
overview of the project and an opportunity to gather initial feedback and comments.
Following this, focused group meetings were strategically organized around topic areas
including zoning compliance, development planning, heritage planning, policy planning,
building and emergency services, servicing and utilities, environment and urban forestry,
transit and transportation planning, and bylaw enforcement. Written comments were
received from agencies including Bell, Grand River Conservation Authority, Waterloo
Catholic District School Board, Waterloo Region District School Board, Fire Services,
Kitchener Utilities (gas, water, sanitary and stormwater services), Engineering Division,
Sanitary and Stormwater Utility, Building Division, Parks Design and Development and the
Region of Waterloo. The written comments received from staff and agencies have been
included in Attachment `H'.
Comments received from staff and agencies have been taken into consideration and
reflected in the proposed changes as discussed throughout this report. There are,
however, some comments that are relevant information for implementing additional
dwelling units, some that are out of the scope of this project, and some which may be
addressed through other bodies of work. These are discussed below.
Infrastructure, Services and Facilities Capacity
As Kitchener grows in population, there will be an increase in demand for community
infrastructure (road, water, gas, hydro, sanitary and stormwater), community services
(police, fire, transit, etc.), and community facilities (schools, community centres, parks,
hospitals, etc.). It is challenging to predict locations where additional units will be added,
and how quickly uptake will occur. Based on past experience, staff expect that uptake will
gradual and dispersed. To effectively plan for community infrastructure, services, and
facilities, it is important to monitor the locational uptake of additional dwelling units closely.
On-site Utilities
The utility providers allow one set of services for a lot. It is at the cost of developers and
home owners to make upgrades (for example, to waterlines and electrical panels) for
capacity, extend and connect services to the additional dwellings detached, and provide
separate utility meters. It is important for property owners to know that there may be a
need to upgrade on-site utilities for capacity and that it is critical to engage utility providers
early in the development process to understand the extent of additional costs that may be
incurred.
Page 40 of 343
Development Fees for 4 Units
Under the Development Charges Act, the Planning Act, and the Education Act, the Region
of Waterloo, the City of Kitchener, and the School Boards collect fees associated with
residential development for the development of various services, facilities, and
infrastructure. The provision of a 4t" unit is currently not exempt from City and Regional
development charges or education development charges. However, the City's Parkland
Dedication Policy does exempt additional dwelling units (including a 4t" unit) from parkland
dedication fees. These fees (development charges, education development charges, and
parkland dedication) can add significant cost to projects and impact the financial feasibility
of development, however are important to ensure that the Region, City and School Boards
can provide new and/or enhanced services, facilities, and infrastructure.
Proaerty Standards and By-law Enforcement
Planning has consulted with By-law Enforcement staff regarding zoning compliance and
other property standards considerations. The City will continue to enforce by-law
regulations on a complaint basis, including matters associated with illegal driveway
widenings and complaints associated with on -street parking, which are often of concern to
residents.
Storage of waste (garbage, compost and recycling) is also frequently identified as an area
of concern to enforcement staff. As a result of provincial changes to the Planning Act, Site
Plan Control is no longer available as a tool to enforce aspects of site function including
garbage storage. Staff is of the opinion that waste management cannot be effectively
regulated through the Zoning By-law, however by-law enforcement staff are exploring
revisions to the Property Standards By-law. Contemplated updates will enhance current
provisions for garbage storage on properties with additional dwelling units and where there
are multiple dwellings with 10 units or fewer, to ensure that garage is stored in a safe,
secure and sanitary way. Recommendations resulting from this review apply more broadly
than the scope of this report, will be provided as part of a separate report in Q2 of 2024.
Urban Forest Canopy
Kitchener's 2023-2026 Strategic Plan notes strategic goals, goal statements and actions to
achieve the community's shared vision for the future of Kitchener. Implementing the tree
canopy target plan is an action noted in the Strategic Plan. Although a key corporate and
Council priority, provision of additional housing and residential intensification through
enabling 4 units may directly impact component trees of the urban forest, and compromise
achieving the urban tree canopy targets in some areas of the city. City staff is in the
process of evaluating and updating its tree conservation processes through a separate
body of work. This work is considering further regulating the impact and damage to trees
under these and other circumstances.
It is important for property owners to note that the provision of additional dwelling units,
particularly detached dwellings, may impact trees shared between neighbours and/or trees
on adjacent properties. When development impacts shared/boundary trees or those on
adjacent private properties, it is a civil matter and the City does not get involved. In
addition, certain properties may be the subject of approved tree preservation plans and
Page 41 of 343
obligations to maintain trees registered on title through subdivision, site plan, or other
development agreements.
Further, although driveway widenings are regulated through zoning bylaw regulations,
driveway apron/boulevard widening beyond the property lines or cutting the curb is subject
to a City permit that considers impact on existing City trees. However, where there are no
existing City trees, this may lead to loss of adequate soil volumes for planting trees on City
property in the future. In addition to City policies and by-laws such as the Tree
Conservation Bylaw, other legislation, or regulations such as the Ontario Endangered
Species Act, the Regional Woodland Conservation Bylaw etc. may also be applicable.
Next Steps
The recommendations contained in this report create a regulatory framework that will
enable more dwelling units on more lots in Kitchener. While the zoning may permit
additional units, the City is reliant on homeowners and developers to build these additional
units. With the support of the Housing Accelerator Fund, staff will prepare tools to make it
easier to work through that approval process which can seem daunting for some
homeowners and developers. Next steps in 2024 include:
• identifying a core team of staff across divisions who will take the lead on
coordinating with customers from inquiry to final inspection to good neighbour
property use (e.g., waste storage, parking, etc.);
• collectively, the team will identify how the approvals and inspections processes can
be streamlined to remove barriers and simplify from a customer experience
perspective;
• update the City's website with tools and resources to ensure that it is easy to locate
and understand information on building and operating four units; and,
• on-going monitoring of uptake, functioning of new zoning rules, the approvals
process and timelines, and bylaw complaints to look for ways to continue to support
four -unit developments in our neighbourhoods.
Conclusions
The proposed Official Plan and Zoning Bylaw amendments aim to enable four units as a
form of gentle density in neighbourhoods across Kitchener. The proposed zoning rules
seek to balance site functionality and flexibility in built form while mitigating potential
impacts on the community. While as -of -right permissions will enable four units on more
than 41,000 residential lots in Kitchener, staff are of the opinion that growth will be gradual
within neighbourhoods which will allow time to monitor impacts and determine strategies
for mitigation (e.g., monitoring service capacity or adjusting zoning rules). Additionally,
staff will support uptake among builders and property owners through a comprehensive
implementation strategy to remove barriers and simplify processes. Staff is of the opinion
that the proposed amendments align with Provincial, Regional and City planning policy
frameworks and represent good planning while supporting local, provincial and federal
housing targets.
STRATEGIC PLAN ALIGNMENT:
This report supports the delivery of core services.
Page 42 of 343
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 — This report has been posted to the City's website with the agenda in advance of
the committee meeting. A notice of Community Engagement was placed the Waterloo
Region Record on January 5, 2024 and January 12, 2024. Further, a notice of Statutory
Public Meeting was in the Waterloo Region Record on March 1, 2024.
CONSULT — Community engagement included:
o Enabling Four Units online engagement page on Engage Kitchener launched
December 2023;
o A Virtual Community Meeting on January 17, 2024;
o Three (3) public Open Houses on January 20, 2024 at the Kitchener Market,
January 23, 2024 at the Stanley Park Community Centre, and January 31, 2024
at the Forest Heights Community Centre;
o One-on-one discussions by phone, in-person at the city hall service center, and
via email;
o Consultation with the Kitchener Development Liaison Committee on January 19,
2024 and February 23, 2024; and,
o A Development Industry Workshop on January 31, 2024.
PREVIOUS REPORTS/AUTHORITIES:
• Municipal Act, 2001
• Planning Act, R.S.O. 1990, c. P.13
• Provincial Policy Statement, 2020
• A Place to Grow, 2020
• Regional Official Plan and Regional Official Plan Amendment 6
• City of Kitchener Official Plan, 2014
• City of Kitchener Zoning By-law 2019-051
• City of Kitchener Zoning By-law 85-1
• Housing for All — City of Kitchener Housing Strategy (DSD -20-214)
• City of Kitchener Municipal Housing Pledge (DSD -2023-063)
• Enabling Missing Middle and Affordable Housing(DSD-2023-160)
• Implementation of Bill 13, Bill 109 and Bill 23 (DSD -2023-239)
• Missing Middle Housing Motion to Support Housing Affordability (October 16,
2023)
0 AN I ATM 41l WS
Janine Oosterveld, Manager, Customer Experience & Project Management
Darren Kropf, Manager, Active Transportation and Development
APPROVED BY: Justin Readman, General Manager, Development Services
Page 43 of 343
ATTACHMENTS:
Attachment A —
Proposed Official Plan Amendment (2014 Official Plan)
Attachment B1
— Proposed Zoning By-law Amendment 2019-051
Attachment B2
— Proposed Zoning By-law Amendment 85-1
Attachment C1
— Amendment to Zoning B -law 2019-051 with Rationale
Attachment C2
— Amendment to Zoning By-law 85-1 with Rationale
Attachment D —
Newspaper Notice
Attachment E —
Municipal Scan
Attachment F —
Lot Size and Built Form Analysis
Attachment G1
— Engagement and Public Comments
Attachment G2
— Survey Responses
Attachment G3
— Email Correspondence
Attachment G4
— What We Heard (Open Houses and Development Industry Workshop)
Attachment H —
Agency Comments
Page 44 of 343
AMENDMENT NO. ## TO THE OFFICIAL PLAN (2014)
OF THE CITY OF KITCHENER
CITY OF KITCHENER
Page 45 of 343
AMENDMENT NO. ## TO THE OFFICIAL PLAN (2014)
OF THE CITY OF KITCHENER
CITY OF KITCHENER
INDEX
SECTION 1 TITLE AND COMPONENTS
SECTION 2 PURPOSE OF THE AMENDMENT
SECTION 3 BASIS OF THE AMENDMENT
SECTION 4 THE AMENDMENT
APPENDICES
APPENDIX 1 Notice of the Meeting of Planning and Strategic Initiatives Committee
of March 25, 2024
APPENDIX 2 Minutes of the Meeting of Planning and Strategic Initiatives Committee
— March 25, 2024
APPENDIX 3 Minutes of the Meeting of City Council — March 25, 2024
Page 46 of 343
AMENDMENT NO. ## TO THE OFFICIAL PLAN (2014) OF THE CITY OF KITCHENER
SECTION 1 —TITLE AND COMPONENTS
This amendment shall be referred to as Amendment No. _ to the Official Plan of the City of
Kitchener. This amendment is comprised of Sections 1 to 4 inclusive.
SECTION 2 — PURPOSE OF THE AMENDMENT
The purpose of the Official Plan Amendment is to incorporate certain modifications to the text of
the Official Plan to enable up to four dwelling units to be located on lands which currently permit
a single detached dwelling, semi-detached dwelling or street townhouse dwelling.
SECTION 3 — BASIS OF THE AMENDMENT
In order to provide additional housing options, the City of Kitchener is seeking to permit up to four
dwelling units on parcels of land which currently permit a single detached dwelling, semi-detached
dwelling or street townhouse dwelling. The proposed change deletes policy 4.C.1.23 which
currently permits up to 3 units on a lot, and which specifies how the units must be arranged within
buildings. The proposed policy replaces the existing policy and will permit up to 4 units and
continues to enable these units to be further regulated by the zoning by-law which will specify lots
sizes, setback requirements, parking, and other matters. The additional dwelling units could
include four units in a principal dwelling, three units in a principal dwelling and one unit in an
additional dwelling (detached) or two units in a principal dwelling and two units in an additional
dwelling (detached), and may include a new purpose built principal dwelling with up to 4 dwelling
units.
As articulated in the Planning Discussion contained in report DSD -2024-066, staff is of the opinion
that that proposed Official Plan Amendment is consistent with and conforms to the Planning Act,
Provincial Policy Statement (2020), the Places to Grow Act (2005) and A Place to Grow: Growth
Plan for the Greater Golden Horseshoe (2020) and the Regional Official Plan (2010, including
ROPA #6), and represents good planning.
SECTION 4—THE AMENDMENT
The City of Kitchener Official Plan is hereby amended as follows:
Part C, Section 4.C.1 is amended by deleting "Policy 4.C.1.23" in its entirety and
replacing it with the following:
"4.C.1.23 The City may permit up to three additional dwelling units, attached
and/or detached, on a lot which contains a single detached dwelling, a
semi-detached dwelling or a street -townhouse dwelling as the principal
use, unless otherwise limited by the policies of this Plan, and in
accordance with the City's Zoning By-law, in order to provide additional
housing options to Kitchener homeowners and residents.
Additional dwelling units will be permitted as follows:
Page 47 of 343
a) The addition of up to three additional dwelling units
(attached), within a single detached dwelling, a semi-
detached dwelling or a street -townhouse dwelling;
b) The addition of up to two additional dwelling units (attached)
within a single detached dwelling, a semi-detached dwelling
or a street -townhouse dwelling and one additional dwelling
unit (detached); and
c) The addition of up to one additional dwelling unit (attached)
within a single detached dwelling, a semi-detached dwelling
or a street -townhouse dwelling and two additional dwelling
units (detached).
Additional dwelling units (attached) and additional dwelling units
(detached) may be further regulated by the City's Zoning By-law."
Page 48 of 343
APPENDIX 1 Notice of the Meeting of Planning and Strategic Initiatives
Committee of March 25, 2024
NOTICE OF PUBLIC MEETING
Enabling Four Units
Have Your Voice Heard!
Planning & Strategic Initiatives Committee
Date- lurch 25, 2024
Location, Council Chambers,
Kitchener City Hall
200 King, Street West
vrVirtual Zoom Meeting
Go to kitchenerca/meetings
and select;
• Current agendas and reports
(posted 10 days before meeting)
*Appear as a delegation
• Wzitch a meeting
To learn more about this project, including
Information on your appeal rights, visit
000
ww,lCitchenerca/
PlanningApplications
or contact
AdditiunaI Parking Zoning Katie AnderL Project Manager
Dwelling Reductions Regulations enabl.ingfourunit kitchener.ca
Units 519.741.2426
The City of Kitchener will consider City -initiated applications OPA23/020/K/KA and
7BA23%035/KA to amend the Official Plan and Zoning By-law. These amendments will
permit up to 4 dwelling units on lots which permit a single detached dwelling,
semi-detached dwelling; or street townhouse dwelling, subject to regulations for lot
sizes, parking, landscaping and built form.
Page 49 of 343
APPENDIX 2 Minutes of the Meeting of Planning and Strategic Initiatives
Committee of March 25, 2024
Page 50 of 343
APPENDIX 3 Minutes of the Meeting of City Council — March 25, 2024
Page 51 of 343
BY-LAW NUMBER
OF THE
CORPORATION OF THE CITY OF KITCHENER
(Being a by-law to amend By-law 2019-051, as amended,
known as the Zoning By-law for the City of Kitchener
— Enabling Four Units)
WHEREAS it is deemed expedient to amend By-law 2019-051;
NOW THEREFORE the Council of the Corporation of the City of Kitchener enacts as
follows:
Section 3 of By-law Number 2019-051 is amended to add the following new definitions in
proper alphabetical order:
"Bicycle Parking Stall, Class C — means a weather protected area with controlled access
in which a bicycle may be parked, including but not limited to a private garage, an
accessory building, a bicycle locker, or an indoor storage alcove.
Building Footprint — means the horizontal area of a building, as seen in plan, measured
from the outside of all exterior walls and supporting columns.
Dwelling (Detached), Additional — means the use of a building containing one or two
additional dwelling unit(s) (detached) on the same lot as a single detached dwelling, semi-
detached dwelling, or a street townhouse dwelling (as the principal use). An additional
dwelling (detached) is not an accessory building.
Unobstructed Walkway - means a path of travel providing access to the principal
entrance of an additional dwelling unit (attached) or additional dwelling unit (detached)
and shall be unencumbered by obstructions including but not limited to: stairs, decks and
porches (except those which form part of the path of travel to the principal entrance);
parking spaces; driveways; chimney breasts; window wells; balconies; secure outdoor
areas associated with pools; mechanical, heating, ventilation, air-conditioning equipment
and utility meters; and amenity structures such as playgrounds, garden trellises,
pergolas. An unobstructed walkway may be shared between more than one dwelling unit
on a lot."
2. Section 3 of By-law Number 2019-051 is amended to add the portions of the below text that
are highlighted in grey, and delete portions of the below text with a strikethrough in the
following definitions:
Page 52 of 343
Dwelling - means a building containing one or more dwelling units and can include a
single detached dwelling, semi-detached dwelling, street townhouse dwelling, add+t+epa4
Gl WelliRg „r;+ (attaGhed) additional dwelling 4PA (detached), cluster townhouse dwelling,
multiple dwelling, small residential care facility, or large residential care facility.
Dwelling, Multiple - means the use of a building containing five few or more dwelling
units, or a building containing two or more dwelling units where there are a minimum of 5
dwelling units located on a lot, and can include a stacked townhouse dwelling and a back-
to-back townhouse dwelling. A multiple dwelling is not a street townhouse dwelling, mixed
use building- or cluster townhouse dwelling, SiPg;e G19ta^hted_ .-144P-11in , With additippsi
�a#aGhqd).
Dwelling Unit (Detached), Additional - means the use of a building where a separate
self-contained dwelling unit is located in adetar#ed-an additional dwelling (detached)
3. Subsection 4.5 of By-law 2019-051 is amended to add the portions of the below text that are
highlighted in grey:
a) "No buildings, structures, motor vehicles, food cart, signs, landscaping, or other
impediments shall obstruct visibility within a corner visibility triangle, corner visibility
area or driveway visibility triangle. An obstruction to visibility shall not include objects
0.9 metres or less in height from the ground, or objects higher than 5 metres in height
from the ground. This provision does not apply to the location of fences constructed in
accordance with and regulated by Chapter 630 (Fences) of The City of Kitchener
Municipal Code, or motor vehicles parked in a parking space on a driveway.
b) A corner visibility area shall be required in MIX zones. One leg of both triangles shall
measure 6 metres and the other leg of both triangle shall measure 3 metres.
Subsection a) shall not apply to existing buildings or new construction which replaces
an existing building with the same building footprint within the corner visibility area.
c) A corner visibility area shall be required in SGA zones. One leg of both triangles shall
measure 5 metres and the other leg of both triangle shall measure 3 metres.
Subsection 3 a) shall not apply to existing buildings or newconstruction which replaces
an existing building with the same building footprint within the corner visibility area.
d) A corner visibility triangle shall be required in all zones except SGA zones and MIX
zones and shall be measured at 7 metres from the point of intersection of the street
lines.
Page 53 of 343
e) A driveway visibility triangle shall be required in all zones except SGA zones and MIX
zones and shall be measured from the point of intersection of a meet lot line and the
edge of a driveway a distance of 3 metres from the street lot line and 4.5 metres from
the edge of the driveway."
4. The second title of Table 4-2 of By-law 2019-051 is amended to add the portions of the below
text that are highlighted in grey, and delete portions of the below text with a strikethrough:
"Permitted home occupation use in a dwelling unit within a single detached dwelling with
ae additional dwelling unit(s) (attached) or additional dwelling unit(s) (detached), semi-
detached dwelling unit with a additional dwelling unit(s) (attached) or additional dwelling
unit(s) (detached), street townhouse dwelling with an additional dwelling unit(s) (attached)
or additional dwelling unit(s) (detached), cluster townhouse dwelling, or multiple dwelling
(9)(10).,,
5. Subsection 4.12 of By-law 2019-051 is amended by inserting subsection c) thereto:
"c) A maximum of four (4) dwelling units are permitted on a lot which contains a
single detached dwelling, semi-detached dwelling unit or street townhouse
dwelling unit, subject to the regulations contained herein. The maximum number
of units shall include the principal dwelling unit, additional dwelling unit(s)
(attached) and additional dwelling unit(s) (detached)."
6. Subsection 4.12.1 of By-law 2019-051 is amended to add the portions of the below text that
are highlighted in grey, and delete portions of the below text with a strikethrough:
"4.12.1 One Additional Dwelling Unit (Attached)
One additional dwelling unit (attached) may be permitted in association with a single
detached dwelling, semi-detached dwelling unit or street townhouse dwelling unit in
accordance with the regulations specified by the zone category in which an additional
dwelling unit (attached) is permitted, and the dwelling type in which the additional
dwelling unit (attached) is located and 0A addit+ea subject to and as amended by the
following:
a) one additional dwelling unit (attached) shall only be located in the same building as a
single detached dwelling, semi-detached dwelling, or street townhouse dwelling;
b) an additional dwelling unit (attached) shall be connected to full municipal services;
Unless otherwise provided for in this By-law, in any zone where a single detached
dwelling with one additional dwelling unit (attached) is permitted, a new dwelling with two
dwelling units shall also be permitted and considered a single detached dwelling with an
additional dwelling unit (attached) in accordance with regulations specified by the zone
category and in this section."
Page 54 of 343
7. Subsection 4.12.2 of By-law Number 2019-051 is deleted in its entirety and replaced with the
following:
"4.12.2 Two or Three Additional Dwelling Units (Attached)
Two (2) or Three (3) additional dwelling units (attached) may be permitted in association
with a single detached dwelling, semi-detached dwelling unit or street townhouse
dwelling unit in accordance with the regulations specified by the zone category in which
additional dwelling unit(s) (attached) are permitted, and the dwelling type in which the
additional dwelling unit(s) (attached) are located and subject to and as amended by the
following:
a) additional dwelling unit(s) (attached) shall only be located in the same building as a
single detached dwelling, semi-detached dwelling, or street townhouse dwelling;
b) additional dwelling unit(s) (attached) shall be connected to full municipal services;
c) a minimum of one pedestrian entrance to the principal building is required to face a
street line;
d) a maximum of two pedestrian entrances shall be permitted to face each street line,
except where more pedestrian entrances are existing;
e) an unobstructed walkway that is a minimum 1.1 metres in width, shall be provided
from a street to the principal entrance of each new additional dwelling unit (attached),
where the principal entrance is not located on a street line fagade.
f) where a lot is located farther than 800 metres from a Light Rail Transit (LRT) station
as shown on Appendix E, and outside the Central Neighbourhood Area as shown on
Appendix C — Central Neighbourhood Area the minimum lot area shall be 360 square
metres or in accordance with Table 7-2, 7-3 or 7-4, as may be applicable for the
principal dwelling type in which the additional dwelling unit (attached) is located,
whichever is greater;
g) where a lot is located farther than 800 metres from a Light Rail Transit (LRT) station
as shown on Appendix E, and outside the Central Neighbourhood Area as shown on
Appendix C — Central Neighbourhood Area the minimum lot width shall be 10.5
metres or in accordance with Table 7-2, 7-3 or 7-4, as may be applicable for the
principal dwelling type in which the additional dwelling unit (attached) is located,
whichever is greater;
h) the minimum front yard landscaped area shall be 20%, excluding surface walkways,
patios, decks, playgrounds or pathways;
i) the minimum rear yard landscaped area shall be 30%;
j) Unless otherwise provided for in this By-law, in any zone where a single detached
dwelling with two (2) or three (3) additional dwelling units (attached) are permitted, a
Page 55 of 343
new dwelling with three (3) or four (4) dwelling units shall also be permitted and
considered a single detached dwelling with additional dwelling units (attached) in
accordance with regulations specified by the zone category and in this section."
Subsection 4.12.3 of By-law Number 2019-051 is deleted in its entirety and replaced with the
following:
"4.12.3 Additional Dwelling (Detached)
An additional dwelling (detached) with one (1) or two (2) additional dwelling units
(detached) may be permitted in association with a single detached dwelling, semi-
detached dwelling unit or street townhouse dwelling unit in accordance with the
regulations specified by the zone category in which an additional dwelling unit
(detached) is permitted, and as amended by the following:
a) for the purposes of Section 4.12.3, the area that is designed to be a separate lot for
a street townhouse dwelling or semi-detached dwelling shall be considered to be a
lot as calculated by extending a straight line along the demising wall between
dwelling units to the front and rear property lines;
b) an additional dwelling (detached) shall only be permitted on the same lot as a single
detached dwelling, semi-detached dwelling or street townhouse dwelling;
c) an additional dwelling (detached) shall not be severed from the lot containing the
single detached dwelling, semi-detached dwelling unit or street townhouse dwelling
unit;
d) additional dwelling units (detached) shall be connected to full municipal services;
e) the building footprint of the additional dwelling (detached) shall not exceed 80
square metres, and shall comply with the maximum lot coverage included in Table
7-2, 7-3 or 7-4;
f) where a lot is located farther than 800 metres from a Light Rail Transit (LRT) station
as shown on Appendix E, and outside the Central Neighbourhood Area as shown
on Appendix C — Central Neighbourhood Area the minimum lot area shall be 360
square metres or in accordance with Table 7-2, 7-3 or 7-4 as may be applicable for
the principal dwelling type with which the additional dwelling unit (detached) is
associated, whichever is greater;
g) where a lot is located farther than 800 metres from a Light Rail Transit (LRT) station
as shown on Appendix E, and outside the Central Neighbourhood Area as shown
on Appendix C — Central Neighbourhood Area the minimum lot width shall be 10.5
metres in accordance with Table 7-2, 7-3 or 7-4, as may be applicable for the
principal dwelling type with which the additional dwelling unit (detached) is
associated, whichever is greater;
h) the maximum building height for an additional dwelling (detached) shall be:
Page 56 of 343
i) 4.5 metres for a hip, gable, shed, or gambrel roof, measured to the mid point
between the eaves and the peak of the roof, excluding the eaves of any
projections;
i) for a shed roof the lower exterior wall shall face a rear lot line or the
nearest side lot line, except where the lot line is a street line or lane;
ii) 4.5 metres for a mansard roof, measured to the deck line;
iii) 3 metres for a flat roof, measured to the peak of the roof.
i) despite subsection h), the maximum building height for an additional dwelling
(detached) where the principal dwelling has a building height equal to or greater
than 9.1 metres shall be:
i) 6.0 metres for a hip, gable, shed, or gambrel roof, measured to the midpoint
between the eaves and the peak of the roof, excluding the eaves of any
projections;
i) for a shed roof the lower exterior wall shall face a rear lot line or the
nearest side lot line, except where the lot line is a street line or lane;
ii) 6.0 metres for a mansard roof, measured to the deck line;
iii) 4.5 metres for a flat roof, measured to the peak of the roof.
Measurement of Building Height for Additional Dwelling Unit (Detached)
peak of mof
peak DFraaf
Buildheight hht eaves
height
FLAT HIP or
ROOF GABLE
ROOF
peak If '00 -
deck. i ne I peak
ak of roof
#•:ES _ _
I I I I highest elevaticm
6 ! of the finished
j) an additional dwelling (detached) which has a maximum building height of 4.5
metres shall have a minimum setback of 0.6 metres from a rear lot line and interior
side lot line;
k) an additional dwelling (detached) which exceeds a building height of 4.5 metres
shall have a minimum setback of 0.9 metres from a rear lot line and interior side lot
line; and notwithstanding the foregoing, where an interior side lot line or rear lot line
abuts a lane the minimum setback shall be 0.6 metres;
1) an additional dwelling (detached) shall not be located in the front yard of the
principal dwelling, and shall not be located in the area created by extending 5
metres from and parallel to any wall of rear fagade of the principal dwelling.
Illustration 4-2: Minimum Separation of Principal Dwelling and Additional Dwelling (detached)
Page 57 of 343
ADDITIONAL
DWELLING
4CETACHEDj
5.6M
DWELLING
STREET
ADDITIONAL
DWELLING
(DETACHED)
MM
5.01
DWELLING
STREET
AREA CREATED BY EXTENDING 5 METRES FROM AND PARALLEL
TO ANY WALLOP REAR FACADE OF THE PRINCIPAL DWELLING
m) an additional dwelling (detached) may be located in an exterior side yard of the
principal dwelling, and must be setback in accordance with the required exterior
side yard setback of the principal dwelling in the applicable zone;
n) an unobstructed walkway that is a minimum 1.1 metres in width, shall be provided
from a street to the principal entrance of each additional dwelling unit (detached);
o) For a lot containing three (3) or four (4) dwelling units, the minimum front yard
landscaped area shall be 20%, excluding surface walkways, patios, decks,
playgrounds or pathways;
p) For a lot containing three (3) or four (4) dwelling units, the minimum rear yard
landscaped area shall be 30%."
9. Subsection 4.12.3.1 of By-law 2019-051 shall be deleted in its entirety.
Page 58 of 343
10. Section 4.12.4 of By-law Number 2019-051 is amended to add the portions of the below text
that are highlighted in grey, and delete portions of the below text with a strikethrough:
"4.12.4 €suK Five to Ten Dwelling Units on a Lot
Au (4) Five (5) to ten (10) dwelling units on a lot without any non-residential use except
permitted home occupation uses shall be permitted in accordance with the regulations
specified by the zone category for the dwelling(s) and shall have:
a) a minimum of 20% street line facade opening which includes at least one (1)
pedestrian entrance to the principal building;
b) a minimum 20% of the front yard landscaped, excluding surface walkways, patios,
decks, playgrounds or pathways;
C) a minimum driveway width of 2.6 metres;
d) despite section 4.12.4 c), where a driveway is immediately adjacent to any building
or structure on a lot, the driveway including any curbing shall be a minimum 3.0
metres wide."
11. Section 5.3 e) of By-law Number 2019-051 is amended to add the portions of the below text
that are highlighted in grey, and delete portions of the below text with a strikethrough:
"e) Where a parking lot is provided for a development that does not require site plan
approval pursuant to Section 41 of the Planning Act, the following regulations shall
apply:
i) The parking lot shall be setback a minimum of 1.5 metres from side lot line
and rear lot line. Notwithstanding the foregoing, a parking lot may be
located as close to an interior side lot line as the driveway which provides
access to the parking lot, and only for the interior side lot line on the same
side of the lot as the driveway; ap,
ii) The minimum drive aisle width shall be 6 metres; and.
iii) Parking spaces and drive aisles shall not be located within the front yard or
an exterior side yard. In no case shall any parking spaces be located within
3 metres of the front lot line, exterior side lot line or a street line.
iv) where a driveway is immediately adjacent to any building or structure on a
lot, the driveway including any curbing shall be a minimum 3.0 metres
wide."
Page 59 of 343
12. Section 5.3.3 of By-law Number 2019-051 is amended to add the portions of the below text
that are highlighted in grey, and delete portions of the below text with a strikethrough:
a) "On a lot containing a single detached dwelling, semi-detached dwelling, street
townhouse dwelling, additional dwelling unit(s) (attached), additional dwelling
unit(s) (detached), small residential care facility, lodging house having less than 9
residents, or home occupation:
i) Parking spaces located within a building shall be tesated setback a
minimum distance of 6 metres from a street line;
ii) DecAite Qi ihcentOGR i\ V.4here bAgG Ar mere parkiRg spares are reel iirerl
Arse Y1a*iRg crane may IAnate Art the rlrnie;AAA �eiithiR 6 MAtrec Af the
fFG9Rt let lime Ar ev4eriAr cilJe let lime and may he a tandervm pa*iRg serine
Up to three required parking spaces may be tandem parking spaces;
a444,
Illustration 5-1: One Tandem
Parking Space — Option A
DWELLING
STREET
Illustration 5-2: One Tandem
Parking Space — Option B
iii) One parking space located on a driveway shall be setback a minimum
distance of 0.5 metres from a street line neSpite S bSentien ii\ ,.,here
three Y1r]*iRg spaces ere rem Hired GR a let erre Pa*iRg Space may lenete
eIA driveway WithiR 6- MtatrtaC Af frent'At ImAte A_.teterer ci�ontr
line apd- three parking spaGec may he taR dem parking spares; a444
iv) Not more than one parking space for a home occupation may be located
in a rear yard, except in the case of a corner lot, a through lot, or a lot
abutting a lane;
Page 60 of 343
DWELLING
r
3,0
2.6 6
2M
STREET
iii) One parking space located on a driveway shall be setback a minimum
distance of 0.5 metres from a street line neSpite S bSentien ii\ ,.,here
three Y1r]*iRg spaces ere rem Hired GR a let erre Pa*iRg Space may lenete
eIA driveway WithiR 6- MtatrtaC Af frent'At ImAte A_.teterer ci�ontr
line apd- three parking spaGec may he taR dem parking spares; a444
iv) Not more than one parking space for a home occupation may be located
in a rear yard, except in the case of a corner lot, a through lot, or a lot
abutting a lane;
Page 60 of 343
V) where three (3) or more dwelling units are located on a lot, parking may
be located in a parking lot in accordance with the regulations of sections
5.3, 5.3.1, and 5.3.3 b) i); and
vi) where three (3) or more dwelling units are located on a lot, and despite
regulations in Table 5-2 and 5-3, a driveway located in the rear yard may
be permitted to have a maximum width of up to 8 metres."
13. Section 5.4 a) of By-law Number 2019-051 is amended to delete portions of the below text
with a strikethrough:
a) "For all residential uses other than large residential care facilities, multiple
dwellings f+11RtaiY iRg 4 Gr rrm9-ro !.n/oII1NlY , Rits and mixed use buildings, a required
parking space shall have direct access from a street or lane via a driveway."
14. Section 5.5 of By-law Number 2019-051 is amended by inserting subsection f) thereto:
f) "Notwithstanding subsection c) and e), Class C Bicycle Parking Stalls are not
required to provide overhead clearance, and are not required to abut an access
aisle."
15. Table 5-5 of By-law Number 2019-051 for Additional Dwelling Unit (Attached) and Additional
Dwelling Unit (Detached) is amended to add the portions of the below text that are highlighted
in grey, and delete portions of the below text with a strikethrough, and to add footnote (5)
thereto:
Table 5-5: Regulations for Minimum and Maximum Parking Requirements
Additional
Lands within 800
Lands farther than
Lands farther than 800
Dwelling Unit
Minimum
metres of a Light
800 metres of a Light
metres from a Light
(Attached)
and Additional
parking
n/a
n/a
1 peF 649 g upit (5)
Dwelling Unit
spaces:
Station as shown on
Station as shown on
(Detached)
5) Parking spaces and bicycle parking stalls for additional dwelling unit(s) (attached)
and/or additional dwelling unit(s) (detached) shall be provided at a minimum rate as
specified within Table 5-5-1.
Table 5-5-1: Regulations for Minimum Parking Requirements for Lots containing
Additional Dwelling Unit(s) (Attached) and/or Additional Dwelling Unit(s)
(Detached)
Page 61 of 343
Lands within 800
Lands farther than
Lands farther than 800
metres of a Light
800 metres of a Light
metres from a Light
Trail Transit (LRT)
Rail Transit (LRT)
Rail Transit (LRT)
Station as shown on
Station as shown on
Page 61 of 343
16. Table 7-1 of By-law Number 2019-051 is amended to delete portions of the below text with a
strikethrough:
"Table 7-1: Permitted Uses within the Residential Zones
Use
RES -1
Station (Appendix
E)
Appendix E, and
within the Central
Neighbourhood Area
(Appendix C)
Appendix E, and
outside the Central
Neighbourhood Area
(Appendix C)
Additional
Minimumn
No minimum
0.3 per dwelling unit
0.6 per dwelling unit
Dwelling
parking
✓
✓
✓
Unit
spaces:
Additional Dwelling Units
(Attached)(1)
✓
✓
(Attached)
Minimum
0.5 per dwelling unit
0.5 per dwelling unit
0.5 per dwelling unit
and
Class C
without a private
without a private
without a private
Additional
Bicycle
garage, where there
garage, where there
garage, where there
Dwelling
Parking
are a minimum of 3
are a minimum of 3
are a minimum of 3
Unit
Stalls:
dwelling units on a
dwelling units on a
dwelling units on a lot.
(Detached)
✓(4)
lot.
lot.
Townhouse Dwelling — Cluster
(7)
16. Table 7-1 of By-law Number 2019-051 is amended to delete portions of the below text with a
strikethrough:
"Table 7-1: Permitted Uses within the Residential Zones
Use
RES -1
RES -2
RES -3
RES -4
RES -5
RES -6
RES -7
Residential Uses
Single Detached Dwelling
✓
✓
✓
✓
✓
Additional Dwelling Units
(Attached)(1)
✓
✓
✓
✓
✓
Additional Dwelling Units
(Detached)(2)
✓
✓
✓
✓
✓
Semi -Detached Dwelling
✓
✓
✓
Townhouse Dwelling — Street
✓(3)
✓(4)
Townhouse Dwelling — Cluster
(7)
✓(4)
✓
Multiple Dwelling (7)
✓
✓
✓
Lodging House
✓
✓
✓
✓
Continuing Care Community
✓
✓
✓
Hospice
✓
✓
✓
✓
✓
✓
Residential Care Facility, Small
✓
✓
✓
✓
✓
✓
Residential Care Facility, Large
✓
✓
✓
Non -Residential Uses
Artisan's Establishment (5)
✓
✓
Community Facility (5)
✓
✓
Convenience Retail (5)
✓
✓
Day Care Facility (5)
✓
✓
Financial Establishment (5)
✓
Health Office (5)
✓
Page 62 of 343
Home Occupation (6)
✓
✓
✓
✓
✓
✓
✓
Office (5)
✓
✓
Personal Services (5)
✓
Studio (5)
✓
✓
17. "Additional Regulations for Permitted Uses Table 7-1" of By-law Number 2019-051 is
amended to add the portions of the below text that are highlighted in grey, and delete
portions of the below text with a strikethrough:
"Additional Regulations for Permitted Uses Table 7-1
(1) Shall be permitted in accordance with 4.12.1 and 4.12.2.
(2) Shall be permitted in accordance with 4.12.3.
(3) The maximum number of dwelling units in a dwelling shall be 4.
(4) The maximum number of dwelling units in a dwelling shall be 8.
(5) Permitted non-residential uses must be located within a multiple dwelling (despite the
definition of multiple dwelling in Section 3) and are limited in size in accordance with
the regulations in Table 7-6.
(6) Shall be permitted in accordance with 4.7.
(7) 45 to 10 dwelling units on a lot provided without any non-residential use except
permitted home occupation uses shall be permitted in accordance with the regulations
in Table 7-5 or Table 7-6 as applicable and Section 4.12.4."
18. "Additional Regulations for Permitted Uses Table 7-2" of By-law Number 2019-051 is
amended to add the portions of the below text that are highlighted in grey, and delete
portions of the below text with a strikethrough:
"Additional Regulations for Single Detached Dwellings Table 7-2
(1) The minimum lot area shall be 0.4 hectares on lots without full municipal services.
(2) The minimum lot width shall be 30.0 metres on lots without full municipal services.
(3) For lands identified in Appendix D — Established Neighbourhoods Area, the minimum
and maximum front yard shall be in accordance with Section 7.6.
(4) A combined total of 55 percent for all buildings and structures on the lot. Accessory
buildings or structures, whether attached or detached, and additional dwellings
(detached) shall not exceed 15 percent.
(5) The regulations within Table 7-2 shall not apply to an existing single detached
dwelling on an existing lot with or without one existing additional dwelling unit
(attached).
(6) For lands identified in Appendix C — Central Neighborhoods, the maximum building
height shall be in accordance with Section 7.5."
Page 63 of 343
19. "Additional Regulations for Permitted Uses Table 7-3" of By-law Number 2019-051 is
amended to add the portions of the below text that are highlighted in grey, and delete
portions of the below text with a strikethrough:
"Additional Regulations for Semi -Detached Dwelling Unit Table 7-3
(1) For lands identified in Appendix D — Established Neighbourhoods Area, the minimum
and maximum front yard shall be in accordance with Section 7.6.
(2) A combined total of 55 percent for all buildings and structures on the lot. Accessory
buildings or structures, whether attached or detached, and additional dwellings
(detached) shall not exceed 15 percent.
(3) The regulations within Table 7-3 shall not apply to an existing semi-detached
dwelling on an existing lot with or without one existing additional dwelling unit
(attached).
(4) For land identified in Appendix C — Central Neighborhoods, the maximum building
height shall be in accordance with Section 7.5."
20. "Additional Regulations for Permitted Uses Table 7-4" of By-law Number 2019-051 is
amended to add the portions of the below text that are highlighted in grey, and delete
portions of the below text with a strikethrough:
"Additional Regulations for Street Townhouse Dwelling Units Table 7-4
(1) For lands identified in Appendix D — Established Neighbourhoods Area, the minimum
and maximum front yard shall be in accordance with Section 7.6.
(2) Each dwelling unit shall have an unobstructed access at grade or ground floor level,
having a minimum width of 0.9 metres, from the front yard to the rear yard of the lot
either by:
a) direct access on the lot without passing through any portion of the dwelling unit;
or,
b) direct access through the dwelling unit without passing through a living or
family room, dining room, kitchen, bathroom, bedroom, or recreation room or
any hallway that is not separated by a door to any such room; or,
c) access over adjacent lands which, if the lands are not owned by the City or the
Region, is secured by a registered easement.
(3) A combined total of 55 percent for all buildings and structures on the lot. Accessory
buildings or structures, whether attached or detached, and additional dwellings
(detached) shall not exceed 15 percent.
(4) The regulations within Table 7-4 shall not apply to an existing street townhouse
dwelling on an existing lot with or without one existing additional dwelling unit
(attached).
(5) For lands identified in Appendix C — Central Neighborhoods, the maximum building
height shall be in accordance with Section 7.5."
21. Table 7-6 of By-law Number 2019-051 is amended to delete portions of the below text with a
strikethrough:
Page 64 of 343
Table 7-6: For Multiple Dwellinas and Non -Residential Uses
Regulation
RES -1
RES -2
RES -3
DCrccv-446.)
RES -5 (6)
RES -6 (6)
RES -7 (6)
Minimum Lot Area
4954:g-'
495m2
Minimum Lot Width
4
19.0m{�
30.Om
30.Om
Minimum Front Yard
or Exterior Yard
4.5m (84
4.5m (8)
3.Om
3.Om
Setback
Minimum Interior Side
3.Om
4.5m
4.5m (5)
Yard Setback
Minimum Rear Yard
77 5PA
7.5m
7.5m
7.5m (5)
Setback
Minimum Landscaped
2404
20%
20%
20%
Area
Minimum Floor Space
0.6(2)(7)
2.0(2)(7)
Ratio
Maximum Floor
g_. &
0.6
2.0(2)
4.0(2)
Space Ratio
Minimum building
11.0 m
14.0 m
height
Maximum Building
11.()m (94
11.0m (9)
25.Om
(5)
Height
Maximum number of
a
3
8
storeys
Minimum number of
5
5
dwelling units
Maximum number of
4
dwelling units
Private Patio Area
{3l)
(3)
(3)
(3)
Maximum Gross
Floor Area of
600m2(4)
600m2(4)
Individual Non -
Residential Use
22. "Additional Regulations for Multiple Dwellings and Non -Residential Uses Table 7-6" of By-
law Number 2019-051 is amended to delete portions of the below text with a strikethrough:
"Additional Regulations for Multiple Dwellings and Non -Residential Uses Table 7-6
(1) A min gpi9 GlWelliRg with 4 GlWelliRg i ROtc Gh;all hrnio .; rr iii. . .M. ht 14iii-!fh ref I C. Q
(2) Combined total Floor Space Ratio of all uses on the lot.
(3) For multiple dwellings, each dwelling unit located at ground floor level shall have a
patio area adjacent to the dwelling unit with direct access to such dwelling unit.
(4) The total gross floor area of all non-residential uses shall not exceed 25% of the total
gross floor area on a lot.
(5) The maximum building height shall be 25 metres within 15 metres of a lot with a
(RES -6) Medium Rise Residential Six Zone.
(6) The regulations within Table 7-6 shall not apply to an existing multiple dwelling on an
existing lot.
Page 65 of 343
(7) Individual buildings will not be required to achieve the minimum floorspace ratio
where there is an approved Urban Design Brief that includes a Master Site Plan that
demonstrates the overall development can achieve the minimum floorspace ratio.
(8) For lands identified in Appendix D — Established Neighbourhoods Area, the minimum
and maximum front yard shall be in accordance with Section 7.6.
(9) For lands identified in Appendix C — Central Neighborhoods, the maximum building
height shall be in accordance with Section 7.5."
23. Site Specific Provision (312) of Section 19 of By-law Number 2019-051 is amended to add
the portions of the below text that are highlighted in grey to subsection b):
"b) the minimum front yard setback shall be 4.5 metres and no part of any building
used to accommodate off-street parking shall be located closer than 5.7 metres to
the front lot line, and the minimum setback to one parking space located on a
driveway shall be 0.2 metres."
24. Site Specific Provision (313) of Section 19 of By-law Number 2019-051 is amended to add
the portions of the below text that are highlighted in grey:
"Within the lands zoned RES -5 and shown as affected by this provision on Zoning Grid
Schedules 210, 249, and 250 of Appendix A, the following shall apply:
For single detached dwelling:
a) the minimum cornerlotwidth shall be 12 metres;
b) the minimum front yard setback shall be 4.5 metres and no part of any building
used to accommodate off-street parking shall be located closer than 5.7 metres to
the front lot line, and the minimum setback to one parking space located on a
driveway shall be 0.2 metres;
c) the minimum interior side yard setback shall be 0.6 metres on one side, 1.2 metres
on the other, and in the case of a corner lotthe 1.2 metres setback shall be applied
to the exterior side yard;
d) the minimum exterior side yard setback shall be 3 metres;
e) the minimum rear yard setback shall be 7 metres;
f) the maximum building height shall be 11.5 metres; and,
g) encroachments may be permitted for stairs and access ramps, provided the
minimum setback to the encroachment is 1 metre from the exterior side lot line.
For street townhouse dwelling:
a) the minimum lot width shall be 6 metres;
b) the minimum corner lot width shall be 9.5 metres;
c) the minimum front yard setback shall be 4.5 metres and no part of any building
used to accommodate off-street parking shall be located closer than 5.7 metres to
the front lot line, and the minimum setback to one parking space located on a
driveway shall be 0.2 metres;
Page 66 of 343
d) the minimum interior side yard setback shall be 0.6 metres (end units);
e) the minimum exterior side yard setback shall be 3 metres;
f) the minimum rear yard setback shall be 7 metres; g) the maximum lot coverage
shall be 60%, of which the habitable portion of the dwelling shall not exceed 50%
and the accessory buildings, whether attached or detached, shall not exceed 15%;
g) the maximum lot coverage shall be 60%, of which the habitable portion of the
dwelling shall not exceed 50% and the accessory buildings, whether attached or
detached, shall not exceed 15%;
h) the maximum building height shall be 11.5 metres;
i) encroachments may be permitted for stairs and access ramps, provided the
minimum setback to the encroachment is 1 metre from the exterior side lot line."
25. This By-law shall become effective only if Official Plan Amendment No._ (Enabling Four
Units) comes into effect, pursuant to Section 24(2) of The Planning Act, R.S.O. 1990, c. PA 3,
as amended.
PASSED at the Council Chambers in the City of Kitchener this day of , 2024.
Mayor
Clerk
Page 67 of 343
PROPOSED BY — LAW
'2024
BY-LAW NUMBER
OF THE
CORPORATION OF THE CITY OF KITCHENER
(Being a by-law to amend By-law 85-1, as amended,
known as the Zoning By-law for the City of Kitchener)
WHEREAS it is deemed expedient to amend By-law 85-1;
NOW THEREFORE the Council of the Corporation of the City of Kitchener
enacts as follows:
Section 4.2 of By-law Number 85-1 is hereby amended by adding the following new
definitions in proper alphabetical order:
""Additional Dwelling (Detached)" means a detached building containing one or
two additional dwelling unit(s) (detached) on the same lot as a single detached
dwelling, semi-detached dwelling, or street townhouse dwelling (as the principal
use). An additional dwelling (detached) is not an accessory building."
""Building Footprint" means the horizontal area of a building, as seen in plan,
measured from the outside of all exterior walls and supporting columns."
2. Section 4.2 of By-law Number 85-1 is hereby amended to add the portions of the
below text in the definition of "Multiple Dwelling" that are highlighted in grey, and
delete portions of the below text in the definition of "Multiple Dwelling" with a
strikethrough:
"Multiple Dwelling" means a building containing fe4r five (5) or more dwelling units
but shall not include a street townhouse dwelling or semi-detached dwelling."
3. Section 4.2 of By-law Number 85-1 is hereby amended to add the portions of the
below text in the definition of "Semi -Detached House" that are highlighted in grey,
and delete portions of the below text in the definition of "Multiple Dwelling" with a
strikethrough:
"Semi -Detached House" means that part of a semi-detached dwelling on one
side of the common wall, which may contain eRup to four (4) dwelling units."
4. Section 4.2 of By-law Number 85-1 is hereby amended to add the portions of the
below text in the definition of "Townhouse" that are highlighted in grey, and delete
portions of the below text in the definition of "Multiple Dwelling" with a strikethrough:
"Townhouse" means that part of a cluster townhouse dwelling or street
townhouse dwelling divided laterally but not internally by common walls or an end
Page 68 of 343
wall; . A townhouse located within a street townhouse dwelling may
contain APA AP WAA-up to four (4) dwelling units."
5. Section 4.2 of By-law Number 85-1 is hereby amended by adding the following new
definition in proper alphabetical order:
""Unobstructed Walkway" means a path of travel providing access to the
principal entrance of an additional dwelling unit (attached) or additional dwelling
unit (detached), and shall be unencumbered by obstructions including but not
limited to: stairs, decks and porches (except those which form part of the path of
travel to the principal entrance); parking spaces; driveways; chimney breasts;
window wells; balconies; secure outdoor areas associated with pools; mechanical,
heating, ventilation, air-conditioning equipment and utility meters; or amenity
structures such as playgrounds, garden trellises, and pergolas. An unobstructed
walkway may be shared between more than one dwelling unit on a lot."
6. Section 5.3 of By-law Number 85-1 is amended to add the portions of the below text
that are highlighted in grey:
"Except in D-1 and D-2 Zones, no obstruction to visibility, whether from buildings,
motor vehicles, landscaping or other impediments shall be permitted within a
corner visibility triangle or any driveway visibility triangle; provided however, this
shall not include objects 0.9 metres or less in height from grade. This regulation
does not apply to the location of fences constructed in accordance with and
regulated by Chapter 630 (Fences) of The City of Kitchener Municipal Code, or
motor vehicles parked in a parking space on a driveway. The purpose being to
allow complete view of oncoming motor vehicle and pedestrian traffic by other
such traffic entering the intersection or street."
7. Section 5.13.3 of By-law Number 85-1 is amended to add the portions of the below
text that are highlighted in grey:
".3 Home Businesses permitted in Duplex Dwellings, Multiple Dwellings,
Semi Detached Houses containing two dwelling units and Street
Townhouse Dwellings, or on any lot containing an Additional Dwelling Unit
(Detached) or an Additional Dwelling Unit (Attached):
Academic Instruction
Artisan's Establishment (not including retail or instruction)
Office"
8. Section 5.13.4 of By-law Number 85-1 is amended to add the portions of the below
text that are highlighted in grey:
".4 Regulations for Home Businesses in Duplex Dwellings, Multiple
Dwellings, Semi Detached Houses containing two dwelling units and Street
Townhouse Dwellings, or on any lot containing an Additional Dwelling
Unit(s) (Detached) or Additional Dwelling Unit(s) (Attached):
Page 69 of 343
a) The home business shall only be conducted by the person or persons resident
in the dwelling unit.
b) The home business shall be conducted wholly within an enclosed building.
c) No outdoor storage shall be permitted.
d) No storage or display of goods shall be visible from the street.
e) The home business shall not attract customers, clients or employees directly
to the lot containing the home business, except for academic instruction to one
customer or client at a time.
f) Only one home business shall be permitted for each dwelling unit and the gross
floor area of such use shall not exceed 15.0 square metres.
g) The building containing the home business shall comply with all applicable
regulations for the dwelling type in the zone in which it is located.
h) The home business shall not create noise, vibration, fumes, odour, dust, glare
or radiation which is evident outside of the building.
i) No combustion engine shall be used in the process of conducting any home
business."
9. Section 5.22, 5.22.1, 5.22.1.1 and 5.22.2 of By-law Number 85-1 are hereby deleted
and replaced with the following:
"5.22 ADDITIONAL DWELLING UNIT(S) (ATTACHED) AND ADDITIONAL
DWELLING UNIT(S) (DETACHED)
a) a maximum of four (4) Dwelling Units are permitted on a lot which contains a
Single Detached Dwelling, Semi -Detached House or a Townhouse located
within a Street Townhouse Dwelling. The maximum number of units shall
include the principal dwelling unit, Additional Dwelling Unit(s) (Attached) and
Additional Dwelling Unit(s) (Detached);
b) for the purposes of subsection 5.22 a) the area that is designed to be a
separate lot for Semi -Detached House or a Townhouse located within a
Street Townhouse Dwelling shall be considered to be a lot as calculated by
extending a straight line along the demising wall between Dwelling Units to
the front and rear property lines;
c) Additional Dwelling Unit(s) (Attached) and Additional Dwelling Units
(Detached) shall be connected to full municipal services;
d) Unless otherwise provided for in this By-law, on any lot where a Single
Detached Dwelling, Semi -Detached Dwelling or Street Townhouse Dwelling
is not permitted by a zone, however is permitted by a Special Use Provision,
Page 70 of 343
Additional Dwelling Units(s) (Attached) and Additional Dwelling Unit(s)
(Detached) shall also be permitted;
e) Unless otherwise provided for in this bylaw, where a Special Regulation
Provision permits a Duplex Dwelling to be counted as one Dwelling Unit, a
Single Detached Dwelling, with any permitted combination of Additional
Dwelling Unit(s) (Attached) and Additional Dwelling Units (Detached) shall
also be counted as one Dwelling Unit;
f) an Unobstructed Walkway that is a minimum 1.1 metres in width, shall be
provided from a street to the principal entrance of each new Additional
Dwelling Unit(s) (Attached) where the principal entrance is not located on a
Street Line Fagade, and each Additional Dwelling Unit (Detached). The
Unobstructed Walkway shall not be located within a required Parking Space;
g) where three (3) or more units are located on a lot, 2 bicycle parking stalls
shall be provided. Bicycle parking shall be located in a weather protected
area with controlled access, and may include a private garage, an accessory
structure, a bicycle locker, or an indoor storage alcove; and
h) Unless otherwise provided for in this By-law, in any zone where a Single
Detached Dwelling with Additional Dwelling Unit(s) (Attached) is permitted, a
new dwelling with up to four Dwelling Units shall also be permitted and
considered a Single Detached Dwelling with Additional Dwelling Units
(Attached).
5.22.1 ADDITIONAL DWELLING UNIT (DETACHED)
One Additional Dwelling (Detached) with one (1) or two (2) Additional Dwelling
Units (Detached) shall only be permitted in association with a Single Detached
Dwelling, Duplex Dwelling, Semi -Detached House, Semi -Detached Duplex
House, or Street Townhouse Dwelling, in accordance with the regulations
specified by the zone category in which an Additional Dwelling Unit (Detached)
is permitted, and as amended by the following:
a) an Additional Dwelling Unit (Detached) shall not be severed from the lot
containing the Single Detached Dwelling, Duplex Dwelling, Semi -Detached
House, Semi -Detached Duplex House, Townhouse located within a Street
Townhouse Dwelling;
b) the building footprint of the Additional Dwelling (Detached) shall not exceed or
80 square metres;
c) the maximum combined lot coverage of accessory buildings and an
Additional Dwelling (Detached) shall be 15 percent;
d) where a lot is located farther than 800 metres from a Light Rail Transit (LRT)
Station as shown on Appendix I, and outside the Residential Intensification in
Established Neighbourhoods Study (RIENS) Area as shown on Appendix H,
the minimum lot area shall be 360 square metres, or in accordance with the
Page 71 of 343
regulations of the zone as may be applicable for the principal dwelling type
within which the Additional Dwelling (Detached) is associated, whichever is
greater.
e) where a lot is located farther than 800 metres from a Light Rail Transit (LRT)
Station as shown on Appendix I, and outside the Residential Intensification in
Established Neighbourhoods Study (RIENS) Area as shown on Appendix H,
the minimum lot width shall be 10.5 metres, or in accordance with the
regulations of the zone as may be applicable for the principal dwelling type
within which the Additional Dwelling (Detached) is associated, whichever is
greater;
f) the maximum building height for an Additional Dwelling (Detached) shall be:
a. 4.5 metres for a hip, gable, shed, or gambrel roof, measured to the
midpoint between the eaves and the peak of the roof, excluding the
eaves of any projections;
i) for a shed roof the lower exterior wall shall face a rear lot line or
the nearest side lot line, except where the lot line is a street line or
lane;
b. 4.5 metres for a mansard roof, measured to the deck line;
c. 3 metres for a flat roof, measured to the peak of the roof;
g) despite subsection h), the maximum building height for an Additional Dwelling
(Detached) where the principal dwelling has a height equal to or greater than
9.1 metres shall be:
a. 6.0 metres for a hip, gable, shed, or gambrel roof, measured to the
midpoint between the eaves and the peak of the roof, excluding the
eaves of any projections;
i) for a shed roof the lower exterior wall shall face a rear lot line or
the nearest side lot line, except where the lot line is a street line or
lane;
b. 6.0 metres for a mansard roof, measured to the deck line;
c. 4.5 metres for a flat roof, measured to the peak of the roof;
Measurement of Building HeightforAdditional Dwelling Unit (Detached)
peak �f roo' peak of roof
•;eak �F roai peak of deck line I roof
eaw•e= eaves
&i idn'4
ha;gt
I • ich a st lltvati0n
of the finished
FLAT HIP or MANSARD GAMBREL SHED ground
ROOF GABLE ROOF ROOF ROOF
ROOF
h) an Additional Dwelling (Detached) which has a maximum height of 4.5
metres shall have a minimum setback of 0.6 metres from a rear lot line and
interior side lot line;
i) an Additional Dwelling (Detached) which exceeds a height of 4.5 metres
shall have a minimum setback of 0.9 metres from a rear lot line and interior
Page 72 of 343
side lot line. Notwithstanding the foregoing, where an interior side or rear lot
line abuts a lane the minimum setback shall be 0.6 metres, and there shall
be no restrictions on fagade openings for the fagade facing the lane;
j) an Additional Dwelling (Detached) shall not be located in the front yard of
the principal dwelling; and shall not be located in the area created by
extending 5 metres from and parallel to any wall of rear fagade of the
principal dwelling;
Illustration 4-2: Minimum Separation of Principal Dwelling and Additional Dwelling
(detached)
ADDITIOF;:r!
D'NELLIN�
ii.€T�Ct1ED'4
DWELLING
1�
STREET
ADOITION41-
DWELLING
(DETACHED)
s.ann
s:DM
DWELLING
STREET
AREA CREATED BY EXTENDING 5 METRES FROM AND PARALLEL
TO ANY WALL OF REAR FACADE OF THE PRINCIPAL DWELLING
k) an Additional Dwelling (Detached) may be located in an exterior side yard of
the principal dwelling, subject to the required exterior side yard setback
required for the dwelling in the applicable zone;
1) For a lot containing Three (3) or Four (4) Dwelling Units, the minimum front
yard landscaped area shall be 20%, excluding surface walkways, patios,
decks, playgrounds or pathways; and
m) the minimum rear yard landscaped area shall be 30%;
Page 73 of 343
5.22.2 ONE ADDITIONAL DWELLING UNIT (ATTACHED)
One Additional Dwelling Unit (Attached) may be permitted in association with a
Single Detached Dwelling, a Semi -Detached House or a Townhouse located in a
Street Townhouse Dwelling in accordance with the regulations specified by the
zone category and applying to principal dwelling type in which the Additional
Dwelling Unit (Attached) is located, and in addition to and as amended by the
following:
a) Additional Dwelling Unit(s) (Attached) shall only be located in the same
building as a Single Detached Dwelling, Semi -Detached Dwelling, or Street
Townhouse Dwelling;
5.22.2.1 ONE ADDITIONAL DWELLING UNIT (ATTACHED) AND DUPLEXES
A Duplex Dwelling shall be considered as a Single Detached Dwelling with
one Additional Dwelling Unit (Attached) and a Semi -Detached Duplex House
shall be considered as a Semi -Detached House with one Additional Dwelling
Unit (Attached).
2 New Duplex Dwellings or Semi -Detached Duplex House may be permitted in
accordance with regulations set out in sections 5.22 and 5.22.2 one Additional
Dwelling Unit (Attached).
5.22.3 TWO OR THREE ADDITIONAL DWELLING UNITS (ATTACHED)
Two (2) or three (3) Additional Dwelling Unit(s) (Attached) may be permitted in
association with a Single Detached Dwelling, a Semi -Detached House or a
Townhouse located in a Street Townhouse Dwelling in accordance with the
regulations specified by the zone category and applying to Single Detached
Dwelling, Semi -Detached House, or Street Townhouse Dwelling in which the
Additional Dwelling Unit(s) (Attached) are located and in addition to and as
amended by the following:
a) Additional Dwelling Unit(s) (Attached) shall only be located in the same
building as a Single Detached Dwelling, Semi -Detached Dwelling, or Street
Townhouse Dwelling;
b) a minimum of one pedestrian entrance to the principal building is required to
face a street line;
c) a maximum of two pedestrian entrances shall be permitted to face each
street line, except where more pedestrian entrances are existing;
d) where a lot is located farther than 800 metres from a Light Rail Transit (LRT)
Station as shown on Appendix I, and outside the Residential Intensification
in Established Neighbourhoods Study (RIENS) Area as shown on Appendix
H, the minimum lot area shall be 360 square metres, or in accordance with
the regulations of the zone as may be applicable for the principal dwelling
Page 74 of 343
type within which the Additional Dwelling (Attached) is associated, whichever
is greater.
e) where a lot is located farther than 800 metres from a Light Rail Transit (LRT)
Station as shown on Appendix I, and outside the Residential Intensification
in Established Neighbourhoods Study (RIENS) Area as shown on Appendix
H, the minimum lot width shall be 10.5 metres, or in accordance with the
regulations of the zone as may be applicable for the principal dwelling type
within which the Additional Dwelling (Detached) is associated, whichever is
greater;
f) For a lot containing Three (3) or Four (4) dwelling units, the minimum front
yard landscaped area shall be 20%, excluding surface walkways, patios,
decks, playgrounds or pathways;
g) the minimum rear yard landscaped area shall be 30%;
5.22.3.1 TWO OR THREE ADDITIONAL DWELLING UNITS (ATTACHED)
AND MULTIPLE DWELLINGS
An existing Multiple Dwelling with Three (3) or Four (4) Dwelling Units
shall be considered as a Single Detached Dwelling with Additional
Dwelling Units (Attached).
10. Section 5.33 of By-law Number 85-1 is amended to add the portions of the below text
that are highlighted in grey, and delete portions of the below text with a strikethrough:
"5.33 €Gw Five to Ten Dwelling Units on a Lot
96iF-(4) Five (5) to ten (10) Dwelling Units on a lot without any non-residential use
except permitted home business uses shall be permitted in accordance with the
regulations specified by the zone category for the Dwelling(s) and shall have:
a) a minimum of 20% street line fagade opening which includes at least one (1)
pedestrian entrance to the principal building;
b) a minimum 20% of the front yard landscaped, excluding surface walkways,
patios, decks, playgrounds or pathways;
C) a minimum driveway width of 2.6 metres;
d) despite section 5.33 c), where a driveway is immediately adjacent to any
building or structure on a lot, the driveway including any curbing shall be a
minimum 3.0 metres wide."
11. Subsection 6.1.1.1 b) of By-law Number 85-1 is amended to add the portions of the
below text that are highlighted in grey, and delete portions of the below text with a
strikethrough:
"b) Single Detached Dwellings with or without Additional Dwelling Unit(s)
(Attached) or Additional Dwelling Unit(s) (Detached), Semi -Detached
Page 75 of 343
Dwellings with or without Additional Dwelling Unit(s) (Attached) or
Additional Dwelling Unit(s) (Detached), and Duplex Dwellings with or without
e+�e Additional Dwelling Unit(s) (Attached) or an Additional Dwelling Unit(s)
(Detached); Residential Care Facility having less than 9 residents; and a
Lodging House having less than 9 residents
On a lot containing a Single Detached Dwelling with or without Additional Dwelling
Unit(s) (Attached) or Additional Dwelling Unit(s) (Detached), Semi -Detached
Dwellings with or without Additional Dwelling Unit(s) (Attached) or Additional
Dwelling Unit(s) (Detached), and Duplex Dwellings with or without e44e Additional
Dwelling Unit(s) (Attached) or a44 Additional Dwelling Unit(s)-(Detached), Semi -
Detached Dwelling with or without Additional Dwelling Unit(s), or Duplex Dwelling
with or without one Additional Dwelling Unit (Attached) or an Additional Dwelling Unit
(Detached); Residential Care Facility having less than 9 residents; or a Lodging
House having less than 9 residents: (Amended: By-law 2021-040, S.9)
i) The following provisions shall apply to off-street parking spaces: The „ff_stroo+
r»r Fp96iireGl fir ciinh rl\n/oII1NlvC shall be ler_, tend a miNimi .M. rlic+riNno Af Q
a) Parking spaces located within a building shall be setback a minimum
distance of 6 metres from a street line;
b) One off-street parking space required for such dwellings shall be
located a minimum distance of 0.5 metres from the street line.
Notwithstanding the foregoing, where a special regulation permits a
portion of a building which accommodates off-street parking to be
setback 5.7 metres from the front lot line, one parking space located on
a driveway shall be located a minimum distance of 0.2 metres from the
street line; and
c) Up to three required parking spaces may be arranged in tandem."
12. Subsection 6.1.1.1 c) of By-law Number 85-1 is amended to add the portions of the
below text that are highlighted in grey, and delete portions of the below text with a
strikethrough:
"c) Street Townhouse Dwellings with or without an Additional Dwelling Unit(s)
(Attached) or Additional Dwelling Unit(s) (Detached)
On a lot containing a Street Townhouse Dwelling with or without a+R Additional
Dwelling Unit(s) (Attached) or Additional Dwelling Unit(s) (Detached):
The following provisions shall apply to off-street parking spaces: The -of-
stFeet pa egeiFedf4A_F SHIGh shall Petbea lerVafea vVithip the
Page 76 of 343
a) Parking spaces located within a building shall be setback a minimum
distance of 6 metres from a street line;
b) One off-street parking space required for such dwellings shall be
located a minimum distance of 0.5 metres from the street line.
Notwithstanding the foregoing, where a special regulation permits a
portion of a building which accommodates off-street parking to be
setback 5.7 metres from the front lot line, one parking space located on
a driveway shall be located a minimum distance of 0.2 metres from the
street line; and
c) Up to three required parking spaces may be arranged in tandem.
ii) The following provisions shall apply to driveways and driveway widenings:
a) A driveway shall be located leading directly from a street or lane to a
parking space located a minimum distance of 6.0 metres from the
street line and shall have a minimum width of 2.6 metres.
b) A driveway may be widened to a maximum of 65% of the lot width or
6 metres, whichever is the lesser.
C) A driveway and widening thereof may be used for the parking of
vehicles provided that a parking space on the driveway or the
widening meets the minimum length requirements of Section 6.1.1.2
d). (Amended: By-law 2018-125, S.13)
iii) Notwithstanding clause ii) above, on a corner lot an access driveway shall not
be located closer than 9 metres to the intersection of the street lines abutting
the lot. For the purpose of this subsection iii), where one or more parking
spaces are provided with a setback of less than 12 metres, the driveway
including any widening shall be deemed to be at least the same width as the
parking spaces, for a minimum distance of 12 metres from the parking space,
measured perpendicular to the end of the parking space closest to the street.
iv) In the case of a Street Townhouse Dwelling containing Additional Dwelling
Unit(s) (Attached) or Additional Dwelling Unit(s) (Detached), each additional
required parking space may be arranged in tandem behind the first required
space.
V) Within a front yard, side yard or side yard abutting a street, motor vehicles
shall only be parked on a driveway conforming with Section 6.1.1.1.
Page 77 of 343
vi) The driveway shall be comprised of a material that is consistent throughout
the driveway and that is distinguishable from all other ground cover or
surfacing, including landscaping or walkways, within the front yard, side yard
or side yard abutting a street."
13. Subsection 6.1.1.2 h) of By-law Number 85-1 is amended to add the portions of the
below text that are highlighted in grey:
"h) Where a parking lot is provided for a development that does not require site
plan approval pursuant to Section 41 of the Planning Act, the following
regulations shall apply:
i) the parking lot shall be setback a minimum of 1.5 metres from side lot
line and rear lot line. Notwithstanding the foregoing, a parking lot
may be located as close to an interior side lot line as the driveway
which provides access to the parking lot, and only for the interior
side lot line on the same side of the lot as the driveway; and,
ii) the minimum drive aisle width shall be 6 metres."
14. Subsection 6.1.2 a) of By-law Number 85-1 is amended to add the portions of the
below text that are highlighted in grey, and delete portions of the below text with a
strikethroug h:
Column 1
Column 2
Additional Dwelling
I fnr o;;^h G]WelliRg i Ri+
Unit (Attached)
a) 0 for each dwelling unit where the lot is located within
800 metres of a Light Rail Transit (LRT) Station as
shown on Appendix I;
b) 0.3 for each dwelling unit where the lot is located
farther than 800 metres of a Light Rail Transit (LRT)
Station as shown on Appendix I, and located within
the Residential Intensification in Established
Neighbourhoods Study (RIENS) Area as shown on
Appendix H; and
c) 0.6 for each dwelling unit where the lot is located
farther than 800 metres of a Light Rail Transit (LRT)
Station as shown on Appendix I, and outside the
Residential Intensification in Established
Neighbourhoods Study (RIENS) Area as shown on
Appendix H;
Additional Dwelling
I fnr o,^" rhe,oll'iRg , ini+ nr n ,.,"oro +ho In+
Unit (Detached)
vec
n+hin 8_00 mo+roof � h Light Rail Tranci+ (LRT-) c+a+inn as
chnvin nn 4nnonr-7iv I
a) 0 for each dwelling unit where the lot is located within
800 metres of a Light Rail Transit (LRT) station as
shown on Appendix I;
b) 0.3 for each dwelling unit where the lot is located
farther than 800 metres of a Light Rail Transit (LRT)
station as shown on Appendix I, and located within
Page 78 of 343
the Residential Intensification in Established
Neighbourhoods Study (RIENS) Area as shown on
Appendix H; and
c) 0.6 for each dwelling unit where the lot is located
farther than 800 metres of a Light Rail Transit (LRT)
station as shown on Appendix I, and outside the
Residential Intensification in Established
Neighbourhoods Study (RIENS) Area as shown on
Appendix H;
15. Section 6.7.2 is amended to add the portions of the below text that are highlighted in
grey, and delete portions of the below text with a strikethrough:
"2. The provisions outlined in subsection 6.7.1 above shall not apply to any off-
street parking facility constructed or redeveloped that is used exclusively for
one of the following:
a) Parking for buses.
b) Parking for delivery vehicles.
c) Parking for law enforcement vehicles.
d) Parking for medical transportation vehicles, such as ambulances.
e) Parking used as a parking lot for impounded vehicles.
f) Any residential use with less (4) or fewer dwelling units on a lot."
16. Section 19.1 of By-law Number 85-1 is hereby amended by inserting "Additional
Dwelling Unit (Attached)" and "Additional Dwelling Unit (Detached)" into the existing
list of permitted uses thereto in proper alphabetical order.
17. Section 19 of By-law Number 85-1 is hereby amended by inserting the following new
regulations thereto in proper numerical order:
19.6 For Additional Dwelling Unit (Attached)
In accordance with regulations set out in Sections 5.22, 5.22.2 and 5.22.3 of this
By-law.
19.7 For Additional Dwelling Unit (Detached)
In accordance with regulations set out in Sections 5.22 and 5.22.1 of this By-law.
19.8 For Lots with Five to Ten Dwelling Units
Five (5) to Ten (10) dwelling units on a lot provided without any non-residential
use except permitted home business uses shall be permitted in accordance with
the regulations in this Section as applicable and Section 5.33."
18. Sections 31.3.6, 32.3.9, 33.3.5, 35.4, 36.2.3, 37.2.2, 38.2.3, 39.2.5, 40.2.7, 41.2.7,
42.2.12, 43.2.8, 44.3.14, 45.3.14, 46.4, 47.2.7, 47A.3.4, 53.2.7, 54.2.7, 55.2.7 of By-
law Number 85-1 are hereby amended to add the portions of the below text that are
highlighted in grey, and delete portions of the below text with a strikethrough:
Page 79 of 343
"For Additional Dwelling Unit (Detached)
In accordance with regulations set out in Sections 5.22 and 5.22.1 of this By-law."
19. Sections 31.3.7, 32.3.10, 33.3.6, 35.5, 36.2.4, 37.2.4, 38.2.6, 39.2.8, 40.2.10,
41.2.11, 42.2.13, 43.2.9, 44.3.15, 45.3.15, 46.5, 47.2.8, 47A.3.5, 53.2.8, 54.2.8,
55.2.8 of By-law Number 85-1 are hereby amended to add the portions of the below
text that are highlighted in grey, and delete portions of the below text with a
strikethrough:
"For Additional Dwelling Unit (Attached)
QALQ 4dditinnal IDWellinn Unit (attaGhed) may be permitted in �nnnrrl�nno nii4h
reoulatiGRS s.,2tG9ut�v26tielp 5_22.1 of this By law-.
T�nir� dditiG Ral P' WelliRg I INltG (4ttaGhed) rgay be pee muted OR
annr-rdaRG9 �nii4h
roni ilatinnc cot GI -It in CoGtlnn 5_22.2 of this By 40.4.
In accordance with regulations set out in Sections 5.22, 5.22.2 and 5.22.3 of this
By-law."
20. Sections 32.3.11, 33.3.7, 40.2.11, 41.2.12, 42.2.14, 43.2.10, 44.3.16, 45.3.16, 46.6,
47.2.9, 47A.3.6, 53.2.9, 54.2.9, 55.2.9 of By-law Number 85-1 are hereby amended
to add the portions of the below text that are highlighted in grey, and delete portions
of the below text with a strikethrough:
"For Lots with Fn --K Five to Ten Dwelling Units
4 4e-10 5 to 10 dwelling units on a lot provided without any non-residential use
except permitted home occupation uses shall be permitted in accordance with the
regulations in this Section as applicable and Section 5.33."
21. Section 39.2A of By-law Number 85-1 is hereby deleted in its entirety.
22. Section 129 of "Appendix C — Special Use Provisions for Specific Lands" of By-law
Number 85-1 is hereby deleted in its entirety.
23. This By-law shall become effective only if Official Plan Amendment No. _ comes
into effect, pursuant to Section 24(2) of The Planning Act, R.S.O. 1990, c. PA 3, as
amended.
PASSED at the Council Chambers in the City of Kitchener this
day of , 2023.
Mayor
Clerk
Page 80 of 343
Gl
m
C
O
mf0
s
�3
Ln
O
C1
r -I
O
N
3
f0
00
OG
C
O
N
O
C
Gl
E
C
Gl
E
Q
r -I
u
++
C
Gl
E
s
u
m
Q
c>
p
v m
U
0 c
o
aY v
c
.�
.Q a 'mo
>
v
v
9 x 3 9
u v on u
a
uco
°
v on O
u v 9 a
o
c
'-
N
pp
Y -o
t m
v
.O
ro 3
U -o
A
C
ro _6
_
v 9
.. mo
E N
� Y v
N 3 E
O
oo
- .�
y m
m t
.w
.� O
cc E t 3
'
o
t
-o
v
3
=
c
p
'c -o
�w
1E
a ."
3
o v
O
-p °
t
oo E
o
v _
0 p
c c
a
0 oOn oOn
c -o
O
'cow
v ro
z, 3
ro
v
v
'a
v
w
v 3
O
c 3
O
'cu
0
v c
0
c
-6
'�
c
-0
O
c
O
'
v
c -o °
on 0 '� p ma
i O rip ro > v
'v
° 9
me 3
�- v o �, .0 v
x
° o -o o
0 c oA t c
4� .� v Q o
own 9roo
v p c u.
�E, 'Nc'-c
no cc
Ev
E' ro v
m
c
v
Y
'" p
9 0
E
WD
u
c 3
c c
N'
v 3 `o
1E
C a) 0 on
Y '""
o o on
9 ai v .n
v `v i
v
a v v O
m E
3
v a
= 3 c
3
o
c
- U o
-
o �- E�
.i a
0
N p
E
9
a
'°
v
vE 3
°1 N
af0,
E
> v
t `0 v �
c
0 9
`0
-o
-
a -o -o °� ro >' °
>
a 0
u u
c c
u -
'�
E Y 'v"
E '
`°
v ocn
o
ocn ocn o
c rco c
_ v a
'Q -o
rco
E
°c
v
aro -o
o
ro'3 N
F
v
o uvoo °c
cvN
v
c ro
o
a
v
-
vo
> 9
E
c -c
.
- a a M. -o
c
v v
c
°o
E°3>
o
vv
LE
of mu n
cc
v Q
'vc�
N
'You
o a
v
,v
-iovn tc
o
E uo
o o
oo 3 3
Y
a
Yoo
oc
p c
°.
u
cO
3
v c
v o
ov
°"
o
0 SO.0
oA
a
�->v
o
v
Y
m
0
on v v v
'° .c N
v on
r�o c ;° 3 c -o °1
=o
.c
c-
9
O t `> c
a`
y c-
ro f0
c v
'c -o nn
-
° °1 :° f0
v 3
c
ro -o
E c
v -
E
a o 3 .° 0
o E
0 o
.ti a
- a
ro
u > c 0
p
°' 3
`° c Y 2 c
t
ro c o
0 on 0
y o -o '-
-o o
c c v
0 0
rco u c a 3 v ro v
v o o a Q 3
v
y o
o C7 o ro 0 on
z E c 'Y
U
N c o0
v .� >
_o .0 3 .'�
E
mc o 'c v
a
'.
=o v t c
N>
;o i r� 9
v Y u
-o
wv
o U 3.
v"
a t c
'�
>. r .. o v c u v
v 3
w 3 9
v c
O- i c
9 N v
0 c
c E 3
-o v on
c
p
m 3
O
ro c 9 9 v N
Y O a >,
E
O
z " >' 0 0
i= c
m
'c a
U
c
Y
a rco .a .�
,� 0 c
v -o o
N
ro c 9 E
"
J
m Y 9
in o
'� ocn
•c m
'
•c .�
'D '' o
•y v
u v
v o E 'c Y 9
a v
c
w rn N
v
0 9 Y
v v v -moo
D E f0 v
o E 3
c ro Q v
D 'E
.�...
0 .c '" u
v
v v t t m
O
.E' i m O
o
o, -o
o
0 r°
9 i v E
o
o
w o
m a E
o v v v
m
o t v
m
o c v
m
c ocn c
ocn ocn ocn
i
.. o 3 3 Y r>o
o p z 9 p Y
.c
.c .own
•�
mo
u
-o ',�,
.Y
u u u
°1 rte° m
D
v= c v 3
D o
S v c
0°
v v v o
D
o� v p> o v-
� u a z �� E
vi m
;A
vi o
vi
.�
r�o Y -`o oa rEo 3
m o
a H m '> o
on
v c
°D on
-o c
c E
°1
-ocn
c
v
E
'�
'c '�, -o -o
v
E
a3i v H
v F E
v v
ocn E t
.� .;
p '�
m E>
c
- 0
= a 0 m
a
> t v p
c '�
3 on 3
N m .c
Q o° o`n
o
3 0 E
v
a
E
v 3
v.Y
Y
o E
ro
v o=
0U `o
o
3
on v
p .Q - o
u 9
3 c w
°
c E 0
v
on v
=o c
z>
o
c
9y o�
N
o
° °' N
on3�Y
C O '� V
E
N c�
v
O .�
nn
3
y
c
p v
ro v;
0 9
by Y >,
a ai .� v
z
v _ o
c- 'c
E o
nn
c o v
°° v on
v '� °
m ro c E
o
E v t
oox c
o m
ri
v
`p Y on
c
ro E v
-6 c
0> c
> O - m
vi
v on v r`o
c c -o
- 9 on 3
-o c -o
rco t on m
v c
on v" O
ro f0 v C v
N v
> 9 mon
x
c� �.Y
o c�.0�
��
uu > ->O �
0 C -6 _6
O v v
in
w O c .,
o 3`
v o m=
v
c oD m0 9
on v -o v
Y N c Y Y
Q v v
•m Q i o
c-6--
c 0 3 3
.; o -o
. p
9 '.,
v c c °A
E v==
c c
Y 0 c
c
c v
N
on -moo
c 3
.p-. v o b 3 3
c t
N
.p-. f0 on a oo
u
m Y 9 Q o
`w
'c
'c c ro v
'c -o '" _o
'c v E c .E
m on
o
p.��3 3�3
c�� °Nc°v Y
o'
o
w o g ' E
z b
In
m nn -o ;° on
^� on .� v =o
^n v f0
a .� ,, o
'Z
0
2�
0 'c `° '�
° ° v
c '� '� v
' ° v on Y
o '� '� -0
v ro =
o O z 9 p ''�
g °
Z
w W
w 3 v c 3
w 3 3 c
W 3 0 Ul 'moo
W
W
W
W In CC N .� N
wz
rn0-o �-o
mo.E-o, 3
mo -o wz
z
z
Gl
m
C
O
mf0
s
3
r -I
Ln
O
C1
r -I
O
N
3
�o
co
Eu0
C
O
N
O
C
Gl
E
m
c
ai
E
Q
r -I
u
C
Gl
E
s
u
m
Q
v
00
c
z
Y
`v
v u
v
o
c
a f0
u
u
v Y
E o
O
-
U�
Y
o c
°
`-' -o
C:i
v
3
�
o
E
'x
m
E
O
g
°
pip
v o
3 ro
z o
'
v -
v
0 v
o
— o
y O C v
— o
ovn .� -o v
o
c N c
U'3 0
c 3
v at 'c
� m a
t0 U1 -6 0
o c
�i lo
o
o v
ocn a u
t Y
u Q
3 on
° `o -o c
3 0 v v
-o v y 9 v y a
o 'c v
v o v v ocn -o Y 3
9
nn v c v
._.
v v f0 c c v
c u 3 io nn -o
on ro Ynn�
v 'E
— -FD = .0
v N N N u .Q u
O :° -p -6 �v 3 ,O
0
3 -o
= on c
Y v
LE
t ro 'c _a ro ° -o -o L-
3
on ro
v v-
_.
.� N c °
'c c _. ro
v N
v '° v :° v
nn N .• c .. -o �,
.3 .� o'n .f0. v u v
c o0
�- c ro E c E t ro v a;
u
:�� Y 3
'3
N m 3 v 'c
° v �, v E on 3 v Y c t
E
c -6 °
- rot u o°n .�
ro o°n 3
Y w nn 3 v 3 3
O
3
3 `o
t m o 3 v N
o v c o v v Em o v
a
v°
v
3 3'
0 3 o v o 3
c g v v 0 v 3 Y 9 v o`0
c
v
c°
v N a Y m N 'c -o
E� c
N v° 3 3 -o >.
o— 0 3 v v o f
O0
" u
o v o
m -6 ° O
o
v
" t O v o o v u
v
.0 p
.f0 -= ,ro,
Vf ? w
P c c Y y c
c m v .O v
E c ro .O v 'LuY U C C
m o
u
o— v
3 -o
Z Y° o
" 'E E
v p =o o c` 9 c v v a ±o
a t -o O �, ro
w
v c
o
z 30 0° 3° Q v c
_ :t
r 9 N 3 v N m o N c� M
'
" v"
c .. E ro
u> E Y Y on _ 3 R.v c o c y 3 9
C
m O O O m in _6
Y E i? 0 N
a
c
E v 'E .; c
3 Y c- v Y Y 'X
Q oon t v t
O
o 3 -o =
t -o o°n t v
0 -o a -r3 c� Y
0 c °' ro c o E
.. v� p; 3 v v
c :° y v 3 v :° a
c=
= v c .� ro
Q o' u c v oc-n N
u u.c
Cc
c ±o o°n c �- E = _. E Y 3 m e
w Y
o f '� �� c
o� -o a 3 v o" v c-
O.=_ _. v o Y ro 'c . o- o v c c v 'o
m -o — .o
a
m z N .. 3 .v
—03.0
ro v � -o c :. O
ao o
- 5; .c u �- a2 1E -o nn
W
ao D '� -o �, -FD � m o'n
O
ro `�
OC Q '� mm 3 Y i -6 '�
t 9 3 -FD N — > O
o f 3
m Q w O °i
os=n
m 0 .N 3- c 0 0 ,�_ 3
0a.. -o
m 0 3 v -o on Q v"
`w }'-6 0"Lu v E
v~ v
o .�
c'- =-o
w° v v v =
�0 3� p -o
0 oc v 9 v 0 uO 0
F, c v�
v �o a o c v
°° �"
o—
0
v
ro v
��—
� Co t `o c° aE o
o -o
C7 Q o aE :� 3 ° a
v o
ro
>
a N o o
v E c'..
a o v'
c� -o-o }z x,09 Z ro u
a c= o o -o - ro ¢ 3 `o c
fl- 00
C t O '-'
�-
C v v N N N N '� -6
-6
C 0 .0 Y mw o
N " t to in N
Q LL v
O f0
O N u n
U 9 sem+ -6 "
O Z E
a+
U E O f0 c Q v
to = N to to ° F N v
V N N J E O sem+ N v N. a+ j Cl O bA 0
° �-
vi H m E
o'n
vi v m 0.: o°- v.
vi v O v a. ro D o D v H '� ro
a
t�-o� nn
.�
_ o
0
v N
v m m m
ob 'c
3 °1 v
ro c N
v v
.� N
.3
v
0
t v u O
N„
ro 9 Y
3
o N m
y
—
ro 0n t '� —
c 0
o
4,
3 v .�- 3
o
� .4 'c
= Y=
c
3
o � �3 ° m '- 'E o
- S v
O —
0n
v
3 �'
v m 0
c' E
ro .c-
v >.
m
Y p c
__ o s �w 3
v 0
v c
m
e
'v u c 3
m .° -o
p c E
O v
v 0
O ro O v ..
z
O u
c= N
w v
.E 0 9 m
Y
o m o
c Y o
v o 3 o c v° a o
o
v
io c
v
�- c -o O v -o v 'c
y
X0.0
c u :t o
ro E O—
u> o 3 on N Y o°n
o v
° v 3 v
m° o o m
:9 E '" v u°
N
o�
E�� N
~O Y v
v.o 3� .�.�-o
x
io o
= m 0n _
-o O
c
E v O
t c c Y :° -o •� -o
� 0
7 0 0
0
W =
NO
Y 0n >. ro -2 .�
um
Y N
C :t u E -6 N
O -p �- i
3
O `--' N ate.+ N c ot f0 " y N
o
m v 6 v
-o
m z
u
m w 3> v w '�
a 0
v v "
y W Ou of v
w0v v v Eu E. 0v
a
:t0
mc-
$ �- 3 m 3 Y
oc m ._ t w 3 m v N— m -
0 a
m o3n
r�o o
m o 3 v �- on ° 3 on
°t
c c'E=
c0 3 v a
�:a-o-o c �E— =o�'u
U
01
O) ° v N v=
O) oC Ul 9 U 0
C7 W t ro o ro
W '0 N c 0 0 0 c -0 u Ul
C7 Q c E o ° :�= 3 Q c 3
9
c
.0
0 -6
o
in !o
O o Q
O Z E -o
bfJ -2 .0
O ti� v= -6 v N N two
O w
•u 9 :° N lo
•u 0 c
•u v rho 0 :° Q N ° :°
- v
vi m E
vi v ro `o o o°
N
vi v O Y a .E ro v
v
m
a
Gl
m
C
O
mf0
s
3
r -I
Ln
O
C1
r`I
O
N
3
f0
m
bn
C
r_
O
N
O
Gl
E
C
Gl
E
Q
r -I
u
C
Gl
E
s
u
m
Q
c
o
o
v E
M
.0
y
oN°
v
o f
3
E3:
'cam
E m
m w
ocn ocn
'�
w w m a
ro
v
E
v
vvN
v
o
v roo
-o
v Q
N v
O a
v
3 .E
Q a
m
0 o
>. -6
a
S
o
ic
a
vv f-OoE
`v v
o `v
v v `O .
v _o
y v Y
'� ., it '�
a f0
D c
.� a v
a c w v
E a m o o— '3 N Y
m v t° Y m v- v
o o c c° m o
0o
u O
E
E
vv va vc3 v' wov °ov vE E moO
to v
m n
.� m p c cc E a p -o
o c
t-2 v o Y `c° - v v `v' nn
-6 v '„ •� 'ro N u v c.
39 y� pw > cw Y v c
m v N c m �'O
O C -6 a v> in -o a ocn m
v p .� o m 3 0 3 0
.� a v t ,� t v .v o >, v
2 a o Y 3 E 3 m y o 0 0
'
c .� 3 omn
v Y m o'v
°
co
a
C°0o
'U
o00
of3Qo
v in '3 ocn
v a y
' c 3
v 'Q v v -o
v� E -o
o m c Y a�
w m am+ N
-o
o
E v .� v
Z o o Q
um
o
cm
aNc
o
0
m
c
'ro
v
z
3 c
3 v
:
v v
v
v
m°
N c Y 'O
N c o
o 9
n
v E
a
-
I
m v v
c
v
o x Y
O x 3 '� mom-
3 Y
on
c v w
-
-
-o
.>
% -o t
c o
:° -o
c
v
>
3 N
a
u
m
a
mu
o
s
J c 3
J o Y 3
v m N
c um v
m a �
c al C a
m
_
-- c
•• O o a
— c u
" O m u
0 0 -o �
on f, v
= 0 0
N -o a
v
-moo o v E '-"
w
t Y
v
� o `o c ocn
m a 3
v o
o Y N
o v
_c
N
o v
o v a o
v
ocn m
w
" v '� o o .6
-0
3
v
cc ro 3
f0 v Y -
v v
-o c
.o
c
3 Y v c o 9
Y
C=3:
v a
J v E ocn v
v v
3
ID
c 9 m 3 ; m
E
v of
J a a
a u = o
c o `o
o 0
E
al -6 O o N Q
al
N g
m -o
m -o O0 D
O
o 0
N -o Y
w
�� c E
v
Y
o v a
Y
o 9
mm c% E c
3 Y
c O .a
v
E c
9
.� =
`-' v
f 9 v
nn
o
v v
,� - m
`�
o
v m N v
c a
m 3
`o
-o
. v v
v m O p Y
=
N on
E -6
Y
v N
N .a
c N
v
3 C 0
v v
v
c
N o
v
E v
E v v v
E -o v v ami
m c O Y
rco
CL
N c°n
v c = u
c X
'c c
ami
O z m 9
z
o z '3 Y m
v m- m �.
o '�
a
o v 3 v
° v
E°
f0
o t
3
o t v
o 3
m Y 3
o
t in
Y t -o
f0 v Y v Y v
c m
c v
ami
.� o
c c a
U.
c a
Y U, u
-
E c
m
c
� 3�
v 9 - m - m
m
Y v
Y m v
v 9 m
9 v
`v m m m
rvao ,+�� omn
o 0 '�
O D
v°
±°
ai
Y .E
Y c m o
Y .E
c a m
-o :° 'v"
omn
c
c Y Y
v
3
v
w ;o E E .,�
E a -o
I
'-c-� Y
=°
v .io .
_
O. m E. p_
O.
N v
Y m
aY
v Y al -6 > m'
N o nl 3 C -6
v
ba
w W
bA t0
c v
v
°'
3 �.E
O m
o m 9
o c
v 3
c c N
m u 0
3 v
o'o_0
ooQ^:°
°oa E:° �-o
v ��
v -o m
v °
E a
E a N
w o° y°
w o m 0 0 o
E o 0 0 °un
w z c
Y c
v
in F 3 E
m y
v in
o .x 0
� .x 0 E nn
v '� Y U
t
C7 p ..
E 3
Y
o -moo o E
E `p
o Y o
m m N m
m m m 'c
E N
'� o 0 3
v 15
Q --
.°- Q o
�t c
`x° v
0 o v
v a9° c
v a9° o c E'
E v 3 `='
o m
ot a' v
Y°° v
v
o o
a u 9 v
3
3 a u^ -FD Y Y
Y v v o
N
9
o z
on o z
o -
v m �
o
v '�
O
m .y t t
m
m v Y
t
o
v o on o >
a 3
v
'
�Y
v 3
�aY
m c
v m 3
0 u
of S
0
3
.O
'�
U
o
m O N
un U Y a o m H
m
O y 0
Y c
O.
c E v 3
N
v
O c
rao
N
'-
nvxEc
omcEcv .co
p -o v
v�c
ot
a o cp
v m 3 ro
=3:
m Sv
m c c o
'c °�
v
3
ao
a E
m o c' m
c
e v O a,
rco
�- °
c
c= c O c c u° `°
c
D c O v .Q v :9 v
m
t
3
v 3
O
Y o m E
a°
E v
v>.
M
c
al
v O = c ocn a ,
m 3 9
.0
`o m o
.Xv
o
v
- v :° c o v in ti
N
Y nn .� v_
0
t c
w
a m- % v E 3 m v
c v w
o O v
c o '� v 9 9
v
E v a"
v �.
_o m
p
�
v U v= c- v Mu
X
'6 Y v 5
w v
_c v v aci
.uw
0 v �° 3:c
3 m 0
'ca
E v o
m D
`w
v in m
o� c -
Qct
.3
m
�� �ro
E m Y .
'••
v ,� .3
(w9 .2
o
N m E E
m f0
m
b�A 0
EEE
2
cm
QN
ocn v
O °yvt
Y
u_
O
OE Ci
v v E
al
� 3: 3: ��.vw
°
v a
o�Y a
m
a
Gl
m
C
O
mf0
s
3
r -I
Ln
O
d1
rq
O
N
3
f0
m
C
c
O
N
O
C
Gl
E
m
C
Gl
E
Q
r -I
u
C
Gl
E
s
u
m
Q
ou
c
�•
w
cv 'E o o O v
Q3 46 v E�av
3 V O `O v° N
�o E `o v m m v 0
0 M O[2 O
E c
o cO
� y v
>° ° °
vYnv v:a,
v v o o o
v v E
ng
9 v o p cc
u p o a °
3 9 Y o f
o a m o c a v a
0 v a c ro -
ou ou ou v f0 v c v N 3
ti c `o
c c c N9o'QN. Eao'v���
�• �• �• v E E v E c o v -o -' -o
w w w o r Y '2 a o Y 3 E 3
J ..
o_
Y E o >
oo m
E 'o3 2
c
c.�OaYm
o E3'v
0 'v =
E
E aa v f0 u-90
N N w U a
i .o
N�= a ocn ro
3 c�
° o v ro -o on
O `o- v
�v°O�'9
> v 'z ro
m v Y 0 0 o
-p
crn 3
o O v
` E I
v O
t==
0
-o= c�
on E -
o o .v°
c
v E c -6 c '"
v .� E .Q oo u v
o v o v
a m N v .on t 0
'� m y t
'� ° z E
c c - c
'§-0�`Ev
O v `O 9° c m .�
¢ ° u E go
O
U.
f0
E
v
m
a
E
3
0
v
o 9
�ovn
on ro
.
ro
—
Y v
>
c
° q u 3_
N
U
3 v
v v
v 3
f0
v
C I� N v v
N c u c y
O
f0 f0 f0
c v o
o
U, N
c
c
U N N
.. c
9
X
X
t
c
v t
E N
N
`° > N 0 0 3
N bA -6 fl- N
V' N v m
H Ra C N
.. -6 .o o
N u N
a
N o 0
- +' v
E
`° ro
o� u
a Y `o v
Q Y
`o
v .° ui
Y o
v v v
°°
v 9
v o 3 v o
u vi
Y o
Sic0
N Q
E 0
-o f0 0
'� v� ° c i v `v
3
c
c v v
c r' -o c v v
o v
Y ° o E ° v ~ 0 E .c v t 0
~ 0
0 v o 0 'c a
— 2 0 `0 'C a o
E v
° N Y C w N -o ro v v o`n
v 3
ro tm,u a, -
o Y um v ,c
a c
t o 0 0 v c t v c .�
v E `v
E r>o w` u
v = v E >o `` u Y
._ ocn o
�, c .� -6 t 'v nn a a m >
Y
un a in on
on .� v '° m
E°=
'�' m v m m o
E
-6 v v
O v al " Y ro m _6 O .a �
m -p O .O m
E� v
O O v O
y
E°
`v v > > o f v .E
a v N 0 ono 3
o f 3
— 6-
3 v c 3 .� 0
v m `o v c 3 .� 0 a
a v v
a
N
Y on
0
9 9 '� v m Y v
v
9
o
Y 0 0
'o
N C
v 0 9°
T - N -
�° a>
v
.o on x
C bA x Y v N o
a
0 3
o c ° c N E v v v o
E v o u
Loo o v 0 v-6
�� v o o v v v v
CL
v
3 3 O oo o m
oo o
v o 3 6-
E v- v 0 3 o v
3 N
v E °° v E a .a
ro c °
°U' � O ro
° v Y v a°
v Y v a° E
E ro ai
ro
t
t v v ro � v Y U, v- v
U U N Y v E U
Y
v E O
o Y v -6
t N u t0
E o Y v
x m, m Y x N o
m
O '6
v N
v Y v Y = = Y y c 9 ro
N
Y ,�., O m
.� °n N O v C
o E mon v o c
O
,_, E
-6 v -6 v �, '3 v E v
-o -o �- p -o -o
v E ,- ,�
-o
a s ai
-6
v c c a ai
-6
u. N
w
cE cE �a yEY
w ._
t v E E
E
Y= t v E
E E .�
c o on
v v c a m
m
.� `° v
m v
t v_
o y on
v 0= 0 c a c
v 9
o c a
O v
o o- m
N .. a v O v v
t a 3
`° m= 3 N �, f0 -o `O v
f0 -6 E
E v> v
v °' c v' v v
c
o� io �0��
� �'c
v
E 9 ao v ovEi
av��
c�
-6 =o -o ,o '� `° c N m
�WD
v
'x rn rn
0 .c Y=
o
m ao ^ o
v a� ^ c
E
a v
v 0 3
rco:° rco:° Y v 3 a on9_o
3a onm v
y=
0�—
u ° ro0
�� c'.,� � v E w oz�
onozis�
t
—3
v
0
° 0 -
Im
v v
o
u �, o
v
- m
° v o o E o
E c o
o °
O ro .3
c u w r90 'c x
3
t c v 3
o °
v ., 0 t�
c `> on `u v E v
0 v .0 HiQ N o
9 v
9
M.� v c J
N 0O
`o ',
E.3
c — v 0 v
v o ao v�.�� v
—
ro c
�".0
Y 0 3
v'c° v °
v v
'��°
`M
o o o v'3 `° >
E
O m 0 9 c c
o
0 v
Oc
m Y v
v c 3
c N
Y y v E° u m 0 0
3 '° Y m =
--5 O
v �o c v
-- 6
0
2 v :E 3 o v 3 N Y
=0 0 v
E c v v-2
°1 v v
v Y O
.6
O E c -6
9 v°
u. Y
o
E
f0 v
' u- v a v '^ °A v
_,
v? O
N _
c— c� m a- �
m
m O c
`v 3
E m v c —u ,� ro v .E Im t
> 3 o :_. v on E '-" f0
E� c
ro c O
�
ro u v u v O
ao
a o
a:° N O 0 -6 .c v° o o v v o
E E `° v
sg
Y 3 c v 3 ro c v ._
C
io N v
v ro v> ro v _6 .O v
t 'E
a v O v
X O v
E
s e
E v a Y
~ a E v
0� p N 9 Y chi
E 0 6
o> 0°
E
a`, v
T,
oc0o
cc`0��c��v3°on �c
YvvO0
x. Ev Eos
vi
v v N on
N v N on N v v 0 ro v '-" c '�, N
.: Y -o a
s w8
p '� v E u a -6 �c m
ba
-c o 0
t on
.t 3 'E
- 6 v °1
v t 3
v v v c 0 v
t c t 3 =_ c v v m
o _`
v `O v
o`
a—
Y t 9 3 v
x
m t u -c
m .O -6 :° v .� c rEo m .� 3 c ro
-6 -o x E v c
a
Y Y
O
-6 t
-6 '6 t N 9 N 9 'O
O
v -6 N !0 bA E c
v
c-6
Y
v C
-u.• ro ro Y—^—^ v y
'E
'c o° ro g
a c -y,c 3 U ro
y,
'� E
y cY
3' Y o o N 9 o ro�
c 9 ° -o E p
�8
Y f0 3 t a
Yo
v 'v^ on '- .,
'o
on .' on .- c _o m •' m H t m c 0 on
° .c
= oron Y m o -
o`n v — a
v -6 E Y m on 3
rn c E.
0
c c E_ -6 v
'y3 v
E
3
on v
E 3 on °A
v v 3 v o'n
3 on 3 on -6 c -6
Y
ro ro row
3 o a vm x
m
.�
.0 . O O- O N sem+ -6
0°O
v 15
E
Y
O
° Y O O
a 3 v
3
D c m on 3 E 90 0 0
c
°° v° °_
y m Y v a
v v
o 3
a N.o -6
o 3 o 3 .o Y 6 E' o
. -6 v '" 'c c .E c ocn
Y
v v g
s
64 v .. v a
Y
o 0 9
-6 ��-6
=0 -6-6 0'� o'c' v -o
E
v v
N c- o .. rri c
0 .Q .Q Oc
Y 0 t o
c c
t t m E °n 9 '� E v v r�o
c c v 9 E
rco E rco E v
rn v rn E
f0 o v rn
v
o 3 0 6
c -�
0 Y O Y Y 3 Y
c on - o m
o> m
t0 9 -6 N
_ _ _
U w bA O t :^ .E O Y?
'-' N N 9 U
m
E v C v O H a
.F
O
N
O
C
Gl
E
C
G1
E
Q
r -I
u
C
Gl
E
s
u
m
Q
u
c -
un
v
v
(M
p
N O bA
3
D
-2 v N
v v c
W
v v
.o
v
`o o
O
o
c y
v
c
9
o
x.0 v
a
o
a a
3
0
U
-o a
E
N
c 6
o ro ro
. c
t
> ro
> °1
v
N
O -6 °'
N a 0 0
c v —'
�-
O
C
O v a
O y Y Q
O ro c
� cu O
rco
� -o
v v v 3
v a-
uu ro 0
za ate°
z �� u
w 0 0
E
o
v
c
v
v
o
c y
v
9
o
t
> ro
9
N
u
O
U
v
N
o
v Y
v o .E
o 0
o
o
N
3
O -6
E
C N
Oo
C v
Oi N
�p
v
O
a
v
Y
v 0
E
E
E c
fr
-6
v E
C T
N N
0C
o
bOA
i
N
v
v
J
N
ci t0
9
Y a
O
.c c
v —
v
E
o3
O .4
E O
o
Y
uv
0
O
C �Il
o
9 Xm
v
E
'C m
v
o
v
�
o
gas
E v
c o
-6 O
-o `o
-o v
v a
-
'�
v-
3
_o
x
v
'v
t v
m
o
v
m
M y
m
m a
w
y
Y -c
Y v
Y
8
v v
E 0
v
B;
m
m
°
u
!LLL
a.
3 v
3 Q
c
k
'6 u
v
-6
C
N
_ m
N
E v
_ m 3
-o
O
'� 0
U
0-
E
N
c on
c9
O
crnt
o0 3
c v
Oy
0 v
��
i'
v
E
O c
_o
s
FF
s�
p
'_ o
'L6 c u-
-o c v
Y
p
c
_
o_
m E
-o Y .c '
'° m O1 v
-o .E
M y
M- a
c um a
c
E
m x
v
C 'C_
N 9 N
C M a
N 9
N it
ate+
o
E
- 0Y
Gl
fm
C
O
mf0
s
3
r -I
Ln
O
C1
r -I
Q
N
3
f0
m
bn
C
r-
0
N
0
C
Gl
E
C
Gl
E
Q
r -I
u
C
Gl
E
s
u
em
Q
O
ma
a.
a
Yv
9
v
N .�-
m y0
?
a
c m
°—_
m _
3
O
N
Y
a
E
O
v
O
a
O2
.0
c ">
bA C
--
O -o
bA _
N v
u
v
v c
o 'o cc 0 'o
'v ro °
O w t O Y
w v 3 ma amu v m
mu �
i � O �
N a
-o .,
E
a o
,�., '.� v a ro ',- ? m
in -6 N
N O t -6 °
0 ~ v Y
�~ Y y N c O ,O
ro O v
bA N v N t0 jp .0
v 3 u a y -o m
v
ocn .i 0
bA v u '> N bA T
c c C uo m O bA
v t i 0 9 a O
a ° a v
v
_ o 0
.� o
p ai
t c c
ro E
= - o
E m
0
°
0O
v
0 °
° ? a o
ot
c
v o °
= c a ro v
m ° m °- Y
>
v o
° °
p
a LD ti a 9�
� .m v
o v 3 v .E
c `c° p a v 9 0> Y c
v
c m m m E
m :F ` o 9 0 Oc E '" v Y 3
v .� ro
_ on
v -o o .o v on `v' Y v
c mu - f0
w
a,
` c
c 0 O .n w , -o v v io
'- ,-
E
Y =o -o
o
N 4 , E v o
v O m -o O v
t
° u
m y
M Mv Y v ,n o v
`° 0 Y v
c E C
C 3 3 v E�
m E m c c nn w v
`° v o i v .° O ocn a 9 v
c -
o
46 u
o a o v c a
IN
o p a > a
-o c a 9 , ai " O o E v c 9
C
m Y o ui a u v 3 rco
'3
o rco io rco v 9 > _ 'c `O 3 v N N ocn
v
CL
c > o -o > I
O -
'" o a tom^ - c � a E v `m E
.O -o m O m v
CL
t m E -`o -o
c '� m- m I
v N m m Y
o .�
a c Y c 3 °o v ° 3
o o
N
C 4+1 w bfJ
v Y
'i v C 9 O
C v>ba
T N '�
O t mu v
c p v- 0 E f0 0 > c v
ai v nn v v
a c o Y t m.
9>
i 9 a
o ° a — v— o
v
o 9 3` f
°u>
a oo
vann
Ec_
3 �
3 N >
c
moc-vv c oO
n
0
U .o n
o0
w
ii Y Y E Y E° E f0
vai a 3 on v f0 ro N° v a in °' E i X
v
° c o o -o o
O E E c E
ao m c u c m°'�
f0 N
,v,
v m O .c c ,c o .c a Y
m up
v `° a u
j
c-onE ro E onE v
v 0 m m> m -o i
a�� oa vca�pQ
D
v o u cc a �
O v
a a 3 Y v a
�>-� r'o c"�
umi r'o mu cc3 Z-
:t uuw
-v
v m > o
o
m e o 3
v o v
Y v c
N
rco a -o v
Y v 0 -o E
m YO mo Y E m v m
O Y o �, Y
'E v
a+ O N= -6
30
aN C N
> 6 v v N O=
v
a O O
ro -o c .6 E u a m O
Y ° E a 'C
v
v o v 3 v 'E
c nn f0 O a v m ` `° -0
o '
3 v c .�
c E c c
N � v o'
u o
.y v v w v
0 9 o c
c
'� 0
o v ° —
v N
9 c v o
3
v
-O v bA 9m
—,u
w ,
0 6 mo w f0
° v Y v N
W
t C -6 N t N
' Y 3 t v y v ro .o
J N
.3 c x E c
'6 v bA by v .6 E
� E c cLQ
p
m o.EL :° i, � ° v
o u 3� v E
i i
9 0 � E E .O ti v
y��
V
v m '� ° Y .0�
a
U
c v °1 v O E E
'^
Y on E v x
a
O w a v 3 ro
v
oq o ro -o m y 9 v co
C y c v C v y v :� v
o > o -o > m
'" p ma t c a .E 0
W
a N a
O 3
a° .� > v N
v
E° v Z, c m v E O v
N u =o Y v -0 0 9 c Y
�fN N v c
a" o Y °? -
c� 3
v C t0 -6
- 6 v t m u Y
m 3 o 'E '� a a m -o
0
-o _ '� _
�9.--.v9 N `° c N m
3 c -� 0 3
aoo `v -o
ao ._ v .� E v v -o o Y N 3
c y.�9 a c—
.-:v
0
.�
'a 'a m ti `—°
m c a Y m N
\o
o 'N c o g 3 `O c M a 9
'5
in -o .� .E +m .� i ni p
9 0 9 9
,c ° v a Y
° m N 3
N
oB un v v v c -6
'� N„ u C
.� v a+ v v .Nti v
E'omONYYaao�NY3�YOYN`p�'
a° �- ` 0 0
H U1 v
in .O
s tmJ E d .in
`ma�E. 6E�v �v°
c o
' O ..- c
a in a C 3 C c o a N ° v a E
I v O� o
o c v .E E v '" 0'
a vci
Y g E E E v°
'� >' 'c °U
`° ro `—° v on v f c
`O c
3 °1 3 Y v
O C o .c .Q
E
v v rco v v a E
`-'
ni m Y m 3 t 9 U
ti c " O
N �- v E m u`�n E v u
ti 0 m m m -o i
a r`o p— v N t
m p Q v 9 a v Q E� E H
u
v O ro .� v ro
v o ro v a:-
cYi
v
m
a
m
4
z
E��
o v�
., Yo E
O o'c >
EE 0 v
v E °1 v
c w m o u v 3
Y y Y m>
`va9c f0;
Y O- ons o m
c`> v 0 0
Y 3 ° b
o v> c o 0 o a E
N o E m Q
.o. E
ro O E
v E c -o on
`p
c o
-6 N C C O 0 't O v
E9 0 + N O` '� v
0 omn a Y
v
`n
E E
0
�.E
u'
0
v v
O N
o
a
0
O v
3 m
v
v .
v
3 `p
v
v-0
o
N a
o a
u i m
.0 >' o
� 9
-0
M 0 .0
u m
v 0 on
z a v
c
o E -0 0
c v9cv
o
3 '0 v v m°>
on
v
o v io c m 0 m
0- v c
c a
—
v m 'u E
v 0 E
0
ri .Y
on j E v o f cri a
c y. p E E
v m
a s
c
N c Y a C 9 m Y -6
`o
v
m in
3 v
c c E .z- a m
w v v
u
U1 v v N i Y C j 0 p p E
In :t m
m
v m O ..
ro
0 m m um
w on
c
-0 c ° O
-o
a
rn _ u
4 c a 9 m° v v
z u� >
v
m
INv v _ io m y
o y 2 m v_ o
D
N 3
r90
i
0
a
_
�p m E O O O m O Y
w.
CC v >
CO _0
N dm t t v o v
v -.. ®
-0 -0 -6
v
-
'0
m
3 v v
o Y do ®® > o c
OLL v .X m
E
v
a
c 4 u> .3 0 v
s v -0 t .� o o` 3 -6 0 Y o
v .>
z on
U
o
a`
m v a m m f0 on t on >, v
v
p m c
v c
.f0 �, 0 c a c c m E
ro O O O .0 3 .0 o�
> m
c - v
m -0 m .- °'ic m0
c 'm -0
a v
rco m
c
bA m -6 N UO N O. 0 0 m
(7
O N
c m E E m
m
N
c E Y
v -m d a m y o o mu
o
a E
rco
v ¢ ® a v c 0° c° _0 3
.2
( O
N v
- +' r° U avi avi rco
a'
0 io `�
—
`m .z- v a E E Y c `n
c c p v v E
a o O 0 o a 3 m o c v v .X
w G N a w E
>
Q m
Y>
-E
o v
N
1f1 U YO Y v c = c v o a 3 a 3 E
v
O
Gl
0 m c c
46
m
a
v-0 cc v
m c -0 -o
—
m
3
N a �
° m.. �� ao
c c- v
Y
c
v
3 ° c
9
m v
m
�_ a
'0
Ln
0 a y m
o v
9 0
O
v vv ;0 c
v c m o
v on
3 c
o
C1
mu o oc v 0
0 0 .c
v m
c m
O
-o E -0 ai
on E v Y o'_ o
a
" -0
'Z-
o v
N
3
c :t o O- x v c
- t 0 v - 0 v m
v
0 0
0 .-
m
3=ovvo voQ 9a
o
c
i•
v E m c
.m
:u f0
o c
o m c a
-v6 a O
�- O m v
v =6
9
•
Oq
C v E
O c c bA w N N m
H
z u
O
um v o y m c E ° `O
p m
0 3 t
p
v um
v .>
j 3
O
c E v atm =0
cc�� 0
vm
Y w -0 .. t -o v 3
c c v
5 z
w
-c " +� . t v v" U 3 on
Vf p
aN
on
om -0 - c 0 m Q 'c Y Y Y c
c d M 0
m K '^ >
09 C —pvp m 'bA N 3 3 bA - 0 C m N O
m c `�
m d Y v a—m+
.N. o .� > v v v v
c°
Q
m
0 Y m 3 >; -0 a E Q 9 c o o
.0
ocn -0 -t Z- v e o .. c v
J (9 0 v 0
mo (D
U
,�
a c w " .5 v d o u ® ° >o Y
®®
od '�a°
c
a
o v a 6 j
v c v Y
s> p `v'
Y
s a L' i
y
v
x 0 0 0 y m 3 0 = o
Q o
m a v v
0 w m° cy o Q E .c
.`° .Q o 9 °
ui u o
a 3 v
c v
a v 9
�n u a a
t
omn .-
c 0 m c c m v >. >. z v
=
c m 'c -
c v o N
+m,
um0 via E E = v
�� c >
umuvuu
Q
vi vi ro v
vi vi ro ° t
vi vi ro 3 :3o
m
a
m
O
z
LT
++
O
OAC
E E v
s
v Y E a
E
¢.•E o
3
c
Eo E
Ln
b
2Y
W,
p
?
o v 3
v
C1
f0 f0
_
. E >, v
ri
E u
N
Y
E N o
o
?
D
E o 0
3
v
a
a9
�Ev Y
m
o
5 c -e
m
0 m `v
o
:E o
v E
0
v
�'-
M E
u a
�
3
.�
v vv
0
w
—
v
N
c {
E
Q
c
o
v v a v
ro v
a
v
U
mu
a
U �
C
Tj
Gl
:�
E v Y v 9
.E 0UbA
'C
W
3 0
c
m E c v
v E U
E—
9 m
C a N o
C '^
Q
v
0 v Ouc
C
Y 9 v p
ov
(>
m
v o "v u
-o
o t v 9 v
ro 'o 39in�
t
a E
v m 'o E'Q 0
u
m
u
o
v
v
E
o
E
E
:E
m
0
M
V
M
O
00
00
v
m
(6
a
O
m'
E
¢.•E o
3 E w �'o i g
c
H
b
6 O N v
eat �•�_ �
?
a
Cc
f0 f0
v v -6
a « g
$ E e
O'^
.+'
Y
o N N v
o
?
D
t t
r�o E
v
a
a9
N
o a o
o
5 c -e
-o
0 m `v
o
'vim o
v E
-E 9
on E
c a v o
— vUm
v c
M E
a§e'nmi�
c
on ro
v a
c {
c _
c a v
c
v 0 -c
ro v
a
v
U
v
Y
a
v— N
M
V
M
O
00
00
v
m
(6
a
E
E
¢.•E o
3 E w �'o i g
a
9
m
eat �•�_ �
?
� � S
U.
m
a « g
$ E e
3 E?
¢
d
¢
o$ {3 E a
5 c -e
om.
� •� �
E
m
a$� d.E c
a
i
3Er?
a§e'nmi�
a
E a
E v
c {
c
Tj
M
V
M
O
00
00
v
m
(6
a
a
� 3
c v v o c
t E c
.3 nn
o
� o
a o ocn
O
0c 1q
cm v on m
z v 'E .X 3
`v
v on
v Y
a 0 3
M loc
E 3 Y m a
a c
o c
�- Mot
a �
-6 O
Y O
of O C c
3 N N N
6 U u ~ U
U0
X0 cLa
v
O
3
v o -f0 `2
0
0 0—.
ai O v
O
C a
W c N N U— N N N Y O _
y v v o '3 °
K
s w ^ 3 3 v o
.`fi N N N t0 t0 N '6
'3
O N d, -E
d •,� 0 H ci c-I .� � a C N
oa a Y Y v cn a v .c
0. I F w t t 'E 'E c t -6 -te a ^? 3 v
7 N O �O 0
W w v v c c E v v a E a ni u ro
a 3 3 o Q o v o
a y o o'm v v e c
0 u
o
z o .� 9 ~
y 0 m uu o o .M ° v
M v v c v u- N v t
N Ifl a+
~ 0 c v v E E v v^ v on 9 O In M
., c c a v ., c m o v
Ja E E oc 3 .0 a a'o ' v
b a a .- .- -o E E Q Q N 3 v
X X y p 0 O U 'o a
y c 9 9 E E E O .0 9 0 c c v ti
W O N tO v v O^ O z -6
ttn ttn F- F- a c ttn E 9 '6 O i v
p o a� oma n 0 v�o�0H as v
to
t o c
3
O v v -- o
C1 X ._ v
on o
-0 v o
O v
N 3 �
3
v c v Y
f0 a Ib a
o
m o E .E t v 3
Op •;� N c v o 3 0
c U °
N c rco 3 3 v
Q w .� ni -o -o ro O O o
t v�� In,
o Y N
3 3 o�no�n�'o 3'>f,r, i.-ot
x of ;; v v E E E v E N ;°
W K s m m v v v c c a a.o y o -o
C 3 E 6 6 3 3 -6 0 `O
v
Q N g M M C v ro O ro O v t
Ip .@ .0 C 0 9, 3 C a+ fl- y
w € C v v v a v 0 In m
U -0 v
E E o E'� o a 0 t
O wp c v a aoo v
y z F a s .X .X v E a a 3 v
v v M M o v
E E E .0 z- 0 c c v ti
f0 uavtiHHa.E �vtia9 :a o i v
Qa�Nma��� aa�v
z
C
s
�
�
v
d III
➢ �-
�
�
�
C
�
�
r.. i
N
Go
W
Vi
-
c; •--.
mOaOb'�'
3 v
m O
O
So U
C�
U te
ro �y
W.f''��
K lo
ro�
[i
v
Z
vl
h
h 02
n,
m
m9
� ro
� ry
�7
E
U
vl
m
a
.F
O
N
O
E
C
E
Q
r`I
u
C
Gl
E
s
u
m
a
c
O
3
K
O
v
C
u
H
K
v
�>
vEi
n
9Eo
0
x
E'z-
C v
O
v
`o
f0
� v
o v
v E
on.°
E
0
E 3 a
v
E
0 0
m E
o
m Q 0
m
m N
bA f0 O
C -6
9 N
E
E.
o E o
o
-
v
v
J 9 'X
N j
E - v
un 3 v
c v
=
o
W V
E
V
Y
iEq
N
H
K
�d
ro
vEi
e
vEi
n
o
�
c
ro
o
v
E
c
t
'v
t
N
0
o-
o c
-
v
E
d'
cc f0
c
vEi
E
0
E
�
Y
m
r� E
rc'
E
E
E.
c
o
v
v E
m
of
F
N o
o
W V
E
V
o
iEq
N
E
on v
v
w a E
W
rc
o
c
v
E
E `^ o
a
'6
w'
u
irl
c .X
O ate+ N j
E m `° oo
y
c Q
N
rc
O
�
v �°
w pA =
o -6
"
o
'^ in
v o v
C
'3 m
N C
m a 'v .c �°
til
rc
Y -o
v >
> v z"
v- o o 'v
a
., o
v v o
c° u
0 d
a
t Z
c Q
a
v
0�°adv
v
m e N
mt
a
,n v
C v=
E v c
CC N
o
c3
sem+
C U
9
0
O ,c
— N
E
>
;`Ey
z v
�a
'0c
rc E_E_E_°N
m m
E�'Ero
E ro
E'�EuE$Ec`
�o
m.'c
w a
Er
E_
EE'a
t C^
v
Ea v'_9
K N
u
t t0 bA
0 3
v u6
ocn
bA O
v a>i aci . D
cwt a�
-u.
'
v
av 0
�x9°
aa
Q 9 Q
mcn
rc
N
vEi
e
v
Y
v
un
�
c
ro
c
t
'v
t
N
0
o-
o c
-
E
f0
ro YO
cc f0
c
3 .. E
� on
o c E
c
O >,
N O
E
Y
c
E
o
o
8
o
v
v E
o
F
N o
o
a Y
Yom^
9 Y
E
'E
E
on v
v
w a E
°1 —
o
c
v
E
E `^ o
a
'6
w'
u
irl
c .X
O ate+ N j
E m `° oo
y
c Q
O L'i
O
�
v �°
w pA =
o -6
"
o
'^ in
v o v
C
'3 m
N C
m a 'v .c �°
Z
a
Y -o
v >
> v z"
v- o o 'v
a
., o
v v o
c° u
0 d
a
t Z
c Q
a
v
0 ro
v
m e N
mt
o
,n v
C v=
E v c
CC N
v 0
c3
sem+
C U
9
0
O ,c
— N
.v E I in
m m
u 9
z v
o v o
N
v m` v 0 o u
m m
E
E ro
4 3 3 c
�o
c Y x x c
w a
N
AL
C
t C^
v
9 v 4 N -6 .0
Y
K N
u
t t0 bA
0 3
v u6
ocn
bA O
v a>i aci . D
cwt a�
-u.
9 c
v
av 0
�x9°
aa
Q 9 Q
cN
=
O f
3
-o a
ro Y
o o
0
0 o.
LL v v o
9 0 3
c o .v o .° U
w w
E p N
I-- m
io 3 y
o
E
> v m m
E v >' N
v -o
N
° .� .�
z 3
O O O
-a 4 tlm
N O
� o
o
Y .�
t
O
Z z
m
v
5
'E v�
N
O
v� o�
-6 c N
m 3�
'6
E�
�_ O
0 @c
W o
-c N O N
E E -o v v
v
v E v on
c E c ,c
.?
on I
,c
E E E
i+
O O f0 t m
t .� t .E
O .E O 9
C v
c
v v E
w .0
U t0 H 0
H -6 H N
X =
v
t
N t0
C
y y 0
D Q
`� m m a
`n `° v^
Y O °� E °'
m N -o
m m
mcn
rc
Eof
vEi
e
v�,
E
w
rc
E
"'
vEi
v
vEi
`e
E
v
n E
W Q
d'
E N
�
E
8
o
q E
W V
E
�
E
E
'E
E
W
LL'
N
K
N
C
E�.�E
c3
y
E
E
E
E
'C
X 5
E
.2
0 Vi 02N
E ' me
K E
N
E E
E
E ro
E y£
m
E u
Ec
E.c
£
E_
Ei
a E Q a s
f
�fJ=?�tilf
vl�yg
N�Nfcf
TE`°�b
�`oa
Ek ��
v N
t N
'O
v .� o o c
Q o =
E o 3 ow o> v o
�
o o E :> a
Y E - o �o
3 = v v E a=
Uv E
0 Y Y �Y
Y o
d > C N O. O c it 'X
3 v v o y, O m Q ro
0 on v v a E v° o
m E o= v v E t o Y v° E
3w: tE c E g
co M? E t c 0 2 MU t o o t
0> Y o N3 O ma'v .0 9 N v Q v v
z N O z tuA _6 ., NO
'o t cU_ v �' O In 'N C Q it U1 u
O a
o u' v a m c E Y z a o v E v
ao -„„ 0 E f0 0' 9 3 f0 w o E �
C N c v= N Oc -p Y E sem+ v cCC N � v p
CU
-6 -6 v 9 v
0 un O E I m m 9 9
w .E o v m v x o u m a v Yo 3 3 c am" 1O c Y x x c w t u
N
.vO v -6 N -6 .0 K t Y m
bA O v c v v
x 'p 9
r90 t Q v Qin c N 3
- v - c Q- Q 0 a
. 3 m v ro c c '3 c .-5 o o m
C — -p O _ bA -6 -6 v it
E
O c -6 � .v -p .v uwv NC N Cf
w m w m y on 0 0 w
3�ovoo°�v4 5oaac>O�Y�'oEEo
a un c E v ro 9 Q 0 p= o c v a;
ra
E m.> v v E E E
Y E o `o 0 ' .� '- `o .E `0 9 ocn v v E
U f0 H 0 H -6 � N c v X = N ,� f0 y y 0
ci N m C Q roO� n Ypjm O E no
v v
-o ro ro
0
Y
m
E
E
Y
ai
m
O
mf0
s
�3
r`I
Ln
Q
C1
r`I
Q
N
3
m
m
c
O
N
0
C
G1
E
m
C
Gl
E
Q
r -I
u
C
Gl
E
s
u
m
Q
m
C
2
0
v
0
o
E o
E .y
O
u�
o v
un m
c v
Y a
O
� Y
Y N
9
m N
� v
v
u m
J �
bA
v v
f0 j
bA �
Y
a �
Y
O .0
(D O C Y o p C
o X
v
v o_° X ' v o_
'c
v E
'^ v v v v
= c 'c_ = c
v�
E Y E
o v
c O v v y E O v
N O v
O -o v E E p E
Y
O 9 O ti O
m v
v
Cv O C �-
o
>' O N 2 C
v O N
9 a—
a—
Q o
O
E> o
Ya E> 0 C
`° a a° a�
N
v E o
>, 3 o N 3 v
° u v E o p v v
Y f0
-6 N C > it Y f0 C C > i1 '
EO
E
E 9 N N
Y c N Y 9 N U E m E w
C
� N E m u a,
D m ._ ._
w 3 v v c N E ° a v c. E
m p ._ p m ., N O m
w
v i1 v v v -6 v
N p it Ul O v it v El -6 N v N O v O v v
w
t E t E E Y
E `n io o f0 t E
o Y E `n % o m E t E ,n
0
Y Y N N Oi
.'"
Q .ti 9 O v Y o v Y
ri
ti v .ti in v 9 Y v
v— v N N
9 " v— v
-6 Y in ci
Q UN Y N
9 tuA �
CC t m bA 9-E N
p 'p a j, > 9 E 'N awc ? >'
v p v
9
E
0=_� p a O o m E t O a O
O O O ro 9
v ? v O O m c? -6_ ? v y0
f0 c .� v
`v v
a;°1 E o
c` u v E o 3 c c` u
v o °; c u v v o w m c v
E u v v 9
v t o 0° v
Y v
c v '" Y v v '"
v
o E 3
N O
c -o c c x Y
v c o E -o c c mu 0 c c 'c o f .c c c
E E E E o Y
.c .c
on E E E c E E E E°� v E E E E c E E E
9
'm tN ate+ ate.+ Ou v Y Y Y Y v 9
o i. v w un
m in ° ro ro Y v o i. �a v w unN 0 m: c",i um Y�a v w
Y
c.o
`v
(D oc Y `o_ p c
E
o E
x
m o= o v o—
N x v 0
E
v v E
v '�
c v v
° v c
'Eo
EY E
c o vy
O a, E -6
N O v
Y
0 v v
c
9
ai v -6
O v 9 O
O.>
.n a
O cm C u, - a '> ro v
c v o c
a o v v ° c p
aa E 0 9 a= E
o a=
0 a�
o
Y
a� 0 a° a� v
c
C
v ._ E�
- f0
Oen ._ E w p�
-6 N c it - N C C v .�
•o
3
v Im
v U,
E o
- N v -6 N v
" m c y v 9 v o c v
E U, E v
z
o m '_ ro x
N ° '_ oo m '_v f0 x oom _
o
v c v
v v v v v v
c E o 9 v Y v E o 9 9
w
NE NEn.�E
oY Ea�NE NE�`E na�NNE
N°
Q .ti 9 O Y � Oi
9 w
Y ti w v 9 YY v
x 9 u
C
f0 v f0
—_ N v f0 N —_ v
x
N= -o v
�n v — N N= -o v E N= N ro
x
yj
O ro Y E
" ,�
w a N Y N N O N Y E
-O N -6 -6
Q m � �
N
9
cc t t u
N
v 0 v un v
-o :o 'v a v
0 .� 3 ro o a v= 3 ro o
''^
mon w E
0 0 0 c>
N v o a '�, `° un E a t o v- -o
o 3 > v p o `o_ o c> o o > v `p m
a, ' a, o E o
.o
'° c c N 'v a; E o
c u ax, v 9
v ° .� c u v v 9 '" o 0 u ° w v v
Y v v
c o ;° v Y E v 3
E .E E Y
E E v
N o E E E .E E E .E y o E E E m E E E
c_ - . c c 'X O
E E E E 2-6
v 'C E �O :E - C 'C_ x u O 'C c 'c � c 'C_ '
E E E E E E E°� v E E E E E E E
>. v c
-o �, v v E v >. v v v c u .. v v v E v v
Yv Y w
w v Y v 9
'6
Y Y° Y v Y Y Y v Y Y Y u Y Y y
m '6 w un °
o v w un
in ro mu v o v m v ro v w
v
m
a
G1
m
C
O
m
f0
s
3
Ln
co
3
f0
00
Op
C
c
O
N
O
C
Gl
m
C
d
E
Q
I
N
u
C
Gl
E
s
u
m
Q
°
Ov
- O
-o
0
ai uq
Y =o
o '� Y
'E v
Ul ate+
v�'�
z—
9
c
v
o
'C
Ul
v
z
tlA
O -o
3 `o
Y 0
0 0
O'E°
0 on
c
'E -o >
o c
ate+ v
E a+
�o�
cc E 3
a
o
0
'c
t0
v
bcA
a
o
0
'c
0
t0
i �;
v
v
w >,
r`o 3
o
o -o
'c u
Ul �,
9
3 0
c -6 y0 N
C C >
ro
.0 3 o a .v-
N w
u .
o i in v
v v f0 3 o c
v o v
O � -o `0 Z-
0 o°n �-
.v 0 o E
o°n 3 E v
v E 'c v Y
°m on f0
bA w N
'0 >' bA v bA
;= c ro ucn .�
v v 9
E °
- �5
v
-6
C
ro
ro
m
a
v c
v
3
'y m
c
u .o
Y
O
+Y'
:L- E m
vv
o
a
3
v
v
— f0
� `D a 3 `o 0
u v
0
0 0
°1 un c
c
o
v o
c m y
.Q
9 0 o m
o .E oE
m
9
v
v v
+-
.N c Y v c
:t
°
c
'c
0
3
o
c
o '� °1
o m y
0 a
N
°
o
0 0 0
v a_
9 0 0
o v
3
°�
a
v a
N
u ro C" o
Y o o
E cm v u -o
ro
m
a
o
-
°c'
v
_
own 3 0 -°o c f0
tom^ >, c a rco
v a
`o ob
3
0 3
° v .�- - E o o
- 3 Y a ii
9 '�
E .E
-0 7"
-o
" c v .a on
zz
o
Y
o
0
t °
-o
o
-Y
12 o'`c
0 'E0
Eo
O
0
—
°v
°v
OU
9oE0
NNcE
o
�
3
o
.v
o
0
0
E
�ooE
o
o
`
o
mv'E
o oSO
CL
comm
0
E c u.
N
o o c 0
zo
o° 0
v 3
o .�
o
c Z o. E v 'E
c
9
'�
3
-o
`°
`v
.° v
Y 3 0 3> a 3
.Y
o p _ v
`o v- Y
c
on o
c
o
E
E 3
— v u
x
>'
.E N
'° 9 E ro .E ro
o o> ai o°
> c o
3
c 3 .� u
D
c v=
c °1 E
c Y°°
c -�o o v o �' '� v
w F ^' 0 ro ro v 3 `v
CC O
vin
O c
Y
'2 C
p
v
��—, 3
'2 O
�C—, O U
'E =
Y C" c
'C N 9
Y Y •• v U 9 t m
'C c
m D v v 0 ro c
i > 0
O
w
i �
Z
o
.W 3
O
i E t u v N
3 E 'c
w m -6 C u .o- y0 --u
'�,
w
=0 v
.c
-oma
w v v
v
w E _>,
f0
v c u u 9
p
f0 > .c ocn 0
-6
m
D 3 3 .�
0 3 v
0
0
O N v
O v N E m
.� rco v -6
m o
W
Q
m o
1
LD
I ;0 3
° ..
I c o c Y ._
0N E
ro y 9 u
c c °1
o ° y
y
c .�- v
o Y o
c o
o E
c -o `°
o c v c
c' v m E y ro
o 9 v 3 3
c 0 v v i c N �',
0 a un v v o
°1 a
c O
o x
u -o :° v
p
u'
u v E
u o 5 Y
u x> o v
u m ro v c v t
u rn
w
viz rm
z w
v .c
v in o
vi ~ =o 3
viz v °1 -`o a m i
v vi w> b E o Y a o
w v
9
un 0
> p
C v
C N U.
o w
_
0
v 0
>
o
Y
3
o
0 v .
io
o
v :°
O on .i
v
=0
EiEy� v
9
6
v
0
c c
'^
c
3 E
y o o
-o —
'E
o
o u
.59 y N
v.v.c
pn
o
v t
5- vi 9 C Y t0
v
c
on
3
E
Eo �' o °;
-
c
o v
Oc
3
° 3
v O� U >
-.0
oii
o
m '� t o
E
° c
c' H
3-E°°
3
um
3:m
w o E
Y — v on
mu
u
o v°
Z = o N u .c
¢ v o 0 v
w—
um
c
E cc
0 mu
3:E
~ > Ea
c
v
c
o o
'Fu E0
O
E
c a
w
0
O v
O
m e 9 v o v 3 0
T
o—
'�'
in i— 0 a. j
0 uw
c
?
•' N Y
z
U'a°1
W
y °
f09
o '^�q
n o
v
- v
3
0 c
c
c
o 0 E° o v o v
o 3
ro 0
v 0
E �,
m y
�- c
F - a Y
U c v 0 v 3
m
>
N 0
N
pq o fl- bA m ° 0
pp Co
C
C
E
C E
Y
c c
1' y~j N t0 t v o sv+
1'
3
: 0 u
m9
c
�O ��> °n0°Z
Ian
o
=�
E 'c
a
c o = t .� u
in
0
0
3 v
p t
a
O r°
0
0 °n 3
m
O
2
v on
C7 ~ ti 9 v ,°
`> E
W
N
1 3
0
%
o o
'Q
a
c
a
c
v �p
av
a c
c� o
a O v
c�-6 3
u1 2 0 T C O_ u
c0 u �•� N
3
u1 C
c0
x
0
u
0
u
_ o
''
o E
u v E
o° v 6
u 0� o
0 0 o a
ua v� >.�o . 0
o
urn
w
w
w n o
w >- 3
-6
w ^' x c' v
-6 m o
w
w
in
c .�
w -
w -
of ui t H
of ui
N
m
a
Gl
f0
C
O
s
�3
u,
co
3
�o
00
bn
C
c
O
N
O
C
G1
E
m
C
Gl
E
Q
I
N
u
C
Gl
E
s
u
m
Q
v
m
a
c Y
.Q Y
U c
Ev
p v
.0 0
Y f0
c .�
° o
a, -o
U :' t
'v
f0 v v
u a -6
vT
3._ 0 O
0 a N
a o -6 un
v 'x E 3
v .N -o
fl- p
° v
O
° v v °
cv> u f0
o -o o
M `0 2 c
_ „ p
o'n v c v�
t
v :°u 0 own
t N v v
rc
'w
'w
v
3
-o
E c
v 2
Y a
v v
0 ro
a >.
o 9
Y
o
v
a s
v
3
-o
E c
v 2
Y a
v v
0 ro
a >.
0 9
."�.
o
v
a s
o
v u
3 v v
6 —
u a v
- on
c p v
t o
o
m y ,�
`o
.>
c v
E u y c
v ., v
.�
a w v
nn a o
v v Y
-o ° o M
a o a
v�
N O
3 m
3: o
v>
a;
.n
-
° O
c
E°
v on
a
-o
a
°
N
c v
'v -o
3 c
o O
a 9
E E
Y c
v
f0 3 0
u o a
=ro
on
un 3
0
N
m
-6 .o
`> N
o
t v
3
.E
u
:° ±o
0 o
c v� v
v v' a ''
.E
—
° 3
—
-o -o
Y 'c
o-o�
t
v
-ot��
`�° 3
au °o
U
v 3�
c v
a
in
E
O m Y
o ;�
�- :°
9 .6
v
c v 0
WD
E c k
m c .� _
io v
ro
on Y
c :ta
v m y
v m
o v
0
in
v t a—'",
`3
a o
0
-o a' E
-o f0
9 u
o `p
v
t E o v
uA ° E
c
0 Y °
�,
—ovn o v `v
a
° °1 °1
.�
'� 'c rco
= c
� 3 v
on
:°
o v
.. -o v
ro 3
"
c
N N
a
N o
�, c
a
v
c °' -o .c
u
v o
- m
v c o
o'n nn v
o
t -o
o 'a ��o O
nn o
N
E c 0
Q.
3 0 v
o v
ocn
o
0
3 v
v o
v v `o 'c
v v m
o
_ 3
v
=_
v io
v
'c v m
3 3
ro
Y v
on
0'
0
-63
0 un
—- N
M
v E
M 0 un
m c
N
on ro
0
O v M
a,
c- E
c r>o
v
o'c
_o
�
c
C �O 'O v
N Ul 0 0
v° o Y
> °1 v
0.LO
X 3 3
0 0
t c
c
c °' p� -o
M
'N 3
.o
t '� 0
c
v Z-
E =o ro
r! 3
9 v y
`� o
M -o
N
:t�
a
.-
c O u
o 3 a
v
c o O
3°
ro
c o
o Q 2
E t
v c
N° t
v °
3 v
'a v `o `v rco
¢ a .,
Y v
u
Q
-o
° v
o—
3 f0
E v° U
c v
N
t >
um -o
r3o
:°
N =° 0 3:x
v t
v
c v E v
v O
c
r3o v
— v—
zr
ro c
f0 -o .o
E 2
°
o io o
�, _°. •• .
CO
v
0 c
a �' v
a _°
t.
_
9 Z 'E
v c c
v o o
v 3 0
v t
E
io x m
0
Uo
W 'c v
t o
Y° on
Y o 9 v
m O 0
u
p v
t c v v
N a+
;o
tLJ ' E
.,
ry c
Y '�
,a
c N .�
C E U
in N C N
ro
0
c
a O
'� v p�
.c
.-.
'�' 'x°
vNi 0
?
._ —
o v v
p 9 -6 :°
.n -c
M .�
-6 m
._
O m
o
_
a v 0 E
o `�°
v
-oY
a c c -o
00 �Ny
on.
�.sv
�g��
Yoo
a
:t
�
�-cE°0.
°�
Y +' v
io +' 'c 0
_
v 0
_
C v H C
to
N N f0
c
v
'> U E O
O
_
> C
O v `v
3 N u
yi a
v ro
v M
9
> C
O '^
—
CO 3:
m—
o°n
in
o O 9
E
a h a
a 1 a
m
3 M w
v — ,v,
°
O
mo 'o E 3
E O c
= o ._ v -o
°
v -� '� `°
=
'v" v
.c
a '-
N .?
E a
0 3.
_�=0
v v 3
3 O3�o
D°
-6
3>r°o
r°o
v
.3�Y3
v c N Em
on
vv'o
3��c
oY �3
v t -o 'v
o
a��°1
t �,
3
iYa"
O a
-6
t 3 3 .o
v
a " c o
.0 Q
c:°
m v =o
:°
a v
v
c ..
3 _6
o on o v
Y
o on c
..
� Q -o
Y
a —
o M
rco
o 'X
v c
.o v
,� c t t
�, .. c .O
O v v
' '�
c
'a
0 c m o°n u
.� 0 o°n
:. ro �0 3 „
E v o c
Y o
`p v
-o
a� v ;o
c a ;u
a� E a�
v 3 -o
a`� a�
c '^ t 3 v
f0
v U
t `° o
a� -FD o t
3
E°
o
v
o .�
a 0
N
in
O
a
-o p
a -o
ro 3 -0
3 `m E �,
p.
-0 3
O
"'? °
°
N M
9
-6
N
bA
t
Z ro
vi
°1
0
'c
_
uo
E o c
m u
v'
° ,°-u
u
o 0
vow
v 0 u
tE 2
°
cc
`v
0c
v `p
v 3
va v
0
X 3
0
-c
uA v
v
c
c 3
c 0 o
3 H
�
9 v c
� v
x
E .'0-
ao
t c v v
0
u
ro
c �w
0
cc
c o
°
O .0
.E
U Y
— •• 'c 0
'c
m 3
N'�..
v v c c
v-00
0 3.
3
ocn v
.c
a Y o o
vm
p m v .c c
Z -M O 0
v..
e
°
Y �a
o uu=
O c
v
m
a
Gl
f0
C
O
s
3
r -I
LA
co
3
f0
m
Eu0
C
O
N
O
C
Gl
E
m
C
Gl
E
Q
I
N
U
C
Gl
E
s
u
m
Q
v
m
a
o
ro
v
Q
o
>.
z v
c
o
a
cf0
E
o
co
v u
3 v
z
c
w
v
v E o ;v
o ro o
1 =
o' v E
o
wv ar.
v E
oc
E
o vYc
o a v V
° 0
v 9 ° v'o
v E= p
H o nn 2
v
E o v rr >
m 3 ro 0 0 a
v -3Y
m m �
� 3 E
v
E p y
ca o
0 o
_
3 9 a v v o
O O m v 0 v°
E o .�_ o
� o `v ro c N
a Y �- o a cL
3 o oo
a E t -
c .E 3 t 9
° c E ° c
o_ v.O
ro
ro
v nvn
u
o c
c
a o °
V "v
c
w>° :° c t
O 0 J v c m
v .� 3 v Y
-o o v a E
m ro 3 E ro v°
Y E= E
v E .c m t o ro
c
E 'v^
O O
vE cE0
v o Ev Y0
-EY
E
o
E of o 0o aY�E`v,
ED -
o v o z '3 0
j c 9
3 c 6 c° �°
o v 0= t E 0 M .E
Q .N 3 E 3 rr
X
c
N
0
Q
bA
-FD
c vC
-p M0
ON
v
m 9 v
9
t
0 o
.0
.Q
9 v
m v
c
on o f
:° ro
° m
-o
46
in v
N
in v i m ,_
y
Q c
`o
N y
0 c
`o
c 3
c= c 3
c v
° o
c
v °
t =
J '-" v v
t v—
J .'-" -0
O
9 :o .,-
E
- v o
'- .y
Z -
Dc
3 0
0
°
v
9 E v 3
.c
9 E �o w
.c
v
= E v .� u
.o
v v
3 v E v .� u
.o
3 -o p
v v
a
o
w' ro
E v
w '-
N Y o
Y
ro o
vv Y
Y v
°
c v Y oco
'Z-
c v 0
° r`o o
c m 2 `o
c ro in v 9
.0 v
E on
o o c
-o
c
c Y
= o o
.o o c
v .E ._
o Y v .E
00 v
=
N m
Q=
'' -° v c o
r�o ° v c°
N -o
o
Q v c
-6 -o v
v v 3
uA
v
m=
x c
two o v
v v
x Y
two 3
v ro v= O
-o v> v�
v �',
m v -
f0 v> vY
-ocn O y v
> t 0
c
t _o'er
Y'�
o o
E
rco y
v E
N In =
�° v
�°
v
N v a
v
ro v a ro
nn v= v Y
c v N -6
v= v
O bA ,� v N '6 O
o m v 9
v 0 0
0 9
E c a v
E a o.0
v o Y w O
Yv
o o
nO v
o E
OYc
O u c
- O
O
nn cv
v- c 3= o a
0
3� t
v
Y'.f0
3 v vY
g3 0
Ea
o Y
vovo
cv
v
3
vvNv
vvNvY
�v
.My �Y
:x w
.g`3
-ovvW
MY
°
E
°
E
° �
-o v
ov v 0
-o
x v ov
o o v
o
�n
°0y
m
v°
EEm.-
:°vXc
v 3 o
f0 N9E
E—,003:462
v0`p
v3
c
bEYO
o E
�°
o 0
'
'c
0
0 E
o
mm m
vn
0v
o'
va
o a
'-0o
v o
° °
v
°
bo
c
=Y
o
0
c
c
-o = c nn
c t v .� E ,�
v
:
to
cN
3
c
v v
x
._
x
Y
Y
mv
Um mc
N
3
ao
0
0 ovv
°o
0 0mv 0
3
° 3
o
v
vcv;a°v
c
-m
c
E
,
o
m v
6
>
v3
wo
o v
c E
'00
E
o
o �
E E
E
EwaE4
X
O O
O O >
c
x
m
Q
�tcc
0 mu
v3 o
U
�E
. Y o
m== 'o
=
ro
3 ro v
N
N v v
c 0 3 3 0
uj
O o 03:
v° c
v
un
;� °
o a
v E
. _ ry .c -6
v v >,
v
_
o Y
Dov
Y=
0
vE
YEx� N
v
ro = o
N
bA =
c
X In Y N
bn N v a
c E
0 v
3
t x-
S a o
p
x `>
.F a
v on
o o
�- -
v 0 E
o
.�
.E
9
3- -o a 'c
o a
9
c
o o
o
;
''
o
c -
O a
- v nn �
3 .E
E
-0
'o
-o
u a
ro
c
v-
o U 'c
N 9
3
v E- Y
v
ro m
> N a
ro
v
c
Ul
c o °
ro v
av+
ate+ Ul E
o —
E
v c
UM 0 0 'a
Ul
—
`0 3 E -
w� N C
v ate+ O
- 'E a
`v
E v
E O
D o f v
o� rn N N
Y
c o v
`°
ca
0
-o
v v v
'c 3
a O n
9wN
N O
N
E
Nv=E
Uro
u
oUM
vYEE
Ev v
° 0�
v
3v
mu —O
o v
o
ro
O
°�
�
YO
o YO
o
E
`' o
o
vv
o
v v
OY
Yvv va
9 Yc
.0°oc
v
E
E
x
vvmY'c
NO
o m
o
a
`o
D
v o
Y t rn
m
N rn
rri
.� v c
o =
ro ocn :9
Y � v o
c
on Y m- o
c v c o
v
v 3
v -o v -o X E v
z
0 v t
3
:°
vNi 0
v
9 - v
v= 0
O v �,
3
FU
° v v o
vC
.6 9 .6 3 0 :-
v
E 0� o N v o
" 0
c_
o
c o
°
., .�
o
mon
ro ro >
v v '-
°o
N
o v
c c ai O E
z
v .o
ocnav
,�
rn
v
-_5
v .c
oav '�
f0 v v Q
3
a- .a o f c
c cN
o .Q r90 v r�`o
EY
0
o
o
Q
3
_°o on
c
v.c uMcn,
�- �- 0 'c
Q o
v
3 ocn
c
v= 0
c
0 o c
3
o ocn o
m =o v v c
.c :� rn .c inn
v
v v H 'ro
3 E Yo
ro o° o ro ro ro w
z0NNvi
o
mc E
-
v
E
oavvE
avro
cct
o 3°
E
E E
a o
0 c p
-
o
v E v v Ou
E c v c
.o ° v
y>
3
aN c
°
.0 o
3
M.
3: E -c 'E
3
vE
o
E
3
UMv
" 9
c
H
c
0
o otE
v
OfovC0
ro u
v
m
a
F -FAM
m
c
0
ll�
m
m E
E c o
>
.0 u
0
�o -
E
0
0 t
E .0
co
2 u
-o
-u
m�
E
3: 3: ui
E
Lo c
b.0
c?
2
m.o
.S
E
0
r-4
EO
o
u
um u c
m m E
In
8 f 4�
'C"
E
4
ou �E D
om
1.
uo w m
E
>
4,�
w u- a
u�
o o
_u
mc u.
x
-o o
x
u
E
u
E
E
u
o u
u
-E o
2 E u o
r
E
E--
-62.-.um
x
m o
u I
E
m
E
4
2m uxw �c� 03: o
U
4�
E
u
u
X
Ul
0
Iz-
0 3:
4,�
m
u
E E
>m
0
>
.0 2
4� a
m o
-2 'E
0 0
s . .- Oa
46
0
X
0
�_u
u
0 0
0
E
0 0
. 4,�
.-2
-2
4�
!E
u
m
LO
0)
u
>
E
E
0
0 t
E
-o
-u
m�
-o
E
2
m.o
t o
-6 o
x
4�
E
4�
E
w o
w
4
x
1.
uo w m
o
w u- a
u�
x
u
E
u
E
2
2
E--
-62.-.um
u I
w o o w
o z
E
ow E ow
o
m
E�o
m
o
E
--o E
o
z -
E
_E
E :L c
E E
E
E E
wo
o
z
0 3:
4,�
m
u
E E
>m
0
>
.0 2
4� a
m o
-2 'E
0 0
s . .- Oa
46
0
X
0
�_u
u
0 0
0
E
0 0
. 4,�
.-2
-2
4�
!E
u
m
LO
0)
G1
m
C
O
m
s
3
r -I
Ln
co
3
f0
m
Eu0
.r -
r_ r_
O
N
O
C
Gl
E
m
C
Gl
E
Q
I
N
U
C
Gl
E
s
u
m
Q
v
c .o
v io
v m
a
�-'E
m c v
m E
m
m `O v
m
v j a
U
°v
c v v
o m o
c 0
o
c v
°
E
.�
c
v
c
m
9
E
C
v
on
u
c
-
o
v
a
N
irl -o
o v
� u
vY
O v
on
e
O
.�
m
ao
m N
o
m
N m
O iu
c 2
m
v 3
on Y
c
c
e°
E
o o-
o y
o
O
0 v
c -m
O m
° U
E
E 3
v
ocn
e a
vv
v
o
v
amb
w v v
YY
0 0
N m
u
�v
o a
a s
v Y
v
E 0
0 3 w c v
v m
v c v t
m 9 v -o
Y
o9�vo
m m y v
,n v° `o v
C C t
o" O m
p v in
v v
�9'-�
m
o
o v° v v
a v m mon
' o m °
v v m 3
w
m Y o
t
v
-o.
v o
3
c
on
v
c m
.i° m E
-o o
cc�cn
OE c
o N
u
mO
v
-o v
n
4;,'v v v
''
on 3a f0
3
c 3 a 3
°1 o
N o 0 0
c a
O m -off
0
m ro o
O O
v
J
'-' S v
O Y
v
C v
o
u
m m
t N N mu
v
p .c
v N
Y
v
v
w O
o 0 '-
c
-
E
.�
4 c v -6
y o
o3n u E
E c v 0
v`
o
m y '� v
um
v
o
°
u
Y
° c
o _°.
v v
m
3
w N 9
c
E o° 3
.�
9
a
Y
on
J' v
m °1 3
'�
v vY
'c
o `O
av m
.p
av -o
''v
c
a'.°-�
a Y
E �Q c
mon 3
o
o
,� Y
v' a
v
N�
3 t v E
p m o u N
�, Yo
v 9 �, v
c
° D
a
,�
9 .x
ro o t
w
c v
v
= 9 ocn
9=
-o t -2
u a� 9 °yam' c
m -o
v
- v
0 c 3 '3
v
9
3 v .�
c 3
m v:° t
y m c v '" -o
E 3 ._
`o
N t
Y
N v
m
v 3 v v v
o
3 N
a O w 3
v
° o
-o
o a .. x
v
¢ o u
v v
v v
o
v v
v v N v
E
c� a
u '^ -6
ai -o
Y
u �- y
D
v
c
nn nn
oo v m O c
m
v
-2 u
0
m Su
mum v v
c
O
.4
E o
° 3
f°v
0oo v
v
v vc
vc
Y o Qv
vOZ-
m
•
m
°0
u
w a t
i
n
p y v y
ou '�,
n
N
C
t y
m
'""' C
C C N O N
p bA -6 t
bA 3
C Q
v
v -6
a v
v 9
-6
O C y v Y �' 9
•N
:
."
c=
m O m -6 N
3 -o
O C '� N ate+ E ami
•m v -o
N v
v
a
v a
a
_6 _6 E
v x
H=
on N
i
m
3 3 'E
nn 3
9 O
p= m y°"
t N
Y
' `a -o
u
c
v
3 O
v Y�
u m o
3 .c
u
N o °Ncn
E 3 on
w a N
°
v
° a o a° m
v
z m 'v" v a v
= m c E
°1 v
in
v
o= t= c
v .��
c v
m y
c
0
0
'_^ a o v ,�
o f0
c
y
c 3 on un
:a c :° '3 3 �
w o
m v '_ on � 3
0
� v
0
.=
o c m -6
u v
a i,
E
y
c -o = o.�
v -o y
m v
c
'o v Yo N -o °
Q 3
c --oo.c o--oo=
v m y v
--co
E.c
'�
E 3
'x a
m o90 v.Qt
c 9
� f0
c
m c
C7 ¢ c 3 m v m°
3
0
= °1
x N
v -o +' O v
v
C7 `O v i m 3
m om_
m y
v
m
v t a
v 3 on
'v
m -o
E
v
-o 0
-ocn
x c t a
o v -o p
l o v -o c mu
.n 3 Y -o v m on
3
o
E
m
E x
m y
t N m y
3 z
o 0 � c a.0
m
N a �
3
o r o c
o
N v N
•--•
N Q
N z
m
•u N O m v bn =p o
—
E
W 3 'C
Vf un O -o -o a m
3
un -4 -o -o N v
vi ui H Z m
v
v
N
t
ot
3
m
on N o
c 0
= O m
° a,
v +'°
f0
v c
v
O �_
Y
O
.y m
O 0 v
v c
O
.N
E o`n
v .Ym_.
on Y on ,�
un
u
-o m
u
v m m f0
v
'c
E m
ui 3
-o
m m
mu
f0
o
v
E o`n
t
v
v t
0
io
Y t
c
o ,c '_'
v E :°
v on
'3 � -o v
v
a
t v t
-Dunt 'v" =
� 9 c
°
1E
3
v v
o °tom
v
.�
3 0 Y
N ocn
E Nx
v
Y
v
Yu
f0 v c
0�
E
c v v Q
f0 v v
un v
co
c a
3
o'm .0
onv
c
v 9 a-
v c
Y uc 3
3
o m
a v
a v
� on
c
v a
a
'� c -moo
v t
°
x N 9
c v
v� °1
v Y
o_
c y
: 0 c 0
0
' 0 E
mu u
c a �`
9
o
v c �O
0 Y
-0 t 3
'on
Ou v
O a
uu 3
cti
E o '�
v
9
c
v io
o m
o
v'
c
a m
u N
v '�
m
E o
Y
v c a 3 a
v
o
v
° a= x c
m .c on
E v c �o`o
v
o
a
w o -o un -o
f0
`o
9
r a :�
w v p O o
N
c
E v
v c
r c c v
m
Y m o on o
-o -o
u N 3 o
— o v
c o
v y
-
u a ,�
Y m v i v c
.-. N
v c
u=
,�
v
-o v a
Q Om E
v p
a :° 3 t c
a a t om' Y Y
m o
C- �
a O
N m
t
m
•2 v -o m O
& v 3 a u 9
`f° c E
v
rn o
d o io
•c u m
-
7 -o m v ti
Oq ._ E c -6 N
•c 9 0 t
m- _o _o
3
m v v
c v
3 =
v
v
9 i
Y°
N u t
c c m
�. u
.. :9
.%
c c N ,O c�
=° " E vi
pq m a� rOo
c E .m c
„. m=
'c b 3
m 3
c -o
=
= 0 m
m on v
.
4. 0 2 3 o
m -E .� t v o
c v
-o
.t
m m o N c
3 m
00
v
o_ nn v
m w 'c o°n � E
v
O
'.. o
m y
N p
E a m
u -o
c
3 3 v Y v
p= m y
3 3 0 v v N
E v
`v
m
a
.O
oq p un t �. v ._
- N
c
m m .-. c on v
u o m o% 3 m
v o- v
9
v Y
� c
3
m
3
v
o on m
v v v
3
m
0
m O v v v m
-o °
m
-0
3
-o
=
+• c v .,
=o - :° 3
m o v. c- m
`w o
o
- m
Y
,c
v -moo v
m .c
o a,
c
3 0
a 3=
t 0 o
v -60
Y c o°
c °
E
Y o
E v
o w
E
E 9
a
(7 Q c O m
.. 3
O
v -0 -E o v v
a
v
C9 ¢ c t 3 '..
o° 9 0
v
c
.X =
v
o m
'c °1
'c v E
c :0 f0 c v
'n O -o on .m v io
m y
'-
-moo
o v.= c
ti a m y -o O
m
�^ F v -o -o
m y
E E
�-
E m
'E w
p a-I� io UO
c
rl� m
O N �_ 'w v
E
u N c v '� :° v
O :°
Q
N Q °1 :° z '�
u N° E v -o
Y
VOf �n O -o v -o m
m -o
�n .� -o -o c� v
vi H . a O m
m
-c3, -o
v
on
v
N
a
W
m
C
O
.P
m
s
3
Ln
co
3
�o
O
N
O
C
G1
E
C
Gl
E
Q
I
N
U
C
E
s
u
m
Q
v �
v
.0
v
> E o o
v
m Y D oo O
c�
N O .'
-o
9 9
3 o
v °
on ro =
Y v
O
p
..
v c v
�- w u o 'c
.Q
N 3
o
of E�
'
-o u m
5
o -0 9
m 3 _ y u 2
`o
c,
ro Y
'c
- m
o c
o
u
w
c c a m
E -6 4 O.
u in C .0
N o v
io
Y .in -6
v
NO
v t
-6um
.v
E c
-o ro
f0
O
v
N '�'
v> Y
m E'er'
a
v
.0 a on `
c
-o °1 >
u a 3
ro '� c
o
>° c o 9 0
0
g v'c
v v
0 Y 0
3�:
c o
O
o�
y
t`
v v
mu u
O
c t
° m m m3 u°°
z°
u I
m o
o c
0
C
u
a
o
c
0
O 9 bA N
aQ
W
0
v
'-" EE'` c
a
00
o
onv
wQ
v O
V 9 3
E m-
w
H
v v a
Y
'�
c E
o 0
tLi
O
L
N c v 0
E° _
o
N
v
bA .--.
— v ti
a
a
_
J n
9 o
++
Q
3
�.0
v v
Y
r
oyY
a
��
o
m4io= o� E a
D
v' f0
f0
E
�.3
u x Q 20-
o Y
w
U
o
c v v
f0
v
:c
E
vi
m
° c ui
w
m
c
a
E- Q °°�
E
4 on v
0
m
Q
o
o-
on
>=
O
p
-
v
it cc C 'w w
F
p m N
-p u
N
-6 bAum m
0
W
L
ate.+ Ul
v 3
u
Z
.c
3 v
E
:6o
Y v
a
v
z
v.t
3
°'t
v
v
_°
o� t0 bA N J
m
-6
3
-6
c
C N -_
C
1=
ate+
C
C v v m C� O—
-o a te- v x
v
a
W
0
C
-
m o a N a
c Y v 3 o
v
>,
m m
O
L
Vf
Y.. in ° 3 u o v
m °1
00 9 v
Z -o t m�
v o m
O
L
L
e
m
a
o
3>
v v o c
>
" o v v
.,
-
a o E m '� v � cmv
W
z
0 t
v
0 a u a
Y ro
>
"
m
3
Q�� o N. .,
=
Q.3
c _
�Y u cod
o�
3
mY
07
o c E v -o o v
E
~
,.
o u 0 0.
a
o io
>
`n _
c
Q -o
v
c
v a
'E
z
c
.o.
O
o a
N
LL
v 3 9 N U N
_
O 'v m
O
bA
1 E ate.+ Y
LL
O
-o
—u N
0
W O N
W
F d
D
3 z rao ° ro o
Z
.X
LL 9°
'- -o E
E c
E
H
M
.0 O
C
a
LL
v w
bA
N
Q Y
rnf0
m
m
U
i
0 K J IA
y„
'6
u a5 -m v
v
U
Y C u i
`O
v
a�Lo v
v _ o
v a a a � .3
U 9
v C v >
in N O Y N E
J y
io� ro m-2°
3 �m
Y u v O
�Y w uE
0
4,� E
c u o m
°-R = axi E�
o
= > c v t
.3
o m 'E a -
c �
a v m c
J° v N O v v 9
E v
O in v �fN pp t0 N
t0 Ul
u C
m'
m
D o o o io > `n 3
v c O o �- o a CO j
C d O 'i
D }~O, Y a p S O � v
n oot
' v E E c E a u
O lL ° U 'O C C D O a 0
v E o E ob E v
ii m E c m m -6 m
vi vi o= o m v a u 0
cD
z
Y
z
a
Z
W O
V J 0
LL
O W
ti
w ti .
N
N
a
on O
tO J -6 y v
E c 5°
p_ O v 9 o ro
ro c c
v Y
o
v 0 o 3 E c a
-o ro E v E Y w
u o U C_ O
N N= o' Q"
9 m E c v
v
�9 ° v�'3�
o E a 1 0> f0
E o f0 m m v
o v �° c o v m-
- c. v c
0 = 3
o
0
o- -> c E ai v
v f0 v o o
E 02
a Y 0 3 E o0n
° �on O
tO J -6 y v
c E'5 °
= O v 9 o ro
:u
v o v Y XO
Y o 3 E 'm a
E v E Y w
3 9 o f0 .0 0
O N= o a"
v E c o
v9 ° v�'3�
E a °1 o>
E o 0 m m y
o v'o c° v c -o
.� c i v c
0 = 3
o c
0
-> o f ai v
v f0 v' o 0
02 v -`o -
Q Y 0 3 E o0n
ov E
v c O
a-=
c
`o o
v o v
° v o^ °
E �'vim u
� v
30: c
c
v . v io c
E
=
•�
v N3
-
N m
A o
.� o c� U v
-o o
¢
p N
3
_
E v
m
v v .o
.o m
E mu o
v
m 41_
E o
o m
° �- o N �o
E
O p p
v o
'c = v o E v
O
-o v
m
m y cc 4
-o
rEo o"n o v �°
m y
'c
f0
Q o 'c t v
Y c c v c
w
� E
E
t� � ,uf0, rn rn
V'
Y u v E v
C7
Zro
D
t o
Y v 'c v ro 0
co
_ Q m
'3 aEi v Y a
3 t� �!
v -o .- 3 0 0
0
a
p
`o
9 o°n N
9 m °1 ,� -o v Y
o cc C v v
'a
Yv
v v O m ai E
ocn v
y v m ono
z 0 9
~
O
3 p
Y o c O
p a 0
o E U
D
° v E
v .L m
' v°
v E a
LL
O
3
0 c
o o 3 .m
Y
m- -o
ov
'° N o"
o v o `o 2 c
Z
r
N
p .�
row'
`o3 a p E
apt = °
-o m y
ro o -v E c
'3 a E m E
a
3
t 3
c p
0
c z t c .E
M
vcco ma
C7
Z
aor
o
v o
o3n°v Eo
3 c �;
Yo = v io o
z
•v w
~
3 v� .E c v ro c
-o -o
v N
p v
cmy��v
v
ovava90a
a
o.Z
=
3m
.0
v
v
_ E v v
��
t
`
O
-�o
a
� cv�0`"
o t
o
p
U v vEi '0 0 9
o v
w Y
F Q
Q
3
m
ono
M
a o 0 o v 9
E N 9 N
o
N
c
`o p :°
c 3
o
O
c
y
v w `O v m ,
c
O _ 3 v in
E c p v
v ro c
t0 y v O.
a v 0 v
F
F J
c F
o
c
O
Q
on E 6
v Q° -6 > 3 N
o v `° ,� E v
c
0 0 0v c
ro E =o �- a -`o v
p O W
O w °_
°
a `° c E' v E a
_
-o
.,
" •�
v
— E O c y
a
o?a0��
_
����
�a
o��.
°:o aE
�o
O
E
c o o
o N v
°
°
o
`O
E c 3 3
v
c E 3 > m
c 3 3 u v
v
E 3 � `m °
OC
t
°1 o
v
Y`
w
c .c 0" -6 m
c~ .c
+=
vv
i pv v pn .E v
v pn .-c v v
E
Yv
EE
r3
°
o
i0c
E
LA
Y .c
o Y
0 o a
3° 0 o a m E 10
e
'c
=o 0 3 v
`o
3
v E
avoo
ct0
oN� �9
o �� v °
bA
N
C O N N .0 N N
v Z_ Y C> Y
N Lo
v
w
3
m c -o m
0 U c
E
c -o
v- a u c ° o
m
to
v 0
.v
-o v
C7
Z
D
t -o Q m e
°1 v o a.Y
9 Q m e v N .-
o a.o c v
-Y
C
o
cc
x
U v -o v Y
_
OW
c
0
Q
'un
o
o
'O
33cE
E c
o = EN
>
C
u
i
, waE
c N 0
0
0
E
o
=
v
0orn
o cc o
E
Q E
41
C
-o
�' U
°
�i
3
�° -o c. L E
po =po
-o .� c ,� E v v
_ v
= Y'E
v �',
v
3 '
O
Z
r
.� �', r90 o 'c
w° E oY
�', r90 .� v 'c o o E
-O0
o
cc
a
=0 o-2 E
omv'�E vw=m
y
v °; v
vv
t 0 a
z
3
ao
3 .E v v O v °o
-
o v O v °o v` N o
-o
Q
rn _
c o '�
m a a v
y 0 v c
v
3= v
v
N Y
Y
as
5
-
°' y
o _ 0 m v
� v '� c c m
3 O o>
p v E-
- ro
'� ' c c M E vi c
o o> v
v :- v� 0 4 -o
N
o
v°
C7
~ Z
o u
v v
in c c E u o
0
c E -moo u E 9 `° 0 3
r90
W z
y m
a w
m
c a w _° 'n v
u
c3 ��
Yeo
�a
o.
3p
.o i
c=�'Ecu�
�'Eocnu� Nvo9
a
++
� ro o- v
c c c
in
LL `~" ZO
r ..
.�
'c a v E 3 .E
.� a v y 'E c
v E 3 .E o N ro
°1 Y 'c c N 3 E
Gl
m v ..
-o i s
W
F
3
0 D
c
v
o° b `o o E
c
v ci — f0 >'
3 -0
`o o E
3
o o
° a=
w J
c
o m
-o -o -o v
> E'
w -o v o �° v
i
LL -6 0"
v v
C �i 7
W 0
p t 0 ro ocn Y ti
o m U Y C -6 E .i N
u
c v
v 0
.,
3�
o LL C7
O W
u i :.
0 2
a =_ c vi
0
N v ♦2+ t
�' —_ c a v
t c v Y 1E ci C -6 v
QQ
t v
v — E
O v a,
z
ti z
n o r
m
au+ C
O 3 v
o?^ p 3 0
O 3 0.
- w p 3 N - E: Y
Gl
m
C
O
m
s
�3
r -I
Ln
co
3
m
m
bn
C
c
O
N
O
C
Gl
E
C
Gl
E
Q
N
u
Gl
E
s
u
m
Q
N
m
a
c c i Y
E
O
9 t a
v
N 9
o N
>' - 3 -o
N
O Y v c t0
c
- O
aono o -o
_
a 3rn
o Y
o
t0 N
m
!0 .x C v t v
Y `°
t
o ..
o v v O v U
E o 3
~ v
O
n o cm
c r°o c
> ti
0
ami -6 0 0 s O v
ro v
on mon '� ro ro
c c >' 9 0
a
�v
C
t 0
3 v E
sem+
w?
v Q 3
0
`°
c c o
- �c,
n
0
9
15
�mm
oo
E
-6 v
9 v Y 0 o 0
N
aV+ v In
O
N
V O
-6 N
m v
a O
N
N
t
c 0
0 ro
o"
Y Y
O f0 fl- -0
c 9" O
fl- O
N .-.
tp
Y
y, ro 3
t0
v ?
''' N v
N
m
N
c
Y c
a v 9
o� v c N
N
0 in
o .F i
v .� c
3
E
-o
ti
O i N
v i O
t c -i
C m—
N
m
0
v
om-3
>N
°�v
v�°oY
oc
�v
E-�
o
co
c o oc
io
i
°'-mEo
.E
oE
Z
;n
v
E m
r90 a v
a
v �,
o
z
w o
z o
oa
o
v
ro
v y
ocn
`°
Y
Y m N
`° c v o o
.o E
N
N o
a��.
v o
¢Ca Lq 3:°
v
t
�mvi
o
rco= u9
ti v
E�?��
v
c
v�
i
OJ
_c
�'3 E °
v o n 9 c
OJ O
m
��
a9
3
v r
-o E `^ o
o v o N
•' p
o
Y o
-o
'+'
F
"' `V
E
H
c
E c'c
a
°
ro
a ro ro -o
E
v
°
.oc
m
cc
r
v c O
2 v v
O v c ro
c v o
= .-: v
O
-o '.,
v o^
m O
n
�y
v y E v E
v O y? io
n w
�L 3
E u
'C
— t
9 o 0 3
ro o a �' �-
3 v
i. ,°�
nn -6
`v
LLO
-o Q 'E c o 3
O>, c
E in
,on
m3 N m
c
O O v >, c
.N c E
D v
_6 Y
'3
0 t?
v
p
c
on - i =
o c E ro
O-
p m N
Y O
o x
o Y m
O
E m'
o °cn
N o
o
b
o vi
-o -o
'"
z
Q
m U
'c ro a -`o N
o
Z w-
Q J Q
c
N
=o
v v
v >, -o
v m
o .E a
`v `o _o c
o ;c`
c N v
-o ' c
m m
'- E -o o
C9
Z
m Y m mu v
� a 9 Y -o
C7 o
Z D
.v
v
0 v Q
Y ro -o c
r90 °'
— .� E
3 Y
i,
E o i
Y
oa v
o v c -o '3
Y = v
9
E
o E Q
> c
.o
v
-6 C
C N
(D
N° v v 0 —vi
cc
d( o
c
U
t0
-o v a
'° O v ro °
v v
'" O
Wi m°
H Z
9 o a v ro
H Z �'
v E
c
3YQ ro env 3 f0
ut �'�
�� one Ntv,1E >
zzY c 9 0
c
^
c -6
.c >
-o o :- -6 a
E
ro =o v
-6 -6
>' v
N Y''
on m
c
.a
a
c o 3 ° -`o
� Qa ¢
N u
=
c In
N
O
c E c v
D Q c
>
c
o -0
>. c -O
Y v
3 -o
H Z '06
LL W
LL O q
i 0 c >. �
m y m E
en -o
F d
LL W
LL w a
'�
-6
`ti
c
v �
3 v
o
>' u .� o
ti
•� rn .o Y c
t
No ;o
o
.�
-0 3
W
O
a in 3
ro o c C v
W
O
v
u °'
O t
3 a .�
v �d
c_ v
N v ro
.E
-o
c c
.>_ .� v
F J
> E 'E
v .c
cc
;°
ocnc
c
Y
�-o
m¢
cLL=•-
m a -o N E
cLLLLin
ocn�
'.,
a .o
N o
z v Ey a
3
vy
°
�Ozo
v
Y 3yYY
�0
�'E
., ro v i,
v a in m
N
D Y N `v
._ — ,� ro a
'>_ Q ro
ro
'> a
oY
= c '� r'
`> ro 3 vi
w `~ �y N
of �o
o c
a .� z ro o �i
w `~ N .--.
in ro
ro ro
a v
Q
>,
O ro v
-o
v
ro
vi
—
ro ui
`O
°oma
o� Y
m
Y
v
m
> c
° -
u
v
�
Ev vi
a -o
>'
> `o `�'
°
a °" v
o
rao
ui
o E E
-6
v o m
V c
o c o
co v
m
v
it N
>p
9 Y Y Y 0
O u m ti
.� 10
o N
3
a
v�. c
N
N
m
.,
c p
m
tp
t0
.N
a
m
c
v
3
E
on .ti
O
v fl
0E vi
t
No
c o
vc
u
u
-o
Y
26
v
.O
Eov
oO
o Y
m C
o
O
o
-'E
o
.
o0cmE
E't
.Yo fv
`o
E
E
Nv
uw
i�e
E m
vi c.
y
C7
Z
0
Z
a
�
c-
0 o v v Y
u v v -o
a 3
on a ro
v i
N m
o
D
v v
9 0
D
0
YYmN
�,c m9 o
_cv
J Lq 3
c o
O
o
O v
v
°
0
a
-6 E O
''' �' bA O 0
0 v -6
� t0
N O>
W
cc
a
W N N
E ,0
. ti
c C '� v v
`o c
C N N
c E
t90 c0
-o '..
N o
Yo -o `p
v Y° v
E
F Oi x
w
- a+
E v
v c o
u iev ro
a
-
m
E cc
> _
3
3oN
c c 3L6 m
v
ro o ro
O
ma'c
O i,o
Ein
0��,mm
0 0 v T c
m
0-o
-o
a
v t
3
� T
' `v
0
un ._ —
°
m
0 m N
v 0
-6
o N E
E a
�t
0 v
�...,
��'
a
C7
c N
Y t
a
(7
O?
. _
ro °' o _o .c v
Y
o
c _
'�
E
- O -p
`o- — vi
Z
ro
a ro
v v
E
E
y o u o
3 -6
o U v
i
v
-o c
E i
O E 5
c o
a
o Y v 3
a w
x
a u o
in v
—>
O
-c> c
y v'
UO 3 N
i�
O
O
v O N
9
a C7
Z
v
N o g -
a C7
Z C7
Z
a c
v .i
-6 T
Ul o
N
W Y
W K
a
O— N
N >
c
W Y In
W K Y un
9 J
— O
O
Y
-c :� a O
rmZ Y
i v
NAY 3
� a
o
ie
F a a Y
� U
N
U
E
N
0?
N
C .�
Oi -6
N .J
m
N
LL W Z c
O O N
f0 Ul O E
a In C
O W w a
u v
m ci
Z- Y c
c
ma
LL
w E
Ln
-6 c o 3
Y a+ f0
p N o v v
Z v E a
Y -o E
v
C -6 -6
t�
v
Y
v� m
.'" 3
Y
c
o C7 '
O W d
a
N v v
c LL
o LL .�
O
on s
c
Y t
Q i
N Y
'"" O N Ul
Q
N
a+
~ E
d
Y Y
J
d ° °
f0 f0
U a In m
._ — ate+ ci m a
.� O sem+
> a
> ate+ 3 Q
Vf l0 ti N
t o c -I f0 (V
of l0 N N
d N
N
m
a
d
.o 0 o y 3 •=.
c
Y N m
CO
c 3 ro c
Z- lo m3 0 aQ
v > N
ro C ro .c Q �o m
0 o
opo ono❑
o oQ v a
v E Em9 ° v`-'
p O O E � �O
v°� t on c v
c one'3
in t v i' C O
C N aL+ C
vC = ci
m v-
z o v a o a v m
o
U
v
ro
•�
n
❑p
a
`0o
bA N
C t
Oi u.u
in
'> C
e°
°
v
v
v
w
vo
m p
C
a m
Y
0
m
-ti
.n
v
❑ c
a 0
N
m
O C
v
0=
N
D C
v '� :_ o X
c
y
F to
Z Z
p
p
to to
Z Z
Ua C
`
0
�
O v
N C U L
U
O
U
v CM
o+c
Y 3 t 9
w o
.0
� � 'f0
N
`YY° v .Y 'f0 in
o �❑
o 0
`n
N
° N
a o a
o E a
o Y o o � o
� �
f0 �
A � Y o o�� o
�
I
0 9 0 3 v
y
o
o o
C t t
o
o
o o
t
O p
r E o E
O
°Y o °" v o
N
o °" v o
u o N v
f0 C Q
'�
>' v
C
v O
_
m v N u
0 a
a Cp
c --
..
0 C
'v 'v
'v
v
v H ;; ro v H �
�
v H'v ro v H �
Z
v.ro �z= v.� z=
Boz= v�Yz=
D
`v '5
E
E c
3 cc o v .x 3 `Y o v .x
�=
3 `e o v .x 3 `Y o v .x
.v C c
m>
_
v
3
W
v O �v
>
u
L L
_
ac -I
un ro — w Q oCn ro x
� x
x w Q oCn ro x ;� a
w a
W
X v
a C >' m L 0>�
X
-0
3
C
o -o �=
c v c
o -o �= o -o
v c v c
ay'..
on °1 a
D c p c p
-�
c p C p
v~i
LL
v ro
C aL.+ t0 ❑ w
� v a o 3� v a o
a o 3� v a o 3
O
O
� E a � 0C
E a r
E a � E a �
a 9 f0 '� m
Z C o
v> a p
N�
MU
v 0 0 ;� v p 0 ;�
x
N° -6
mu N�
N
v 0° ;� v p 0 ;�
Z
'm mN 7 C
Y O Y
H
v O=
v
Q v m
t .0
> y 0
W
m rOo o v v io D o v v
o v �-
m rOo o v v io � o v v
Z
p 0 -_
ma v v
LL 9 Q ti
W N 0 n
C O
0
C5
Y
v " 3 3
m o�
v a
w
V.
Qa Z
v v m❑ v
Y m� j m m
c>
v m
of �� ti
E
t 0 ro
z
W
N m C
O O
`v
W v v
`o
> Y
�O m m
a
K
w a
z a
c a Y Y }' nn
o -o c
a o
-o N>
i
v c U o-
w
VI W
E
N v bA O Q i E
p
W U N
v 3 Im f0
N E
0❑
LL LL'
J .J C ci -6 a C
a -o v
LL O i ), 9
CO
_6 -6v
0 0 �, v
Z H
O
U N
''' _6
K .� .� 0
p CO
0
P bCA
H
1p lL
C LL
O
v .v L
0
Y Y L O L a 3
K
1' Q -6
CM N
Y Y
a -I CC
C
O N
.3 N m 0
y c
m t- v m
>
N N f0 C
C a
uCi
'- v pin v�onn�=
Eaaaaaa
�.�
Y
v _ O
Y v
O rCo �
a a
m" �
t O
v
v
c 3 0
0
z n
o o
O E
c v
0 v
0 Y
0
0
C C
C
a C
N
❑ i
'� v
o m
Q
m o
u .
m O
'= a
�C
z
3 nn
o°
9 m
'C
to C uO � O
'�
C
_ •�
—
>
u t
'17 F X
W
t0 N 9
9 v
N> C
C
N L L N a
K
C
u
N
ci v
—C
N v
W
C d+
�y
C
U :
Z
dl v v
E
9
O
7 0 N C Q
G G
O
v
a= v
U.
Z C m
v O
v> o- O
F O
Z
-6 N
Y 'O aL.+
U
'�
v
O C
>
H
U'
v
a a
o
Y
a O
J N
[O
v a -oun ai
w
•C •C
K
1 z
Y >'
C>
_6 _6
t v
cc
b7
m
yVfj
U
C by
E G C
W
H 1
C m
O O
+' O .�
W p -6 In N>
C U
N 'p N
y�
v
VI W
N v
W Y� J
9
v 3 v N m
t0 E
0❑
ad
4j ❑_
LL LL'
U J f0
LL O i c -I
C
Z
Q
Cp L O
t0 LL
v v 0
W >
K° O p C
C cm w) v
am -I K
L77 ++ y0
C LL
C
aL+ y a+
v m
1' O- N
i i
c
o a
p
Q Q a
-. c
n
%f 1p
9 Y 9 m
l0 N w m t0
9
v
N
a
a o a
o E a
o a o a
v
v -6
f0 �
C
O p
a �
v
N
a
Gl
m
C
O
.P
m
s
3
r -I
Ln
W
3
f0
c
3
a
m
a
o 0
D
D •C
D
z. c
0
a
LL
m
m
c
v0
0 �
3
'Y
� U
3
u O
v
13
O�
6 i
•--• C
n o
m
c -I
m
m o
C�
am
o
O C
t
v
Ym
3
a Y
3
Y
ro
o > °O u
m
z
-_
v
a
o
O
m
m
X
v c
m
O
m
E6 LL °o
vc
Q
a y un O
N
1E
0 0 0
Z
a
m a I .- v v' v
uY
0 U u
g
N.
-
'f0 C C o v
on m =
ti w
O
J
m
O
c w
K
O E N .fl-
=o E m> a m m
i N CC CC v
N .0
w c> a
p t
t
O K
•�
Q uu Om 0=��O
m m v
a`a`��mmmin
r��o r`o
inmH��
N
Ul no
0
N
N
N
�
U
N
C
o
N
c
0 3
C
o
N
N
�y
u
O
0
N
N
N
U1
N
N
In
Y�
oc
O
O
`p
t
'6 .o
r
'6
r
O
'6
r
m
m
z v
W
v v
" u
c ro
u v
u
v
u
°°
vi
t
m
c
m
O
N um
0 E
Q
c v Y
o
0
a
0
O
g o
v
Oi
o
o
to T
m
— N 3 c
bA 9
W C ivn
C ivn
ba
U u°
= ro d O
c
c
m
ao
o u
r°o
z .o
z-
H 9 m
o
-o
o
'LL
no
> > o o v.
o
a 3
3
w° N c
0
»" m
c v = v v in v
on
c
o'n
D v
no
D v
o
o'nto
m v
m
y
m
no oCnv c v
E on
� LL'> i.� 3
o `v v o
v
v
v' z mt
c.
mt
c.
r'c N'.•
v
c�
-
'3
0
.'
�
c
Y
FD v aY wo c
N
_ vin in -o
°
C�°
`O
0 Y 3
Y 3
&'
mNm
3°
a
3
0 0 a v' v
c o
v°°
9 m
.
Z a&'
v
v
a
a
m m' 3
0
o o
c °� °
m a
Q
3 'E
-o
o:
-o
O
0 0> N v 0 �o N
on U C N N? p
C CC CC
° E O ;�
c CC O
O
0 9 9
LL
O
LL
N
O
.y O E y, U v Y .a
=o =o =o E x a m
v 4,+ - v i Ul .0
:c > a v v on
N N v v
t
O LL u
o io m
LL u
N m
LL N .�'
00 o E a
1p
m
^'
m
Ol
m
Q Q Q v v D D=
.c
O a` a` in in in in in
ro
in H
vi z ti
ti
t rao
m C
m
C
m
3
a
m
a
o 0
D
D •C
D
z. c
0
a
LL
m
m
c
E
a
0 �
a'
a °1
� U
u O
0 E
ti
O�
6 i
•--• C
n o
m
c -I
In N
m o
C�
z
z
ON
o
O C
t
v
12vi
Y
o > °O u
m
z
-_
.� CO
~ '� no
> > o o E
a
o
wu zcc
i ii m
c v = w u
c u
v� v
c
E6 LL °o
vc
DZz
a y un O
v in in -o
`p `o
C v
oCn
0 0 0
Z
a
m a I .- v v' v
uY
0 U u
g
N.
-
'f0 C C o v
on m =
ti w
> v E v O u v
on U m c v v a p
N
° E O f0
T N
c w
K
O E N .fl-
=o E m> a m m
i N CC CC v
N .0
w c> a
p t
t
O K
•�
Q uu Om 0=��O
m m v
a`a`��mmmin
r��o r`o
inmH��
oNi
in�z
3
a
m
a
o 0
D
D •C
D
z. c
0
a
LL
m
m
al
f0
C
O
++
m
s
3
r -I
LA
0o
3
m
co
Eu0
C
c
O
N
O
C
ai
E
m
C
ai
E
Q
I
N
u
C
al
E
s
u
m
Q
v
m
a
v
a
E
o
`v
E
�
0
v
a
v
w
v
c
o
v
v
a
v
a
E
'E
o
`v
E
�
0
v
a
v
I
w
v
c
o
v
v
a
v
w
v
c
o
v
v
a
v
w
v
c
O
v
v
a
v o
v o
v
v
Y
mv0
CO
m
v .0
m
m
m
m
m
t0
N
'p Y
N
N
t0
N
'p Y
N
N
t0
N
N
N
t0
N
N
N
�I1
0�I1
p
�I1
�I1
V
lfl
C
C t0 '6
='o O
c
c
N 'p
7 0
lfl91lfl
c
c
lfl
c
lfl
c
lfl
c
O
O
-p ,O 'p
O
O
O
O
-p ,O
O
-p ,O
Ul
W C
= Ul =
Ul
C
d u
Ul
= Ul L
Ul
= Ul L
O
w
0 a
O
O
O
O
7
13o
v- a
'c 'c13D
13D
c
> 0 9
c c
c
w 0 9
D c D
c
c c c
c
c c c
O
LL fp =
_ O —
d
O
? ro =
O
O
= � O =
O
= O =
co N tmvl
W
LL c N tmvl
_
W d
W d
m
v
0
N v
y
C 0
0 v
v
N v N
v
N v N
i
c o n
'3
3
i c o n
'" .�
o '3 0
3
'3
3
'3
v
U
-0 v io
v 'o
Q
v
v
3 c- ro
,y o U
Q c
c
3 c-
O U
c -60
Q Q
c
Q c Q
c
Q c Q
0
9
ti O m
LL `o
O t0
O
LL 9
^ .ti p m
`0 0 `0ug
0
LL LL
M 0 V
0
LL LL
N 0 V
N
O v .'
M E Q
M M
O v
M E Q
V Vf
I
N N
N u N
m d a
m m
m d a
m m
m m
m m
v
v
v
E
O
v
v
v
E
O
v
v
v
v
c O
o
°
c o
0
°
c o
0
c o
0 .�
un
E c
O
un
E c
O
un
un v
un
un v
a U.
v �
a U.
v
v
v ot
3
3 v
XU
x
3
3 v
U-
x
:L3
3 v
3
3 v
v c
c �
v c
v c
c �
v c
v c
c �
v c
c
`o
`o
.0
3
`o
`o
.0
`o
`o
'u
m
c
M
m
c
m
c
m
'
'
.� E
c
p
��
o
N
..-
� E
c
p
��
o
N
..- � E
o
N
..- � E
o
N
�-
9
c
cc
m a o
a 9
•" c
'c
o
0 N
9
-
a o
v
a 9
-0
a o
L a
E
o�
ba
.-r Y
w u v
v a
om
-o
v
-6
y ro E
r
u v
v a
L ro E
v y
^'� ui L
Ym
E
,��
c 3
z m
Y E
3°
u E
m n
:°
.°
a—
v
oWE
—
_
•Ul �v
mum._
d
Y— �
�v t
AWE
W 0
_ �
a v t
v.s
Z 0� a
-
�' �w
O
3 0'
W
z o
a-
z O
u
O. o
Y 3 3
p v
z •�
•� ;� 3 '' 3
D '
O
±u
.. Y2 3 3
O 'c
c m 3 3
^' •c 'c
�•
-N
O
C T in
m. m
Y
o
CO
Uq
'
'E
G! UUq
0o s
v
o
O c
c
'E
_
S t
D
a m
c
F w
3—
v t tv,
3 .-
3 c
a v—
v .- �-
a 3—
3
y, v
E" nn
E c
�._ o- o
o v vi
LL o c
in
z 0 o'n
Em Z- m
O c c
_ o- o
v Uri
o o c
LL
3 o'n
nn
3 c c
_ o- o
F p
p uOn c
_ o c o
c —_ —_ N
v v
Y '^ = p
-t N' Y
1' v
N— ci — N
N v
in = O
L Y f0
Z D v
W
m
D— ci — N
v v
m
Z N v
W
N— ci — N
v v
Z N v N
W
O N O N
v
o o
0 3 c�i 3 c�i
Y D N O N
N
'3 N
p t
C
3 c�i 3 c�i
C 0 N 0 N
O p t
p 3 c�i 3 c�i
Y D N O N
O p t p
u u
J
a 3
-o v
a u u
-o
c
3
CCv
u u
mu
a 3
-o v
a u u
-o
a 3 a
Q c o c o
o. o
= c
v c
Q c
c o c o
Q ,o . ,O .
J= c
v c
:a
o c
:a c o c o
a .o . O.
Q c
c o c o
Q o o.
Q c Q
LL -6 v -6 v
LL -6 � 9
M LL
LL -6 N -6 v
LL -6 � 9
M Q
Q -o v -6 v
M O '6
0 to v -6 v
M O '6 O
0¢c¢ c
�� a.0
o n o
�¢c¢c
�� a.�_
o�°
�°¢c¢c
om g
a o� o�
Q c Q c
cLL o LL
o N a
m - -
c 3
p p_
v
- -
v O
M Ii
V u
_ -
q v O 4
N
N v O
uo
N N
ni
m O o� o
C4 a
M a o m
w m c
of M
m e 3
M O O� O
m° a
M a o m
w .n c
of M
.n c 3
M O o� o
w �o c
of M
�o c 3
M O O� o
w is c is
of m m
v
m
a
'E
0
3
3
om
v
C O
0
- 00
v
ot
v
3 3
ucuc
u
c
o
`o u
u c
c �
ot
`v a
a v
� v �
= a �
E �
a—
V N m
'' 3
a
m +N' m
3 'E
Q on on Y
O
C N N N
�,
D N 4 N
a — n — n
a o.4 o .4
LL OD -u 'y -u
O� neo n
N N Z O
c
a 0 o � o
v
c
v
v
v
3
3
4343
�
v
v
o
-
O
- v
u
u v
v
v
v c
O
m
a
a v
'E
0
3
3
om
v
C O
0
- 00
v
ot
v
3 3
ucuc
u
c
o
`o u
u c
c �
ot
`v a
a v
� v �
= a �
E �
a—
V N m
'' 3
a
m +N' m
3 'E
Q on on Y
O
C N N N
�,
D N 4 N
a — n — n
a o.4 o .4
LL OD -u 'y -u
O� neo n
N N Z O
c
a 0 o � o
c
3
3
3
a
a
o°
v
a
m
0 3 m
p 3
m
Y
—O
Y
Y
o
m
o
o
N
0
N
v
N
rco
N
N
ti
c�i
N
�
m
N
N
3
N
c
rco
N
N
Al
N
N
N
'6
N
N
N
N
N
t0
o
N
N
N
O
-p ,O
O
C
-p
'p
O
in
w
� inin
w
w
Q
a
O
O a
o
"
o
'c
m
c
N
ao
o
= o
o
=
o
3v
3
w
Q w 3
v
N v Q
v
N N
N
v
C
C
o
3
O
3:3
3
c
a c
c
a N
u
a
-6
O
o
-6
O
m 0 LL
O
o
W
O
v
um
N l0
N -u
N
U1
G1
m m
m in
^'�T 3 To
m
C
N
M
I=
o0
o °
2 o
'4,�
o
o °
0
•3
�
�
�
v v
o
v v
o
v v
3
3 3
= 3
LA
3 v
v
3 v
Wv
°1
u c
_
c
c
c
3
m
o
`o
3
—
o
o
m
3
o
`o
mu
c
m
c
m
c
C
v v
Y
v t
•C
EE
N
E
N
E E
O
U
N
U
N
U
N
O
v
p
9
cc
v
r"
w
r"
w a
C
E
m
E
u+ m
um E
EW
Ul t
u
Q
Z o
a
W 0
a N t
u
W
Y
Y 3 3
O .. o
N c
N
.. Y
m
c ;° 3 3
Z .. o
O
N
.+
Y 3 3
Z
O
C
fO Q f0
LL. Q
Q V N Q M
N Q
Q N Q N
N
W
++ m +�' m
C in C in
O E c
LL = .-
E a+ m Y m
= O . c .
% E cc
LL = .-
E ++ m •t+ m
= C . c in
LL
QYY
a 3
3 wYY
a 3
3YY
a
C o c o
F Q on
Q D c o
F Q on
Q c 0 c 0
F
(V
N ci v N
W N
N Ul ci v N
W N
N v ci w N
W Vf
0 N 0 N
O N O N
0 N 0 N
4a
N lfl lfl
W :6 3
:6 lfl - lfl
W V 3
V - lfl - lfl
c
W J
z
c c c
'o v
-o c c SEE
o
'6o v
c c c
i
t
:o 0 'o .o
-o v =o v
a c
m �
a :o ,o .o
v =o v
a c
m LL�
a ,o .4 0 .o
LL =o v -o v
rn O
U
Q c Q c
,p
c m o
,o
I Q -o
�a
c o
c! �a
oa
i•+
N O
o o
u N m
N O
.2ma+
u N m
N U1 O
c�
u N
ac
3
O o� o
w oo c
i rn
oo p 3
m o� o
w of c
inm
of 3�
mO oo
w o
i rn
'E
0
3
3
om
v
C O
0
- 00
v
ot
v
3 3
ucuc
u
c
o
`o u
u c
c �
ot
`v a
a v
� v �
= a �
E �
a—
V N m
'' 3
a
m +N' m
3 'E
Q on on Y
O
C N N N
�,
D N 4 N
a — n — n
a o.4 o .4
LL OD -u 'y -u
O� neo n
N N Z O
c
a 0 o � o
al
f0
C
O
41m
s
3
r -I
LA
0a
3
m
co
Eu0
C
c
O
N
O
ai
E
m
C
ai
E
Q
I
N
u
al
E
s
u
m
ice•+
Q
v
m
a
v
a
E
o
E
c
0
v
a
v
w
v
c
o
v
v
a
v
a
E
'E
o
E
c
0
v
a
v
w
v
c
O
v
v
a
v
a
E
'E
o
E
c
0
v
a
v
I
w
v
c
O
v
v
a
v
a
E
o
E
c
0
v
a
v o
v o
v o
v
v
v
0 co
Y
o v c
m v�
N
v
'
CO
ic
O
o
m
N
v c
v�
v
'
CO
ic
O
o
m
N
v c
v�
v
'
co
t
O
o
m
N
t0 '6 Y
N
N
N
t0
N
'6 Y
N
N
t0
N
'6 Y
N
N
t0
N
�Il O
O
O
�Il
N
N
.fin >' C
N
N
.fin >' C91
N
N
ul C t0 'p
C j 0
_ �Il
C
u1
C
C t0 'p
j 0
�Il
C
u1
C
C t0 'p
j 0
�Il
C
u1
91
C
C
c
'
,
O
O
,.O,w
'.O,
O
OO
.
Yu
_ YO
-u
u uL
-u
_
o .o .
o
o
.o .
o
o
.o .
c o c
O
o
N Y a a
o4 N =
N
Y a a
N
N
Y a a
=
13
c
c
c
O
=o3
m,
c
c ,cO
.Oc
9N
m�o
=o3,Oc =y3
O
N mo,c
�
o N m
�
Im
m
o
o
un O
un
un
O
'C N
0 un 0
O
'C N
M
un
O v c
v
L O
N v N
v
L O
c v c
v
L
°1
c� c
3�.
° °
3
c
:. '3 :.
. '3
c 0
v
vm
v
v
0
U
�
OUO
3am
O o
�
3am
O o
O O
o
O M
O
O
0
OO
O
-p LL
0
-vpO
LLaOO
O .0
N
-!
O v u
.
(n
vU
N
M
MQ -I
E
o
N
N
Ea
N
.LL
E
p
N
ma
v
v
v v
E
O m
v
v
v v
E
O m
v v
v E
v O m
v
v
c oc
O -
° a
o
O -
° a
c o
O -
.0
° a
c o
O -
b�A v
oC
b�A v
o C
b�A v
o C
b�A v
v
a o
v
a o
v
a o
v
t .3
a
t o3
a
t .3
a
t o3
3 v
x �,
3 v
x�,
3 v
x
v c
v Y
v c
v Y
v c
v Y
v c
c ro
v
c ro
v
c ro
v
c ro
o
`o
m c
3
`o
`o
o
3
o
`o
u
o
3
`o o
v'
U
v'
v'„
m
m
m
-6
c
-6
c
-6
c
ot E
C
°
ot E
°
ot E
°
cc
" N
.t E
E
Y
N
E
Y
N
E
W N
N
3
'o c
v
.�, Y 3
c
a v
� 3 ), ot
Y Y
Z uj
O
N O.
T t0
� o
U"
L T t0
� o
-u
'6 9 m
W >, t0
co"W
c
2, -z-
Z u
U1 9 ),
L) t0
C
E E
C
c o
w m Mw
Y E E
C
c Y-2
L
m m
y f0 E
C
ba --Em
U
p m
Y E E
ao
c
-0
= 3 0
"
— p c
a ._
= 3 0
"
z y .c
W
:°
a 0
3 o
"
Q D E
a
v
t
v
0 -o m
Z.
C
. v
•E t
v
0 -o ro
o
z
v
-
v
0
z •c o
v
•c
0
Y
Y 3 3
p .E
O O
N
m
Y 3 3
c o .c
.. O
O 'c
..
Y
c �0 3 3
.o
c o .E
O
u Y
;u 3 3
N
c �-'
~
N
Oq
ba �.
F fl-
ba N
W C
C �.
ICU
~
T in T
z m- m
o O=
�= •W O
W
`-M
T . T
-_ a+ m- m
ate+
Y YO =
Z
00
Z
T in T
a+ m a+ m
Y
Y YO -
K- O
T in ?
- a+ m= m
Y
C in C in
1E D
E
3
m
d C in C in
3
E
3
.y
C in C in
-E D-
E
3
d .y
a 3,
d C in C in
3 D D-
3
w
C D ,C 0
O c N
LL O fl-
a o
H N bA
o y
C O C D
o c v
LL O fl-
a 3
H D pp
3
O C O C D
o c v
LL O fl-
u o
K N m
-E
o �Y �Y
C O C o
O
LL
c=
Z C v
W O
O v
Z N
C
= -
C v ci v N
Y 9
C O
= -
O N ci v N
L
3 N 3 N
o
:. 3 3 N
N O N
3 =
N m
O O
Vf
"
0
i+ O N O N
N
0 •+
O N O N
�n
- lfl - lfl
����
m
W -0 3
Fav
- lfl - lfl
a����
m
W 3
- lfl - lfl
m
O 3
- lIl - lfl
a����
o .o o
v c
0
c
o .4 0 .4
`O '.- '._
���v
v N
`0
a c
a o .4 0 .4
'.-
�uav
v N c
0
c
`O
o .4 0 .4
`O '.- '._
`o
u Z-.4
-6 v -6 v
3 o
LL -6 in
N ,�
a
-- -u
LL -6 v -6 v
3 o
LL -6 in a�
M
a LL -6
y .. ..
LL -6 v -6 v
3 o
LL -6 in -u
a
a LL -6
-u -u
LL to v -6 v
LL
a a
v v
o °
ti a c a c
v v
o o
a c a c
v v
o ti o
a c a c
.- .-
•u
.- '-
•u
'-
•u
.-
v O
N O vi,
N U
N v O
N O 'ui ,
N N
N v O-
N O S
M N
M y O Z
M
O o H o
v a rOo
vi v�
v O o H o
v a rOo
vi v
v O o H o
v a m
vi v
v O o H o
v
v
m
a
v
m
a
v
w
v
c
o
v
v
a
a
E
o
E
°
0
v
a
v
w
v
c
o
v
v
a
a
E
o
E
°
0
v
a
v o
v
w
v
c
o
v
v
a
a
E
o
E E
°
0
v
a
v o
v o
v o
to 3 o
Y
v
ro
Y
v
ro
Y
v.
vc
v .o
bA
.O
a
m
t
Y
m
N
N
�
vc
v .o
N bA
n
.O
o m
ic
O
0
m
N
vc
v .o
N bA
.O
.. v
o m
ic
Y
O
o m
N
�
vc
v .o
f0 no
.. v
.O
v v
c 3
�
N
C
N
v v
c 3
N
C
N
v v
c 3
�
N
C
N
v v
c 3
Ov
o v
O v
o v
> c
N
N
yin >'N
N
>' c
N
N
>' c
V
t0 'p
j 0
lfl
C
y
lfl
91
C
C t0 '691N
j o
c
91-
C
t0 '6Lri
Y j 0
C
C
N '6
7 0
O
t
,O
O
'.,
O
5 t
O
'.,
O
O
'o ,O
., w
O
.
O
t um
,�
,�
o
Y ,�
r
'�
3 .c
o f
c o
o
.o E
4
o a
o
.o E
o
o
w .o E
a a
'c � •c
�
� v- a
c c
� � �
�
o a a
c c
m
9
o
c
° 0 9
c c o
c
m° 9
2
o lfl
0 J 0
J
lfl
J
J
LLo
lfl
0 J 0
J
lfl
o
C v
o
v
L '� N O
o
m v
v
'� N O
a+
C
L 'a+
no w
.3
3 o°n
o '3 0
'3
L" c o
l°-. '3 l°-.
'3
3 o
cc
o in
in
in
c
c
3
v
i i
i -o v
¢ ¢
v
a m a
m
U v
O ro
O
O
O m
LL O LL
O
^ O
O
O
m o m
O v .U_
E a
^? o ^?
o
O v .U_
^� E a
? o ^
o
O v .U_
E a
^ o ^
m
O v .U_
^ E a
Gl
d a
a a
a d a
a a
a d a
a a
c
a d a
f0
p
E
o
v
E�
o
v a
E�
o
v a
E�
o
f0
-o a
c o
-o a
c o
-o a
c o
-o a
o
° a
o
° a
o
° o
v
oc
v
oc
v
oc
3oc
a o
v
a o
v
a o
v
a o
v v
v v
v vv
v
3 v
3 v
`�
3 v
�l1
W
x
v y
vc
U
x
v Y
v c
u �
x
v Y
v c
U
x
v Y
3
v
�
v
v
�
v
e0
c
3
o o
o c
3
o o
c
3
o o
c
i
�. O
ro
O
m
m
O
t
m
m
�. O
00m
°
m
°
°
v on
N Y
v
v on
Y
v
v no
K Y
v
v v
K
K
U
v
o y
U o
E
o y
W °
E
o y
O
E
o y
C
C
W N
E
C
Z N
E
C
W N
E
C
N
c Y
3
Z
NN o c
-o v
W c
v
f0 3
N °
o
++
Y
min
E E
c"
L in
r E E
. Y m
in
y f0 E
Y ro
y
`o
¢ D .-c
¢ 6 v
_ 3 o
"3�
a m .c
um
°° 3 `o
Q y ,c
:9
3 0
-2 m
Z. o
um
Zo o
a� u
Zo o
°
Y�
"w
-p
`> c
o'
"' >
o
> 0 3 m 3
0' c
c o'
`++
D Y
u 3 3
m>o c
3 0'
W •c
o
c m 3 3
p3 `> c
O'
_
ci
-o
Y
oq a
w e
oq `-° ?
c
m -o
~
c
W>
•c m
>
w
W Oq
> ro Q ro
Oq
c -o
m
O
T n T
- " m - m
W
Y YO .�
K u o
T n T
u +' m a+ m
C
c
Ul YO -
K o
T n
:L m - m
—
Q
E
m.o
C n C n
3
E
3
c.
_
C C n n
`
E
c n C.
°— E
oQ
g3
cc noo_
un .. ..
o
'�
O c a`i
Q
O
v
z 3 no
v Y Y
3 ,C O c o
Y a
3°
3
K D on
3no�mY
0 C o ,C o
3'ov
,° ° O-
N
Y 9
c=
W v
of
-t-FD N
y 9
'c-
W O v
mt
D v -t v N
m
O
c=
c=
(>
Nm
3�i 3N
N m
c
3N 3N
c p N p N
L ro m
•3
o�
2
o 3N 3N
Y p N p N
'3 N m
a=v
m
O'o
a
'o t
acoco
J m
=v
O
coco
m
�=vt,
O 'o
°
-o m
°
v c
c
o o
v c
, -° c
-°,o o
J.� c
a c
o o
a o o
J=v
v c
3 o
-o I 'Y
v v
o r, w r6 .
-o v =o v
v 3 o
-o �, r.
a s
a- u Y u
-6 v =o v'-
3 o
v `o
`o r u
-o v =o v
`0 3 o
U
o v v
o -I OU
0 v v
lL OU
LL -6 to -6 to
°
LL O v v
LL O
o
LL
�o a c a c
LL o v v
m
c
'in -o
a
u m u
e•I Q C Q C
_ _
r? v O
•y
° n
�? 'in -o
O
u a um
a° Q°
v O
-t ° n
'in -o
u N um
N v O
-t ° n
N 'in -o
}+
O
v a
a 0 o o
O
v c
v a
a 0 o o
O
a
v a
a 0 o� o
O
a
Q
a
a
s
s
v
m
a
v
m
a
v
c
oE
v
io
a
v
a
E
o
'
�
0
io
a
v
w
c
O
v
io
a
v
a
E
o
E
'
�
o
io
a
v
w
c
O
v
io
a
v
a
E
0
`v
E
o
v
a
o c
y O
v
w
c
o
v
io
a
o c
y o
o c
y O
m
a�
m
v
a�
a v
0 m a�
m
t
0
N O
m
0
N O
m
0 N O
-
m
N
'n
o v
'n
O v
'n O v
N
N
>'
N
N >' u
N
lfl
lfl
'p
lfl
lfl
'p
lfl
lfl
lfl
'a C
C
? f0
j 0
C
E
.� f0
7 0
C
.2 N
E 7 0
C
t ,O y
O
O
N
-p ,O .6
O
O
N
-p ,O .6
O O
N
-p ,O .6
u -u L
'''
_ Y
01 -u
-u
C
01 -u
-u C
01 -u y
y in u
iOU
3 3 .E
in u
in
v 3 'E
min u
in w 3 .E
in u
O c
o
ID
'o .
O
'c
o
w .o .
O
'c 'c
O w .o .
O
'c 'c
ao
Y o-
c
a
o-
.W
= c
c
? 0 9
c c c
c
„o,
w 9
c c c
„o,
c w 9
c c c
O W
ON
O
N
LL N-
C N rymj
- O -
01 01
O
N-
LL m
- O -
O N-
LL m
- O
.�
p
m w
Im
,°
O
p m p
un
O
p un p
M O
p m p
c v
v
L .� N O
m v
v
L N O
m v
v L N O
v
°0 3
3
3 o
Y 3 °
3
3 c o
Y Y
v
3 c O 0
v
Y Y
v
a v a
vv
4�
v
v
J v ��
J v ��
o.
V LL
O a
LL O U 9
a a
p p
E
3 a
0 U 9
a U a
p
U 3 a o
0 U 9
a a
c
.
0 of
m
o
t0 ti O N
m O v .0
I, O0 00
``p
Ot O
o v .�
``p
n O0 W
``p
O0 m O
o v ,�
`p `p
n O0 W
Q N a
u
a E a
N N N
N
N E O.
N uu N
N N E a
N N N
Gl
v a
a d t
umi umi
umi d
vai vai
vai d
u'^i
f0
v
o
v
ov
o
v
OAC
o °
v a
o
o °
-
v a
° v a
-
o
a
a
ao
3
v v
v v
v v
v
uu
t .3
a
t .3 a
t
.3
.3
.3
.3
Ln
co
v
v
x
v Y
v
v
x
v Y
v x
v v Y
v
3
c N
v
C N
ry
C N
C
0
0 o
ti
o °
° o
o ° ° o
m
o
m
u
-
-
m
� -
m
m
c0
°
°
° E
°
z
° E � Mbo
°
O L
N
D
_
•�
Ote
OYE
Y
Ote
YOY
NN
Y0
C
W N
N
po N
c
E
�
Z
O i
N O
v
3
p O
v
±° 3
O
9
0N iri
a
v
.0
U Y
w 9
y T f0
c v
=
-o .�
Y
Q 9
01 >' M
+� v
-o .�
Y
Q +� v
>' N c
-o .0
O t -u
L 9
{A
++
lL
m
Y E E
E
C
ou
O L
v u n
U `° E
Y C
p °
Vf L
p U n
t Y C
o
u E -
U u v
m
m
E
C
a w c
F 0 .Y
Q
�.3
O
W"_.3
w d
_6
_6 O
W d
ou o
_6 - -6 °
W
Y
z
w 'c
.- v
'c t
3 v
-o '°
p o
p
v
a v -
-
w v m
?�
x o
v
a v w va
t -o m
p
v
0
p p
Y
> ;0 3 3
p > O
.. O
"' 'c
x
.. u
c um 3 3
;o
p> E
.. o
c
.. M 3
c 0 3 3 p> E
.. o-
x c
..
c M 3
ID
ID Vm"m
v° -o
N
p M Q M o
p °��'
i
p M
01 o
:LE c.0
01 Y
° o.'
c o
c"m"m
Y
o.Y
-
Z c o
- :L co "m o.Y
-
c o
5"m
Q
a 3
3
w'�
w� y�
° E
W
w'�
C in C io Y E
w�t�t
n w'�
w�
U p
z
p nn nn
o E v
LL O a
Z 3
W p
3
p
a c v
o a
Z 3
p
3 a c v
p 0 a
Z 3
W p
3
p
N
cW nn
v
c c
O
9
M
v
c c
O= N
o
t 9
nn
E c o
= O .� N t 9
nn
Z v
c
'� O
U
cC O
t
O v v N
N N=
a=+ +.'
Z@
t
v
N N=
+N'
t
+N'
N N=
t
N
C y
O
& 0 N 0 N
'
.-
i+ O N O N
N
3
p 'y,
i+ 0 N 0 N N m
v 3
Fav
vi vi
a�o�o
J M m
=vim
O & 3
��v
&
��o�o
m
:a 3
�v
m
��o�oJ=vim
2 :a
-0 ME
Q c
o. o.
r
`0 O
a c
m
Q o O.
y Z- -U
J=vim
v O
a c
a
Q o. o. v O
y r .-
�-1v
a c
Q o
y
S
a LL -�
LL _6 N -6 v
3 o
LL -6 in
LL
LL -6 N -6 v
3 O
LL -6 in
LL
3. O
LL -6 N -6 v LL -6 in
n M
LL -O
LL -6 N
c v O
u+ -o in -o in
io o
��
c O
-o in -o in
�Da
o
0 ��
c O
-o in -o in o
CDa ��
c 0
�Da
om
u N
o;a ca O
d v
o;
ci 'in '6
o�
u N N
Oa O
N v O
N 'in '6
o�
u N N
Oa Oma
N v O N 'in '6
o�
u N N
O
N v
N
++
Q
a
v n
in a
n O� 3�
a 0 o H o
0
n c
a a m
v m
in
m O� 3�
0 o H o
O
m c
a m
w v
in
O
v O� 3 0 v c
O O H o a m
v .n
in
O S
0 o
v
m
a
±
2
2
41m
\
�
g
■
2
N
/
E
E
\
E
«
�
u
2
E
\
2
\ ()
® \\
�)
I co
|L
xu
\\
\\�
0�
\
`Uw
E
0 E
} }\
\
CL
\ k\}
oa
/
\
}
0
%}\
\
}��u
{ \ )
■r0aS
.:
�rE
\ \\\u
r}\
q}Esm
/ G,o
\/j
\ ()
�)
- I#
|L
\\
\\�
\
`Uw
0 E
CL
\
%}\
/
{ \ )
\/\> SO
�rE
7—;:2
r}\
\0
\/j
kms)
:{]\(.0
)(%0 Uw
)`�
F-- 0 't
/ \ \
Attachment D - Newspaper Notice (appearing in the Record March 1, 2024)
NOTICE OF PUBLIC MEETING
Enabling Four Univ
k L K TC;HE.NT
Have Your Voice Heard!
Planning & Strategic Initiatives Committee
Dates March 25, 2024
Location: Council Chambers,
Kitchener City Hall
200 King Street West
arVirtual Zoom Meeting
Go to kitchenerca/meetings
and select:
• Current agendas and reports
(posted 10 days before meeting)
• Appear as a delegation
a Watch a meeting
To learn more about this project, including
Information on your appeal rights, visit
a a0 www.kitchener.ca/
FlanningApplications
or contact.
Additional. Parking Zoning Katie Anderl, Project Manager
Owe[hng Reductions Regulations enahlingfourunit5Cc kitchener.ca
Units 519.74..2426
The City of Kitchener will consider City -initiated applications OPA23/02O/K/KA and
ZBA23/035/KAto amend the Official Plan and Toning By-law. These amendments will
permit up to 4 dwelling units on lots which permit a single detached dwelling,
semi-detached dwelling, or street townhouse dwelling; subject to regulations for lot
sizes, parking, landscaping and built form.
Page 108 of 343
Attachment E - Municipal Scan
A background review of some municipalities was undertaken to understand the different approaches in
relation to multiplex (four units or above) development in low rise residential areas of these
municipalities. The municipalities reviewed were selected on the basis of those that have implemented
as -of -right zoning for four units or more in low-rise residential areas that would historically permit single
detached, semi-detached or street townhouse dwellings and included the City of Toronto, the City of
London, and the City of Mississauga in Ontario, the City of Vancouver in British Columbia, the City of
Edmonton in Alberta, and the City of Portland in Oregon, USA.
The following presents an overview of the municipal scan as it pertains to the 'Enabling Four Units'
project for the City of Kitchener. It compares the relevant zoning regulations that would enable up to
four units in the select municipalities with what is currently existing and what is proposed in Kitchener.
Note that the terminology in the table may not be the wording of the respective zoning bylaw for the
purpose of summarizing and comparing through this review. It is also important to note that there may
be additional regulations applicable for four units which may not have been included in the comparison
below as only key site functionality regulations relevant to Kitchener have been included.
Page 109 of 343
N
tLi '6 Y
Y$ a
CL
a°
I
v
4 c
W a y
u W Y
Y c a0+
a+ a
W'
—
w
a
a
v
m -6
Y Y
"
O
a
m of
a
c°
N
Y 'E m in
i v.� ° 3
v c O -o f0
o ff a .� H m
a
E
m ti - C
'E _: -6
t0 'c v v
v_ 0 u
v C 0 m
'o v
0
6 6
O >, a Y �j t O O >, a Y �j t
v N 9 v v
90 y X 0 `o o f E o Y X° `o 0
E .v v v
'c a s m :� I .a .a m
v Y° o z E E v Y° o z
o m o m
E vE
Y `� o - ay o
E -6 v 0 v v o .? v
E v a E ._ a -u a
o '� c D a Y N Y
a un g v on s fl- nn
Y v c— Y — v .c
= N m — N —
223H�
c9 m -o E C7
ot
��-
u 0
o
Z
z
O
O .'�''
c v O
c
o
Y C
t
-o
N
v
c .E
E 9 c '�
c 3
c o
'E v o o E
O O
E= v
m E
c m u
E E a
m E °1
o
a
w- v
-0-amo
-E
O 'E .a
i v.
v v
o .Q
a- r
m y �' E �,
'�
c
c o
o
.�
E ,E
E LQ
a
o
a 'E _
'E
u? E
m
a
v
c c a
a a
o� v c
Q.N
3
c
Y O Y p Y v
E a 0 Y
.a 'c
v
a
= -- E
.c o o f0
v
k4 o f 'N �, c -o .c 'c E.
o v
'c
E
v v v o
3
p
r°' m
o
E x r
m u' O v .•' v v
E
W
ao v OC c c E
o'
'E
`o c 3 t c Y
u v
v ��
v a
o -�-
E Y E -6 � E "
J °� v�
E
� u 3
v°
LLO a .� H t0 -6 O t0 -6
0
sem+ sem+
o
a E
E a a
0
mu
m
o v
c ma
O - - _
c
E
c c
o° E
v .0 .� v
u o c v c .E E c v °A
2 '�, a u O c 0 3 0 of c
'N
of 'E .4
'c 4
=o
i N -6 c E- .Y c c
uo o c O
ii ..
3
c
E q- c a o .N
c ., o v
c .. v
o o Y c 'c _ t t 0 u .3 9
-o
c
x° Yo ro •Lao v o
3 c� o a Y' 3 t E x ocn
3°
>
o v o Y m
c N v '. v c c° -o f0 c a°
E
E o°- m
r`o
c o E -o c
.E o S o a .E o rco o D v
0 c v
° m° m a v
a
0
' o o 0
a 'c
v ai EE a
v ai E E
-
a c 0 .�
a c o
O
°
N_co
ac
c
9 —
O
C ti Y m vc
v N >' c
c v v �' t
3
v
v E
v m 0 H
v a
0
N
v t' v N
a
in ro a .E in in in E
in 3 a .E in in
un
a `o .E O
z
- c
O
E o x —
m
a'u v 3
ao
c � E >
'0
�
O in
°'
O c
C O
i o- '-
w
o c
E
E
o E
o
u
a v
LL 9 m
m
N
bA Om
a
c v
C
Y
Y
3?
u v
C a 0 a
mO
E
3 aom
a ti
°ao�y o
o
o
o
m u
c .vE
c
o
°
CO CO
w ..
oE Eoo
ncn
E ao
E c
NND
L
OD
ON
C
O
Y Y 3
yo
cCL
3
m :o•E
N N O
E
C m
C C
E
pOq
3
a a0
c
`w
J
v
`w •3 `w_�
o
L
�
E 5
3
E E> u
3 N 3 m
m
r
'O
m
`m
3
u O
16
0
a m a m
= n
r` w
Y 4; °
Y m a
0 3
CL
a`
w
'En
u w Y
Y .�.
.� a
3
o
E
E
o a
E z
O
o
v
2
n
o
o2
9 0
f0 v
o y
Y p io
a v t o 3
a.un v o
o c
a_°
E v o o ._
U 3 a
Y
3 m o E m z
�
Y o
o
�- a m v o
o o c um on
E v � .E
0-E u c 3 a
3 m -o E m z
un
v v
E
o N
Q v v O p
a t t t a
ato v v o
z o o 3
v
nn
c
O v v
v o v
`-' -o -o
c a
xL; o v v 3 Y
; z -o -o ° 3
w .Y
O cc
v v o 'c v- p
3 p E v Y 0
E E v
v `o 3 v o
E
o E ov o c Y v E
E a 2 E 3 c a
-o `v v
O C.�O— C t O v O
3 `o c q �° E `v o w
E -o E �o v -o t cc
E a o w o p i v-=ct c
m 'c Y n c o v .v o 0
E S `o a° .� E 3 c a `o �o
N
N
O N
N E E
0v
O
cc O
o� Y
E w rn v
c o
O
o'c
.�
ci
N X t0
Ory
�°
pn N
fO v at+ 0
E E
c
LL N 9
E
O
0
o v c c
o v o v o'c
.c
E o o
o
t0 O N 0
E
�Il �O
x
E
�Il
E
z
of E
C5
zz
z�
q
ri
m
a
0
c
0
E
W
E
E
E
E
E
O
0
O
a 0
un nn
a
U
c c
9 9
�
n t
0
y
� o ocn
0
o o
0 �
E o
rc
>
E E
E
E
E E " m
E
E
lfl
lfl
Oq
X N O
46 O
E
v �
on v
on c
on c
z
O
E -v av
v N
E
o
v
O
3
EE
-o
c
o v v 0
3: m
3
c
.x ro
.xv o v
v c
o
c o
c
3
E t Y
E t v
° :�
o o
O
ovn " O
0
ro
rov
v
v ryo 'c -v
E
avva
m
mu
'c Ev
'cv v
iEz
n o °a
3:ov
n�
zz
z
�o o
�o
z
>
c
o v
E Y
O
o
m
Y
0
o o E
c
y O 9
0
N
c
o
0
o v. a v
° o 0
mE� aE-
Qc- o o
E
E
E
z
o a c o
v a
Y LL°
z
z z
v°
o
v ovn 0 rao .v rao
E
-o a
�
o m
o
O
,v-, O
`v
m xv"
c E ro
C
D O 0 v -6 O>
>
v v t
Q v E
0
`p_ 0 v > - v
o °
on v
m 'x c
o rco rco
> o
>
o
c
a
o
o o
az
v c
0 o
u c :Lu
C9 m o
E E o o
16
c i E 0
E
E
3
�
E
■
E
C
m E
E
E
E
m
E3
E
3
E
m E
u
E
E
um
m
r
a
E
c E
E
m
E
w a
° O
O
L
O t
L N
?
.�
•
m
�
y �+
� W
Y
W
'6
a
m
i
c
d o
c vCL
m
'6
J
p
3
Co
3 3
ZlL
Co
'3 O
Co
O
lL
X
W
co
/
\
j$
\)
\)
\ /
J o
\�
/t
/
o
oo
o'
-FD
E Lo
\\\j
<
C
\o
nLq
\ /
o
-�
a <
J \\\E
co
/
\
\
\)
\)
o
E�
\�
f
/
2
o'
-FD
E Lo
\\\j
<
C
�f&zE
nLq
co
§
\
!
\
r
,;_:
- :
0
0 /
/
,0015
o'
-FD
\�\�\}\
\\�\
<
C
�f&zE
w
�EEEE2
)E§g§S§)§3E
E
_
®
\ j
)\(} j }\
-E
No
7»:�E
E
\o\
E » \
a o \\/
/
§
\
\
e0 -
,;_:
- :
0
0 /
/
,0015
o'
)Emo
\\�\
<
\
�f&zE
w
�EEEE2
)E§g§S§)§3E
E
_
®
/\\\
/
-E
No
7»:�E
�
\-
§
\f/a
2
f®
%f(
} /
j)j�j�j�j�\E
\�y
{/3,2/
�) /z
/
§
\
§
e0 -
,;_:
- :
E
\
/
}
E
-
o'
)Emo
\\�\
<
\
�f&zE
w
�EEEE2
)E§g§S§)§3E
E
_
®
/\\\
/
-E
No
7»:�E
�
\-
§
\f/a
2
f®
%f(
} /
j)j�j�j�j�\E
\�y
{/3,2/
�) /z
t
[)#}G
\\}\
=�R//%
$
E
\
e0 -
,;_:
- :
E
\
/
}
E
-
o'
)Emo
w
<
\
�f&zE
w
�EEEE2
)E§g§S§)§3E
E
_
®
\
-E
No
&
\2
\-
§
_-
j)j�j�j�j�\E
\\\ \\
�) /z
t
\\}\
f,E2E/S/m22 20o
-
_
w ,§u§2§2§2§2§
c s2l�
mm
-
o
\ §(/{t
}/ \
u-E0m \\\\\\\\(
- =�E�������A E
\ L
/
$
E
3
E
E
\
_
E
|
}
E
-
}
E
-
E
§
\
\
\
-
\
)
0
u
ƒ
ƒ ..!
&
!
a
a
0
0
E
W
z
0
z
0
3
m
2
z
O
c
O
0
E
C
E
o
E
o Y
u
E E3:
E E
x Y
E E
Q N
o
�o a
rn
00
v v
�9 c E
rn
00
II _ II-
II II
ON
II II
OC
o
—
v Y
o o O fl-
O O
E '? io
O O
in v O � v�
��
v? v
O rn
w°
E v -6 N
C°
o E v v 'v o
Y
m
E
E
E
v
C
E
t
o Y m
O
O v
a
O a
o -
Y
a o O
O a
Em 9
v
p .6
io
ro
io
n E LL
O
p
Z y
O
N
O O
O
N
O c
E'x�� Y
� v y
N N
-
E
nn
o
o
a E 9 t
o v° o
O
v° o
n T
O
O O
`�
E o E o
io
a
y'u o
EE
o U 9 v
EE
o U 9 v
EE
9
o
9
E
Y v v
E
Y v v
O
o
O m N
O ti
II II
v
�fN
N
U 3
m
v m m O
bA
E
N
N N
1
E v
E
v�
o
Opo
O O
-
mon
O O
rco
°
0 E
O O
v o_ y, O o_ y,
c o ro 3 o ro
3 c U v
3 9 c Elo v
ro p i'
3 ro f0 c
E.
o
o o v i N 0
o
E 9 C
N tp N N
9 Y
i
SO O C 'c v E E
-4
In N
E
E
3
u E
E
E
o Y
u
E
rfl
-
Q N
O m
m
m N
x m
K
m
oo
z
o
v Y
O
o E v v 'v o
E
o
a o
E
J O v ;o
Y
Em 9
v
E m
mY m
E'x�� Y
E
N N
-
E
nn
o
a E 9 t
O
n T
O
O O
`�
E o E o
io
a
y'u o
EE
EE
EE
SO m oo
Sp oo
rrl rrl
Sp oo
t6
II O II O
6
N a Y
Y N
O ti
II II
N
II II
O ti
II II
N°v
O O
`opo
_5 N O
�opO
N N
N N
N N
Opo
O O
-
mon
O O
O O
O O
v o_ y, O o_ y,
c o ro 3 o ro
v
o 'v 3
v o
c 3
v o
c 3
v o
c 3
O
O H
O H
OH
v
o .a ° a
v
oo
' `o_
'
° E _
o
ro
c v
v Y
.9
c
E o
v m
E
v
c
o
E 0 0
ocn ocn
°
o o E
o o o'� o E o 0
'a c ocn
cc
ocn
o E y 90 v Y
.� w
E
.�
v
ocn
o v
a
v w
vEi o o 5
a E
�o o v o rxo
o O o f
x x E O E v c
a '�, E
X .X
�
`o
u m v t o
is
c
C7
v �o C7
E
3 3 u
E
3
u E
E E
m m N
E E a
o Y
u
:cc
�9
t m
-
09
C C `p
O m
.o .o 7
m m
m N
x m
K
E
E
/
E
--
§
\r\\F—%o o
-
/
E\2E \0
E
\`
2/Ek»E\:\
%\/%\E
..- = 0 a
`
}/\\\{\\{
/
. ,
-x \ E < \ E
))/§//\§/i
-E
({E
INEc
0c
{\maMU
-baE&)£
�C
E. 3:S
j5).Q
E
E
/
E
§
/
E
\`
%\/%\E
`
}/\\\{\\{
-x \ E < \ E
E
E
\\�
/
\
2
Attachment F - Kitchener Lot Analysis
The following presents a review and analysis of lots in Kitchener, undertaken with the objective of
understanding how many additional lots will be eligible for up to 4 units with the proposed zoning
regulations. The analysis is based on MPAC parcel fabric data available to City of Kitchener and extracted
as of November 9, 2023.
Summary
• 28,575 lots are currently eligible for up to 3 units, representing 46% of the total lots or 48% of
lots with single detached, semi-detached or street townhouse dwellings.
• 41,451 lots will become eligible for up to 4 units, representing 67% of the total lots or 69% of
lots with single detached, semi-detached or street townhouse dwellings.
• 11,937 additional lots with single detached dwelling, 658 additional lots with semi-detached
dwelling, and 281 additional lots with street townhouse dwelling unit will become eligible for up
to 4 units.
Lots in Kitchener
• Total number of lots in Kitchener (includes parks, utilities such as pumping stations, reserve for
roads, etc., institutional, commercial etc. that may have 0 units) — 67,590
• Total number of lots in Kitchener, excluding lots having 0 units — 62,194
• Total number of units in Kitchener — 109,974
• 96% of the lots are either single detached, semi-detached or street townhouse dwellings, with
single detached dwellings accounting for about 80% of the lots in Kitchener (Figure 1).
Other dwelling
Street townhouses, types, 2,313, 4%
4,407,7%
Semis, 5,381, 9% _
Singles, 50,091,
80%
Figure 1. Total number of lots in Kitchener by type of dwelling with a minimum of 1 unit
• Of the single detached, semi-detached and street townhouse dwellings, majority have only 1
unit on the lot.
• About 55,905 properties in Kitchener (90% of the total lots in Kitchener) have only 1 dwelling
unit, about 3,380 properties have 2 dwelling units and about 555 properties have 3 dwelling
units as shown in Figure 2.
Page 115 of 343
55,903,92%
3,378,5% 554,1%
1 Unit 2 Units 3 Units
Figure 2. Number of lots by total number of units on a lot for single detached, semi-detached and street townhouse dwelling
Eligibility for 3 Units on a lot in Kitchener
• Up to 3 units on a lot are permitted where a single detached, semi-detached or street
townhouse dwelling is a permitted use, subject to regulations.
• Existing regulations for 3 units require a minimum lot width that is greater of that required by
the zone or 13.1 m and minimum lot area that is greater of that required by the zone or 395 mz.
• A total of 28,575 lots are currently eligible for up to 3 units based on existing regulations of
minimum lot width and lot area. This represents approximately 48% of lots with single
detached, semi-detached or street townhouse dwellings (Figure 3).
70000
59879
60000
50091
50000
0
J 40000
0
a)
030000 28237
28575
z
20000
10000
5381
4407
■ 207
. 131
0
Single detached
Semi-detached
Street Townhouse Singles, Semis and
Street Townhouses
■ Total ■ Eligible for 3 Units
Figure 3. Lot eligibility for up to 3 units based on current regulations for lot area and lot width
Page 116 of 343
Suitability for 4 Units on a Lot in Kitchener
• Proposed regulations include a minimum lot width and lot area required by the zone and
dwelling type, except when the lot is outside of an MTSA boundary, 800 m of an LRT station,
and Central Neighbourhood area where a minimum lot width of 10.5 m and lot area of 360 mz
is required.
• A total of 41,451 lots in Kitchener will become eligible for up to 4 units based on the proposed
regulations. This would represent approximately 69% of lots with single detached, semi-
detached or street townhouse dwellings (Figure 4).
• Single detached dwellings will continue to have the greatest potential for up to 4 units, with
approximately 80% of the lots with single detached dwellings becoming eligible for up to 4
units.
70,000
60,000
50,091
50,000
40,174
40,000
0
v
E 30,000
z
20,000
10,000
5,381
■ 865
0
Single detached Semi-detached
e
59879
Street Townhouse Singles, Semis and
Street Townhouses
■ Total Suitable for 4 Units
Figure 4. Lot suitability for up to 4 units based on proposed regulations for lot area and lot width
Page 117 of 343
3 Units vs. 4 Units Eligibility
• With the proposed regulations, an additional 12,876 lots will become eligible for up to 4 units.
This is in addition to the 28,575 lots that are currently eligible for up to 3 units and will be
eligible to add a fourth unit (Figure 5).
Figure 5. Total lots, Lots eligible for 3 units, and Lots suitable for 4 units by dwelling type
70,000
■ Total
■ Eligible for 3 Units
Suitable for 4 Units
Lots with
59879
60,000
Single
50,091
Street
Total
50,000
Detached
Townhouse
0 40,174
Dwellings
Dwellings
41451
0 40,000
Number of lots with up to 3
L
30,000 8'237
units permitted based on
8575
z
11
131(3%)
28,575 (48%)
current regulations
20,000
10,000
5,381
4,407
■ 207 865
. 131 412
865(16%)
0
41,451 (69%)
proposed regulations
Single detached
Semi-detached
Street Townhouse
Singles, Semis and
Street Townhouses
Note — (value) denotes percentage of total lots of the dwelling type
Page 118 of 343
■ Total
■ Eligible for 3 Units
Suitable for 4 Units
Lots with
Lots with
Lots with
Single
Semi-
Street
Total
Detached
Detached
Townhouse
Dwellings
Dwellings
Dwellings
Number of lots with up to 3
units permitted based on
28,237 (56%)
207(4%)
131(3%)
28,575 (48%)
current regulations
Number of lots with up to 4
units permitted based on
40,174 (80%)
865(16%)
412(9%)
41,451 (69%)
proposed regulations
Additional lots that permit up
to 4 units
11,937
658
281
12,876
Note — (value) denotes percentage of total lots of the dwelling type
Page 118 of 343
Lot Width and Lot Area Analysis
Limitations
1. Parcels subject to Zoning By-law 85-1 are excluded, assuming that majority of properties are
subject to and will eventually be brought into Zoning By-law 2019-051 through the Growing
Together project with zoning that allows for more density. However, the exclusions applied also
rule out some of the newer subdivisions such as those in the Rosenberg Secondary Plan that are
subject to Zoning By-law 85-1.
2. Parcels with RES zoning in Zoning By-law 2019-051 that are 'developed' and have a'frontage' as
noted in MPAC data have been included. As a result, many multiple dwelling type properties
(including those with cluster townhouses and stacked townhouses) have been excluded.
3. Lot frontage is taken as a proxy for lot width (means the horizontal distance between the side
lot lines of a lot measured at the required minimum front yard setback).
4. Parcels with multiple zones may lead to double counts and totals not adding up.
5. Parcels with multiple zones may skew minimum and average numbers.
6. Condo ownership has not been excluded and may skew minimum and average numbers,
particularly for low-rise RES zones.
7. Special use regulations that permit higher density forms of housing have not been accounted
for.
Low Rise Residential designation
• Total number of lots that are designated low rise in the Official Plan or any Secondary Plan
(includes low rise conservation, low rise multiple), excluding MTSAs — 53,082
• Total number of units that are designated low rise in the Official Plan or any Secondary Plan
(includes low rise conservation, low rise multiple), excluding MTSAs — 68,228
RES (Zoning Bylaw 2019-051) zoned lots
• Total number of lots that have a RES zoning under ZBL 2019-051 and are identified as developed
per MPAC - 52,138 (approximately 77.1% of the total lots)
• Majority of the RES zoned lots are zoned RES -2 (38.6%) and RES -4 (35.6%), followed by RES -3
(11.5%) and RES -5 (12%) as shown in Figure 6.
25,000
20,114
20,000
18,542
0
J
0 15,000
v
10,000
1
0
5,970
6,254
z
5,000
720
.
0 463 105
0
RES -1
RES -2 RES -3
RES -4 RES -5 RES -6 RES -7
Figure 6. Number of Lots in RES zones
Page 119 of 343
Low Rise RES (ZBL 2019-051) zoned lots
• RES -1 to RES -5 zones are low-rise residential zones, and encompass over 76.3% of total lots in
Kitchener.
• As -of -right permissions for single detached, semi-detached, street townhouse, and 4 -unit
multiple dwellings —
• Single detached dwelling is permitted in RES -1, RES -2, RES -3, RES -4, RES -5 zones
• Semi-detached dwelling is permitted in RES -3, RES -4, RES -5 zones
• Street townhouse dwelling is permitted in RES -4 (maximum of 4 units), RES -5 (maximum
of 8 units)
• 4 unit multiple dwelling is permitted in RES -4 (maximum of 4 units) and RES -5 zones
• Majority of the low-rise RES zoned lots, 48,741 or 72.1% of all lots in Kitchener, only have 1
existing unit on the lot (Figure 7).
60,000
50,000
40,000
30,000
20,000
10,000
0
1 unit 2 units 3 units 4 units 5 units 6 units 7+ units
■ RES -5 5,779 183 136 38 24 79 15
IRES-4 17,146 1,199 169 13 2 10 3
0 RES -3 5,685 283 2 0 0 0 0
■ RES -2 19,434 662 14 3 0 1 0
■ RES -1 697 19 1 2 0 0 1
Figure 7. Number of Lots by Number of Units on a Lot and RES Zone
Note:
1. There may be lots in zones that may not permit a certain number of units as -of -right as these may be zoned with site specific
regulations or may be legal non -conforming. For example - RES -4 zone permits a multiple dwelling with maximum of 4 units.
However, the data captures 15 lots with more than 4 units. This may be attributed to legal non -conforming status or site
specific zoning permitting higher number of units.
2. The analysis also excludes lots with '0' frontage as noted in the MPAC parcel data. As a result, many multiple dwelling type
properties (including those with cluster townhouses and stacked townhouses) have been excluded. This exclusion impacts the
number of 4 or more units noted in the data, particularly for RES -5 zone.
Lot Area Analvsis — by RES Zone (low rise) and Number of Units
• The average lot area typically increases with the number of units on a lot (Figure 8).
• There is not a significant difference in the average lot size for 1 unit and 2 units on a lot. This can
be attributed to no minimum lot area requirements for 2 units.
• For 3 units on a lot, the difference from 1 or 2 units on a lot is about 20% more (from 560 m2 for
1 or 2 units to 680 m2 for 3 units).
Page 120 of 343
• For 4 units on a lot in the low-rise RES zones, the average lot size is 900 m2 across 56 lots. This
may be attributed to larger lot size requirements currently for 4 -unit dwelling being considered
a multiple dwelling.
RES -1 Zone RES -2 Zone
800
700
600
500
400
300
200
100
0
6,000
5,000
4,000
3,000
2,000
1,000
0
697
1 unit 2 units 3 units
RES -3 Zone
5,685
3500.0 25,000
2931.9 3000.0
20,000
2500.0
2000.0 15,000
1500.0 10,000
1000.0
5,000
500.0
0.0 0
1 unit 2 units 3 units
RES -5 Zone
1 unit 2 units
RES -4 Zone
600.0 20,000
18,000
500.0 16,000
400.0 14,000
12,000
336.7
300.0 10,000
8,000
200.0 6,000
100.0 4.000
2,000
0.0 0
1 unit
3 units
2 units 3 units
RES -1 to RES -5 Zones combined
750.0
739.2 740.0
730.0
720.0
710.0
700.0
690.0
680.0
670.0
660.0
650.0
640.0
700.0
602.7 600.0
500.0
400.0
300.0
200.0
100.0
3
0.0
4 units
7,000
1000.0
60,000
1000.0
5,779
902.4 900.0
48,741
900.7 900.0
6,000
50,000
800.0
800.0
5,000694.5
700.0
40,000
680,2 700.0
4,000
600.0
67.1 600.0
541.5 500.0
30,000
500.0
3,000
[321.7
400.0
400.0
2,000300.0
20,000
300.0
200.0
10,000
200.0
1,000183
136 38 100.0
2,346 322 56 100.0
0
0.0
0
0.0
1 unit
2 units 3 units 4 units
1 unit
2 units 3 units 4 units
� Number of lots
-avg. lot area (m2)
Figure 8. Number of Lots by Zone and Number of Units on a Lot, and Average Lot Area
by Zone and Number of Units on a Lot
Page 121 of 343
Lot Area Analysis — By Type of Dwelling (Existing)
• Existing single detached dwellings in RES -1 to RES -5 Zones
• Majority single detached dwellings are on lots with more
than 395 m2 area (current
requirement for 3 units on a lot) — at least 80% of 40,129
lots (32,103 lots) have an area
of more than 399 m2 (Table 1).
Table 1. Lot Area Percentile Analysis for Existing Single Detached Dwellings
in RES -1 to RES -5 Zones
RES -1 RES -2 RES -3 RES -4
RES -5
RES -1 to RES -5
combined
Number of Lots 690 19,402 5,604 12,894
1,539
40,129
Min. Lot Area per ZBL
929 411 288 235
2019-051 (m2)
235
NA
10th percentile (m2) 965 472 371 292
284
335
20th percentile (m2) 1,105 507 390 320
300
399
25th percentile (m2) 1,170 519 400 331
312
428
30th percentile (m2) 1,253 537 408 343
327
458
40th percentile (m2) 1,477 573 424 379
377
488
50th percentile (m2) 1,811 612 449 420
425
531
60th percentile (m2) 2,098 649 475 463
457
578
70th percentile (m2) 2,382 699 512 511
501
629
75th percentile (m2) 2,595 732 538 542
540
664
80th percentile (m2) 3,021 774 566 579
576
704
90th percentile (m2) 4,523 921 660 675
696
853
Note — Percentile means the value below which a certain percentage of the data in a data set is found. For example,
20th percentile value means that 20% of the data is below that value.
Below 360 m2
Above 360 m2
Page 122 of 343
• Existing semi-detached dwellings in RES -3 to RES -5 Zones
• Over 40% of lots with semi-detached dwellings (1,944 lots) have an area of more than
383 m2 (Table 2).
Table 2. Lot Area Percentile Analysis for Existing Semi- Detached Dwellings in RES -3 to RES -5 Zones
RES -3 RES -4 RES -5 RES -3 to RES -5
combined
Number of Lots
79
4,186
550
4,859
Min. Lot Area as per
ZBL 2019-051 (m2)
260
210
210
NA
10th percentile (m2)
313
258
244
258
20th percentile (m2)
335
281
258
281
25th percentile (m2)
342
293
274
292
30th percentile (m2)
347
306
280
305
40th percentile (m2)
348
325
305
324
50th percentile (m2)
360
353
334
350
60th percentile (m2)
384
386
360
383
70th percentile (m2)
390
418
384
417
75th percentile (m2)
404
430
401
426
80th percentile (m2)
432
449
420
446
90th percentile (m2) 459 538 530 536
Note — Percentile means the value below which a certain percentage of the data in a data set is found. For example,
20th percentile value means that 20% of the data is below that value.
Below 360 m2
Above 360 m2
Page 123 of 343
• Existing street townhouse dwellings in RES -4 and RES -5 Zones
• Majority of lots containing street townhouse
dwellings in the RES -4 to RES -5 zones have
a lot area of less than 360 m2 (Table 3).
Table 3. Lot Area Percentile Analysis for Existing Street Townhouse Dwellings in RES -4 and RES -5 Zones
RES -4
RES -5 RES -4 and RES -5
combined
Number of Lots 102
3,460
3,467
Min. Lot Area as per 148
135
NA
ZBL 2019-051 (m2)
10th percentile (m2) 258
171
171
20th percentile (m2) 290
176
176
25th percentile (m2) 302
181
182
30th percentile (m2) 302
187
187
40th percentile (m2) 306
199
200
50th percentile (m2) 343
215
216
60th percentile (m2) 371
239
241
70th percentile (m2) 402
264
270
75th percentile (m2) 454
282
287
80th percentile (m2) 493
307
310
90th percentile (m2) 544 389 388
Note — Percentile means the value below which a certain percentage of the data in a data set is found. For example,
20th percentile value means that 20% of the data is below that value.
Below 360 m2
Above 360 m2
Page 124 of 343
Lot Width Analysis - by Type of Dwelling (Existing)
• Existing single detached dwellings in RES -1 to RES -5 Zones
• Substantial number of lots containing single detached dwellings in the RES -1 to RES -5
zones have a lot width of more than 13.1 m (current requirement for up to 3 units), with
at least 60% having a lot width of more than 13.4 m (Table 4).
• 80% of lots have a lot width of more than 11 m.
• In the RES -4 and RES -5 zone, lesser proportion (around 60%) have a lot width of more
than 10.5 m
Table 4. Lot Width Percentile Analysis for Existing Single Detached Dwellings in RES -1 to RES -5 Zones
RES -1 RES -2 RES -3 RES -4 RES -5 RES -1 to RES -5
combined
Number of Lots
690
19,402
5,604
12,894
1,539
40,129
Min. Lot Width* as per
ZBL 2019-051 (m2)
24
13.7
10.5
9
9
NA
10th percentile (m2)
22.0
13.0
10.7
9.1
8.7
9.2
20th percentile (m2)
24.3
13.8
11.3
9.1
9.1
11.0
25th percentile (m2)
24.4
14.3
11.7
9.2
9.2
11.9
30th percentile (m2)
24.9
15.0
12.1
9.5
9.4
12.2
40th percentile (m2)
27.5
15.2
12.2
10.4
9.8
13.4
50th percentile (m2)
30.5
15.8
12.2
11.6
11.3
14.3
60th percentile (m2)
35.4
16.8
12.7
12.2
12.2
15.2
70th percentile (m2)
40.2
18.3
13.4
13.7
13.5
16.2
75th percentile (m2)
41.0
18.4
13.7
14.6
14.4
16.8
80th percentile (m2)
43.7
19.3
13.9
15.2
15.2
18.2
90th percentile (m2)
53.6
21.3
16.2
16.8
16.8
20.1
* Minimum lot width noted are for interior lots, corner lots have a greater
lot width
requirement.
Note - Percentile means the value below
which a certain
percentage
of the data in a data set is found.
For example,
20th percentile value means
that 20%
of the data is below that value.
Less than 10.5 m
More than 10.5 m
Page 125 of 343
• Existing semi-detached dwellings in RES -3 to RES -5 Zones
• Majority of lots with a semi-detached dwelling do not qualify with current lot width
requirement of 13.1 m for 3 units (Table 5).
• 90% of lots have a lot width of less than 10.7 m.
Table 5. Lot Width Percentile Analysis for Existing Semi- Detached
Dwellings in RES -3 to RES -5 Zones
RES -3 RES -4
RES -5
RES -3 to RES -5
combined
Number of Lots 79 4,186
550
4,859
Min. Lot Width as per
ZBL 2019-051 (m2) 9.3 7.5
7.5
NA
10th percentile (m2) 9.1 7.5
6.9
7.4
20th percentile (m2) 9.6 7.7
7.5
7.6
25th percentile (m2) 9.9 7.9
7.5
7.9
30th percentile (m2) 9.9 8.3
7.6
8.1
40th percentile (m2) 10.0 8.8
7.6
8.7
50th percentile (m2) 10.7 9.1
7.9
9.1
60th percentile (m2) 10.7 9.1
8.4
9.1
70th percentile (m2) 10.9 9.2
8.8
9.2
75th percentile (m2) 11.5 9.3
9.1
9.3
80th percentile (m2) 12.0 9.6
9.1
9.6
90th percentile (m2) 13.4 10.7 10.4 10.7
Note - Percentile means the value below which a certain percentage of the data in a data set is found. For example,
20th percentile value means that 20% of the data is below that value.
Less than 10.5 m
More than 10.5 m
Page 126 of 343
• Existing street townhouse dwellings in RES -4 and RES -5 Zones
• Majority of lots with a street townhouse dwelling do not qualify with current lot width
requirement of 13.1 m for 3 units (Table 6).
• 90% of lots have a lot width of less than 10.4 m.
Table 6. Lot Width Percentile Analysis for Existing Street Townhouse Dwellings in RES -4 and RES -5 Zones
RES -4 and RES -5
RES -4 RES -5
combined
Number of Lots 102 3,460
3,467
Min. Lot Width as per
6 5.5
ZBL 2019-051 (m2)
NA
10th percentile (m2) 7.4 5.5
5.5
20th percentile (m2) 9.0 5.5
5.5
25th percentile (m2) 9.0 5.5
5.5
30th percentile (m2) 9.0 5.6
5.6
40th percentile (m2) 9.1 6.1
6.1
50th percentile (m2) 9.3 6.1
6.1
60th percentile (m2) 10.4 6.5
6.7
70th percentile (m2) 11.1 7.6
7.9
75th percentile (m2) 11.1 8.1
8.2
80th percentile (m2) 11.2 8.3
8.6
90th percentile (m2) 13.3 9.6 10.4
Note - Percentile means the value below which a certain percentage of the data in a data set is found. For example,
20th percentile value means that 20% of the data is below that value.
Less than 10.5 m
More than 10.5 m
Page 127 of 343
Attachment G1- Engagement Summary
Project Engagement Overview
Kitchener's Enabling Four Units project included a comprehensive public engagement
process to gather feedback and respond to questions from the public and the
development industry. This report captures the key findings and insights from the
engagement activities held between December 2023 and February 2024.
How We Reached Out
In December 2023, an Engage Kitchener webpage was launched to provide details
about the project including in-person and virtual engagement opportunities, and
information on ways to stay involved. The webpage has a news feed tab that was
updated throughout the project with all the new documents, materials, and engagement
information.
While working on this project, staff kept open communication and engagement with the
public through different channels, including:
• Engage Kitchener
• Email correspondence
• Phone conversations and in-person one-on-one conversations
• Advertisements in the newspaper
• Virtual Community Meeting
• 3 Public Open Houses
• Development Industry workshop
• Presentations to Kitchener Development Liaison Committee
Engage Kitchener
The Enabling Four Units project utilized a dedicated engagement webpage hosted on
Engage Kitchener, the City's online engagement platform. This webpage served as a
central hub for information, updates, and opportunities for community participation
related to the project.
Our webpage received about 1893 visitors and 146 subscriptions
Subscribe Button
To further enhance accessibility and engagement, the webpage included a subscribe
button that allowed visitors to opt -in to receive email updates about the project. By
subscribing, community members could stay informed about new information, upcoming
events, and opportunities for participation without visit the webpage regularly. This
feature helped with ongoing communication throughout the duration of the project.
Page 128 of 343
W._._, -
Home ( E�ge Kitchener 1 Enabling FourU—
Enabling Four Units
0 0 0 IS
The City of Kitchener is growing and more homes are needed to meettheneed.s of existing and future residents
In March 2023, the City of Kitchener made. Municipal Housing Pledge to build an additional 35,000 homes by 2037. A
key comp—rill of this pledge includes enabling more housing that will support gentle intensi€kation of our existing
low use residential areas.
'Enabling Four Units' will explore the cmat cn of zoning regulations that will permit up to four dwelling units on any lot
that allows a single -detached dwelling, semidetached dwelling or street fronting townhouse dwelling, subjecl to
regulations. These additional dwelling units could be located in:
• existing buildings
• additions to new buildings
• —buildings either as the main building or in the backyard
(image credit rehousin.ca
Why is this being considered?
Housing Demands: With our community growing, there is a need to explore innovabve solutions to accommodate the
increasing demand for housing and pmmote a variety of housing options_
Urban Development Eeal, ling fou- units can contribute to a more effin1.0 use of existing spaces and infrastructure,
Figure 1. Screenshot of the webpage
Updated News Feed
-in'
STAY INFORMED
Subscribe for project updates
Your email address,.
tab mmnhera of mcr mmmimhY are #ollowmatiria pmjecr
Lifecycle
Learn more about Nis projectand
how you can contribute
Dpenfafeedback
Attend a meeting, open house, or
add your feedback online
* Urrda renew
We are reviewing the feedback we
received. A summary of what we
heard, and copies of submitted
comments, will he included with our
report to Council.
ReporttoCosndl
Vim are presenting our report and
The webpage featured a news feed that provided visitors with the latest information on
the project. This feed served as a resource to stay informed about project milestones,
upcoming events, and opportunities for engagement. Regularly updating the news feed
with relevant content ensured visitors to the webpage had access to timely and accurate
information about the project.
Survey
The Engage page included a survey to gather feedback from the community. The
survey allowed participants to share their opinions, preferences, and concerns
regarding the proposed changes to zoning regulations.
The survey response report of the 80 completed surveys can be found in Attachment
G2 to DSD -2024-066.
Page 129 of 343
Email Correspondence
A dedicated email address, EnablingFourUnits@Kitchener.ca, was established to
facilitate communication, gather input and address questions. Since the project's
initiation, staff received approximately 95 emails (including about 40 comment emails
from about 26 individuals) through this dedicated email address.
The emails received encompass a wide range of responses. Many residents support the
proposed zoning changes, citing the potential benefits of increased housing options and
affordability. Others have raised specific concerns or questions about the project's
potential impact on their neighbourhood, infrastructure, green space, and quality of life.
Responding to emails promptly and effectively has been a priority for our team. The
team endeavored to provide responses to inquiries and feedback received within 48
hours of receipt. This timely response demonstrates that staff are listening so that
community members feel heard and valued throughout the engagement process.
The email correspondence can be found in Attachment G3 to Report DSD -2024-066
Phone conversations and one-on-one conversations
Throughout the Enabling Four Units project, the project team engaged in numerous
phone conversations and one-on-one interactions with community members,
addressing questions, receiving feedback, and discussing the proposed zoning
changes.
Residents and property owners contacted City staff through phone calls and walk-in
visits to the City Hall Customer Service Center. Many inquiries were site specific with
residents identifying privacy, change to neighborhood characteristics, and parking as
primary concerns. Additionally, residents wanted to understand how the proposed
changes would impact development opportunities on specific lots, including whether
their properties were included in the project's scope.
Staff responded to each inquiry, providing information and guidance to community
members. They listened to residents' concerns and feedback, acknowledging the
importance of incorporating community input into the project implementation process
Staff noted the specific issues residents raised and committed to considering these
factors when formulating the final recommendations for the project.
Many phone conversations and one-on-one interactions provided positive feedback and
expressions of support for the project as many community members recognized the
potential benefits of increasing housing options in Kitchener and expressed interest in
the proposed zoning changes.
Page 130 of 343
Advertisements in newspaper
A Notice of Public Consultation was published in the Waterloo Region Record on
January 5, 2024 and January 12, 2024 to inform the community about the project
background and the upcoming engagement opportunities (Figure 2).
I
NOTICE OF PUBLIC CONSULTATION
Enabling Four Univ . r- �-�
The City of Kitchener is growing and
more homes are needed to meet the
needs: of existing and future residents_
In March 2023, the City of Kitchener
made a Municipal Housing Pledge to
build an additional 35,000 homes by
2031. A key component of this pledge
includes enabling more housing that
will support ;gentle intensification in our
existing Low -rine residential areas.
'Enabling Four Units" will explore the
creation of zoning regulations that gill
permit up to four dwelling units on any
Lot that would permit a single -detached
dweLling, semi-detached dwe[Ling or
street fronting townhouse dwelling,
subject to regulations.
Visit us during one of our public
consultation events or attend our
Virtual Community Meeting to discuss
this project, ask questions and provide
coMM(?nts.
To learn more visit:
www.engagewr.cal
EnahlingFourUnits
HaveYour Voice Heard
Attend one of our eventy:
Wednesday, January 17, 2024
6-30- 8:0{3 p.m.
VirtuaL Corn muniity Meeting
To connect to the virtual meeting
online, go to; www.zoom.usJoin and
enter meeting i D# 868 3942 3268
Saturday, January 20, 2024
7. -OG a.m. - 2.00 p.rn. (drop-in anytime)
Kitchener Market
300 King Street East
Tuesday, January 23, 2024
3:00 - 7:00 p.m. (drop-in anytime)
Stanley Park Community Centre
505 Franklin Street North
Wednesday, January 31; 2024
3:00 - 6.00 P.M. (drop-in arWime)
Forest Heights Community Centre
1700 Queen's Boulevard
Katie AnderL Project Manager
ena blingfour units ft-kitehener,ca
514.741.2426
Figure 2. January 12, 2024 newspaper notice for public consultation
Page 131 of 343
A notice of Statutory Public Meeting was published in the Waterloo Region Record on
March 1, 2024 (Figure 3).
NOTICE OF PUBLIC MEETING
Enab[ing Four Units
Y
Have Your Voice Heard!
Planning & Strategic Initiatives Committee
Date- March 25, 2024
Location: Council Chambers.
Kitchener City Hall
200 King. Street West
OrVfrrtual Zoom Meeting
Go to kitchener.ca/meetings
and select
• Current agendas and reports
(lpo5ted 10day5 before meeting]
0 Appearas a delegation
} match a rneeting
To learn more about thls prooct, i ncluding
information on your appeal fights, visit
■ s r www kiitch r.oa/
0 Plan ni,rrgApplications
or contact:
Additional Parking Zoning Katie Anderl, Project Manager
DweLLing Reductiois Regutallons enablingfo runits@Aitcl ever.
Units 519.741.2426
The City of Kitchener will consider City -initiated applications OPA23/020/K/KA and
ZBA2.3/035/ A to amend the Official Plan and Zoning -law. These amendments will
permlt up to 4 dwelling units on Lots ~which permit a single detached dwellin&
semi-detached dwelling or street townhouse dwelling subject to regulations for lot
sizas. parking, Ian dsc:apingand builtfbrm_
Figure 3. March 1, 2024 newspaper notice of public meeting
Page 132 of 343
Virtual Community Meeting
The project team hosted a virtual community meeting on January 17 allowing
participants to join remotely from the comfort of their homes or workplaces.
Attendance and Participation
Approximately 30 attendees participated in the virtual public meeting. Residents,
property owners, developers, and other interested parties were present, demonstrating
high engagement and interest in the project through their questions and comments.
Agenda and Format
The virtual public meeting followed a structured agenda featuring a presentation from
staff to provide an overview of the Enabling Four Units project, its objectives, and how it
can look in low-rise residential properties. Attendees had the opportunity to learn about
the project's background, rationale, and potential impacts on the community.
Split Leel Single Detached Dwellin
Lot width -17.5 m{57.5 ft
Lot depth — 35 m / 115 ft
PIP
I Enabling Four Units Everywhere - Virtual. Neighbourhood Meeting
Figure 4. A screen capture of the virtual meeting showing various formats for
Additional Dwelling Units
Question and Answer Session
A question and answer (Q&A) session was held after the presentation, allowing
attendees to seek clarification, raise concerns, and ask questions. Some questions
were about existing regulations related to the two units attached and the street fronting
townhouse building type. Other questions were related to building style and site layout,
Page 133 of 343
such as allowing up to four storeys, and side and front yard setbacks. There were also
concerns about the loss of trees and green space.
f
• Use the Q&A function 9
to type your questions, or comments
Enabling Four Units Everywhere - Virtual Neighbourhood Meeting
Figure 5. A screen capture of the virtual meeting during the question and answer
portion of the meeting
Open Dialogue
In addition to the formal presentation and Q&A session, the meeting included an open
dialogue segment where attendees were encouraged to ask questions verbally. Some
of the concerns discussed included whether this project would help provide more
housing solutions and if the additional dwelling unit could be sold. Lastly, there was a
question about clarifying the review process. The project team helped answer those
questions by explaining the current regulations and how enabling four units can provide
more housing choices on more properties.
Recording and Accessibility
The meeting was recorded and posted on YouTube allowing community members
unable to attend live to access the information at their convenience (or for participants
to rewatch) with approximately 185 views to date. The recording, available through the
project webpage, provided a valuable resource for community members with several
members indicating that they watched the video in advance of engaging with us in-
person or online.
Page 134 of 343
By leveraging digital platforms and technology, staff was able to reach a broad
audience, facilitate open dialogue, and gather valuable feedback from residents and
other stakeholders.
Public Open Houses
Staff hosted three open houses at various locations across Kitchener.
Open House Details
The open houses were held at the following times and locations:
• January 20, 7 a.m. to 2 p.m. at Kitchener Market (300 King St. East, upper level)
• January 23, 3 to 7 p.m. at Stanley Park Community Centre (505 Franklin St.
North)
• January 31, 3 to 6 p.m. at Forest Heights Community Centre (1700 Queen's
Boulevard)
Figure 6. Kitchener Market Open House
Page 135 of 343
J
a
)wnnin
MASI
r
Figure 7. Stanley Park Community Centre Open House
iqff
Ilk
P
r
Figure 8. Forest Heights Community Centre Open House
Page 136 of 343
Engagement Activities
At each open house, attendees had the opportunity to explore a scaled, 3D -printed
model representing different lot sizes and dwelling types including additional dwelling
units (attached and detached). These models provided visual representations of how
four units might function on lots in existing residential neighborhoods.
In addition to the models, community members could view display boards, handouts,
survey sheets and use tablets to access the project webpage and survey. The project
team answered questions, listened to concerns, and discussed the benefits and
considerations of enabling four units on a lot.
Community Feedback
In total, the open houses attracted more than 150 attendees. Many attendees
expressed interest and enthusiasm for the project, particularly highlighting the benefits
of enabling four units on a lot such as gentle intensification, affordability, and providing
house choices. However, we also received comments and concerns from attendees,
particularly regarding:
• Trees and green space preservation
• Parking considerations
• Stormwater management (infiltration) and climate change factors
• Use of units as short-term rentals
• Servicing and electricity capacity
• Privacy and overlook associated with the placement of units.
A Summary of Open House comments is available in Attachment G4 to Report DSD -
2024 -066.
ENABLING 1
FOUR UNITS
FOR KITCHENER'S LOW-RISE
RESIDENTIAL AREAS
Tnk-r-•imt .Nr.il Ih P.1,4I I
W'td.lpnlr' nwnn ry ni r..v�.i
wrew.angagewr.ealena�iegketnenid
rw
Pu`°.
❑■ �
Enabling Four Unitsis exploring
the creation of zoning
regulations to allow up to four
dwelling units on a lot where a
single -detached, semi-detached,
or street -fronting townhouse
dwelling is a permitted use.
V060000
5.V—r C� w: reanvero.>ar�fixmatro,-
I ply � �o�len�aoA.MMe h«peav�eN{Tlnq�rpy. ronm..m
woven �IAlepr..eorarmrrer gµ.oprt.x armlrrw..m r.a.nam.
E papmed fw m¢ Ewew�p iaw,lwaairpk:
P:. au #*wtld.. eeeewdveKVAs
�YPl.rfiH�ls¢f b.xi
,��. ...a re. 1 d. 2 wre.e. e¢n,e.r..weww¢s
1Yi' y.e uw¢x nr NetlCreL+w Hunt
. rr.-.k «.&r'•••-••��+/�Ie.:.mrJr�rW w.w alrn�wti.r�ylie4c�r.
Figure 9. Enabling Four Units handout
Page 137 of 343
Development Industry Workshop
A workshop targeted to the development industry was held on January 31 at Forest
Heights Community Centre from 1:00 to 2:30 pm. The workshop was attended by 20
industry professionals including builders, designers, and developers and designed to
gather insights and feedback on proposed zoning regulations.
Workshop Structure
The workshop was launched with a brief presentation providing background information
on the project and its objectives. Subsequently, participants were divided into four
groups for discussions regarding:
• Lot Size and Area: Discussions centered around considerations for lot sizes and
areas, exploring the feasibility of smaller lots and minimum dimensions.
• Parking and Driveways/Parking Lots: Participants delved into parking and
driveway considerations, assessing the impact of increased density on parking
availability and discussing potential reductions and solutions.
• Detached ADUs: This segment focused on regulations for detached Additional
Dwelling Units (ADUs), exploring design considerations and regulatory
requirements.
• Building Design: Discussions revolved around building design elements such
as height, doors, openings, setbacks, and yard projections, focusing on aligning
design considerations with proposed zoning regulations.
Key Feedback
Overall, the feedback from participants was predominantly positive, with support for the
project objectives and proposed zoning changes. However, several suggestions
emerged from the discussions, including:
• Exploring ways to further minimize the need for minor variance applications.
• Increasing public awareness about the project and its implications for residential
development.
• Developing an online tool or resource to assist with Additional Dwelling Unit
projects and streamline the application process.
Summary of Open Houses and Industry Workshop Feedback can be found as
Attachment G4 to Report DSD -2024-066.
Page 138 of 343
Kitchener Development Liaison Committee
The project team participated in two Kitchener Development Liaison Committee (KDLC)
meetings. These meetings were a great opportunity for dialogue and collaboration with
development industry professionals involved in residential development in the region.
Presentation
• The first meeting on January 19 presented an overview of the objectives and
goals of the project and a discussion of zoning considerations that were being
explored.
• The second meeting on February 23 staff presented and discussed the draft
zoning regulations.
Consultation and Feedback
Following the presentations, the project team engaged committee members in a
discussion focused on high-level considerations. The committee discussed emerging
trends in purchaser and homeowner preferences, including developer built duplexes in
new subdivisions, challenges experienced with constructing additional units, and what
might be useful to assist the development industry in implementing and supporting
uptake of additional units. Committee members expressed desire for streamlined
review timelines, and easy to navigate online resources and zoning tools. There was
also discussion about homeowners who proposed changes to dwellings while
subdivisions are under maintenance periods and when homes are under Tarion
warranties, and implications of this on acceptance processes.
During the second meeting, staff shared the draft regulations proposed for the project.
Questions were raised regarding the feasibility of adding a detached dwelling unit when
the rear yard setback is at the minimum 7.5 metres. Staff highlighted that properties
meeting this criterion might be more suitable for additional units attached.
Another query pertained to the lot analysis and modelling used to determine the
minimum lot width and area. Staff confirmed that several mechanisms were used to
complete an analysis of different lot configurations and building layout which have
informed zoning recommendations.
Questions were raised about capacity and servicing constraints. Building staff confirmed
that servicing can be supplied from the principal existing building. Additionally,
engineering and utilities will continue to monitor capacity, and advise that areas with
constraints may need to be addressed as additional units are added incrementally in
neighbourhoods.
Lot grading and drainage considerations discussed included ensuring that infiltration
galleries and side yard drainage are not impacted by proposed units or the unobstructed
walkway.
Page 139 of 343
Lastly, a suggestion was received to consider more rear lanes in new subdivisions to
enhance the potential of these properties. Planning staff indicated that they are
supportive of exploring new and creative ways of enabling additional density in new
subdivisions through the subdivision design, street layout and site-specific zoning.
The engagement with the Kitchener Liaison Development Committee provided valuable
insights and perspectives from industry professionals.
Conclusion
Our commitment to comprehensive public engagement was one of our priorities
throughout the Enabling Four Units project. From December 2023 to February 2024, the
project team utilized various engagement methods with the goal of transparency,
accessibility, and inclusivity in gathering feedback and responding to questions from
both the public and the development industry.
The Enabling Four Units project team's efforts to engage the community and industry
stakeholders demonstrated our dedication to working with and having meaningful
conversations with our community. By offering a variety of ways for people to get
involved, staff were able to gather feedback that has been considered in drafting the
proposed zoning changes.
Looking ahead, staff is committed to keeping communication lines open throughout the
implementation phase of the project.
Page 140 of 343
Add your comments on the
proposed by-law
SURVEY RESPONSE REPORT
21 January 2024 - 05 February 2024
PROJECT NAME:
Enabling Four Units
�� �s• BAN& THE TABLE
.f1-• engagementHQ
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
343
Page 1 of 69 Page 14
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
Q1 Please check all that apply to you:
55
50
45
40
35
28
30
25
20
15
10
51
17
Question options
i 1 live in a neighbourhood where there are new homes with 2 to 4 units on the property or where homes are being renovated to add
more units to the property
0 1 live in a house with 2 to 4 units on the property 1 am interested in renovating my current house to add more units
0 1 am in the construction industry and will be designing or building these projects
0 1 am thinking about how these changes may affect my neighborhood 0 Other (please describe):
Optional question (77 response(s), 3 skipped)
Question type: Checkbox Question
343
Page 2 of 69 Page 14"
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
Q2 Tell us about your experience living in a neighbourhood where there are 2 to 4 units on a
property. Please share both positive and negative experiences.
Screen Name Redacted For 60 years it was fine,. Respectfully mature neighbours. Give years
1/22/2024 05:45 PM ago the building was sold and I have spent my time dealing with
bylaw for noise after 11 pm, backyard fires past shut off time in space
that was two small. I was called all kinds of names. It made me want
to move in a house and neighbourhood I have lived for over 60 years.
Screen Name Redacted Dfd
1/23/2024 11:11 AM
Screen Name Redacted As far as I am concerned there are no real negatives. We are in a
massive housing crisis. We need to encourage the development of
any and all additional units. Gentle intensification is amazing! We
have done it several times, and it just makes communities better!
More vibrant, more liveable, more affordable. win -win-win.
Screen Name Redacted I haven't had negative experiences with living in an area with 2-4 units
1/25/2024 12:42 PM per property. Typically makes the neighborhood less car reliant
because the area is being used for residential buildings. Increases
viability of small local businesses.
Screen Name Redacted While there are not many yet in the neighbourhood, I haven't found
1/28/2024 10:27 AM any negative impact to the local community feeling.
Screen Name Redacted Some units in area are converted at 2-3 units. Parking problems
1/29/2024 11:18 AM increase with onstreet parking and full use of available spots per
house. Transient renters and absentee landlords reduce sense of
neighbourhood and standards of property upkeep.
Screen Name Redacted I have only positive experiences with the gentle density initiatives and
1/29/2024 11:24 AM would like to see far more happen with far fewer restrictions
Screen Name Redacted I live in Doon and close proximity to conestoga college. There are
1/29/2024 12:35 PM house here with more than legally allowed numbers of tenants. That
is a fact, by the way. Maybe if they did not take in as many students,
there would not be this need for more housing. Many years ago, mr.
tibbits was appalled that our colleges were taking students from other
Page 3 of 69
Page 144 of 343
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 06 February 2024
countries, guess money means more than quality education.
Screen Name Redacted It is great. No complaints.
1/29/2024 03:16 PM
Screen Name Redacted If planned properly, additional residential occupancy on a property
1/29/202403:30 PM has minimal impact. There have been some homes in our
neighborhood where it was done without the proper approvals and
led to over crowding and poor living conditions.
Screen Name Redacted I enjoy having new neighbours. There is definitely a parking issue and
1/29/2024 03:57 PM our street has become much busier. Other than that, It is nice to
diversify our street.
Screen Name Redacted Need for parking has dramatically increased for our neighbourhood as
1/29/2024 06:28 PM current public transport system is not adequate. Our local 2 dwellings
often have atleast 4 cars, 2 per dwelling which leads to cars parking
on the front lawn and spilling out to the street. I support higher density
living but I would also like for there to be governance requiring land
owners to provide enough parking for their renters. Ideally we also
increase infrastructure for public transit but I understand that will take
a longer time to improve. Basic parking requirements would be good
interim fix.
Screen Name Redacted There have been few negative, or even noticeable affects as a direct
1/30/2024 08:12 t1iM result of long-term rental units, however, short-term rental units are
more problematic. Problems include parking issues, garbage
accumulation, property maintenance, and sidewalk clearing.
Screen Name Redacted Positive: more variety in the people who live in an area, community
Iisu/2U24 u0.2b Acv, feels more active and vibrant, more people increases the demand for
additional services such as transit connections, options for people to
stay in community as they transition through different life stages.
Negative: certain property owners do not maintain their properties to
a good standard.
Screen Name Redacted Most of the homes sold recently are being flipped with additional units
added, it has been positive for the most part to date, but I do see
some concerns starting to arise, less neighbourly feelings and
transformation of quiet neighbourhood and 'knowing your
neighbours", guess this is the price of a growing community, but
some new focuses should be alternative, like limiting the numbers
Page 4 of 69
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
and not having a conver e , oage allowable in an area or street vs
all as an example.
Screen Name Redacted The East Ward of Kitchener now has a large apartment building on
1/30/2024 10:43 AM Borden St. N. and it has completely changed that street (try dropping
off or picking up your children) from Sheppard school and it forced
people on East Ave. to sell their homes and now they've built over-
sized units where normal, well kept houses used to be. The East
Ward is not that close to the LRT and we are being adversely affected
so I can only imagine what some other residential areas are
experiencing -----certainly this is not a positive outcome.
Screen Name Redacted The neighbors across the road and to my right are both single men.
1/30/2024 12:04 PM The neighbors to the right are part of a triplex. Two houses down is a
rooming house -- friendly men, good to have them there. On the other
side is a neighbor who put an addition on to there house so they
could host students and other housing challenged folks. All good
experiences. We are a relatively healthy mixed community.... at least
from my perspective.
Screen Name Redacted There isn't a lot of positive. If I look out my bedroom window next door
see 4 shopping carts from Zehrs in various places on the
driveway/front yard. Across the street there are no front yards, only
parking. It lowers the value of every other house on the street,
because obviously these all become rentals, with absent landlords,
and the tenants often don't look after their properties.
Screen Name Redacted In general, our neighbourhood has mostly properties that are single
1/30/2024 09:31 PM family, with some renovated to have a second basement unit. In the
recent past, we have seen some renovations that add additional
units. Overall, some light densification is positive given the housing
challenges in Kitchener and within Canada overall. However, this
type of densification should be done carefully to have minimum
impact to the character of the neighbourhood.
Screen Name Redacted We recently moved from being adjacent to multiple properties with 2-
1/31/2024 12:49 PM 4 units on single detached home properties or low rise multi
residential. While certain properties could have been better
maintained, the housing form was positive, added more diverse
demographics to the neighbourhood, and contributed to having more
residents able to access downtown amenities, transit, and other key
services. I strongly support their inclusion across the city and fewer
restrictions should be placed on housing density to reduce pressure
Page 5 of 69
Page 146 of 343
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 06 February 2024
on the downtown area and suburban eve opmen s.
Screen Name Redacted A few single family homes are being converted to duplexes without
2/01/2024 10:29 AM changing the exterior template. That is fine as long as there is
adequate parking.
Screen Name Redacted There are more people outside and using community resources,
2101/2024 U1:b2 F ✓ which make them more inviting. Negative experiences stem from lack
of pest and garbage control, extra turn -over in the community, and
parking conflicts.
Screen Name Redacted Within the past 2 years the wartime single-family homes on either
2rJ3/2024 02:16 PM side of my single-family house on Queen's Blvd. have been
demolished and multi -unit buildings have been, or are being erected.
A 4 -unit building at 1080-1082 Queen's Blvd. has been completed for
just over a year and has tenants in all units; it was constructed by a
long-established K -W builder whose design and footprint harmonizes
well with the block. A 3 -unit development on the other side of my
property at 1092 Queen's Blvd. is still under construction by first-time
developers due to delays caused by Ministry of Labour violations and
other issues. The 1092 development has caused multiple incidents of
damage and/or disruption to my property and apparent changes in
design have resulted in a higher building that comes much closer to
my property line than was originally told to me; the height of the
building will partially block my solar collector array and reduce my
income from it. In principle, I am in support of mindful and appropriate
urban infill construction, in order to reduce spread onto agricultural
land and to keep city residents close enough to services and
amenities. But I also feel that builders should be more considerate of
their existing neighbours and to build at quality standards that are
sustainable over a generation or two rather than trying to make fast
profits out of our housing shortage. I will continue to live in my single-
family dwelling, where I've lived since 1974 but there has been more
negative than positive outcomes during the construction period and I
won't know for sure how much impact these projects will have on me
until all the construction is completed.
Screen Name Redacted I live in an older neighbourhood with many modest single-family and
2/04/2024 08:21 PM semi-detached homes - the kind of places young people used to buy
as starter homes or lived in for decades while they raised their
children then aged in place before downsizing or passing away. Over
the past few years, however, many of these houses have been
bought by investors and turned into duplexes for rent. On the surface,
this seems great. People need to live somewhere and this increases
Page 6 of 69
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
housing s oc , rightY. In reality this has Changed a neighborhood
and not necessarily for the better. While some landlords and tenants
are conscientious, generally you can tell which addresses are owned
by absentee landlords looking to maximize profits and keep costs low.
Some places are now housing for foreign students who come and go.
Property standards have declined and I don't see the city doing much
to address this. I don't necessarily blame the tenants as it is not their
responsibility to mow lawns, clear snow, maintain structures, etc.
They are not the owner. I fear the drive to add ever more units on
existing lots will only worsen this situation,. I believe this initiative
really does nothing to address the root causes of the housing crisis.
In an environment with no rent controls, where only the rich can
afford to buy and renovate houses to turn into multi -unit rentals, how
will this help build affordable housing and livable communities? How
will more one -bedroom units and studios in basements and garages
help families with children? The number of housing units might
increase, but so will the greed of speculators who have the most to
gain from this. In the virtual neighbourhood meeting someone asked if
the 4 unit initiative would have a pilot project and the answer was no.
also noted a slide in the presentation that showed the very small
percentage of lots in the city that currently have 2 or 3 housing units
on them. Shouldn't you consider encouraging growth of 2 units first
and examining the impact of this before jumping to allowing 4 units
on lots that were never designed for that type of housing density?
Maybe we need to start asking why we always need to be striving for
growth in this city (or on this planet) when we don't have the social
and environmental infrastructure to sustain it. Maybe we need to be
slowing things down, not accelerating, at least in the short to medium
term until we can, hopefully, achieve some balance. I have to say I
am tired of having my concerns labelled as selfish NIMBYism. Worse
yet, anti -immigrant. I am against unsustainable growth and the
commodification of housing in this country. I feel like the city is only
listening to some interested parties in this, like self-serving
developers and naive social activists. You are focused on zoning and
number of units and more, more, more as fast as possible. You talk
about the "missing middle" like you have found a magic bullet to a
very complex problem. Also, I work hard to keep and maintain the
home I own and the quality of life I enjoy on my property in a
community I care about. I won't apologise for worrying about my
property value if my neighbour (an absentee landlord) decides to
build a monster home on the other side of my fence. My opinion also
matters. Many others share it.
Optional question (24 response(s), 56 skipped)
Question type: Essay Question
Page 7 of 69 Page 148 of 343
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
Q3 Tell us about your experience living in a home with 2 to 4 units on the property. Please
share both positive and negative experiences.
Screen Name Redacted blah
1/23/2024 09:35 AM
Screen Name Redacted We share the basement of our bungalow and are thankful we can
1/23/2024 05:-,:,.'— share the space and the bills!
Screen Name Redacted Done properly it's a positive experience. The property owner gets
cashf!ow and underutilized spaces serve a purpose in the
neighborhood.
Screen Name Redacted Unfortunately I live on a busy road (Frederick) but otherwise I really
enjoy the Central Frederick neighbourhood, especially living so close
to many amenities.
Screen Name Redacted It's a much better use of land and ensures there are more rental units
1/29/2024 05:05 PM available in my neighbourhood. It can also help people afford their
own homes if there are additional units whose rent can help offset
mortgage costs and taxes.
Screen Name Redacted I own and live in a triplex so have people above and below me. This
1/30/2024 12:04 PM has been a positive experience for the past two decades, especially
during Covid when we spent a lot more time in our backyard as a
community.
Optional question (6 response(s), 74 skipped)
Question type: Essay Question
Page 8 of 69 Page 149 of 343
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
Q4 In your opinion, what do we need to consider in zoning to better enable development of
Additional Dwelling Units (ADUs)?
Screen Name Redacted Parking and landscaping requirements.
1/24/2024 07:05 AM
Screen Name Redacted The reason we scrapped our plan to build an ADU at 604 Guelph St
1/25/202411:07 AM was the absolutely ridiculous requirements for set -backs AND the
requirements for additional walk -ways in addition to the driveway
space i.e. driveway cannot be used as a walkway. We felt we were
entirely up against a brick wall, so decided it wasn't worth the
hassle/expense/time. No one in the planning/building department
seemed willing to think critically/actually work with us to find a good
solution forwards. Such a frustrating process! Our property is
MASSIVE half an acre so is a prime candidate for extra units.. and
yet... nope.
Screen Name Redacted Streamline the process. I've tried to build an Adu around 2021/2022 -
"" /2024 12:42 PM there is way too much bureaucracy in the process. The current
approach is not solution orientated. The process is laden with
irrelevant property criteria when the goal is to build housing Units.
The government needs to get out of the way and let developers do
what is economically viable
Optional question (3 response(s), 77 skipped)
Question type: Essay Question
05 In your opinion, should properties with 2 to 4 units be required to have parking? Why or
why not?
Screen Name Redacted
1/2J/2024 01:4J f fVI
Screen Name Redacted
1/22/2024 05:45 PM
Page 9 of 69
Parking should be required unless the property is very close to a
main transit point, something like less than a 5 minute walk to a
transit stop with a service frequency of 30 minutes or less. Street
parking is not preferred since streets are public goods and should not
be the default option for temporarily storing, i.e. parking, private
vehicles.
Yes. Most people have cars in subdivisions. No if near transit
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
Screen Name Redacted The occupants simply park on the street if parking is not provided
1/22/2024 11:52 PM with the unit ... with cars constantly on the street it impedes garbage
pickup, snow clearing etc.
Screen Name Redacted Absolutely. Intensifying the number of families on a street means an
1/23/2024 09:02 AM increase in the number of cars. Some families can have 2+ cars per
family and that doesn't even take visitors into consideration. They
can't all park on the street and doing so would negatively affect the
existing residents. Where would these units park during a snow
event? How do you ensure you're keeping roads and sidewalks safe
for existing residents? Even 4 couples living in 4 units could mean an
extra 8 vehicles with all the extra journeys they would bring.
Screen Name Redacted blah
Screen Name Redacted Dfg
1/23/2024 11:11 AM
Screen Name Redacted Yes. People need accommodation and is affordable.
1/23/2024 04:26 PM
Screen Name Redacted Not required. Some people are willing to forego a parking space for
1/23/2024 05:43 PM lower rent and this should be accommodated. We have lots of
transportation options available outside of owning a car.
Screen Name Redacted No parking required; takes a lot of space and there's no reason to
1/23/2024 07:25 PM require it if someone doesn't want it
Screen Name Redacted Yes, and parking should be planned such that properties do not
1/24/2024 07:05 AM become fully paved with parking lots. We need to give consideration
to neighbours who do not want renters in homes surrounding them.
Screen Name Redacted Maybe not for 2 units but any more should require 1 parking spot per
1/24iLW4 U6.23 Ai✓i unit
Screen Name Redacted If properties are within a 5-10 minute walk of a Light Rail Station, or
similarly -critical transit option (which GRT buses may not be), they
should not, or landlords should need to provide a realistic, alternate
parking plan. If properties are farther away than this, occupants most -
likely require* motorized vehicles to get to work, get groceries, drop
343
Page 10 of 69 Page 15 !—Uf
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
off at schools or daycare, etc. Those vehicles would need to be
stored somewhere, and if not in the driveways (or parking lots), of the
properties, they will be parked on the streetside, at the ends of cul-
de-sacs, or in other areas that frustrate other residents. I think this
could generate more pushback for the *perceived* challenges it
poses, from residents who have concerns already. *: it could be
argued that bicycle or e -bike transportation is a viable alternative to
owning a car, but as a 4 -seasons cyclist, I do not believe that this is
currently true or feasible for any areas beyond the catchment areas of
the Iron Horse and Spurline trails. One additional candidate would be
the Homer Watson Multi -Use trail, but from my understanding it's not
sufficiently connected to the downtown core or enough other places
of work.
Screen Name Redacted ***Clarification to my submission from 12:50pm, Wed Jan 24th ****
saw in my response that I'd written that "if properties are within 5-10
mins, they should not require parking, or the landlord provides a
viable alternative..." The landlord -provided alternative was meant to
apply to properties that SHOULD require parking, not ones that
should not.
Screen Name Redacted Absolutely not. Many folks don't have a car, particularly those on
transit lines/in more walk-able/bike-able areas. The parking
requirement is 100% old-fashioned and is purely to appease NIMBY-
ers who don't want cars parked on the street. Rely on appropriate
street parking by-laws and move on. We don't want to encourage car -
centric living.
Screen Name Redacted No. Let the owner/developer decide parking requirements. Mandating
parking is short sighted and counter productive of what intensification
beings to a community.
Screen Name Redacted In areas close to frequent transit I think this should be optional,
1/25/2024 03:48 PM otherwise I believe spot per unit should be required. Those required
spots should be designed with an available EV charging port if the
intent of the ADU is to be rented.
Screen Name Redacted yes-- in a non -walkable area car is essential
1/28/2024 08:28 AM
Screen Name Redacted Yes and no. There should be some parking options available for these
types of residences, whether that's on site, or on street. However, I
don't feel every unit needs parking. We should transition to less
343
Pagel 1 of 69 Page 15
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 06 February 2024
parking as a model for development with strong public transit and
walkable neighbourhoods. But we also need to recognize some
people in these unit will need to travel to location not easily
accessible by foot or transit (or bicycle). So, therefore, some parking,
but not parking to cover all units is a good balance I think.
Screen Name Redacted It is OK to park on city streets for unlimited time in residential areas
1/29/2024 10:08 AM (except in snow emergencies which could be done on the odd
numbered side of streets followed by even numbered side of streets
Screen Name Redacted NO. The tax revenue from these units should go towards our public
1/29/2024 10:12 AM transportation, bike and pedestrian infrastructure. We NEED to
encourage less car dependency and having less parking is a way to
force this.
Screen Name Redacted Parking requirements should match those of other dwellings in the
1/29/2024 10:16 AM neighbourhoods. Dwellings in suburban areas will require parking to
be functional for the tenants, whereas downtown dwellings may not.
Screen Name Redacted Yes and no. It's a tough balance, because if the tenants do not
1/29/2024 10:' > ;- > drive/do not have cars there is wasted space if there is a minimum
parking requirement. Conversely, if there is little to no minimum
parking requirement but all the tenants have cars, there may be
impacts on the surrounding streets. I like the option of not having
parking minimums so more homes/properties can be easily retrofitted
without the potential barrier of providing parking, but then this might
mean more leniency with on -street parking by-laws, may need to
establish more street permits throughout the city.
Screen Name Redacted yes. Otherwise we will end up with vehicles parked on front lawns,
1/29/2024 10:22 AM boulevards and sidewalks more than they do now.
Screen Name Redacted Yes . Adequate parking is essential at 1 car per sleeping unit.
1/29/2024 11:18 AM Currently a detached home usually has up to 2 parking spots per
house to a max. of 4 for a double car driveway at double depth.
Additional occupancy rentals means additional car(s) parked on the
street not withstanding seasonal parking restrictions/ bad weather
restrictions.
Screen Name Redacted Yes, I think parking in a must. My concern is the front yards are being
1/29/2024 11:23 AM used as a parking lot. So much for drainage. I thought there was a
Page 12 of 69
Page 153 of 343
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
yaw regarding how much property can be pare on'? in is will
make neighbour hoods look like trash city!
Screen Name Redacted There should be no parking minimums for adding more units to an
1/29/2024 11:24 AM existing property. Parking minimums artificially subsidize parking
spaces and driving since they represent a floor on the available space
for cars. Housing is the least free of all markets and we need to stop
artificially distorting it as much as we can. One of the best ways to do
that is to stop having parking minimums. Making housing available
that doesn't automatically come with parking is a great way to offer
lower price tiers of housing. Not everyone needs or wants to drive
Screen Name Redacted
Screen Name Redacted
1/29/2024 12:19 PM
Screen Name Redacted
1/29/2024 12:35 PM
Screen Name Redacted
1/29/2024 12:45 PM
Screen Name Redacted
1/29/2024 01:12 PM
Page 13 of 69
and should be able to acquire housing that doesn't have parking so
they can maximize the savings of going car free. Those who choose
to drive should pay more for housing that has parking associated. If
people building additional units want to include parking because they
think it will attract higher rents they should be free to do so. If people
want to skip some or all parking to get a 4th unit in instead of 3 they
should be free to do that. The city should not impose a minimum the
forces everyone to make the same choice.
Absolutely. Street parking, particularity in subdivisions, is already a
serious problem. The crowded streets are dangerous.
don't think they should be required to have parking, because that
further encourages car -dependent urban development. The city
should think about what infrastructure changes are needed to reduce
car -dependency (think walkable cities), and commit to supporting and
investing in such infrastructure in neighborhoods most likely to be
impacted by the 4 -units project. The landlord can consider parking,
but it shouldn't be a requirement.
Absolutely, look at green valley drive, even in the winter when parking
is not allowed. Stiil and overflow of vehicles, why is that? Why not
tow them so they get the message.
They should not be permitted in existing neighbourhoods. If they were
then each until should have parking. The streets are narrow and
residents should not be further impacted by having multiple vehicles
parked on the streets.
Yes parking is required. We are not yet with technology that will
change this requirement.
Page 154 of 343
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
Screen Name Redacted I think that such requirements should exist, if anywhere, only where
1/29/2024 02.. PM the area is not well -served by the transit or active transportation
network and where staff believe excessive amounts of on -street
parking are likely to result. If in doubt, it should be left to the property
owner to determine whether including parking on their property is
necessary to attract a tenant or otherwise make the additional unit
useful.
Screen Name Redacted Yes, Waterloo Region does not score high on walkability and transit
1/29/2024 02:55 PM can be very inconvenient outside of a few core areas (and I say this
as someone who exclusively takes transit and walks). Many people
need to drive to their places of work, appointments, etc. Also, the city
of Kitchener does not allow street parking during the winter, so if
someone was living in a unit without parking and had a car - what
would be their options? Every unit should have at least one parking
spot required.
Screen Name Redacted No. If people require parking, they will simply choose a rental unit that
1/29/2024 03:16 PM offers parking. Parking adds a cost to the construction of units, and
often looks terrible (esp. when there is more of it). The City and
Region have long-term plans for a more sustainable city, and it seems
that parking minimums are at odds with these plans.
Screen Name Redacted No, parking is a luxury. However, there needs to be enforcement on
1/29/2024 03:30 PM. the number of vehicles parked and where they are parked. Having
multiple units on a property isn't the only reason for excessive
vehicles, I live next door to a single detached where one person lives
and he has 5 vehicles parked on his property. Bylaws restricting
parking are what is required, a person renting a unit without parking
should know that going in and plan to use public transit/other means.
Screen Name Redacted Yes. If parking is not required, streets will become unsafe because of
vehicles parked on streets, etc. In addition, only streets with
sidewalks on both sides should be considered for 4 units to keep
pedestrians safe.
Screen Name Redacted Definitely not. First off, parking minimums are something we should
be moving away from, they increase the cost of homes that might not
need them and fly in the face of the city and region's plans for more
walkable communities. Most importantly, for 2-4 unit infill, parking
minimums (when combined with existing regulations like setbacks)
will just end up disqualifying many properties that would have been a
Page 14 of 69
Page 155 of 343
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
great tit. It adding units to a lot requires adding parking, and there's
no economical way to add both units and parking without running
afoul of other bylaws, then these additional units won't get built at all.
Screen Name Redacted That is a tricky question. If there is insufficient parking, the street gets
1/29/2024 03:57 PM crowded with cars. But Greater restrictions on street parking will be a
problem for everyone. Ideally, people will take transit or walk more.
But I have a car and my own parking. That is a huge privilege.
Screen Name Redacted yes but minimal
1/29
Screen Name Redacted Depends how close they are to transit routes. Closer they are to
1/29/2024 05:05 PM Transit, the less a parking space is required.
Screen Name Redacted I don't believe that there is a "one size fits all" answer to this question,
1/29/2024 05:05 PM since the number of parking spots is dictated by lot size, road access
& traffic implications, site drainage, damage to the tree canopy
required to meet parking requirements, and easements & utilities
access / piping.
Screen Name Redacted if they do there needs to be ample driveway space for winter parking
1/29/202405:11 PM
Screen Name Redacted Yes. I live on a street with narrower lots and the road is always full of
1/29/2024 06:10 PM parked cars which in my opinion is a safety issue. Not have parking
on the lots with multiple units would increase the amount of street
parking.
Screen Name Redacted Yes absolutely! Most of the 2 dwellings in our area have at least 4
1/29/2024 06:28 PM cars some of them 5 cars which causes renters parking on the front
lawn as well as cars spilling out into the streets. Need for parking has
dramatically increased I our neighbourhood as current public transport
system is not adequate. I support higher density living but I would
also like for there to be governance requiring land owners to provide
enough parking for their renters. Ideally we also increase
infrastructure for public transit but I understand that will take a longer
time to improve. Basic parking requirements would be good interim
fix.
Screen Name Redacted
Page 15 of 69
YES. We are already dealing with cars parked on boulevards on the
Page 156 of 343
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
1/29/2024 08:24 PM road on the grass of the property.
Screen Name Redacted Yes I think these building need to require parking otherwise the
1/29/2024 08:56 PM neighbours will be affected by cars parked on lawns, partially in front
of their driveway which is happening all too often now.
Screen Name Redacted I think it should be up to the owner and how close the property is to
1,29/2624 09:Oti Hivi bus stops/transit, and of course the layout that best maximizes the
land to keep it functional and fitting in with the neighborhood
Screen Name Redacted Parking must be included, we cannot become another GTA ,
1/29/2024 09:03 PM Mississauga on street parking twenty four seven. Including
commercial trucks
Screen Name Redacted Yes to having off street parking. Otherwise, road become congested
1/29/2024 09:35 PM with parked cars.
Screen Name Redacted No requirement. If the lot can support some parking, then that can be
1/30/2024 06:12 AM the homeowner/developer's prerogative to add or not. Otherwise,
requiring parking can be the difference between a lot being able to
support additional units or not. Parking takes up SO MUCH surface
area on lots. It's unlikely many lots in Kitchener can support 1:1
parking ratio, stormwater requirements, landscaping, and maybe a
tree plus setbacks. I also think, if you require parking, it's going to
push people to only consider adding more units if it's new
development. This should be also be encouraging to folks who
don't/can't afford to tear down, but work with the existing building
they've got! Additions, ADUs, etc. This is a no brainer to me. Remove
parking requirements.
Screen Name Redacted Depends on location and proximity to public transit. Parking should be
1/30/2024 07:39 AM available in residential neighbourhoods. Lang Cres is a good
example of large lots that could accommodate increasing the number
of units/dwellings. There are no sidewalks on Lang Cres. Adding
more cars to street parking would make walking there more
dangerous and more difficult for snow removal.
Screen Name Redacted Yes, particularly in suburban areas where cars are, and will continue
1/30/2024 08:12 AM to be, the primary means of transportation.
343
Page 16 of 69
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
Screen Name Redacted I would really prefer to not require parking, but that might just push
1/30/2024 08:28 AM parking out onto the street. I'd really like to see more investment in
public transit and the walkability/bikeability of neighbourhoods, so that
it's more viable to not need a car. In that kind of neighbourhood, I'd
definitely like to do away with requiring parking.
Screen Name Redacted Yes, because even though the ministry wants to "go green" this
1/30/2024 09:00 AM municipalities transit is not great, everyone knows if you live here you
need a vehicle to get anywhere timely.
Screen Name Redacted Properties with 2-4 units should not be required to have parking for
1/30/2024 09:23 AM each unit if they are on a transit line (bus or ION). A unit without
parking would need to be marketed as such, and would be at a
disadvantage. Forcing a requirement for parking spaces which may
not be used is adding an additional layer of complexity and reducing
space which could be utilized for dwelling or green space on a lot.
Screen Name Redacted Yes parking should be a definite requirement for any conversion of
property use, one space minimum per unit for additional units added.
On street parking always generates complaints and abuse, the reality
of expecting those to 'reduce' their car use is not always achievable.
Our area is rapidly growing and access is a primary generator of new
residents here, if we had all amenities and work places walkable
distance this may change but not realistic. With Ontario such a large
province, to get anywhere you need to literally drive there out of town,
so the focus should not always be 'public transit, walking and cycling'
there is more than just local in this world.
Screen Name Redacted ABSOLUTELY!!!!
1/30/2024 10:43 AM
Screen Name Redacted No they shouldn't. In my triplex, over the years there have been times
'/30/2024 12:04 ri'Vi that I am the only one with a vehicle -- the other two units ride
bicycles. I put up a secure bike shed so they could store their
bicycles. I have had tenant applicants who have requested for two
parking spaces which I have refused because I don't have the parking
space. We need to encourage more reliance on public transit, walking
and bicycling.
Screen Name Redacted Yes, because parking on the street creates hazards for children. I am
on Huber Street and it seems to be used as a high speed short cut.
Page 17 of 69
-Page-1-58-of 343
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
Screen Name Redacted No because lots of people can't afford a car - requiring parking
1/30/2024 02:18 PM increases costs but may not benefit them. We do need good parking
enforcement so that streets don't become difficult to navigate due to
illegally parked vehicles
Screen Name Redacted Yes. Likely renters will work across the region or beyond and public
1/30/2024 04:55 PM transit is not meeting that need. But I would not make it a deal
breaker.
Screen Name Redacted Yes! It is already challenging during the winter months to drive down
1/30/2024 05:23 PM streets that are full of parked vehicles. It becomes a safety issue for
pedestrians and for the ability of plows to do a proper job. It clogs up
streets for EMS and Fire. They can barely get dawn our street where
there is a group home that often has staff parked on the street. Plows
and garbage trucks have had to back out of our street.
Screen Name Redacted Depends on distance to local transit. However, one parking spot per
1/30/2024 07:42 PM unit - on average, should be adequate.
Screen Name Redacted Yes, so the streets won't be full of parked cars
1/30/2024 08: - PM
Screen Name Redacted Yes, parking should be available for all units. In addition, street
1/30/2024 09:31 PM parking should be carefully monitored and enforced by bylaw officers.
Street parking should not be considered a permanent parking solution
for rental units. Street parking should never be allowed overnight in
the winter.
Screen Name Redacted No, parking should be provided at market rates. Tenants who do not
1/31/2024 08:51 AM use it shouldn't be forced to pay 500$/mo for it, which is what is
currently happening.
Screen Name Redacted No, there are many residents who do not need to make use of a car.
1/31/2024 12:49 PM The city and region have invested in improving active transport and
transit and should encourage densification in neighbourhoods located
near employment and amenities. Concerns raised about street
parking can be addressed through better street design and
enforcement. Our household of 4 has a single car and uses e -bikes
and transit to fill as many trips as possible. This can be the case for
others. An excess of parking would actually make me less interested
in 2-4 unit housing, as I would prefer properties with room for natural
yards or simply more housing space.
Page 18 of 69
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 06 February 2024
Screen Name Redacted Yes they should be required to have parking. In the winter when there
is a snow event where would these cars be parked if the properties
did not have parking. The street is for guests to park not people living
in properties. The streets would be too crowded if parking was not
mandatory.
Screen Name Redacted Absolutely, their should be at least one space per residential unit. In
the suburbs, public transportation is not enough, one needs a car.
Mostly, everyone needs a car in Canada. Distances too great and
general lack of public transportation. Need for parking is a major
issue in itself which city development planners are totally ignoring.
Developers love city staff, they save at least $60,000 per space
which goes directly into their pockets.
Screen Name Redacted Parking should not be required, IF transit options can be sufficient to
meet demand.
Screen Name Redactea In my view, the requirement for properties with 2 to 4 units to have
parking is unnecessary and could be reconsidered. This opinion is
based on two primary reasons. First and foremost, there seems to be
no justifiable reason for imposing such a requirement, especially
when considering the existence of other regulations such as minimum
lot size, walkway requirements, and maximum lot coverages. These
existing measures already address concerns related to space,
accessibility, and overall lot usage. Secondly, the current parking
requirement has led to the need for numerous minor variances. This
suggests that the regulation imposes an unnecessary burden,
particularly on smaller lots in downtown areas where the
development of properties with 2 to 4 units is often desirable. The
variances indicate that the existing parking requirement may not align
with the practicalities and needs of these specific locations.
Therefore, I believe it would be beneficial to reevaluate the necessity
of mandating parking for properties with 2 to 4 units, considering the
redundancy of the current provision and its potential hindrance to
desirable developments, especially in smaller lots near downtown
areas.
Screen Name Redacted They should either have no parking space required, or parking for up
to half the units, especially when these properties are located within
easy reach of public transit, street parking or city lots.
Page 19 of 69
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
Screen Name Redacted Yes, the properties should have to prove that they have enough
2/03/2024 03:58 PM driveway space for parking for each unit. Because if not, there will be
a huge influx of people parking on the streets in these neighborhoods.
This is concerning because increased street parking creates difficulty
with clearing snow, and increases danger for bikers and pedestrians.
It decreases visibility for drivers which could result in bikers and
pedestrians getting hit.
Screen Name Redacted Only two unit properties should have parking and that parking should
2/04/2024 08:21 PM be limited in size. Aren't we supposed to be promoting public transit
use and active transportation? I see even single unit properties
expanding driveways (legally and otherwise) to accommodate more
and larger vehicles - everyone who can drive has a car, SUV and/or
truck, plus maybe a trailer, camper or boat. The more units are added
to a property, the more potential vehicle users are being added. Too
many streets are beginning to look like parking lots as it is. It's
especially bad when street parking is allowed. People park their
vehicles on the road (legally and otherwise) while the driveways are
empty.
Optional question (74 response(s), 6 skipped)
Question type: Essay Question
Q6 What opportunities and benefits do you see as more properties include up to 4 units in
our community?
Screen Name Redacted It is critically important to challenge the need for or inevitability of
1/21/2024 01:43 PM continual growth. Gentle intensification of residential areas has to be
preferred over intensive, i.e. high-rise, developments or low-density
sprawl that destroys essential and irreplaceable farmland and natural
areas. It may also be a way of keeping at least some of the rental
housing stock out of the hands of greedy real estate trusts.
Screen Name Redacted None whatsoever. Kitchener is turning into no plan of where larger
1/22/2024 05:45 PM homes are going to go. You can't just change an existing
neighborhood with no consideration to the existing neighbours who
are tax payers. Maybe we are as big as we are supposed to be.
People that live in Owen sound have had almost no growth and very
little good farm land
Screen Name Redacted
1/22/2024 11:52 PM
Page 20 of 69
More intense neighbourhoods resulting in additional retail and more
"eyes on the street" resulting in a safer community.
Page 161 of 343
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
Screen Name Redacted
1/23/2024 09:02 AM
Screen Name Redacted
1/23/2024 09:35 AM
Screen Name Redacted
1/23/2024 11:11 AM
Screen Name Redacted
don't think it's beneficial at all
blah
M•
Community housing
Screen Name Redacted Homes are expensive. This can help spread the cost. Aging parents
1/23/2024 05:43 PM can have a place to stay close to family. Helps add density without
sprawl.
Screen Name Redacted More housing for people
1/23/2024 07:25 PM
Screen Name Redacted Very few, honestly. We already allow ADUs in most properties; 1
1/24/2024 07:05 AM believe increasing to 4 per property is a mistake. Properties will
become poorly managed and maintained and will become all parking
and hardscape. I do not support 4 per property.
Screen Name Redacted 1. Reduced costs of rent & housing prices via increased supply
1/24/2024 12:50 PM of rental units, and increased income opportunities for current or
aspiring homeowners 2. Increased densification, and reduced growth
of suburban sprawl, which can (ideally): -- reduce the City's long-term
cost per resident for utilities and infrastructure -- allow more people
and families to live their lives while relying on 1 (or ideally zero!) cars
-- keep more viable farmland in Waterloo Region, which is not simply
a Subdivision -in -Waiting
Screen Name Redacted More affordability, multi -generational living, supportive living for family
1/25/2024 11:07 AM with disabilities, seniors being able to stay in their homes/stay with
family (out of retirement homes), more options for consumers, more
vibrant communities, gentle intensification, getting away from urban
sprawl. Honestly the list is never ending...
Screen Name Redacted A more diverse group of inhabitants.
Page 21 of 69
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 06 February 2024
1/25/2024 12:42 PM
Screen Name Redacted Creating more middle density areas will improve use of existing
1/25/2024 03:48 PM municipal services, and obviously create more housing. Transit and
active transportation will be used more in denser areas and therefore
hopefully regional transit and active transportation will improve (with
regards to frequency and infrastructure) as more usage increases.
Screen Name Redacted wealth transfer, get rich quick schemes
-1/28/2024 08:28 AM
Screen Name Redacted I would imagine local small business would benefit from more
1/28/2024 10:27 AM residents in proximity. There would also be less demand on
expanding out so we can preserve the excellent farm lands in the
region as well as natural spaces. Could also benefit schools if more
families could live closer to schools and less buses are needed.
Could also provide opportunities to include affordable rental housing,
and disperse renters around the city rather than concentrating them in
specific areas. One note, I think of older neighbourhoods in the city
(think Central Frederick, Auditorium, etc), where small apartment
complexes are a common sight mixed into quite back streets without
any disruption or concerns. So I don't see how these 2-4 unites being
proposed would significantly different, while offering more density to
our growing city.
Screen Name Redacted Provide much needed housing. Provide housing for increased
1/29/2024 10:08 AM population growth. save farm land
Screen Name Redacted More available housing, no sprawl, better usage of existing
1/29/2024 10:12 AM infrastructure
Screen Name Redacted Increased density leading to lower housing costs and more
1/29/2024 10:16 AM sustainable development.
Screen Name Redacted Diversity/range of housing types. Able to house more people and
1/29/2024 10:18 AM. potentially lower rent because of increased supply. More people get
to live in low-rise neighbourhoods or wherever they want, as opposed
to the only option being dense, high-rise areas .
Screen Name Redacted great for investors and speculators not good for resident owners
1/29/2024 10:22 AM
Page 22 of 69
Page 163 of 343
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
Screen Name Redacted 3 units is detrimentel to housing in my area but 4 units would be
CATASTROPHIC in areas of detached homes. Single high value
housing areasdon't seem to be underattack as other neighbourhoods.
Screen Name Redacted I really do not not see any opportunities or benefits to putting up to 4
units on a property. I can not believe that the city is allowing this, is
our drainage going to be affected, how will our sewers handle from a
single family dwelling to a 4 unit dwelling?
Screen Name Redacted There is a huge opportunity to add infill density without radically
altering neighbourhoods and 4 units per lot is a great way to do that.
We do need to be far more flexible with the height and setback
requirements than the existing 3 unit requirements. I looked into
building an ADU with an architecture firm and the size limits made it
basically impossible. The resulting unit would be so small that no one
would want to live in it. My lot should be perfect for an ADU. I live on
a busy street (Lancaster) within 20m of a bus stop. My backyard is a
a blank wall of an apartment building (no windows). And yet the
current rules are so restrictive it makes no sense for me to invest in
an additional unit. Setbacks need to be flexible and allowed to
smaller with various methods to increase fire resistance. Building
heights need to allow for actual practical living units, not 320 sq ft
prison cells. Variances to adapt to the specific lot and situation need
to switch from needing to prove the case to being permitted by
default unless someone directly affected can demonstrate a material
issue. Finally only directly adjoining neighbours should be able to
object to plans, with a prescribed adjudication/mediation method and
standard compensation for disruption. The rules should also
incorporate Transit Oriented Development, with lots near existing
transit routes given more leeway on setbacks and heights.
Screen Name Redacted This will create some housing opportunities, but it is very short-
sighted and the cons far outweigh the benefits.
Screen Name Redacted Increased financial value from the same amount of land. Potential for
more affordable housing and supply reduces demand.
Screen Name Redacted The post secondary institutions can then bring in more students to
increase their revenue. No jobs, no housing, but hey, they get money
and that is what it is all about.
Screen Name Redacted This will benefit contractors and real estate developers and harm
343
Page 23 of 69 Page 164 u
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
1/29/2024 12:45 PM communities by increasing density.
Screen Name Redacted Yes many changes will happen, financial gain for many that buy and
1/29/2024 01:12 PM change land use, overall for people that want to live in nice
neighbourhoods with great neighbours will loose that ability
Screen Name Redacted Including more of these units has the potential to add much-needed
1/29/2024 02:01 PM housing supply relatively quickly, without requiring a massive
expansion of the urban boundary, street grid, or other municipal
services. This increased density might also make more frequent
transit service, more density of service and retail businesses, etc.
viable, especially for neighborhoods near the downtown core or
transit spine. These additional units are likely to, like multiple -dwelling
housing in general, have less of an adverse effect on both
environmental impact (e.g., CO2 emissions) and the cost of providing
city services.
Screen Name Redacted I like the idea of neighbours and community that would come with this
1/29/2024 02:55 PM kind of living. Also, we need more housing and quickly! I feel like
many property owners, not just developers, may be interested in
turning their properties into 3-4 units. We need more smaller
apartments to drive down the unattainable price of bachelor and 1 -
bedroom apartments in the city.
Screen Name Redacted More neighbours. I'll add that I'd like to see commercial units
~9/2024 03:16 PM permitting in more locations, so that more neighbourhoods contain
more amenities.
Screen Name Redacted Better land use, increased ridership on transit, less urban sprawl.
Increased amenities in the down town to serve increased residents.
Screen Name Redacted Poor urban planning by the city is being dumped on home owners so
1/29/2024 03:44 PM the only benefit is to the city.
Screen Name Redacted We have so many great, walkable neighbourhoods - particularly in
1/29/2024 03:51 PM the core - with old 2-4 unit buildings that are now illegal to make
today. This city desperately needs infill, particularly small size,
missing middle stuff. Allowing for these units to be built will increase
overall housing stock, lowering prices, rents, and helping to address
homelessness in the region. Additionally, if we only allow MDUs in the
form of condo towers, family sized units will continue to dwindle in
Page 24 of 69 Page 165 of 343
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
number. I hatwill continue to push young families out of Kitchener
entirely. Denser infill also makes for better neighbourhoods that have
lower per -family infrastructure costs and a lower carbon footprint.
Screen Name Redacted More neighbours, diversity, perhaps more amenities to support the
1/29/2024 03:57 PM increased population, better transit service.
Screen Name Redacted more affordable housing and density
l%29/2U24 04.jd FIVI
Screen Name Redacted It's a much better use of land and ensures there are more rental units
1/29/2024 05:05 PM available in my neighbourhood. It can also help people afford their
own homes if there are additional units whose rent can help offset
mortgage costs and taxes.
Screen Name Redacted I think that the theory is that higher densification of properties will
1/29/2024 05:05 PM provide for more homes at (presumably?) lower or more affordable
rates. While I can see this being the case for "new builds", it's not
clear to me that adjusting pre-existing neighbourhoods is a wise
choice for our city.
Screen Name Redacted I don't see any benefits other than increasing the housing availability.
1/29/202406:10 PM
Screen Name Redacted Ideally this will force street and public transport infrastructure to
1/29/2024 06:28 PM improve as there will be more traffic and higher population density. I
would like to see more pedestrian only or pedestrian/bike only routes
in downtown kitchener. Increase in population density will hopefully
bring more businesses to the area and improve economy. Increase in
population density will hopefully bring more art and cultural events to
the area Increase in units will hopefully broaden the range of
affordable units. Especially adding units minimum wage workers can
afford ($2650 pay a month for minimum wage means units should
ideally be max $900 a month to be affordable)
Screen Name Redacted Easier to have access to amenities without having to drive.
1/29/2024 07:18 PM
Screen Name Redacted none- our community was never designed for this methodology!
1/29/2024 08:24 PU
343
Page 25 of 69 Page -166 of
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February
Screen Name Redacted I don't see the benefits squeezing more people in places that had
1/29/2024 08:56 PM often at the most five people including children. Now I am seeing new
Canadians with 12 people in a house. This affects the neighbour and
not for the better.
Screen Name Redacted Fewer highrises that bring it more congestion, affect bird migration
1/29/2024 09:00 PM and the flight path, not to mention the shadow impacts. Many old
properties have huge backyards and front yards, if we allow for
additional houses, with the same height on the property, it would
definitely help. Maybe there should be incentives for people to build.
Kind of like the first time homebuyers where u can use RRSPs for
financing or something like that.
Screen Name Redacted These units will only lead to a more inclusive and viable city and it's
1/29/2024 Uy).W FUi neighborhood
Screen Name Redacted Provision of more rental properties.
1/29/2024 09:35 PM
Screen Name Redacted Neighbourhoods will still feel and look like neighbourhoods. Allows
1/30/2024 06:12 AM homeowners to have multi generational living or act as a mortgage
helper. In theory it can democratize housing development.
Screen Name Redacted It may, in time, reduce rental costs due to increased availability. It will
1/30/2024 08:12 AM also help offset ongoing purchase costs by allowing for an additional
revenue stream. It is also an opportunity for older adults to age in
place by developing shared accommodation with family members.
Screen Name Redacted
1/30/2024 08:28 AM
Screen Name Redacted
1/30/2024 09:00 AM
Screen Name Redacted
1/30/2024 09:25 AM
Page 26 of 69
like seeing more density, particularly in existing neighbourhoods that
only have single family homes. This allows more people to live in
areas close to existing downtown/uptown areas instead of pushing
them to newly built suburbs on the fringes of the region.
Increase housing without additional sprawl. Maximize our housing
within existing neighborhoods and keep people living in the older
areas. Increasing to 4 units will also shift the economics of renovation
and building to a more realistic scenario: input cost of properties is
still high, need to have more units to make the dollars make sense if
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
looking fora i iona intill eve opmen .
Screen Name Redacted I think the tax base for these units should account for these
1/30/2024 09:55 AM enhancements and additional fees reviewed. Opportunities for
community to grow in various areas rather than all in a new area or
highrise DTK condos which are small and not able to accommodate
families. Benefits - community can adjust and center programs
enhanced for our growth and improvements to community
parks/trails/neighbours day expansions to celebrate.
Screen Name Redacted NONE!!!!!!
1/30/2024 10:43 AM
Screen Name Redacted I have a large back yard where I could build/install at least one ADU
1/30/2024 12:04 PM (Accessory Dwelling Unit). If not for City permitting requirements
which add dramatically to cost, I would have built one several years
ago. Why does a 350 sq ft tiny home need to have R40 in the walls
and R60 in the ceiling and be built to the same standards as a new
build? Unless you install an HRV (Heat Recovery Ventilator) the
occupants would be starved of oxygen because the dwelling volume
is so small! This is a dramatic example, but my point is couldn't we
have different regulations for "tiny homes" so they could be built for
less than $150,000-200,000? There are so many creative ways that
could be explored for this category of dwelling so people would be
encouraged to build them and we would actually stand a chance at
achieving our goal of "an additional 35,000 homes by 2031 ". I would
appreciate being part of that conversation.
Screen Name Redacted I see opportunities for absent landlords to pad their pockets, and for
1/30/2024 12:55 PM the city to enlarge its tax base. For the average person, no benefits.
Please don't insult my intelligence with lip service to "affordable
housing " It does not exist on the open market.
Screen Name Redacted More affordable housing, more density so there's better transit
1/30/2024 02:18 P` `°
Screen Name Redacted Lots of community interaction -- neighbourhood BBQs etc.
1/30/2024 04:55 PM
Screen Name Redacted It depends on where this is happening. It is the demise of the sense
-0/2024 05:23 PM of community. Usually units like this are transient in nature. There is
little to no sense of ownership. If these units are on major transit
routes there could be benefits to people have accessibility to
343
Page 27 of 69
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
Screen Name Redacted
1/30/2024 07:42 PM
Screen Name Redacted
1/30/202409:31 PM
Screen Name Redacted
1i,5Ii'2UZ4 UU:31 W,
amenities/work or school, I hese units do not fit into small crescents
or cul de sacs
Decrease the amount of land currently wasted on single home
properties. Will allow friends/family to live close by without living on
top each other 24x7
Potential alleviation of rental housing shortages and reduction of the
high cost of rent.
Increased density means better, more complete, neighbourhoods.
Screen Name Redacted Most critically - faster expansion of the available housing supply and
1/31/2024 12:49 PM densification of the areas surrounding downtown, high density areas.
This is particularly relevant for family scale housing that may not be
easily integrated or marketed for condo developments. When looking
for our home, we would have actively considered well designed and
located multi -residential properties near key transit locations.
Unfortunately, this intermediate form is mostly absent from our
housing stock.
Screen Name Redacted none whatsoever
1/31/2024 08:00 PM
Screen Name Redacted I see no benefit as 3 Plex is more than enough for one property to be
1/31/2024 09:10 PM able to handle. What about garbage for the additional cost units ?
Also with more population growth transportation, health care and
transportation are also strained.
Screen Name Redacted This idea is really not necessary given all the virgin lands still
2/01/2024 10:29 AM available to build on as well as the vacate spots all over the city ie.
former petro locations.
Screen Name Redacted Huge cost savings benefit to those renting, and young families.
2/01/2024 01:52 PM
Screen Name Redacted Expanding the inclusion of up to 4 units in our community presents
2/02/2024 08:30 PM significant opportunities and benefits. As a lifelong resident of
Kitchener, my family and I are keen on contributing to the vitality of
our hometown. After thoughtful consideration of past by-laws, I
Page 28 of 69
Page 169 of 343
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
propose adjustments to the Zoning By-law to foster this aspiration
and extend similar opportunities to others. Eliminating Parking
Minimums: This adjustment allows for more flexibility in property
development. By approving lower parking ratios through 'unbundled'
parking, developers can tailor parking provisions to market demands.
Granting property owners autonomy in deciding whether to provide
parking enhances adaptability, applicable city-wide, not just near LRT
stations. Removing Lot Width Requirement: This step addresses
redundancy in zoning regulations. With minimum lot size, walkway
requirements, and maximum lot coverages already in place, the lot
width stipulation proves unnecessary. Its removal accommodates
diverse developments, particularly in smaller lots near Downtown,
where the current requirement poses an unnecessary burden.
Increasing Building Height to 4 Storeys: Allowing a 4 -storey height
provides enhanced design flexibility, aligning with efficient slab -on -
grade construction. Uniform height for detached ADUs and primary
dwellings supports a cohesive aesthetic and accommodates
developments with up to 4 units. Permitting Units in Front Lot and
Exterior Side Yard: Encouraging more efficient space utilization
contributes to a dynamic and vibrant community landscape, fostering
innovative development patterns. Seeking Justification for the 1.1 m
Walkway Requirement: Addressing this requirement is crucial,
especially in older neighborhoods near Downtown. Requesting real-
world analysis and engaging in a neighborhood walk with staff helps
understand the implications and align this regulation with practical
considerations. Removing the 50% Building Floor Area Cap: This
adjustment promotes more balanced development, discouraging
overbuilding of primary residences and ensuring equitable size
standards for detached ADUs across all lots. Permitting Severances:
Allowing lot severances where easements for access can be secured
is a financially viable solution. Assessing reasonableness at the time
of severance without necessitating an OPA/ZBLA streamlines the
process, fostering accessibility. In a time where mortgage struggles
are prevalent, these adjustments not only align with the needs of our
community but also lay the foundation for a symbiotic relationship
where communities can thrive.
Screen Name Redacted With greater density, it can be possible to create or rebuild
2/03/2024 02:16 PM neighbourhood communities, where people can enjoyably interact.
Less land maintenance might benefit young single or career couples,
as well as those starting families with two or fewer children. If well-
maintained city parks, green spaces, or community garden plots are
nearby, these can make up for the lack of large lawns or backyards.
Above all, multiple -unit (up to 4) buildings on former single lots should
be AFFORDABLE -- not "market affordable" that developers talk
about, but INCOME affordable, costing no more than 30-35% of
tenant's earnings.
Page 29 of 69
Page. 176 6f 343
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 06 February 2024
Screen Name Redacted We are in a climate crisis. Anything that limits suburban sprawl and
protects natural areas and agricultural lands is necessary. Building
inside city limits and building up is one solution. But only if done
thoughtfully and within limits. We need to recognize that this is
Canada and the majority of Canadians still dream of owning a single
family house on a plot of land, not renting in a 4-plex or being cheek-
to-jowl
heekto-jowl with their neighbours. I don't see that changing anytime soon.
It's nice to think of this helping out multi -generational households.
recognize for many people in the city, this living arrangement is a
cultural norm they want to maintain. If they have the means and the
lot size to do so, this should be accommodated (within reason). Also,
the population is aging and more and more the burden of caring for
the elderly is falling on their younger relatives. So in theory things like
in-law suites and granny flats would give seniors some independence
while having free and caring support close at hand, at least for a
certain time. There might also be an opportunity for younger
members to have an affordable place to live while they save for their
own, larger home (which, like most people, would ideally be a single
family home with a sizeable lot). Unfortunately, I do not think these
situations will be the majority of applications to add units to existing
houses. The majority will come from investors who will not be living in
the primary unit and may not even be living in the city.
Optional question (70 response(s), 10 skipped)
Question type: Essay Question
07 What concerns do you have as more properties include up to 4 units in our community?
Screen Name Redacted Space for gardens, flower beds, trees and other landscaping features
1/21/2024 01:43 PM will be lost to building footprint and parking which will fundamentally
change the character of any neighbourhood with a significant amount
of 4 -unit redevelopment. Zoning requirements for 4 -unit
redevelopment should include measures to prevent the affected
residential areas from becoming something resembling strip malls for
housing.
Screen Name Redacted Too much overcrowding. Most people that live here don't want to live
1/22/2024 05:45 PM in an over crowded city. There hasn't been enough thoughtful plan to
growth and now just stick it anywhere and who cares what it looks
like. Just jam them in.
Screen Name Redacted That owners will simply use the Committee of Adjustment to get
Page 30 of 69
Page 171 of 343
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
1/22/2024 11:52 PM approval o circumvent the tront/side/bacKyard setbacks and increase
the height ... there needs to be height restrictions based on the height
of surrounding buildings. Infill and new builds should be required to
replace trees cutdown due to construction - Toronto doesnt allow
ADUs if trees need to be cut down.
Screen Name Redacted Pressure on services, parking issues, shoddy development impacting
1/23/2024 09:02 AM on existing residents, units being too large for the space, noise from
the concentration of families on one plot, changing the feel of
residential areas, over intensification
Screen Name Redacted Dfg
1/23/2024 11:11 AM
Screen Name Redacted Loss of green space, parks, community gardens needed for health,
1/23/2024 04:26 PM gardens help with poverty.
Screen Name Redacted Added vehicle traffic and street parking is often increased.
1/23/202405:43 PM
Screen Name Redacted Literally nothing
/2024 0
Screen Name Redacted Parking, poor maintenence and management, junky looking
1/24/2024 07:05 AM properties, limited storage for outdoor items thus things left in yards.
Most homes and properites are too small to allow for well designed 4 -
units.
Screen Name Redacted If you increase the density I have doubts that the city will be able to
1/24/2024 03:t> art supply the services eg: police , health, reasonable on street parking ,
fire services and on and on. I also wonder if there will be a property
tax reduction for the people who keep single family homes. After all is
said and done there should a large uptake in tax collection from these
multiple units while there will be a loss in value for those who just
want a single family home if it's located with a 4 unit dwelling on
either side.
Screen Name Redacted 1. That this program/initiative misses its mark of enabling Citizen
1:�n,9f)" 1171 -Fc 0e Developers, and instead keeps a disproportionate amount of housing
in the hands of already -advantaged landlords -- If the City is unable to
provide resources (incl. how-to guides, but perhaps some forms of
incentives) to individual homeowners to add units, there is a high
Page 31 of 69
Page 172 of 343
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
chance that this simply leads to new fourplexes being built into
already -planned subdivisions far from the Core, or for existing single-
family homes to be bought by developers, replaced by new -build
fourplexes, and sold to landlords who do not live there, or have any
interest in their tennants beyond providing MORE monthly income.
Screen Name Redacted absolutely none aside from poorly though out zoning/bylaw standards
1/25/2024 11:07 AfVi that make it nearly impossible for new builds/renovations. It's so
ridiculous, Kitchener claims they want to increase housing and yet
have massively restrictive building regulations, particularly in old
neighbourhoods, where lot sizes are smaller. These are the
neighbourhoods people want to live in!
Screen Name Redacted None. The government needs to get out of the way and let
1/25/2024 12:42 PM developers do what is economically viable.
Screen Name Redacted Constructing in difficult to access narrower backyards to build ADUs
could be very difficult and potentially cause inconveniences for
neigbours, and also the potential for damages.
Screen Name Redacted Increased temporary residents decreases neighbourhood security
1/28/2024 Os::: r: and cohesion. The emergence of slumlords and those who will not
familiarize themselves with the LTB.
Screen Name Redacted Transit infrastructure will need to be reviewed after these start going
1/28/2024 10:27 AM in to ensure we have the capacity and frequency to make more
density viable. Also, walkability in these neighbourhoods will need to
be reviewed to ensure there are pathways, local
businesses/destinations, and schools/parks/other infrastructure to
Screen Name Redacted
1/29/2024 10:08 AM
Page 32 of 69
again make the increased density viable. The tree canopy also need
to be considered. I'm sure more density with mean the need to cut
down some trees, but we should be careful to keep as many mature
trees around in neighbourhoods as we can. They provide a very good
positive impact on the feel, temperature, and environment of an
community. Cutting mature trees down and replacing them with new
young one is not a one to one substitute as they take forever to grow
back in. So lets just keep the canopy in mind when organizing how
this density comes in.
none, put them everywhere
Page 173 of 343
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
Screen Name Redacted 1 -hat it has taken this long to look at this as a way to help with t e
1 /29/2024 10:12 AM
housing crisis
Screen Name Redacted Maintaining greenspaces and tree cover in neighbourhoods without
1/29/2024 10:16 AM impacting construction. Many new build dwellings completely destroy
all tree cover on the lot.
Screen Name Redacted Servicing, garbage, landscaping, and parking need to be carefully
1/29/202410:18 AM considered, but I think it'll work itself out. E.g. many of Toronto's older
low-rise neighbourhoods have a diversity of units like duplex, triplex,
etc. and while it can be cramped sometimes with finding parking,
collecting garage, there is so much character and charm with having
a lot of people in these tight -knit communities - more "eyes on the
street"??
Screen Name Redacted loss of trees, grass and shrubs etc. More pressure on our ageing
1/29/2024 10:22 AM infrastructure, turning the subdivisions into concrete ghettos
Screen Name Redacte(: More occupants/renters (transients) with no sense of
1/29/2024 11:18 AM neighbourhood,property upkeep standards and groundskeeping
standards. Particularily applies if the owner/landlord is absent.
Neighbourhood appeal falls as more conversions occur and
symptoms are more visible.
Screen Name Redacted The city looking run down, ghetto like. Tell me how many family's out
1/29/2024 11:23 AM there do not have one car, than the kids stay home longer and before
long each unit has 2-4 cars.... really
Screen Name Redacted I'm concerned transit frequencies are not sufficient to support people
1/29/2024 11:24 AM who want to live in a car -free or car -light way. Far too many bus
routes are 30 minute frequency which is simply not enough to get
around the city in a reasonable manner. We also don't have nearly
enough separated bike infrastructure to allow comfortable cycling as
a primary means of transportation.
Screen Name Redacted I believe that these housing units will essentially be created slums.
1/29/202411:26 AM The properties most likely to take advantage of this are ones that are
owned by developers, investment companies or landlords. This will
further create generations of renters, which will primarily impact
people of lower economic means. This will also create infrastructural
issues. The communities where these will be built were not designed
Page 33 of 69
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
with is in mind. I here will e traffic issues, concerns around
groundwater demands and other similar issues. For example, how will
garbage pick up be managed? The current policy is 3 bags of
garbage per household. Does this mean that if there are 4 units on a
property that now means there can be 12 bags or garbage or is it still
somehow 3? How is this enforced? I am fully supportive of creating
more housing, such as building new apartment buildings etc., but this
project seems very short-sighted and it will have longterm negative
effects.
Screen Name Redacted So. Much. Concrete. Looking at the proposal what struck me the
1/29/2024 12:19 PM most was the loss of green space for housing. Not all green space is
created equal, but it's so important for humans and other species to
have natural areas to be in. Forget parking, what ecological
requirements will this plan contain? For every mature tree removed to
make space for housing, how will we recoup that ecological loss?
Screen Name Redacted Read the comments above, pretty clear
_ :;24 12:35 PI
Screen Name Redacted This will change the composition of older neighbourhoods. The
1/29/2024 12:45 PM frontage of many lots is not sufficient for larger units. These will likely
be rentals and may detract from the community of many of our
neighbourhoods. The place for density housing is high rise buildings
in the downtown core. Not in established neighbourhoods where this
will detract from the peace and quiet and potentially impact upon the
green space in a negative manner.
Screen Name Redacted These changes will result in junky places to live that are now possible
/2u/2024 W. 12 FIV, to really enjoy. Have a look at locations in Waterloo that have homes
taken over already. The loss of pride and maintenance of homes in
nice neighbourhoods will result.
Screen Name Redacted
Page 34 of 69
On the whole, I think the housing crisis in Kitchener comes before
most concerns I might have, so I think my concerns are mainly that
the city might not remove as many obstacles as possible to the
success of this effort. The city should proactively identify areas where
the planning/building process can accelerate such developments
where they make sense, and include supporting the expansion of the
housing stock in how the city prioritizes, e.g., any changes to
add/upgrade connections to municipal services, regional plans for
transit service, etc. Perhaps the city could even identify
neighborhoods or streets where existing infrastructure (electrical,
water, roads, transit, etc) can already support more units and
Page, 17" 343
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
encourage such eve opmen improvemen s there e.g., through
making that information available to the public; providing blanket,
simplified or expedited approval; waiving or reducing municipal
charges; etc.).
Screen Name Redacted I think there should also be some rules around how these type of
11129/2024 02:55 PiVi properties should be built - since people will be living so closely with
one another. For example, it should be mandated to have an exhaust
fan above stoves and in bathrooms. Also, walls should be insulated
between units and any mandated precautions to prevent outbreaks of
rodents or bugs. It should be illegal to build apartments with paper -
thin walls and all landlords should equip their units with working fire
extinguishers.
Screen Name Redacted None. This is a preferable approach to growth.
1/29/2024 03:16 PM
Screen Name Redacted Ensuring they are properly panned for from an infrastructure servicing
1/29/2024 03:30 PM perspective, as well as transit and other active transportation
methods.
Screen Name Redacted Parking Drop in property value of nearby single detached homes.
1/29/2024 03:44 PM Garbage collection issues Property maintenance issues (absentee
landlords) Streets with single detached homes are not wide enough
for the increased traffic. Reduced number of trees i.e. trees cut down
in neighbourhoods
Screen Name Redacted If the city is not careful, this law will be a change in name only. The
/29/2024 Os:Ji FIV city should make sure to review other relevant zoning regulations and
determine if rules like setbacks or parking minimums will end up
blocking these units from getting built. There's no use making 2-4
units legal if the other laws still make them either illegal in some other
way or so impractical/expensive as to not be built.
Screen Name Redacted
1/29/2024 03:57 F,.
Screen Name Redacted
Page 35 of 69
My biggest concern is about noise. Loud cars or loud parties. The
risk for both go up as the population increases.
My only concern is that this is being framed as multiple units being
the exception. I think from now on, only multiple unit dwellings should
be allowed. No more single family homes.
Page 176 of 343
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
Screen Name Redacted I have numerous concerns. Higher population densities will lead to
more traffic, sewage, and utility usage within pre-existing
neighbourhoods which were not likely to have been designed with
densification in mind. As a result, you run the risk of significantly
degrading living conditions, lowering property and home values, and
changing the very nature of the neighbourhoods in which "post -build"
densification occurs — this will increase crime and decrease the
overall quality & liveability scores of our communities for
generations to come. My strong recommendation would be to NOT re-
zone existing communities, which are a "known thing", but rather, to
incorporate densification "by design" into newly -planned communities,
undeveloped areas, and certain zoned plots on a case-by-case basis
only.
Screen Name Redacted I suspect that most of these units become rentals and most of the lots
that could accommodate such units would be in older neighborhoods
that have larger lots. My concern would be for the residents of those
neighborhoods dealing with poor maintenance of their new
neighbours in these multi units. For example there should be
mandatory lawn and snow removal policies enacted that make
landlords responsible for the property maintenance.
Screen Name Redacted 1- parking and street wear for up to 4x increase in usage 2- sewers
and water management need improvement. Sewers and storm water
need to be upgraded to handle the 4x increase in usage. Building
additional structures reduces open land for water to collect and travel
across requiring improved storm water management. Water tables
are very high in our neighbourhood, additional structures will require
additional access to storm drains, sump pumps and their own storm
water management rather than pushing water onto neighbouring
lawns. 3- maximums on increase on rent to keep these new places
affordable 4 -increase schools and hospitals for population density
increase 5 - increase waste management and recycling for 4x
increase in usage 6 - improve electrical infrastructure to handle 4x
increase in usage 7- increase internet infrastructure to handle 4x
increase in usage 8 - traffic management, up to 4x the drivers
requires additional traffic congestion management especially since
public transport is not currently adequate for many residential
neighbourhoods in kitchener 9 - increase access to public services
and input, more people means you need better systems to serve
them and receive input from them
Screen Name Redacted Our community was never designed for this! Infrastructures are going
to be pushed to their limit and if something fails, it will be
catastrophic!!!!
Pa e 177 ulf 343
Page 36 of 69
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 06 February 2024
Screen Name Redacted More people starting business in their garages. Watering down our
neighborhoods will have a negative effect. The majority of people do
not want this in their community.
Screen Name Redacted Some people may think it's acceptable to have 7 people living in a
house. So 7 x 4 .... It adds up. So there should be a disclosure of
how many people are able to occupy, in total, on the 4 units. Another
thing is the privacy of neighbours and the additional noise that will be
generated by the additional units. Green space should be required for
pets, kids or for a garden for the birds and the bees (environment).
Will these lands be severed or will they have to be owned by the
person who owns the land?
Screen Name Redacted Rent control must be included, geared to income
Screen Name Redacted As a owner of a single family dwelling, I am not interested in
becoming a landlord by developing my plot and providing more
housing. This change benefits those who wish to make money from
their property.
Screen Name Redacted That homeowners won't be able to afford the construction costs
required to do it. So the likelihood of folks converting homes or
building an ADU won't have the positive effects impact on increasing
housing as much as we hope it will. Lack of financial incentives to
accompany this proposed zoning change. Storm water management
concerns. Although, getting rid of parking requirements might
alleviate it.
Screen Name Redacted Will these units fall under the provincial rent control or will they be
1/30/2024 07:39 AM exempt? Will the owner of the units live on site or rent all units? Are
there bylaws in place for the owner of the units/property to be
responsible for property maintenance?
Screen Name Redacted Residential streets are generally narrower so on -street parking and
modification of parking bylaws is not an option. There must be
changes made to planning permissions to allow for on-site parking
development with a minimum of 1 parking space per unit. Existing
parking bylaws must be strictly enforced to keep streets safe and
prevent an encroachment of on -street parking.
Page 37 of 69
Page 1,78 of 343
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
Screen Name Redacted I'm concerned that this creates more of a wealth gap in the region,
1/30/2024 08:28 AM creating more landlords out of existing homeowners. It could result in
more inspection costs and wait time, as lots of renovations to add
units finish, which could encourage renting out units that don't adhere
to building/fire codes. I'd love to see more 4-6 storey multi -unit mixed-
use buildings, like the ones seen in many European cities.
Screen Name Redacted That there will not be enough parking. That there will will be some eye
1/30/2024 09:00 AM sore units that are quality built. I think fire rating and sound proofing
should be prioritized. Fire rating for obvious reasons and sound
proofing, to help with neighbors frustration amongst each other,
limiting/ lowering possible police involvement. I am also concerned
about locations, should be able to be next to 2500 + sf homes as this
could depreciate property values.
Screen Name Redacted My concerns are not directly with the increase in the number of units,
but in how the city will roll out this program and how many barriers
there will be to implementation. The program needs to have options
for all property types within the city, not just the ideal suburb lot.
Screen Name Redacted I think it may/will be beneficial in the long run but short term pain
while construction is ongoing and contractor parking and abuse.
Resident parking will be a concern if exemptions are allowed and a
wait and see approach SHOULD not be used, requirements should
be implemented right from the start and adhered to as current
residents should have a say in their neighbourhoods and
changes/development. Flips and sales and greed is always a
concern, price gauging for max profits and tenant behaviours with
more and closer residents than has been the norm in mature
neighbourhoods. All combined could be a real issue, I understand the
need to change to accommodate our housing crisis but more in this
way is not always the solution, limits on areas, neighbourhood
specific may go a long way.
Screen Name Redacted My comments above pretty much explain my reasons why 4 units on
1/30/2024 10:43 AM any residential property will adversely affect the adjoining residential
properties as they will be de -valued and the individual lot boundaries
will not be respected because of crowding. I have already seen this
happen and it will only get worse.
Screen Name Redacted I think a lot of education needs to happen. The photograph used for
1/30/2024 12:04 PM this page shows very large houses with two -car garages designed for
one family. Often these houses are under-utilized -- smaller families,
Page 38 of 69
Page 179 of 343
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
rea ups, age -- so represent a big opportunity fora i iona shelter.
Many people I know wouldn't consider living in a triplex with
neighbors living on the other side of the wall or on a different floor.
We are fixated on our independence and privacy despite the
homeless occupants of tents we drive by in our city. Is this "comfort"
we seem to think we need part of giving us a better quality of life or
are we being deceived? Even asking the question suggests we've
created a world where our personal needs and wants should be
catered to above the needs of our community.
Screen Name Redacted Over crowding, reduced quality of life due to loss of greenspace and
1/30/2024 12:55 PIVI increase of greyspace, increased crime, increased travel times to
work and school on congested roads.
Screen Name Redacted Just that all the units be inspected to confirm that they're safe and
1/30/2024 02:18 PM livable
Screen Name Redacted None. Come to Laurentian Hills.
Screen Name Redacted The Infrasctrue of existing houses trying to accommodate uses that
1/30/2024 05:23 PM were not intended for the original build. The water and sewer lines for
a single residential building would not be built to withstand the
increased use. Would Direct Detect and sprinkles be mandatory in
these buildings? who would make sure that the units were built to fire
code? How are the builds monitored to make sure that the proper
ventilation is built for multiple cooking times if the dwelling is shared
without proper separation? Who would make sure that there was
enough parking? Already parking is at a premium in many of the
newer developments. Parking is happening on front lawns, across the
aprons of driveways and on streets. Small streets /courts and
crescents were not built to accept the significant increase in density
which impedes the ability for EMS and Fire to gain safe access to the
properties that may not have the increased density. I have seen
where Fire could not get onto our street during an emergency call and
had to honk repeatedly to gain access to the home where the
emergency response was required.
Screen Name Redacted *Absolutely none.* I think it's a fabulous idea, and one which will go a
long way toward correcting the zoning errors of the last 70 years.
Screen Name Redacted We are concerned about how many people the land lords will allow to
A/2024 0E live in one small unit. Some houses, especially rental properties are
Page 39 of 69 Page 180 of 343
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February,
already over crowded.
Screen Name Redacted First, new construction should be mandated to have the style of the
additional units blend in with the design esthetic of the
neighbourhood. Second, construction plans should be designed so as
not to impede proper drainage of the properties that could cause
flooding or excess water on neighbouring properties. Third, since
privacy is important, there should be additional set backs from the
property line that need to be adhered to. Fourth, since green space is
important, construction of additional units should not allow for the
destruction of mature trees on the property. Fifth, as some
densification occurs, the city needs to ensure that local services
(schools, roads, parks, transit) are appropriately managed given the
increasing population in some areas. Sixth, units need to be
permitted and legal, with proper controls on maximum occupancy.
Screen Name Redacted Communities that are zoned for 3+ floors already should also be for 6
units by default.
Screen Name Redacted I am concerned that the zoning requirements such as setbacks and
floor area ratios will be overly restrictive and not make a significant
impact in the increase in housing supply. I am also concerned that the
city needs to continue to expand the walkable, bikeable and transit
accessible streetscapes to support denser, low -car housing. Ensuring
provision of more park space and city amenities is also important to
make living denser more attractive with easy, local options that are
not a car ride away.
Screen Name Redacted You're basically trying to turn middle-class subdivisions into slums!
Bad idea!
Screen Name Redacted Backyards are meant to be a place for leisure and enjoyment. The
more units the more busier neighbourhoods will become. People will
not know there neighbours as much.
Screen Name Redacted Not sure how compatible the residents of these additional units will be
with the existing population. Furthermore, these conversions should
only be allowed in cases where an existing resident wants to do this
and stay living in their residence. The city does not need more
absentee slum landlords, speculators and investors. That would
poison the entire neighbourhood.
Page 40 of 69 Page 181 of 343
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February
Screen Name Redacted I'm concerned about the prevalence of "luxury" units. It seems
2/01/2024 01:52 PM whenever a duplex goes up, it is replacing a house that was on the
more affordable end, and the resulting luxury units are priced far
higher.
Screen Name Redacted One prominent concern with the increasing inclusion of up to 4 units
2/02/2024 08:30 PM in our community is the potential loss of trees, greenspaces, and
naturalized areas, which play crucial roles in groundwater penetration
and water management. As properties are developed to
accommodate more units, there is a risk of diminishing these vital
environmental elements. Loss of Trees: The expansion of properties
may necessitate the removal of mature trees, impacting the
community's overall canopy coverage. Trees are essential for
absorbing rainwater, preventing soil erosion, and contributing to
improved air quality. Their removal could disrupt the delicate balance
of the local ecosystem. Reduced Greenspaces: The development of
multi -unit properties may lead to a decrease in available
greenspaces. Greenspaces serve as permeable surfaces that aid in
rainwater absorption, reducing runoff and potential flooding. A decline
in greenspaces could compromise the community's resilience to
extreme weather events. Diminished Naturalized Areas: Naturalized
areas, such as wetlands and meadows, contribute significantly to
groundwater penetration and water filtration. These areas act as
natural sponges, absorbing excess water during heavy rainfall and
facilitating groundwater recharge. The reduction of such spaces could
impede the natural processes that help manage water resources.
Impact on Water Management: The alteration of natural landscapes
through increased property development may disrupt established
water management systems. Trees and greenspaces act as natural
buffers, mitigating the impact of stormwater runoff and enhancing
overall water quality. Their removal could strain existing water
management infrastructure and increase the risk of water -related
issues. To address these concerns, it is crucial to incorporate
sustainable development practices that prioritize the preservation of
existing trees, greenspaces, and naturalized areas. Implementing
measures such as green roofs, permeable pavements, and strategic
landscaping can help mitigate the environmental impact and ensure
that the community retains its essential natural elements for
groundwater penetration and effective water management.
Screen Name Redacted Some general concerns were expressed in Item 2 but more
2/03/2024 02:16 PM specifically, some others are: poor tenant screening, resulting in
excess noise, uncontrolled or unsuitable pets, illegal activities (such
as theft and drug -dealing); poor property maintenance by landlords
and tenants, congestion caused by too many vehicles parked in too
small a space; light pollution; exploitation by developers concerned
Page 41 of 69
Page 182 of 343
Add your comments on the proposed by-law: Survey Report for 21 January 2024 to 05 February 2024
more with profit an quality and design.
Screen Name Redacted -increased danger for pedestrians and bikers associated with
2/03/2024 03:58 PM increased number of people who have to park on the street. -
increased garbage - how will all these units have their garbage and
recycling picked up? There is a limit on number of garbage cans per
household. -increased noise coming from poorly insulted outdwellings
-decreased curb appeal
Screen Name Redacted Setbacks and heights - Some of the pictures showing of 4 unit
2/04/2024 08:21 PM properties look anything but "gentle" density. It looks like structures
will be allowed practically up to the property lines. How will you
address the impact on the privacy of neighbours, especially where the
additional unit(s) will be more than one story high? Someone asked in
the virtual neighbourhood meeting if you are considering 4 -story units.
This should not be allowed or only be allowed in large lots. The
quality of the additions to the primary unit or additional structures —
When some people build an addition, frankly, they build an eyesore
by anyone's standards. Is there, or will there be, any measures to
ensure these new units will be in keeping with the character of the
primary unit and neighbourhood? This is something that needs to be
in place not just for designated heritage neighbourhoods. What will
stop these sorts of developments from being turned into illegal
rooming houses or short-term rentals? We are losing tree canopy to
the effects of climate change. What protections will be put into place
to prevent removal or damage to mature trees to allow for additional
units? Offering to plant some saplings somewhere else in return
should not be an option to the builder. Because of climate change we
can expect to see more and more severe weather events. What will
the impact be on rainwater management (run off) if permeable land is
effectively paved over to build additional units and parking spots?
Someone in the virtual neighbourhood meeting asked about waving
development charges to build these multi -unit structures. How can
this even be a consideration? I thought cities were in a revenue crisis.
How do you plan on paying for the costs of increasing infrastructure
to accommodate all these extra units?
Optional question (71 response(s), 9 skipped)
Question type: Essay Question
343
Page 42 of 6 �F
Attachment G3 — Email Correspondence
Emails through the EnablingFourUnits@kitchener.ca
The project team attached the feedback and inquiry emails. Other emails related to
registration and information about the open house and engagement process are not
included.
The Feedback emails received:
Page 184 of 343
From: Ediphique Renovations
Sent: Tuesday, February 27, 2024 8:54 AM
To: Enabling Fou rUnits (SM)
Subject: Re: Enabling Four Unit Project Update and Draft Regulations
Hi there,
I took the week to read through the draft amendments a few times. I'm not sure if you were looking for feedback, but I
thought I would just write something to show my appreciation for being part of the process and give some insight on
how it's being read. The draft changes look great and I truly believe that they will allow for a diverse new direction for
infill that can accommodate a variety of scenarios. As an industry member, I think that is what we were hoping for.
This is how I am interpreting a few broad points from the draft. This is just for reference to let you know how it's being
read.
- The Central Area Neighborhood in entirety and areas 800 m from the LRT Stations have no set minimum for frontage
and lot area for 3 and 4 ADUS. These lots would default to the residential zoning for each property to determine lot
minimum requirements. The minimum of 10.5m frontage and Lot Area of 360msq would be required for all areas
outside the Central Area that are not within 800m of an LRT station unless their corresponding zone requires larger (RES -
1, RES -2).
-Detached ADUS are permitted to have two dwelling units, while keeping to the new specified ground floor area,
height/setback requirements and lot zone/location min requirements.
- Parking: For 3 dwelling units and up, table 5-1-1 seems pretty clear. Areas within 800m of the LRT Stations have no
parking minimum, Central Area minimum of 2, outside the Central Area minimum of 3 parking spaces. All require 2
sheltered bike spaces according to Class C definition.
Again, this feedback is just to give insight on the user end interpretation of the draft in case the intention was something
else.
One note that I think is worth bringing up pertains to the proposed changes in landscaping minimums. Just as a case
study, I used the proposed lot minimums as an example, on a 10.5m wide and 34m long lot, and using a typical 6m x
12m building with a 5m front setback to compare the old and new regulations.
The original minimum of 20% of landscaped area vs the new proposed 30% of front yard landscaped, 30% of rear yard
landscaped produced roughly the same amount of landscaped area.
I supposed the consideration here is that the new regulations would not allow as much flexibility for lot design. So for
example if someone wanted to provide more than the minimum parking requirements, or provide minimum required as
rear parking and a detached accessory dwelling this may prevent these options.
I don't believe that this point is a make or break issue as people can find work arounds. The new landscaping minimums
could also lead to less parking which may reduce the use of cars overall, but I thought it would be worth mentioning.
I look forward to working with these proposed by-law amendments to create more diverse housing solutions.
Thank you again for including me in the conversation.
Page 185 of 343
Regards,
Amanda
On Tue, Feb 20, 2024 at 1:32 PM EnablingFourU nits (SM)<EnablingFourUnits@kitchener.ca> wrote:
Good Afternoon,
First — I wanted to thank everyone who participated in the Enabling Four Units Industry Engagement Workshop! We
truly appreciate your time and input into this project.
Staff have completed a draft of the proposed zoning regulations that will enable up to four dwelling units to be
located on a lot that currently permits a single detached dwelling, semi-detached dwelling or street -fronting
townhouse dwelling. The draft zoning regulations were developed based on consultation with agencies, city staff,
the public and members of the development industry. Staff will be finalizing our recommendations for
consideration by PSIC Committee and Council at the end of March 2024.
Thanks again for your input and participation!
Katie and the Enabling Four Units Team
Katie Anderl
Project Manager - Planning I Planning Division I City of Kitchener
519-741-2200 x7987 I TTY 1-866-969-9994 1 katie.anderl(@kitchener.ca
2
Page 186 of 343
From: Hal Jaeger
Sent: Tuesday, February 27, 2024 3:23 PM
To: Enabling Fou rUnits (SM)
Subject: Comments on draft zoning re: Enabling Four Units
Thank you for sharing the proposed zoning to enable four units, Enabling Four Units Team.
I appreciate
• The clarity provided about "Unobstructed Walkways". I hope this will reduce frictions between
neighbours and make people less apprehensive about additional units.
• The removal of the limitation on ADU size based on principal dwelling size.
• The clarity about minimum landscaped areas in front and rear yards.
Does the proposal also include a minimum overall landscaped area for the lot? If so, what might it
be? Does the proposal specify that a landscaped area must contain living plants? I'm seeing more
and more astroturf and hardscaping.
The parts that are more challenging for me involve height and setbacks.
Can you please help me/us understand the logic in permitting ADUs to be closer to a neighbour's lot
line than the regulations governing the principle dwelling permit? I comprehend that the setback was
borrowed from the regulations that existed on sheds and garages, but that does not demonstrate that
the choice was reasonable. Can you please do a "reality check" without assuming any blinders
inherited from our past practices?
I am trying to envision the transitions that would be achieved, and the impact on light, privacy and
skyviews of permitting ADUs to be of 6.Om in height. I do note that the proposal would have theses
ADUs set back an additional 0.3m from the adjoining property line. Do you have any scaled diagrams
that display the relationship in the context of typical, existing lots? Might it help to include in the
regulations that the additional height is permitted, so long as it does not cast additional shadow on a
neighbour's lot or interrupt a particular angular plane? Might an angular plane origin point of 3m
high and the minimum required setback (consistent with existing ADU regulations) be
appropriate? Might it also be useful to note that the City would accept waiving the additional criteria,
should the affected neighbour accept in writing?
As I wrote earlier, I value the vistas of front yards and do not appreciate it being interrupted by
parked cars. So the proposal to have a parking spot O.Sm from the street does not appeal to me. If
there is to be a strong push for parking over the public sphere, might this be an issue that can be
handled differently in different neighbourhoods? Maybe the setback can be greater in
neighbourhoods where there is scheduled to be reduced parking minimums?
Page 187 of 343
I am happy to discuss further, by phone or in person.
Thank you,
Hal
Hal Jaeger
Page 188 of 343
From: Peggy Nickels
Sent: Wednesday, February 21, 2024 3:03 PM
To: Enabling Fou rUnits (SM)
Cc: Sheldon Atos; Frank Etherington; Gail Pool; Mario Chilanski; Wendy Weinberg; Debbie
Chapman; Jeffery Silcox -Childs
Subject: Enabling 4 Units
You don't often get email from
Dear Enabling 4 Units Staff,
Please find below a statement from the Victoria Park Neighbourhood
Association's Development Committee regarding Enabling 4 Units.
Victoria Park Neighbourhood Association Development Committee - Statement
about Enabling 4 Units
We understand and support the importance of urban intensification; it protects essential
farmland, natural spaces, and aquifers. We want a compact city that reduces
unnecessary commuting and makes the best use of existing infrastructure.
We also know the importance of tree canopy and green space in making cities and our
planet livable and sustainable as we move deeper into climate change. Both capture
and hold carbon, clean and cool the air, absorb excess water, provide habitat for birds
and other wildlife, and are vital to our health and wellbeing.
New zoning regulations that permit up to four dwelling units on any lot that allows a
single -detached, semi-detached, or street fronting townhouse dwelling could have
potentially unanticipated consequences. Without protection, intensification on
residential lots will lead to the loss of mature trees and green spaces that, while private,
still contribute to the City's environmental health.
We urge the City to establish additional by-laws that protect mature healthy trees on
private properties that are less than 1 acre, and to require appropriate replacement
trees for any that are removed. It is important to ensure that urbanization doesn't deter
the City from its plan to maintain and grow the City's tree canopy to 30% canopy
coverage in each of the Wards by 2050, and 33% by 2070.
Page 189 of 343
Thank you for your consideration of our recommendation. Please keep us informed as
you move forward with this
Peggy Nickels, for
VPNA Development Committee Members
Page 190 of 343
From: Mitchell Avis
Sent: Tuesday, February 6, 2024 11:07 AM
To: Enabling Fou rUnits (SM)
Subject: Feedback: Enabling Four Units
You don't often get email from Learn why this is important
Hi Katie and Team,
First off I'm brimming with excitement at Kitchener's proposal to permit 4 units as -of -right on all residential lots. YES YES
YES! This is a great step in the right direction for the City. As we all know, the proof is in the pudding - or the Zoning By-
law - in this case. As excited as I am I know that over regulation can dampen feasibility and uptake. I hope the City has
learned some real lessons from the implementation of ADUs that can be applied here.
Here is what I'd like to see in your Zoning By-law Amendment:
1. Remove all parking minimums. The City approves developments all the time with lower parking ratios using
"unbundled" parking as a justification. Unbundled parking lets the market decide how much parking to
provide. If a landlord/developer believes they can rent a unit without parking they should be allowed to.
Similarly, a landlord/developer may decide parking is necessary to rent the unit and want to offer a spot.
Either way, the property owner should be the one to make the decision, not the City. And this should apply
City-wide, not just near LRT stations. Parking is extremely cost prohibitive and space intensive.
2. Remove Lot Width Requirement. This is redundant for two main reasons. First, there is no reason to require
it. Concerned the lot is big enough? You have a minimum lot size. Concerned about access to backyard? You
have a walkway requirement. Concerned about overbuilding? You have maximum lot coverages. Second,
there are many lots smaller than 13.1m - especially near Downtown - where this type of development is
desirable. I also understand this is the provision that has required the most minor variances and
demonstrates it is over burdening and unnecessary.
3. Increase Building Height to 4 Storeys. I understand the most efficient form of development is slab on grade
and this would permit more flexibility in terms of design when allowing 4 units in new builds or conversions (1
unit per floor). The height for any detached ADU should match what is permitted for the primary dwelling (4
storeys for both).
4. Permit Units in Front Lot and Exterior Side Yard. We need to encourage the more efficient use of space.
5. More Justification and Real World Analysis of 1.1m Walkway Requirement. This becomes less of an issue if
parking requirements (#1) are eliminated. Many properties, especially in the older neighbourhoods near
Downtown, will be unfeasible for a detached ADU because they are built off -centered where the house is
shifted to one side of the lot - closer to the lot line than 1.1m and a driveway on the other side. Would
request information from Staff why 1.1m was chosen and what is required by OBC. I'd also welcome a
neighbourhood walk with Staff to share more of the implications of parking requirements and this walkway
requirement.
6. Remove 50% Building Floor Area Cap. This encourages over building of primary residences and penalizes
people who live in right -sized housing. Neighbours should be allowed to have the same size detached ADU
regardless of the size of primary residence. I would like to see a maximum detached ADU size that is standard
across all lots. Would also request information from Staff why 80 sq. m was chosen as the maximum size.
7. Permit Severances. The inability to sever these lots is cost prohibitive when it comes to securing mortgages
and financing. Creative solutions are required. Permit severance where easements can be secured for access.
The reasonableness of this should be judged at the time of severance and should not require an OPA/ZBLA
too, which makes it incredibly prohibitive.
Page 191 of 343
I hope through this process the City will release a map showing the lots where four units will be permitted as -of -right
based on proposed Zoning By-law regulations. And that this map can be groundtruthed for feasibility. All too often, the
regulations make this form of development prohibitive in the neighbourhoods where it is desirable and needed - close
to the Downtown core and in proximity to transit.
I look forward to seeing your draft and the map.
Mitchell Avis
Page 192 of 343
From:
Sent:
To:
Subject:
Attachments:
Hi Katie,
This sums up my suggestions:
Michael Brisson
Monday, February 5, 2024 2:43 PM
Katie Anderl
4 Units - Graphic Notes / Our Open House Chat of Jan. 31
U ntitled_Artwork.pdf
Preservation of the distant views , front and rear, of the the near centre picture windows of mid -20c lots with shallow
back yards is possible by building at each side with small party wall defined 3 storey homes with roof terraces, located at
side lot lines.
The tops of the infill homes will still be well below the height of the predominate large mature trees that occupy the rear
yards of a large proportion of these very numerous lots in Kitchener.
Thanks for a great chat.
Michael
Sent from my Wad
Page 193 of 343
\
k
r
n
t �
�
2
Cr
O
0
\
3.
m
I
� �
CL
\
r
�•
\ R .
+
Q
m
?
ƒ
=
g m /
0 !
2
� q
,
�
Q
�
m
� 9
� 0
2 �
2 �
�
2 Q
�
� �
From:
Sent:
To:
Cc:
Subject:
You don't often get email from
Hello Berry, Mike, Katie, Sarah,
Leslie HOLDWAY
Monday, February 5, 2024 2:10 PM
Schreiner, Mike; Berry Vrbanovic
Sarah FitzPatrick; Katie Anderl
Re: Fourplex infills - as per right
As a follow up to the Kitchener Planning Meeting and developer discussion and our one on one meetings, which were of
great interest, I do have one point I would to follow up on.
Should the four-plex units be limited to 40+ feet in width, that would only take in about 70% of built residential housing
according to Kitchener Planners.
Most of pre1945 residences are in the under 40 foot category.
But much more importantly by my estimates 60 plus % of housing appropriate for renovation or outright demolition to
create the 4 plexes desired in this legislation are in this under 40 foot frontage number.
To get enough uptake of this bylaw/ legislation, it essential that this artificial limitation be avoided.
Thanks
Respectfully,
Les Holdway
Rescom Properties
On Jan 28, 2024, at 12:50 PM, Leslie HOLDWAY wrote:
To Whom it may concern
Four-plex infills - as per right
Some of the parameters of any proposed bylaws, as I see it
1. Lots must be a minimum of 20 feet in width and / or a 600 sq. foot buildable area
2. Lesser width may be considered if depth of lot exceeds 120 feet
3. Units within subdivisions shall have a 42 foot height restriction unless otherwise allowed
4. Ground level units should have asses -ability features
S. Al units should have enhanced sound / fire resistance
6. All sites should require 50% (.5 car) minimum parking requirements per unit or greater
7. 1 in-line double parking may be allowed were a total of 3 parking spaces or more are available
S. Parking may be allowed on up to 80% lot frontage
9. Main Street units may allow a density maximum of 300 per acre by right, 126 foot height
allowance
7
Page 195 of 343
10. Lots of 50 feet or more in width may allow 2 four- plex units
Les Holdway
Page 196 of 343
From: Justin McLaughlin
Sent: Friday, February 2, 2024 12:18 PM
To: Enabling Fou rUnits (SM)
Cc: Nelson Chukwuma; Nathan Barnett
Subject: Letter of Support for Enabling Four Units
Attachments: COK Support Letter - Four Additional Dwelling Units - 02.042024.pdf
You don't often get email from
Hello,
On behalf of Nelson Chukwuma and Conestoga Students Inc., please find attached a letter of for enabling four units in
the City of Kitchener.
Please let me know if there are any questions.
Thanks,
Gas
Conestoga Students Inc
Justin McLaughlin he/h;m
Senior Manager, Advocacy
Celebrating 50 Years Leading the Student Experience
Proud Member of the Canadian Alliance of Student Associations (CASA)
Experiencing an emergency or mental health crisis?
Please call 911 or Here 24/7 Crisis Services at 1-844-437-3247.
Conestoga Official Disclaimer: This email and any attachments are for the sole use of the intended recipients and may
be privileged or confidential. Any distribution, printing or other use by anyone else is prohibited. If you are not an
intended recipient, please contact the sender immediately, and permanently delete this email and attachments.
Page 197 of 343
Nelson Chukwuma
Conestoga Students Incorporated (CSI)
Room 2A106
299 Doon Valley Drive
Kitchener, Ontario
N2G 4M4
February 4, 2024
Katie Anderl, Project Manager (Planning)
City of Kitchener
200 King Street West,
Kitchener, Ontario
N2G 4G7
RE: Support for Four Additional Dwelling Units
Dear Katie Anderl,
On behalf of Conestoga Students Inc., the official student association of Conestoga College representing over 34,000
students attending school in the Waterloo Region, I would like to express our support for the creation of zoning
regulations that would allow for up to four dwelling units where a single -detached, semi-detached, or street -fronting
townhouse dwelling is a permitted use.
As the City of Kitchener is aware, Waterloo Region, like many other places in Canada, is facing an ongoing and
worsening housing crisis. This crisis has accelerated the need to explore innovative solutions that meet diverse
accommodation needs, including the needs of students in the city. As Conestoga College has grown its footprint
through Kitchener and the surrounding municipalities, students have had an increasingly difficult time finding
appropriate and affordable housing that suits their needs, as over 72% of students found the process of finding
somewhere to live difficult.' As such, we are pleased to see the City of Kitchener taking steps to ensure that
neighbourhoods and communities are being developed and allowed to adapt to create diverse residential options
that meet community needs through a mix of residential dwellings to support all community members.
By allowing up to four additional dwelling units, the City of Kitchener supports the need for gentle intensification;
responds to the ongoing housing crisis and both immediate and future housing demands; and supports diverse
household needs including multi -generational, homestay, and other programs that benefit homeowners and potential
tenants. It is important to ensure that these additional dwellings can be served by existing infrastructure, such as
water and power, and we are pleased to see the City of Kitchener considering these aspects to ensure that new units,
whether they be purpose-built or in addition to existing units, are suitable for tenants.
CSI is in support of the creation of zoning regulations that would allow for up to four dwelling units and appreciates
the opportunity to submit our comments regarding these zoning changes. CSI looks forward to continuing to work
with the City of Kitchener and other stakeholders to improve housing availability throughout our communities.
Sincerely,
Nelson Chukwuma
President
' Barnett, Nathan R.G., and Justin McLaughlin, 2023 Year -End Survey Report. Kitchener: Conestoga Students Inc,
forthcoming.
conestogastud ants, com 519-748-5131 299 Doon Va[[PyNlpel 98 of 343
@CStudentslnc csi(@conestogac.on.ca Kitchener, ON N2G 4M4
From: Scott Hannah <shannah@heritagehomes.com>
Sent: Thursday, February 1, 2024 11:40 AM
To: Enabling Fou rLlnits (SM)
Subject: Enabling four (4) units - Comments from Scott Hannah
Attachments: Comments on four unit proposed regulations S Hannah.pdf
You don't often get email from shannah@heritagehomes.com. Learn why this is important
Katie and staff: Thanks for a great workshop yesterday with representatives from the development industry. We could
have used 4 hours, but you did a great job in the time allocated. I've attached my comments on the Enabling four units
initiative.
If you need more explanation of my comments, please don't hesitate to reach out. Please also keep me updated on the
staff report and when this will go to Council.
Thanks again.
Scott
R. Scott Hannah
Sr. Project Manager, Land Development I Reid's Heritage Homes
6783 Wellington Road 34, RR 22, Cambridge ON N3C 2V4
T: 519.658.6656 C: 519.504.24261 shannah(cDheritagehomes.com
It
SIU,.ILRCK N E
, , 106 E
REID'S HERITAGE HOMES 0
2021 Canada's Top 100 Small + Medium Employers
2021 Waterloo Area's Top Employers
2022 Canadian Brownfield Champion for Redevelopmnet at the Community Scale
2023 Certified Great Place to Work
WE'VE MOVED!
Our new office is located at 700 Jamieson
Linkedln I Instagram I Twitter I Facebook
Parkway, Unit #103, Cambridge, ON NX 4N6
io
Page 199 of 343
Thanks for the opportunity to comment on the proposed changes to the Zoning provisions to allow four
(4) units on residential lots. I viewed the online presentation and attended the builder/developer session
on January 31, 2024, from 1-2:30 pm at the Forest Heights Community Centre. I am also a member of
the City's Committee of Adjustment and have spent over 40 years working in Development Planning
bath for municipalities and the private sector, so I hope I offer a unique perspective.
I have several larger concerns with allowing four units everywhere in lower density residential areas:
1. The loss of residential character: Previous changes to the Planning legislation to allow two units
and three units have resulted in changes to some residential neighbourhoods, where larger 18+
metre wide lots with post war bungalows have been demolished and severed to allow two
detached dwellings or, more decently, duplexs/triplexes on the new lots. The character of these
neighbourhoods has changed, and in my view in some cases not for the better. But when done
right these new units can be compatible with the existing. Given the stats provided both online
and at the session there are thousands of properties that can be gently intensified and help
solve our housing crisis. Uptake is only beginning to happen so patience is needed. With the
allowance of 4 units, I fear that that there may be enough financial gain for the tear down
rebuild will start to occur in beautiful neighbourhoods that have only experienced gentle
intensification (ie. New units added internally without noticeable change to the architectural
appearance of the dwelling) without destroying the character of the area. This is the right kind
of change. There is clearly a closet industry (intensification contractors, builders/real estate) that
has developed (I see the same applicants all the time at the C of A) and they only care about the
dollars not the neighbourhoods they destroy. If we were to lose the character of Westmount
(only an example), it would be sad. Perhaps the heritage planners need to look at some of these
neighbourhoods that you want to preserve and create heritage districts. Most of my comments
for and against the changes to the zoning by-law are based on my concern with character.
2. Has servicing and stormwater management been considered: Some of the changes proposed
appear to result in development that will add to lot coverage and the percentage of imperious
surfaces on a property. With climate change and the severity of rainfall events have the
Engineers considered these changes. In my view, any change that will result in allowing more
coverage on a lot (driveway or building coverage standards) should not be allowed as I see
troubles down the road with storm sewer capacity and even the load on the sanitary sewers. I
trust this has been considered. I would also suggest that your building by-law be updated to
require SWM reports where proposals exempt from SPA (e.g less than 10 units) are substantially
adding to imperious cover on a lot (expanded parking areas or lot coverage)
Here are some specific comments on the changes proposed:
Parking
6.0 metre setback to the first parking space — Currently required. Proposed to remove the requirement.
I fully support this change, as this was something that I suggested to staff early on. The Committee sees
this variance one or two times a meeting where applicant's want to convert a garage to living space but
must go to the Committee even though two (2) functional parking spaces exist in the driveway while
meeting the driveway width requirements. Staff always support this variance which is typically seen for
conversions of existing detached dwellings to two units. This is good intensification as the character of
Page 200 of 343
the dwelling and neighbourhood remains unchanged. Based on the stats that were presented, there are
thousands of existing lots in the City that could take advantage of this change added thousands of new
units without the need for tear downs and rebuilds.
Reduced parking for 3 and four units — current 3 required for three units and 4 required for four units.
Proposed changes to allow less or no parking in MTSA, and reduced parking in older built-up area.
The City needs to be very careful with these changes. The City is not downtown Toronto even though you
are doing your best to encourage alternative modes of transportation. I like the idea of allowing the
areas in the MTSA areas to have lessor requirements or not require parking for three- or four -unit
conversions, ADU's (detached) and new purpose-built residential buildings (2, 3 or 4 units). You already
do that for larger residential developments. In this way, you have chosen areas that you want to see
change. Developers then can decide if they want to provide parking (1, 2, 3 or more spaces) based on
the tenants that they want to attract. I am still very concerned with the teardowns and 4 unit rebuilds in
the older built-up areas. These are the areas that have the residential character as many were built
before the cookie cutter designs, we see in modern neighbourhoods. The loss of these wonderful
architecturally diverse nieghbourhoods would be devastating. There are larger properties that can
accommodate 3 or 4 units though conversions or additions with appropriate parking, but parking is
usually the regulation that controls the ability of making the change. I fear reducing parking will promote
more teardown/rebuilds. Parking should remain at 1 per unit for purpose-built duplexes, triples and
four -unit building. Possible reduction in parking (i.e. 3 spaces for 4 units) where a conversion or addition
is made to an existing building. This would retain character, and this has been my theme.
ADU's
Permitted # of units in ADU (detached) and Maximum Height — currently 1. Proposed 2, Currently 4.5m
proposed to go to 7.5 metres.
I strongly oppose these changes. There are two issues typically with ADU's detached for surrounding
property owners. The first is lose of privacy and the section is increased shadowing as the new ADU's are
typically conversion of existing detached garages or accessory structure or purpose built ADU's
(detached) located close to rear or side property lines. The building code does not allow window
openings in structures less than 1.2 metres from the property lines so it is easy to explain to abutting
neighbours that there won't be a loss of privacy as walls less than 1.2 metres from the lot line must be
blank and the new ADUs will only be one storey so no issue with shadow. Even if the new ADU is situated
more than 1.2 metres from the lot line and windows face the neighbours yard any loss of privacy can be
resolved via fencing with a one storey building. The abutting neighbours already need to deal with
increased activity and noise caused by the ADU (detached). They should not have to deal with loss of
privacy and shadowing impacts. ADU's (detached) should be the exception to gentle intensification not
made easier. The regulations should not allow more than one or higher heights, unless a developer
wants to provide a lane -based product where there is a unit over a garage accessed off the lane. This
was successfully done in Oakville when I was a Senior Manager of Planning and there are no issues with
privacy.
Lot width - currently 13.1 metres. Considering narrower for allow ADU's on 12.1 metre lots.
Page 201 of 343
I am open to the idea of openning up more opportunities for 12 m (40 foot) lots to be intensified by two -
and three -unit conversions. These lots can accommodate a double car garage and two ccars side by side
in a driveway and meet the driveway width regulations (as an aside, please don't change this). At the
Committee we have seen ADUs both internally and externally on properties with frontages slightly less
than 13 metres and they appear to function properly. I am strongly opposed to allowing 4 units on
something less than 15 -metre -wide lots. As noted earlier, there are changes that can be made (example
allowing garage conversions with appropriate front yard parking) that will enhance intensification
opportunities. I fear a raft of four (4) unit teardown/rebuilds and they should not be the norm or you risk
destroying neighbourhoods.
ADU's in exterior side yards - currently not permitted. Consider with 4.5 metre setback to the property
line.
I support this change as corner lots (especially oversized ones) are exposed to two streets and have the
unique opportunity of architecturally exposing a new ADU to the street to enhance the character of the
neighbourhood. As an aside, during the development of new residential neighbourhoods in the post war
era (e.g., 1950's) many corner properties were developed with walkup apartments as the two -street
exposure allowed the placement of the building closer to the intersection with a small parking lot with
access from the exterior yard. Perhaps the new zoning regulations could allow this for corner lots only in
new and existing neighbourhoods. Corner lots might allow the tear downs to allow 4 units in a sensitive
manner with appropriate and functional parking.
Needless variances for existing situations
As I mentioned at the Developers session, the City continues to require variances, for example a resident
looking to convert a home to 2 or 3 units, where the lot is the right size, the parking standards are met
and the addition is fully compliant (e.g., coverage, height, setbacks) but perhaps one of the existing yards
(front or side) for the existing dwelling doesn't meet the by-law (i.e. legal non complying). This should be
allowed without the need for the time and money needed to go through a variance which, by the way,
are rubber stamped by the Committee. I have worked for and in other municipalities that have a section
is the by-law that would allow this without a variance. This is just a small example of a way to make the
process easier.
Concluding comments
From my read of the new Planning legislation, you are being asked to allow up to 4 units on lower
density lots in residential areas, but you still can control the regulations that would allow this to happen.
There are many positive changes being proposed that will make it easier for 2- and 3 -unit conversions
both internally and externally and uptake is only just beginning.
The City should be cautious and monitor what is happening (teardowns and rebuilds) with the new
changes. If you find you have made a mistake and want to go back, the legal community will fight you.
Slow and steady should be your approach.
R. Scott Hannah
Page 202 of 343
From: Ediphique Renovations
Sent: Thursday, February 1, 2024 10:17 AM
To: Enabling Fou rUnits (SM)
Subject: Enabling 4 Units - Workshop (Follow-up)
You don't often get email from
Hi there,
I wanted to send a quick addition to my comments regarding the frontage minimum. I know that you are considering
12.1m, so I would like to bring up some case points for making that limit 10.Sm.
1. Kitchener Central Zone, likely has a higher percentage of smaller lot sizes than the city as a whole. From a developers
perspective, I believe the business case for fourplexes will be highest in this area. The access to transit/walkability and
higher likelihood of a rental market because of proximity to the downtown and colleges, will make it more desirable to
create rental properties in the Central Zone. Since the majority is already zoned RES -3,4,5,6,7, zoning already permits
reduced lot frontages from 10.5m and smaller.
Adding higher minimums for lot frontages in this area will result in a further restriction on land that can be used for this
purpose in a market where land is already scarce.
This was my reasoning for saying that 12.1m (40ft) would lead to a need for minor variances.
2. In suburban areas, the larger lot frontages dictated by Res 1 and 2 zoning will prevent a permitted lower min of 10.5m
from being utilized in these areas, so it should have little impact on the street scapes.
3. Because you are applying this to the ADU regulation for 3 units as well, in my experience 12.1m is still too restrictive
for 3. Having 3 units on a 10.5m lot frontage is easily achieved. Even if the 3 parking requirement is kept, tandem parking
up the side is viable. As I mentioned to Katie, If the lot area minimum is kept at 395 sq m it will allow for further
possibilities with building size and parking. There are many narrow, but deep lots in the Kitchener Central Area.
Thank you again for including me in the discussions. I hope my feedback will be helpful. Please let me know if you would
like me to elaborate further on these points as I am happy to do so.
Regards,
Amanda
Ediphique Renovations
On Tue, Jan 30, 2024 at 10:44 AM EnablingFourU nits (SM)<EnablingFourUnits@kitchener.ca> wrote:
Good Morning,
This is a friendly reminder that you have registered for the Enabling 4 Units — Industry Workshop.
tt
Page 203 of 343
Date: Wednesday, January 31, 2024, 1:00 — 2:30 pm
Location: Forest Heights Community Centre (1700 Queens Boulevard)
The agenda for the workshop is as follows:
1:00 —1:10 Welcome and Presentation
1:10 — 2:10 Facilitated Discussions
• Theme #1: Lot Width and Lot Area
• Theme #2: Parking
• Theme #3: Backyard Homes
• Theme #4: Building & Lot Design & Layout
2:10 — 2:25 Group Discussion: Supporting Implementation
2:25 — 2:30 Wrap Up and Closing Remarks
Please let us know if you have any questions.
Kind Regards,
Katie
Katie Anderl
Project Manager - Planning I Planning Division I City of Kitchener
S19-741-2200 x7987 I TTY 1-866-969-9994 1 katie.anderl(@kitchener.ca
You
1 0
12
Page 204 of 343
From: Carolyn Barfoot <
Sent: Tuesday, January 30, 2024 9:33 PM
To: Enabling Fou rUnits (SM)
Subject: 4 units
[You don't often get email from Learn why this is important at
https://aka.ms/LearnAboutSenderldentification ]
We must do a lot more infill and a lot less using good farm land. There is too much wasted space within the city limits to
be allowing more spread.
Affordable units are smaller, more efficient and conveniently located. We have too many monster homes with very low
occupancy rates to be considered an efficient use of housing areas.
13
Page 205 of 343
From: Sarah Rioux
Sent: Tuesday, January 30, 2024 7:14 PM
To: Enabling Fou rUnits (SM)
Subject: Enabling Four Units
You don't often get email from
Hello,
I wanted to express my interest in this project.
I would be in favour of the project going ahead and adding 2 ADU's
We are on a pie lot with significant area.
We would likely require an allowance/curb cut for additional parking in the front, but there is a lot of room. And a lot of
room behind the house.
It would be helpful financially to be able to build one on -top of the other, or at least back to back.
Thank you,
Sarah Rioux
14
Page 206 of 343
From: Hal Jaeger
Sent: Tuesday, January 30, 2024 11:28 AM
To: Enabling Fou rUnits (SM)
Subject: RE: Feedback
You don't often get email from
Sounds as if you have a plan to address some key areas. I invite you to visit me at my home for a tour
of how setbacks and site plan have been addressed at my neighbour's.
Best wishes,
Hal
Hal Jaeger
From: EnablingFourU nits (SM) <EnablingFourUnits@kitchener.ca>
Sent: January 30, 2024 11:18 AM
To: Hal Jaeger
Subject: RE: Feedback
Thank you very much, Hal, for your comments and feedback; it was great meeting you at the market.
We look at each dwelling as a household (family) it is hard to regulate the number of people from the zoning By-law.
As we are exploring the regulations, We will not increase the lot coverage percentage (55%) and the driveway width
regulation.
We are also considering maintaining the 20% landscape requirements and looking at ways to maintain the more green
space and the trees.
I hope this answers some of your questions, we will be at Forest Heights Community Centre (1700 Queens Boulevard)
tomorrow from 3 pm to 6 pm to collect more feedback
Regards,
Enabling Four Units Everywhere team
Development and Housing Approvals Division I City of Kitchener
519-741-2200 ext. 2426 1 EnablingFourUnits@kitchener.ca I
e�10000m6o
15
Page 207 of 343
The City of Kitchener is situated upon the traditional territories of the Neutral, Anishinaabeg and Haudenosaunee Peoples. We extend
our respect to all First Nations, Metis and Inuit peoples for their past and present contributions to this land. We also recognize and
respect the cultural diversity that First Nations, Metis and Inuit bring to the City of Kitchener.
From: Hal Jaeger
Sent: Sunday, January 28, 2024 9:47 AM
To: EnablingFourU nits (SM)<EnablingFourUnits@kitchener.ca>
Subject: Feedback
You don't often get email from Learn why this is important
Thank you, Katie, Gaurang, and Arwa for handling the Enabling Four Units file.
I really appreciate the materials you shared via the live presentation and video and open house at the market.
As I said at the market, I see two very different issues being addressed in Enabling Four Units:
a. the question of the layout, room allocations and relationships of residents and
b. issues of lot coverage as it relates to residents' quiet enjoyment, including lot functionality, greenspace,
privacy, access to light and aesthetics.
I do not see why the number of units, the internal layout of a building (number of kitchens, bathrooms, etc.), the
relationship of residents (single family, multiple families) or the relative size of ADUs to the gross floor area of
the primary building should be subject to a neighbours' concerns (beyond general public safety and well-
being). With three units already permitted, I imagine and hope the expansion to a fourth unit could go largely
unnoticed.
Conversely, I believe issues of lot coverage can impact a neighbour and the general community profoundly. I
cannot speak directly to the question of minimum lot sizes and coverage, but I can speak to some of the
contributing factors. I have concerns about lots reducing their green space and tree canopy, from which we all
benefit. I support establishing and, in some cases, expanding minimum green space requirements, as opposed to
merely regulating lot coverage or landscaping requirements. I already see people interpreting hardscaping
and/or carpeting their space with astroturf as meeting minimum landscaping requirements. I take no issue with
raising of maximum height limits on principal buildings or detached ADUs or reductions of setbacks where
such would not compromise a neighbour's enjoyment (sightlines of the sky, access to sunlight, privacy,
etc.). Regarding setbacks, my first-hand experience suggests that inadequate setbacks and poor site layout can
be exacerbated under more intensive uses. I suggest that 1.2m setbacks are already inadequate for maintenance
purposes and allowing setbacks to be reduced further by projections in the setbacks can be even less tenable as
the number of units increases.
I see parking primarily as another issue of lot coverage. I value the vistas of front yards and do not appreciate it
being interrupted by parked cars. I am pleased to see the reduction of parking requirements, so long as it does
not lead to an externalization of costs. I would be unhappy to see the city subsidizing new parking lots or
spending more to clear snow if users cannot remove their cars from the streets during snow emergencies. I
know that my neighbour clears snow from their parking area onto my property and onto the street. I believe this
is the result of a parking lot area out of proportion to the location and size of space for snow storage.
I hope that your work can be paired with updating of our bylaws and their enforcement, to enable swift
resolution of the increased pressures between neighbours' interests that I expect our intensification may
produce. I specifically ask you to coordinate with bylaw so as to ensure any additional units are used as long-
term residential units, not as short-term rentals or commercial rentals, which I believe can produce more
frictions with neighbours.
16
Page 208 of 343
Thank you for your consideration. I invite you to observe the outcomes at my property,
Hal
Hal Jaeger
17
Page 209 of 343
From:
Sent:
To:
Cc:
Subject:
You don't often get email from
Good morning,
Susan Lloyd Swail
Monday, January 29, 2024 10:39 AM
Enabling Fou rUnits (SM)
Ron Swail
Considerations for 4 unit policy
Learn why this is important
I would like to see analysis on the upgrades needed to community centres, schools and parkland to meet the needs of
the population demand at 4 units per lot.
As food growing is a way households make ends meet new quads should be built to minimize shadowing on adjacent
yards growing areas particularly on the south and west exposures.
Setbacks should enable provision of energy infrastructure like heat pumps and access for maintenance in the side yard
i.e. 6 ft minimum.
Parking requirements should provide paved areas for a minimum of four cars unless they are within 100 m of an all day
regular transit route.
Due to additional paved areas yards of four plexes should require rain gardens to reduce heat island effect and reduce
runoff to adjacent dwellings.
Units should require sprinklered systems to minimize fire damage to adjacent dwellings.
This may be a building code issue.
Regards,
Susan Lloyd Swail
is
Page 210 of 343
From:
Sent:
To:
Subject:
You don't often get email from
Chris Hund
Monday, January 29, 2024 10:32 AM
Enabling Fou rUnits (SM)
Four units
Learn why this is important
Why bother with comments. This has already been back room approved. Like most other "unit cramming" to make
future ghettos out of older subdivisions with single family homes being bought buy speculation.
Some of us purchased homes to enjoy space. Not to experience how many people the government can jam in per square
foot.
19
Page 211 of 343
From:
Sent:
To:
Cc:
Subject:
You don't often get email from
To Whom it may concern
Four-plex infills - as per right
Leslie HOLDWAY
Sunday, January 28, 2024 12:51 PM
Schreiner, Mike; Berry Vrbanovic
Sarah FitzPatrick; Katie Anderl
Fourplex infills - as per right
Learn why this is important
Some of the parameters of any proposed bylaws, as I see it
1. Lots must be a minimum of 20 feet in width and / or a 600 sq. foot buildable area
2. Lesser width may be considered if depth of lot exceeds 120 feet
3. Units within subdivisions shall have a 42 foot height restriction unless otherwise allowed
4. Ground level units should have asses -ability features
5. Al units should have enhanced sound / fire resistance
6. All sites should require 50% (.5 car) minimum parking requirements per unit or greater
7. 1 in-line double parking may be allowed were a total of 3 parking spaces or more are available
S. Parking may be allowed on up to 80% lot frontage
9. Main Street units may allow a density maximum of 300 per acre by right, 126 foot height allowance
10. Lots of 50 feet or more in width may allow 2 four- plex units
Les Holdway
20
Page 212 of 343
From: Andrew Vlcek
Sent: Thursday, January 25, 2024 9:08 AM
To: Enabling Fou rUnits (SM)
Cc: Philippe Fournier
Subject: MSS Staff Masters Thesis - The New Plex
You don't often get email from
Hi,
One of our Intern Architects Philippe Fournier recently finished his Masters Thesis on the topic of urban intensification
and may be of particular interest to you. Philippe and Patrick Simmons from our office recently met with Liberal MP
Brian May who will be sharing Philippe work with the housing minister. We have attached the thesis here:
https://we.tl/t-te*ELaazlK
You can also find a digital copy of this which was uploaded at the link below:
https://www.yumou.com/en/document/read/67943797/the-new-plex
Best,
A.J. Vlcek B.A.(Hons.), M.Arch, OAA
Important Notice: This message is intended only for the use of the individual or entity to which it is addressed, and may contain information that is privileged,
confidential and exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, or the employee or agent responsible for
delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited.
If you have received this communication in error, please notify Martin Simmons Sweers Architects Inc. immediately by phone.
23
Page 213 of 343
From: V K
Sent: Wednesday, January 24, 2024 12:40 PM
To: Katie Anderl
Subject: Re: 4plex By -Law Questions
Hey Katie
It was nice speaking with you last night.
I remembered 3 other points I wanted to bring up.
1. Having the front doors at the front of the triplex or 4plex is also a better idea for security and privacy reasons. As a
neighbor, I'd much rather have a house with 3 or 4 doors upfront and people entering that way then having side door
lights turning on, flooding my house windows each time someone is walking in and out of their units. Also, Id prefer not
to have someone walking along the side of my house late at night to get to their door at the neighboring house.
2. We need to get rid of that set back rule concerning being in line with neighboring homes (reins or something). I would
allow someone to do it if it benefits them (allowing them to exceed the 4.5m set back requirement for example). But
otherwise, there should be no issue with sticking out or in if it meant being able to build a better structure. I think that is
far less of a negative impact on a neighborhood then allowing 4 stories.
3. Three bedroom units need to be incentivized more through reduced fees or something. The reason we're bringing in
so many people is because our replacement rate is so low. One key factor for people having less kids is cost and
availability of housing. More three bedroom units allow for people to rent a family size unit that is cheaper then renting
a full blown house or townhouse, which is more expensive. We need to provide ways for builders to make 3 bedroom
apartments more financially feasible for them at every level of build (I would even mandate a minimum number in the
buildings being put up).
Thanks for setting up the info session last night. I hope it went well and some good ideas were brought up.
Mad
On Tue., Jan. 23, 2024, 9:41 a.m. Katie Anderl, <Katie.Anderl@kitchener.ca> wrote:
Hi Mad,
I recall you were interested in attending our industry workshop for discuss the proposed zoning regulations. In case you
didn't receive our mass email late last week, I've include the details for you below. Please be sure to register if you wish
to attend.
Thanks,
Katie
Workshop: January 31, 2024 1:00 — 2:30 pm at the Forest Heights Community Centre (1700 Queens Boulevard).
Workshop space is limited to 20 participants and registration is required. Please email
enablinp,fourunits@kitchener.ca to confirm your attendance.
24
Page 214 of 343
Open House,: January 31, 2024, 3:00 — 6:00 pm at the Forest Heights Community Centre (1700 Queens Boulevard).
Drop-in any time to this open house which is open to the development industry and the public.
You are also welcome to attend a Public Open House. These are scheduled for Saturday, January 20, 7:00 am — 2:00 pm
at the Kitchener Market, and Tuesday, January 23, 3:00 — 7:00 pm at the Stanley Park Community Center.
For more information and to share your feedback through our short survey, please visit and subscribe to our
EngagePage (https://www.engagewr.ca/enablingfourunits ).
Separate comments are also welcome and can be emailed directly to: enablingfourunits@kitchener.ca
M
From: V K
Sent: Saturday, January 6, 2024 10:30 PM
To: Katie Anderl <Katie.Anderl@kitchener.ca>
Cc: Gaurang Khandelwal <Gaurang.Khandelwal@kitchener.ca>; Arwa Alzoor <Arwa.Alzoor@kitchener.ca>
Subject: Re: 4plex By -Law Questions
Thanks Katie, I'll definitely make a note to attend.
The only other point I would bring up that I thought about was parking setbacks in rear yard areas. I was
told that there was a 1.5m set back required on all three sides of the parking area (left and right side and in
front of the parking space between it and the property line). I agree with the right and left setbacks, but the
one between the space and property line is going to limit a ton of properties from being converted/developed
into 4 unit dwellings. We have a TON of 40ft lots where existing houses with laneway style driveways could
have a rear 2 storey bump out built on to them to create 3 additional units (bsmt, main, upper). If you lose
the 1.5m, it makes pulling in and out of that space more difficult. But if you're allowed to park the car right
up to the fence line, it opens up a ton of potential on that size of lot. Existing houses could be spared from
demo and more housing could be built. That's a win for the environmentalists, the developers and the
neighbours who want their streets to preserve their existing feel and look.
Thanks for the info and I'll make sure I attend.
Thanks!
Vlad
On Tue, 2 Jan 2024 at 14:48, Katie Anderl <Katie.Anderl@kitchener.ca> wrote:
Hi Mad,
Thanks for reaching out — your comments are timely. We are currently working on reviewing and drafting new
regulations, and will be engaging with the public and builders such as yourself throughout January.
We have just set up an EngagePage: https://www.engagewr.ca/enablingfourunits I would encourage you to subscribe
to get updates on when engagement opportunities are added. We are planning a couple of public drop in sessions, a
virtual meeting as well as a builder/industry workshop.
With respect to your questions, I anticipate that two driveways will continue to be permitted for corner lots (however
driveways will continue to be subject to regulations for maximum widths, etc). I appreciate your feedback on the
limitations on pedestrian entrances. We are currently reviewing regulations for such matters and can take this one
back for further consideration.
25
Page 215 of 343
Thanks,
Katie
From: V K
Sent: Monday, January 1, 2024 9:49 PM
To: Katie Anderl <Katie.Anderl@kitchener.ca>; Gaurang Khandelwal <Gaurang.Khandelwal@kitchener.ca>
Subject: 4plex By -Law Questions
Hey Katie and Gaurang
Hope you had a nice holiday.
I was given your contact info from one of the planners at the city in order to find out more information
regarding the proposed 4plex bylaw that the city will be voting on in the first quarter of this year.
Have you established any guidelines yet that you will be proposing for the bylaw? My interest relates to
parking and what will be the guidelines for it? I have a property located at 1180 Union St in Kitchener, which
I am hoping to convert to a 4plex if the bylaw is approved. I currently have a driveway from Union, but
would like to add a second off Maple Ave to accommodate the other parking spaces. I understand that this is
permitted for duplexes and triplexes for corner properties and am wondering if it will be allowed for 4plexes
as well?
I also want to know if the disastrous idea that was applied to triplexes which only allows for 1 door at the
front of the dwelling will also be applied to 4plexes? I will never understand how in a city that is promoting
densification, having more than one door at the front of the building is somehow seen as a negative. It
actually impedes our ability to design/redesign new and existing homes in an efficient manner in many cases
(depending on grading and lot size). I understand that a variance application can circumvent this, but that
then just becomes a cash grab for the city and time lost for the builder and future occupant. Is this also
going to be applied in the bylaw?
Thanks for any information you can provide.
Vlad Knezevic
26
Page 216 of 343
From: Katie Anderl
Sent: Wednesday, January 24, 2024 10:46 AM
To: Enabling Fou rUnits (SM)
Subject: FW: 4 Plex Lots
From: Leslie HOLDWAY
Sent: Wednesday, January 17, 2024 12:31 PM
To: Katie Anderl <Katie.Anderl@kitchener.ca>
Subject: 4 Plex Lots
You don't often get email from
Katie
Here are physical examples of possible 3 and 4 plexes that would fit 20 to 25 foot lot widths
Les Holdway
27
Page 217 of 343
t.4A
�JIr
r�
Ildl I-- � ��
A
. ,�.> �: \i�p :. : \ � \� � \ �� § \ � � \: \ �
Khandelwal<Gaurang.Khandelwal@kitchener.ca>; Hajnal Kovacs <Hainal.Kovacs@kitchener.ca>
Subject: FW: Headline in record Jan 19 Front Page
From: Debbie Chapman <Debbie.Chapman@kitchener.ca>
Sent: Sunday, January 21, 2024 9:14 AM
To: Carolyne Wagner
Cc: Jeffery Silcox -Childs <Jeffery.Silcox-Childs@kitchener.ca>; Joshua Shea <Joshua.Shea@kitchener.ca>
Subject: Re: Headline in record Jan 19 Front Page
Hi Carolyne,
Thank you for contacting me about this important issue. I pasted a couple links below that detail the city's tree
conservation policies and urban forest goals. Of course, there is always room for improvement. I am copying Jeffery
Silcox -Childs and Joshua Shea on this message, as they will be able to better respond to your concerns.
Regarding the role of the Horticultural Society, it is an independent body with its own board, budget and agenda. You
can learn more about the society at the following link: https://www.kitchenerhs.ca/about/
https://www.kitchener.ca/en/water-and-environment/tree-conservation-and-management.aspx
https://www.kitchener.ca/en/strategic-plans-and-projects/urban-forestry.aspx
I hope this helps.
Debbie Chapman, PhD
Subscribe to monthly newsletter here: https://bit.ly/3NMIDTe
Councillor, Ward 9 1 City of Kitchener
0: 519-741-2200 ext. 2798 C: 226-752-7104
Debbie.Chapman@kitchener.ca
aa U you 00
II`'C&J
Customers can now connect with the City of Kitchener anytime by calling the 24/7 Corporate Contact
Centre at 519-741-2345
From: noreply@kitchener.ca <noreply@kitchener.ca> on behalf of Carolyne Wagner
Date: Saturday, January 20, 2024 at 6:27 PM
To: Debbie Chapman <Debbie.Chapman@kitchener.ca>
Subject: Headline in record Jan 19 Front Page
[You don't often get email from 'Learn why this is important at
https://aka.ms/LearnAboutSenderldentification j
There was an article by Brent Davis in the Record Jan 19 about Kitchener properties allowing up to 4 units on large
lots. I would like to see something in the bylaw that ensures the owners must keep or plant the same size trees already
on the lot or add a certain number of trees. This has not been done in Queen St. South near Blueridge and I fear we will
soon be creating a concrete jungle with few trees, more global warming and poor drainage and habitats for small
animals and other plants. I was told by a city planner that they had no jurisdiction over how homeowners cut down
31
Page 220 of 343
trees in their property. This SHOULD change and I would hope you as a member of the horticultural society would have
more influence to see this becomes true.
I am not in the country right now and unable to attend any of the open houses or I would be there in person , for sure.
Origin: https://can0l.safelinks.r)rotection.outlook.com/?url=httr)s%3A%2F%2Fwww.kitchener.ca%2Fen%2Fcouncil-and-
city-administration%2FcounciIlor-debbie-
chapman.aspx&data=OS%7CO2%7Cdebbie.chapman%40kitchener.ca%7C4ae0eaaf497342ec9c2208dc19eS7b90%7Cc703
d791S3f643aS92SS622eb33a1b0b%7C0%7C0%7C63841372063384SS21%7CUnknown%7CTWFpbGZsb3d8eyJWlioiMC4
wLIAwMDAiLCJQ1 ioiV2luMzIiLCJBTi161k1haWwiLCJXVC16Mn0%3D%7C3000%7C%7C%7C&sdata =epbRPSTuaFW D2JU3kXv
aEObRnpxEwh7kr0udVVWpeDc%3D&reserved =0
This email was sent to you by Carolyne Wagner
https://can0l.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.kitchener.ca%2F&data=OS%7CO2%7Cdebbi
e.chapman%40kitchener.ca%7C4ae0eaaf497342ec9c2208dc19eS7b90%7Cc703d791S3f643aS92SS622eb33alb0b%7C0
%7CO%7C63841372063384SS21%7CUnknown%7CTWFpbGZsb3d8eyJWlioiMC4wLiAwMDAiLCJQlioiV2luMzliLCJBTil6lklh
aWwiLCJXVC16Mn0%3D%7C3000%7C%7C%7C&sdata=hilxN9KkxDoVlzYKuiekPsxOkJBnADscssRYQSXiggU%3D&reserved=
0.
32
Page 221 of 343
From: Klas Bockasten
Sent: Sunday, January 21, 2024 11:32 AM
To: Justin Readman
Cc: Enabling Fou rUnits (SM)
Subject: The Missing Middle: Los Angeles Needs to Build Different Types of Housing
You don't often get email from
Hi,
thought you might find this page interesting:
htti)s://commonedge.org/the-missing-middle-los-angeles-needs-to-build-different-types-of-housing/
know it does not exactly meet the discussion on four-plexes, but highlights the need to construct the missing middle. My oldest
daughter lives in Malmo, Sweden, so I am quite familiar with the area and the missing middle discussed in the article about Los
Angeles. Contact me if you want to discuss this further.
Klas Bockasten
33
Page 222 of 343
From: Enabling Fou rUnits (SM)
Sent: Wednesday, January 10, 2024 10:41 AM
To: 'Sam Head'; Enabling Fou rUnits (SM)
Cc: 'brockl'; 'Andrew Head'
Subject: RE: Four Units -
Hi Sam,
Thanks for your comments below. We are exploring many different permutations of how four units can work, and what
the constraints might be.
The intention of this project is to enable zoning to permit four units and expand the number of lots and existing
dwellings that can take advantage of such expansions. We have had some experience and uptake now on the 3 units
per lot regulations which have been in place since early summer 2023, and are exploring whether we can allow for some
reduced lot widths and sizes, and to consider when parking may or may not be required for additional units and how it
can be organized.
Applicants must still comply with building permit requirements, and we acknowledge that there are various fees and
costs that are associated with development. However, site plan approval and urban design review will not be
required. We will require a basic site plan as part of the zoning occupancy certificate and building permit process to
allow a review for compliance with zoning regulations.
There may also be some additional projects and work as next steps to creating the enabling zoning for example
resources and guide for homeowners and builders, further exploration of financial incentives etc. This is beyond the
scope of this initial project, but may be explored to help support uptake, and will follow as next steps.
We will be hosing a workshop and open house targeted to builder/developers/industry on January 31 (workshop
(registration required) 1— 3 and open house (drop-in) 3 — 6) at the Forest Heights Community Centre. If you subscribe to
our engage page you will received further notice when more details are available:
https://www.enp,agewr.ca/enablinp,fourunits .
Thanks!
Katie
From: Sam Head
Sent: Monday, January 8, 2024 2:17 PM
To: EnablingFourU nits (SM) <EnablingFourUnits@kitchener.ca>
Cc: 'brockl' <brockl@dsh.ca>; 'Andrew Head' <andrewh@dsh.ca>
Subject: Four Units -
Hi Katie
As I understand the system currently, every residential property with a single house is entitled to adding an additional
unit.
34
Page 223 of 343
Additions to the building and conversion of the basement to add a unit basically does not need planning approvals but
needs building permit ,plumbing approvals and pay building permit fees.
The owner needs to hire a qualified designer. I assume the usual DC and Parkland fees apply.
Adding an ADU Additional Dwelling Unit requires planning approvals and has to go through pre consultation process to
see if it will work.
No consent is permitted and you need to connect to the municipal services via the existing home.
Again you need a builder designer. Pay the permits fees and other municipal Regional Fees,
Often leads to the owner getting a survey done. And hiring a planner to get them through the process.
A servicing contractor is necessary for the sanitary , water and electrical work. More expenses.
Parking is often a problem. We are often looking at Tandem parking.
This is all time consuming and expensive.
Often do not realize that the need to pay Development Charges to City, Region and School Boards. Sometime the GRCA
get it hand out for fees.
Some time there is a parkland dedication fee.
All of this makes it less desirable to the owner to go through that expense and the cost of actually building a home.
Most of our recent application need to go through a minor variance application process. More time and expenses.
I am saying all this to let you know that the easy is not easy.
On the question of adding 4 units.
This should say adding 3 or 4 units, if two are already permitted.
I don't see too many lots qualifying for three or four units.
People will see an opportunity to add more dwelling units to their property.
The City needs to be clear on how you might qualify for the additional units.
I would suggest that the 30 and 40 foot lots would have a had time meeting all the requirements for even an additional
unit.
Let assume the following.
Only large lots will have any chance of adding up to four units.
Do we need to provide 4 onsite parking spaces . One per unit.$$$
Will there be a frontage requirement.
Do you recognize that the existing dwelling is legal not conforming to reduce the number of variances.
Does every new unit pay the three development changes. $$$
How is the parkland dedication applied. Should have that number up front. $$$
How do you address the capacity in the existing sanitary and water line currently servicing one unit. They were not
designed or sized for four units.
Do we need to dig up the street and oversize the connection to the city systems. $$$
How about electrical. The current system is designed for one unit.
Need to retain an Designer qualified to work with City Building Departments.$$$
Building permit fees. Plumbing fees.
All contractors will need to be hired for these services. Renovations to the existing services to accommodate the
additional units.
Are you going to ask for Tree saving plan. Are you going to ask for Archaeological Assessment.
Does the Region get its hand on the project. They love to do unnecessary archaeological assessment because the
property may be in a area that is identified. Off all the one I have completed recently not was found.
35
Page 224 of 343
Can we add units to properties that are on Septic Systems.
I assume site plan application is not required.
We still do a site plan sketch on how things work. What is the level of detail that we will need to submit on behalf of our
clients.
Can we just give you a bunch of bicycle spaces in lieu of Parking.
Do we need to install an electrical charging station. $$$
You need to be up front with the rules, guidelines , etc. so we know what is required.
You going to ask for Urban Design.
You need to let property owners know what the cost will be and what is required.
Some random thoughts of a seasoned Planner.
Good luck with making this work
Love to see how this plays out.
Sam Head, President
Dryden, Smith & Head
Planning Consultants Ltd.
36
Page 225 of 343
From: Katie Anderl
Sent: Monday, January 8, 2024 8:09 AM
To: Enabling Fou rUnits (SM)
Subject: FW: 4plex By -Law Questions
From: V K
Sent: Saturday, January 6, 2024 10:30 PM
To: Katie Anderl <Katie.Anderl@kitchener.ca>
Cc: Gaurang Khandelwal <Gaurang.Khandelwal@kitchener.ca>; Arwa Alzoor <Arwa.Alzoor@kitchener.ca>
Subject: Re: 4plex By -Law Questions
Thanks Katie, I'll definitely make a note to attend.
The only other point I would bring up that I thought about was parking setbacks in rear yard areas. I was told
that there was a 1.5m set back required on all three sides of the parking area (left and right side and in front
of the parking space between it and the property line). I agree with the right and left setbacks, but the one
between the space and property line is going to limit a ton of properties from being converted/developed into
4 unit dwellings. We have a TON of 40ft lots where existing houses with laneway style driveways could have a
rear 2 storey bump out built on to them to create 3 additional units (bsmt, main, upper). If you lose the 1.5m,
it makes pulling in and out of that space more difficult. But if you're allowed to park the car right up to the
fence line, it opens up a ton of potential on that size of lot. Existing houses could be spared from demo and
more housing could be built. That's a win for the environmentalists, the developers and the neighbours who
want their streets to preserve their existing feel and look.
Thanks for the info and I'll make sure I attend.
Thanks!
M- ad
On Tue, 2 Jan 2024 at 14:48, Katie Anderl <Katie.Anderl@kitchener.ca> wrote:
Hi Mad,
Thanks for reaching out — your comments are timely. We are currently working on reviewing and drafting new
regulations, and will be engaging with the public and builders such as yourself throughout January.
We have just set up an EngagePage: httos://www.engapewr.ca/enablinpfourunits I would encourage you to subscribe
to get updates on when engagement opportunities are added. We are planning a couple of public drop in sessions, a
virtual meeting as well as a builder/industry workshop.
42
Page 226 of 343
With respect to your questions, I anticipate that two driveways will continue to be permitted for corner lots (however
driveways will continue to be subject to regulations for maximum widths, etc). I appreciate your feedback on the
limitations on pedestrian entrances. We are currently reviewing regulations for such matters and can take this one
back for further consideration.
Thanks,
Katie
From: V K
Sent: Monday, January 1, 2024 9:49 PM
To: Katie Anderl <Katie.Anderl@kitchener.ca>; Gaurang Khandelwal <Gaurang.Khandelwal@kitchener.ca>
Subject: 4plex By -Law Questions
Hey Katie and Gaurang
Hope you had a nice holiday.
I was given your contact info from one of the planners at the city in order to find out more information
regarding the proposed 4plex bylaw that the city will be voting on in the first quarter of this year.
Have you established any guidelines yet that you will be proposing for the bylaw? My interest relates to
parking and what will be the guidelines for it? I have a property located at 1180 Union St in Kitchener, which
I am hoping to convert to a 4plex if the bylaw is approved. I currently have a driveway from Union, but would
like to add a second off Maple Ave to accommodate the other parking spaces. I understand that this is
permitted for duplexes and triplexes for corner properties and am wondering if it will be allowed for 4plexes
as well?
43
Page 227 of 343
I also want to know if the disastrous idea that was applied to triplexes which only allows for I door at the
front of the dwelling will also be applied to 4plexes? I will never understand how in a city that is promoting
densification, having more than one door at the front of the building is somehow seen as a negative. It
actually impedes our ability to design/redesign new and existing homes in an efficient manner in many cases
(depending on grading and lot size). I understand that a variance application can circumvent this, but that
then just becomes a cash grab for the city and time lost for the builder and future occupant. Is this also going
to be applied in the bylaw?
Thanks for any information you can provide.
Mad Knezevic
44
Page 228 of 343
From: Ediphique Renovations
Sent: Friday, January 5, 2024 11:32 AM
To: Enabling Fou rUnits (SM)
Subject: Suggestions for Fourplex zoning
Hello,
I wanted to provide some feedback regarding the mandate to allow four units on any residential lot ( single detached,
semi-detached and townhouses). I have been researching fourplexes in different cities for a few years and have been
familiarizing myself with Kitchener's zoning over the past year.
I will say that Kitchener's Res -4 zoning is one of the more progressive I have seen. The set back and lot area parameters
as well as parking requirements are workable. The main difficulty we are having is securing land that has the correct
zoning with the right lot dimensions. As the number of properties with zoning for Res -4 is limited, securing the
appropriate land has proven challenging. So opening fourplexes up to all residential zones and using the existing Res -4
setbacks, lot, height and parking parameters would already be helpful.
I will make two suggestions for altering the existing Res -4 zoning to make it easier to work with.
1. Reducing the Interior Side Setbacks will help with both the conversion of existing houses and allow more flexibility in
design for new builds
2. Allow more flexible parking options; While rear individual access parking is the ideal arrangement, allowing front in
tandem parking may also work in some situations. Allowing this will also make it easier to convert existing homes into
four units.
If the goal is to go further than this then I would suggest a reduction in the frontage and lot area size. Right now the ADU
policy restricts 3 units on a property to 13.1m lot frontage and 395 sq m area. Making this the case for 4 units as well will
allow for builds on more residential plots, while still accommodating the parking and set back requirements outlined in
the Res -4 zoning. However, this may not accommodate semi-detached or townhouses.
Right now the semi-detached and townhouse min frontages would not allow 3 units under Kitchener's existing ADU
policy. The policy would have to reduce the min frontage required to 9.3m or 7.5m. With this, I believe that 4 units can
be comfortably accommodated within the building. The parking could be achieved in certain circumstances. 9.3m could
allow for a suitable building with tandem parking up the side, or double drive tandem to accomodate 4 spots.
If there is an option to forgo the parking requirement near transit or in the central areas then this can work better. I
myself lived in one of these types of 4 plexes (semi-detached) in Toronto during my school days. They work really well
near a university where students typically walk and don't have cars or in high transit areas where cars are not required.
I will mention though that as far as the 3 unit ADU policy goes, that can easily be accommodated on a 7.Sm or 9.3 m lot
frontage. The limitation of the 3 units to 13.1m frontage is removing the opportunity of semi-detached and townhouses
to accomodate more residents, as well as existing detached homes with smaller frontages. In the case of detached and
semi-detached buildings these can often allow tandem 3 car parking up the side of the building, or have garages that can
accommodate a third car. My thoughts are that 3 units with parking is easily achievable on 7.Sm or 9.3m frontages, 4
units in some circumstances (or with a parking exemption).
I was very happy to hear that four units were being considered for all residential homes. We have been advocates for
multi -residential builds for years and will participate in the building of these over the next few years. I hope my
suggestions will be helpful. I will try to attend one of the Neighbourhood meetings to connect.
45
Page 229 of 343
Please let me know if you would like to discuss any of my suggestions further.
Regards,
Amanda
Ediphique Developments
46
Page 230 of 343
From: Heidi Valee
Sent: Saturday, December 23, 2023 9:11 AM
To: Enabling Fou rUnits (SM)
Subject: Thought on this project
Hello,
Thank you for the opportunity to voice our opinions on this project.
I believe it needs careful consideration as to how this will impact neighbours in an established neighbourhood.
We bought our house because of the private backyard. We chose not to buy in a crowed subdivision where neighbours
can look over into each other's yards. We like our space and privacy. If our neighbours, for example, were to build
another unit on their property, they could potentially build one high enough that the occupants could have full view of
our yard. We have a pool and appreciate our privacy. I believe it would lower our property's value to have an intrusive
building overlooking our property. Not to mention shadows created etc.
The landscape of the Region of Waterloo has completely changed and in my opinion not for the better. We moved here
30 years ago from the Toronto area because the K -W area was a quiet, smaller region. It is the opposite now. Thanks to
both the City of Kitchener and the City of Waterloo it has been ruined. It is no longer the attractive area it used to be.
Random buildings are going up without any forethought of how it might change the aesthetics of our neighbourhoods.
Traffic in the area is also a nightmare that city officials don't seem to take in to consideration. This project is just another
one that could potentially make a mess of our region.
H. Valee
47
Page 231 of 343
The inquiries emails received:
Page 232 of 343
From: Enabling Fou rUnits (SM)
Sent: Friday, February 23, 2024 6:33 AM
To: 'theluketaylor'; Enabling Fou rUnits (SM)
Subject: RE: Draft zoning language
Hi Luke,
Thanks for reaching out — the 30% landscaping in the front yard and rear yard is intended to measured only on the areas
located within the front yard and the rear yard of a property. Therefore, with a front yard setback of 4.5 m and a width
of 10.5 m (47.25 m2) you would need 30% to be soft landscaping or about 16 m2 which accommodates the root zone for
a small tree, or plantings and grass.
For a rear yard having an area of 100 m2 would require 33 m2 to be landscaping which could include landscaping,
walkways, decks/patios and lands that are part of setback to the ADU or a parking area.
This adds up to about 49 m2 between the front and rear yard. We assume there may be more landscaping in side yards
(but possibly not if you require a walkway, or a driveway is located beside the house.) The intention of the regulations is
to ensure there is some green space in the front yard, and greenspace and private amenity space in rear yards. If you do
not have parking in your rear yard, the 30% should not be too difficult to achieve within the rear yard area.
This compares to a minimum 20% overall landscaped area for small multiples which would be about 75 m2 for 360 m
lot. The landscaped area may actually be less with the new zoning, but we are a bit more prescriptive with where it
needs to be.
The lot area for the ADU is measured based on 15% size of the entire lot (and coverage of all buildings is up to 55%) the
same as it is today. For a lot with the minimum lot size of 360 m2 your maximum ADU size would be about 54 m2.
If there are particulars of your property you wish to discuss please let us know,
Thanks,
Katie
From: theluketaylor
Sent: Thursday, February 22, 2024 9:14 PM
To: EnablingFourU nits (SM) <EnablingFourUnits@kitchener.ca>
Subject: Draft zoning language
Katie, Gaurang, and Arwa:
I have taken a look at the draft language to enable 4 units and I have questions about the landscaping coverage.
In the existing zoning code the landscaping coverage is 20%. In the draft it's 30% backyard and for 3/4 units it's 30% both
front and back, for 60% total landscaped. That's a staggering increase in landscaping requirements and seems to
drastically limit both lots that can have ADUs and the forms it's possible to actually use. How many city lots (especially in
the central city) currently have 30% front yard landscaped? Will this prevent prime infill development lots of being as -of -
right? What research led to 30% being the recommended value?
Page 233 of 343
From some quick measurements using the zoning map I have about 9% of the front yard landscaped. Would someone in
my situation need a variance to go to 3 or 4 units? If so, what would be the value of the variance process given the
whole point of by -right is to prevent special variance needs.
My backyard currently seems to be about 39% landscaped. Would that mean the maximum effective lot coverage I could
have in an ADU would be 9%, or about 40.S m"2 / 440 sq ft rather than the 1S%?
Absent the landscaped requirement an ADU on my lot could be around 67.5 m"2 / 730 sq ft. The landscaping
requirement seems to impose a nearly nearly 40% floor area penalty and would be the difference between a tight studio
and a comfortable 1 bedroom unit.
As part of developing plans for some renovations I looked into building an ADU with an architect this summer and came
away very disappointed. The existing restrictions resulted in such a small unit I would feel like an abusive landlord taking
advantage of a cost of living crisis.
I was excited about going to 4 units by right since it seemed like some of the arbitrary restrictions were planned to be
lifted, but it seems like the actual result is not substantially different from the existing code.
Am I misunderstanding the requirements (or my lot measurements)? How does dramatically increasing the requirement
for landscaping not just replicate the gross floor area restriction requirement in a different form?
Also, is there a reason to refer specifically to LRT when raising certain minimums? Shouldn't major bus interchanges like
Sunrise Centre get similar treatment?
Luke Taylor
Page 234 of 343
From: Katie Anderl
Sent: Thursday, February 22, 2024 8:29 AM
To: 'Michael Brisson'
Subject: RE: "Reaching YES on Infill via A New Making of Allowances"
Hi Michael,
Thanks for forwarding — unfortunately I was not able to access the file. Is there another format or file type you could try
sending?
Thanks,
Katie
From: Michael Brisson
Sent: Wednesday, February 21, 2024 9:27 PM
To: Katie Anderl <Katie.Anderl@kitchener.ca>
Subject: "Reaching YES on Infill via A New Making of Allowances"
Open my shared note:
Reaching YES on Infill via A New Making of
Allowances
Sent from my iPhone
Page 235 of 343
From: Rya n
Sent: Monday, February 5, 2024 4:40 PM
To: Enabling Fou rUnits (SM)
Subject: Re: 4 plexes on existing residential lots
Thank you Katie. I appreciate it.
I will review this material
Ryan
On Mon, Feb 5, 2024 at 4:32 PM EnablingFourUnits (SM)<EnablingFourUnits@kitchener.ca> wrote:
Hi Ryan,
Thanks for reaching out. The City of Kitchener is currently exploring regulations that would permit up to 4 units to be
located on lots which currently permit a single detached, semi- detached or street townhouse dwelling, subject to
regulations for items such as lot size, parking, etc (which are still being developed). You can learn more about this
project through our Engage Page: https://www.engagewr.ca/enablingfouru nits .
Kind Regards,
Katie Anderl
-----Original Message -----
From: noreply@kitchener.ca <noreply@kitchener.ca> On Behalf Of Ryan Moore
Sent: Monday, February 5, 2024 11:42 AM
To: Building (SM) <building@kitchener.ca>
Subject: 4 plexes on existing residential lots
Good morning,
I have had a client inquire asking me if City of Kitchener is following Toronto and letting investors potentially buy
certain existing lots to build 4 plexes on them. Any insight appreciated.
Regards,
Page 236 of 343
Ryan Moore
Keller Williams Innovation Brokerage Realty
Regards,
Ryan Moore
Sales Representative
ASA T11
CC Realty Group
Page 237 of 343
From: Enabling Fou rUnits (SM)
Sent: Monday, February 5, 2024 4:32 PM
To:
Cc: Enabling Fou rUnits (SM)
Subject: RE: 4 plexes on existing residential lots
Hi Ryan,
Thanks for reaching out. The City of Kitchener is currently exploring regulations that would permit up to 4 units to be
located on lots which currently permit a single detached, semi- detached or street townhouse dwelling, subject to
regulations for items such as lot size, parking, etc (which are still being developed). You can learn more about this
project through our Engage Page: https://www.engagewr.ca/enablingfouru nits .
Kind Regards,
Katie Anderl
-----Original Message -----
From: noreply@kitchener.ca <noreply@kitchener.ca> On Behalf Of Ryan Moore
Sent: Monday, February 5, 2024 11:42 AM
To: Building (SM) <building@kitchener.ca>
Subject: 4 plexes on existing residential lots
Good morning,
I have had a client inquire asking me if City of Kitchener is following Toronto and letting investors potentially buy certain
existing lots to build 4 plexes on them. Any insight appreciated.
Regards,
Ryan Moore
Keller Williams Innovation Brokerage Realty
Page 238 of 343
From: Yvonne Fernandes
Sent: Wednesday, January 31, 2024 1:39 PM
To: Enabling Fou rUnits (SM)
Subject: Re: Public Open House for Four Units
Thank you for the response to one of my questions.
I am waiting to understand the reason for not choosing another Community Center as a place for public engagement in
person.
Why was the Doon Pioneer Park Community Center not added as one of the locations for these open houses? With
our diverse community and the large number of students that we have living in this area, i would have thought it
would have been one of the most important areas to receive input from.
Cordially
Yvonne Fernandes
President of the Doon Pioneer Park Community Association
Follow your dreams of a better world, and keep on trying, even when there seems to be little hope, because it is the right
thing to do. Robert Alan.
On Wed, Jan 31, 2024 at 8:53 AM EnablingFourU nits (SM)<EnablingFourUnits@kitchener.ca> wrote:
Good morning,
Thank you for contacting us, yes we have one today
Jan. 31, 3 to 6 p.m. at Forest Heights Community Centre (1700 Queen's Boulevard)
In addition, please note that our open house poster and information are available Open House information now
available I Enabling Four Units I EngageWR
Our virtual neighborhood meeting is available online Enabling Four Units Everywhere - Virtual Neighbourhood Meeting
(youtube.com)
Please follow our Enabling Four Units I EngageWR and let us know if you have any questions or comments
23
Page 239 of 343
Thank you again for contacting us!
Regards,
Enabling Four Units Everywhere team
Development and Housing Approvals Division I City of Kitchener
519-741-2200 ext. 2426 1 EnablingFourUnits@kitchener.ca
o�e��oomoo
The City of Kitchener is situated upon the traditional territories of the Neutral, Anishinaabeg and Haudenosaunee Peoples. We extend
our respect to all First Nations, M6tis and Inuit peoples for their past and present contributions to this land. We also recognize and
respect the cultural diversity that First Nations, Metis and Inuit bring to the City of Kitchener.
From: Yvonne Fernandes
Sent: Tuesday, January 30, 2024 5:32 PM
To: EnablingFourU nits (SM)<EnablingFourUnits@kitchener.ca>
Subject: Re: Public Open House for Four Units
Hi Katie,
I understand that you are the project manager on this project. My husband and I attempted to attend an open house
that I believed was supposed to be at the Stanley Park Community Center.
Apparently it was scheduled for last week but I am almost certain that I saw that it was for today.
I will make my comments known on the Engage Kitchener site but I have a question that is more about the location of
these public open houses.
Why was the Doon Pioneer Park Community Center not added as one of the locations for these open houses? With our
diverse community and the large number of students that we have living in this area, I would have thought it would
have been one of the most important areas to receive input from.
24
Page 240 of 343
Will there be any more opportunities for the public especially in the Doon /Pioneer Park area to attend a public
meeting? If not then I believe that you will have a very skewed response from those attending the open houses that
were made available to the public.
I would ask that another opportunity for the public to respond in person to this very significant change to our
community be considered before the report comes to Council.
Respectfully,
Yvonne Fernandes
President of the Doon Pioneer Park Community Association
Follow your dreams of a better world, and keep on trying, even when there seems to be little hope, because it is the
right thing to do. Robert Alan.
25
Page 241 of 343
From: Jenn L. Ward <
Sent: Friday, January 26, 2024 2:46 PM
To: Enabling Fou rUnits (SM)
Cc: Nicole Cotie
Subject: Additional units and group home bylaws
Good afternoon,
It was great to speak with City of Kitchener staff about the Enabling Four Units project at the Stanley Park
Community Centre. I appreciate how the City of Kitchener has provided various opportunities for information
sharing and feedback.
I represent Karis Disability Services (formally Christian Horizons), a developmental services agency with six
properties in Kitchener registered as group homes (non -correctional) as per zoning bylaws. The Engaging Four
Units projects has raised a zoning bylaw question for us that actually applies to any additional units on the
same lot. Currently the City of Kitchener group home definition in 430.1.1 defines a group home as 3-10
people, and zoning bylaw 5.17 and 4.9 state there can only be one group home per lot. If we were to add an
addition or renovate a lower level to create two separate dwelling units, both supporting 3 people, we create
2 group homes on a lot which appears would not have zoning approval. When we discussed this on Tuesday,
staff wondered if the bylaw could be interpreted to mean one group home operator per lot, however this
would require clarification in the current wording in the bylaw. If this is not the intent, then a revision to the
bylaw is needed to ensure that increased housing opportunities created by additional units on the same lot is
more widely available to include people who experience disabilities.
Thank you for flagging this question and bringing it forward for further discussion.
For further contact and consultation feel free to contact:
Jennifer Ward, Community Facilities Specialist - jward@karis.org
Nicole Cotie, Community Development Manager— ncotie@karis.org
Thank you,
Jennifer
My email has recently changed to jwardMaris.org to reflect our new name! Please update your email contacts to reflect
this change. Emails received byjword@christion-horizons.org will continue to forward for the time being.
Jennifer Ward
Community Facilities Specialist
Karis Disability Services — West District (formally Christian Horizons)
Supporting the regions of Waterloo, Wellington, Hamilton, Niagara, Halton and Peel
Cell: 519-505-3878
27
Page 242 of 343
We've changed our name!
C:hrj� tianii oriroris
1
ka r s disability
services — I
New Name. Same Values.
CONFIDENTIALITY: This email message (including any attachments), is confidential and intended only for the addressee.
Any unauthorized use or disclosure is strictly prohibited. If you received this communication in error, please notify the
sender immediately and delete this from your systems. Thank you for your cooperation.
Karis Disability Services, formerly Christian Horizons Waterloo Office 1 26 Peppler St, Waterloo, ON N2J 3C4 1519-783-
6810 1 www.christian-horizons.org
You are receiving this message because of your interaction with Karis Disability Services, formerly Christian Horizons. To
unsubscribe click here.
28
Page 243 of 343
From: Planning (SM)
Sent: Tuesday, January 23, 2024 3:40 PM
To: Kevin Stewart
Cc: Enabling Fou rUnits (SM)
Subject: RE: Request arising from Enabling Four Units Market info booth
Hello Kevin, I am forwarding this to the enablingfourunits email, copied above. One of the staff involved in that review
will reply.
Regards
Sheryl
From: Kevin Stewart
Sent: Tuesday, January 23, 2024 3:32 PM
To: Planning (SM) <planning@kitchener.ca>
Subject: Request arising from Enabling Four Units Market info booth
I found Market info booth and your video informative however before commenting on proposed change, my request is:
Could one of your staff members contact me to arrange a phone meeting to review how the proposed zoning change
would affect our specific property as it has a non rectangular shape with 8 adjoining properties?
Thank you for your consideration of this.
Kevin Stewart
29
Page 244 of 343
Arwa Alzoor
From:
Katie Anderl
Sent:
Monday, January 22, 2024 2:00 PM
To:
'Sam Head'
Cc:
'Andrew Head'; 'Brock Linklater'
Subject:
RE: Four Units
Hi Sam,
Yes, there is opportunity for additional units in Heritage Conservation Districts, however the architectural controls and
heritage permit processes would continue to apply like they would for any development or redevelopment. We have
been discussing this with our Heritage Planning Staff as well.
Parkland dedication would be in accordance with the policy in place. My understanding from our parks staff is that if
these are additional dwelling units, they would not be required to contribute to parkland dedication.
Thanks,
Katie
From: Sam Head
Sent: Monday, January 22, 2024 1:50 PM
To: Katie Anderl <Katie.Anderl@kitchener.ca>
Cc: 'Andrew Head' ; 'Brock Linklater'
Subject: Four Units
Hi Katie
Watched the video.
Can you do this in the Designated Heritage Districts.
There are areas with a lot of smaller homes i.e. near the St Mary's hospital.
Will parkland dedication apply.
Thanks
Sam Head, President
Dryden, Smith & Head
Planning Consultants Ltd.
30
Page 245 of 343
From:
Katie Anderl
Sent:
Monday, January 22, 2024 1:32 PM
To:
'Peter Maxwell'; Michael Maxwell
Subject:
RE: Enabling Four Units - Development Industry Workshop and Open House
Attachments:
Virtual Meeting Presentation.pdf
Hi Peter,
Here is a copy of the slide deck from our virtual meeting.
King Regards,
Katie
From: Peter Maxwell
Sent: Friday, January 19, 2024 7:43 PM
To: Katie Anderl <Katie.Anderl@kitchener.ca>; Michael Maxwell
Subject: Re: Enabling Four Units - Development Industry Workshop and Open House
Hi Katie,
Thanks for the quick response. I saw the video. I was hoping for the slides instead of writing down the
information provided.
Thanks,
Peter
From: Katie Anderl <Katie.Anderl@kitchener.ca>
Sent: January 19, 2024 7:40 PM
To: Peter Maxwell ; Michael Maxwell
Subject: RE: Enabling Four Units - Development Industry Workshop and Open House
Hi — yes, there is a link to a recording of the presentation available through our engagepage:
httos://www.engap,ewr.ca/enablingfouru nits
Regards,
Katie
From: Peter Maxwell <
Sent: Friday, January 19, 2024 5:51 PM
To: Michael Maxwell Katie Anderl <Katie.Anderl@kitchener.ca>
Subject: Re: Enabling Four Units - Development Industry Workshop and Open House
Hi Katie,
Can you share the slides that were used for the Enabling Four Units Everywhere - Virtual Neighbourhood
Meeting?
32
Page 246 of 343
Thanks,
Peter Maxwell
Maxwell Building Consultants
From: Michael Maxwell
Sent: January 19, 2024 5:11 PM
To: Peter Maxwell
Subject: Fwd: Enabling Four Units - Development Industry Workshop and Open House
Get Outlook for Android
From: Katie Anderl <Katie.Anderl@kitchener.ca>
Sent: Friday, January 19, 2024 5:07:12 PM
Cc: EnablingFourUnits (SM)<EnablingFourUnits@kitchener.ca>
Subject: Enabling Four Units - Development Industry Workshop and Open House
Enabline Four Units
The City of Kitchener is growing and more homes are needed to meet the needs of existing and future residents. In
March 2023, the City of Kitchener made a Municipal Housing Pledge to build an additional 35,000 homes by 2031. A key
component of this pledge includes enabling more housing that will support gentle intensification in our existing low rise
residential areas. Council has directed staff to prepare a by-law to enable up to 4 dwelling units on a lot which currently
permits a single detached, semi-detached or street -fronting townhouse dwellings. These additional dwellings could be
located in existing buildings, additions to buildings or new buildings (either as the main building or in the backyard),
subject to regulations.
You're invited to provide input!
Planning is seeking input from builders, developers and others in the development industry as we review existing zoning
regulations and prepare revisions that will support and enable additional units in residential neighbourhoods. We are
inviting interested members of the development industry to join us in a focused workshop session, or to drop in to an
Open House to discuss regulations with us.
Workshop: January 31, 2024 1:00 — 2:30 pm at the Forest Heights Community Centre (1700 Queens Boulevard).
Workshop space is limited to 20 participants and registration is required. Please email enablingfourunits@kitchener.ca
to confirm your attendance.
Open House: January 31, 2024, 3:00 — 6:00 pm at the Forest Heights Community Centre (1700 Queens Boulevard).
Drop-in any time to this open house which is open to the development industry and the public.
You are also welcome to attend a Public Open House. These are scheduled for Saturday, January 20, 7:00 am — 2:00 pm
at the Kitchener Market, and Tuesday, January 23, 3:00 — 7:00 pm at the Stanley Park Community Center.
For more information and to share your feedback through our short survey, please visit and subscribe to our
EngagePage (https://www.engagewr.ca/enablingfourunits ).
Separate comments are also welcome and can be emailed directly to: enablingfourunits@kitchener.ca
Regards,
33
Page 247 of 343
Arwa Alzoor
From: Maxim Carpenter
Sent: Friday, December 22, 2023 12:49 PM
To: Enabling Fou rUnits (SM)
Subject: Re: Doon
It does a bit re. Preferential treatment ...
Still hate the idea and what it'll do to our city.
Thankyou
On Fri, Dec 22, 2023 at 12:46 PM EnablingFourU nits (SM) <EnablingFourUnits@kitchener.ca> wrote:
Hello Maxim,
The council's decision on Lower Doon applied RES -4 zoning across the majority of Lower Doon. Therefore 4 units is
permitted. Going beyond 4 units is what Council didn't approve
xaugmy etgnt area properties tnat c urrenui . nae nigner-aensity zoning wouiu
keep it.
The maximum height for low-rise residential properties throughout the area is
being raised slightly from 10.5 metres to 11 metres, or a rna.,dmum of three
storeys; this is in beeping with similar zoning city-wide.
"It's a very dedicated group of citizens in Lower Doon who lore their
community, and they also work well with the college and the college students„
said ward Coun. Christine Michaud, acknowledging there have leen
frustrations.
"My goal when I first started... was to create a beautiful Lower Doon where
the students and the residents can live harmoniously and just continue to
grow."
New hiLyhri se develunment in the area is being directed to the ,vacant lands
I hope that clarifies your concern
35
Page 248 of 343
From: Maxim Carpenter
Sent: Friday, December 22, 2023 9:21 AM
To: Enabling Fou rUnits (SM)
Subject: Re: Doon
It doesn't seem that way....
https://www.therecord.com/news/waterloo-region/revised-development-plan-for-kitchener-s-lower-doon-would-limit-
density-in-existing-neighbourhood/article 36e82058-c152-59ba-b24a-783b72f9bbe9.html
Honestly this is a terrible idea
https://Phys.0rg/news/2023-06-houses-high-rises-zoning-hasnt-effective.amp
Anyway, it seem like the die is cast and our politicians are going to cram this down our throats regardless. It is
unfortunate the wealthy in the region will not have to suffer with the rest of us.
On Fri, Dec 22, 2023 at 9:04 AM EnablingFourUnits (SM) <EnablingFourUnits@kitchener.ca> wrote:
Hello,
Thank you very much for reaching out to the 4 units the team
This project applies everywhere in the city
We are working on updating our regulation to enable 4 units everywhere in the city in Single Detached, Semi Detaches
and street townhouse
There is an increase in housing demand, and part of that is promoting a variety of housing options.
This project includes opportunities for community input. Your comments will help us to determine the appropriate
permissions to include in a proposed four -unit dwelling by-law, for example:
lot width, area and setbacks
building height and form
driveways and parking provisions
Please let me know if you have any input, recommendation, thoughts or questions about that
Regards,
Arwa Alzoor
Planner I Planning Division I City of Kitchener
519-741-2200 ext. 7847 1 arwa.alzoor@kitchener.ca
The City of Kitchener is situated upon the traditional territories of the Neutral, Anishinaabeg and Haudenosaunee
Peoples. We extend our respect to all First Nations, Metis and Inuit peoples for their past and present contributions to
this land. We also recognize and respect the cultural diversity that First Nations, Metis and Inuit bring to the City of
Kitchener.
39
Page 249 of 343
From: Sue Weare
Sent: Thursday, December 21, 2023 4:06 PM
To: Enabling Fou rUnits (SM)
Subject: FW: New on Engage Kitchener: Enabling Four Units Everywhere
Sue Weare (she/they)
Community Engagement Consultant I Communications and Marketing I City of Kitchener
519-741-2200 x 7058 I TTY 1-866-969-9994 I sue.weare(cOkitchener.ca
From: Cari Van Niekerk <Cari.VanNiekerk@waterloo.ca>
Sent: December 21, 2023 2:08 PM
To: Sue Weare <Sue.Weare@kitchener.ca>
Subject: Fwd: New on Engage Kitchener: Enabling Four Units Everywhere
From: Byron Murdock
Sent: Thursday, December 21, 2023 1:27:37 PM
To: Cari Van Niekerk
Subject: [EXTERNAL] RE: New on Engage Kitchener: Enabling Four Units Everywhere
The unmanageable policies of asylum seekers have created this problem and that is a whole different
discussion. To me it is not the number of permitted units on a property. More effective is the number of
inhabitants per unit. It is common in our current over abundance of immigrants that there is two or three
families in one unit. The federal policies need to change. My message is stopping immigration until we can
catch up and diversify the landing spots. It seems KW has more than its share of new Canadians and I am
opposed to that.
From: Engage<EngageWR-NoReply@repionofwaterloo.ca>
Sent: Thursday, December 21, 2023 12:54 PM
To: Byron Murdock
Subject: New on Engage Kitchener: Enabling Four Units Everywhere
41
Page 250 of 343
From: Sue Weare
Sent: Thursday, December 21, 2023 4:06 PM
To: Enabling Fou rUnits (SM)
Subject: FW: [EXTERNAL] Re: New on Engage Kitchener: Enabling Four Units Everywhere
Sue Weare (she/they)
Community Engagement Consultant I Communications and Marketing I City of Kitchener
519-741-2200 x 7058 1 TTY 1-866-969-9994 1 sue.weare(cOkitchener.ca
From: Cari Van Niekerk <Cari.VanNiekerk@waterloo.ca>
Sent: December 21, 2023 2:07 PM
To: Sue Weare <Sue.Weare@kitchener.ca>
Subject: Fwd: [EXTERNAL] Re: New on Engage Kitchener: Enabling Four Units Everywhere
From: Carolyn Hertzberger
Sent: Thursday, December 21, 2023 1:09:19 PM
To: Cari Van Niekerk
Subject: [EXTERNAL] Re: New on Engage Kitchener: Enabling Four Units Everywhere
No housing projects on agricultural land, or expanded boundary changes. Ford has reversed that concept so I expect that
no building will occur on land outside the borders of our urban development.
Calandra may want to approve that land but that is a corrupt process, against the new provincial legislation. If Kitchener
builds outside the boundary , that they are also corrupt, going against the law.
On Thu, Dec 21, 2023, 12:54 p.m. Engage<EngageWR-NoReply@regionofwaterloo.ca> wrote:
eNGAGe
K I T C H E N E R
44
Page 251 of 343
From: Katie Anderl
Sent: Thursday, December 21, 2023 3:50 PM
To: Enabling Fou rUnits (SM)
Subject: FW: New on Engage Kitchener: Enabling Four Units Everywhere
From: Sue Weare <Sue.Weare@kitchener.ca>
Sent: Thursday, December 21, 2023 2:09 PM
To: Katie Anderl <Katie.Anderl@kitchener.ca>
Subject: FW: New on Engage Kitchener: Enabling Four Units Everywhere
And also this one.
Sue Weare (she/they)
Community Engagement Consultant I Communications and Marketing I City of Kitchener
519-741-2200 x 7058 1 TTY 1-866-969-9994 1 sue.weareCa)kitchener.ca
000000000
From: Cari Van Niekerk
Sent: December 21, 2023 2:08 PM
To: Sue Weare <Sue.Weare@kitchener.ca>
Subject: Fwd: New on Engage Kitchener: Enabling Four Units Everywhere
From: Byron Murdock
Sent: Thursday, December 21, 2023 1:27:37 PM
To: Cari Van Niekerk
Subject: [EXTERNAL] RE: New on Engage Kitchener: Enabling Four Units Everywhere
The unmanageable policies of asylum seekers have created this problem and that is a whole different
discussion. To me it is not the number of permitted units on a property. More effective is the number of
inhabitants per unit. It is common in our current over abundance of immigrants that there is two or three
families in one unit. The federal policies need to change. My message is stopping immigration until we can
catch up and diversify the landing spots. It seems KW has more than its share of new Canadians and I am
opposed to that.
From: Engage<EngageWR-NoReply@regio nofwaterloo.ca>
Sent: Thursday, December 21, 2023 12:54 PM
To: Byron Murdock
Subject: New on Engage Kitchener: Enabling Four Units Everywhere
50
Page 252 of 343
From: Maxim Carpenter
Sent: Thursday, December 21, 2023 3:28 PM
To: Enabling Fou rUnits (SM)
Subject: Doon
Why was Doon exempted from this. Is it only middle class people that are going to have to put up with the disruption
this will cause???
It would seem like the large lots in Doon, Hidden Valley and Westmount would be best suited to this. Start there and
then expand the project.
Honestly, you guys are going to do this no matter what so this whole outreach is pointless.
It feels like you guys are intentionally prioritizing newcomers & drug addicts over the people that live here and
contribute.
Please plan to quadruple the size of every school where this policy is put in place.
Maybe think about the quality of life of residents who will have to suffer through ongoing major construction,
destruction of peaceful neighborhoods and property values. Based on the regions track record that seems highly
unlikely but hopefully things change soon.
Max
53
Page 253 of 343
Attachment G4 — Summary of Open Houses
and Industry Workshop Feedback
The following are notes from staff, based on feedback received through discussions at
the three Open Houses and the Development Industry Workshop.
Open House at Kitchener Market — January 20, 2024
• Overall positive feedback, supportive of allowing more units on each property.
• Concern about tree loss and associated urban heat impacts with canopy loss.
• Concern about the increased impervious surface on residential properties and
implications for stormwater management (infiltration) and climate change factors
— increased frequency and intensity of storms and urban heat islands (retention
of heat in paved surfaces). Suggestion for a maximum impervious ratio on
properties and requirement that driveways and/or walkways be made of pervious
materials (e.g., pervious pavers).
• Side/rear setbacks avoid impacts on adjacent properties, such as stairs in the
side yard and limited space to get to the rear yard on a property (e.g., residents
or maintenance requiring access to neighboring properties).
• Request that we consider allowing direct access to a trail (e.g., Iron Horse or
Spur Line trail) as the primary access (1.1 m sidewalk) rather than requiring it to a
front yard.
• Questions about the degree of impact that this project would have on new
housing being created.
• Concerns that units would become short-term rentals.
• Concerns about the overall affordability of housing.
• Concerns about traffic and parking in the neighbourhood streets because some
properties do not have enough driveway capacity to accommodate 3-4 cars.
• Concerns about reducing parking requirements for neighborhoods that do not
have easy access to transit. One resident said it takes them 20-30 minutes to
walk to the nearest bus station.
Page 254 of 343
Open House at Stanley Park — January 23, 2024
• Allowance for lower ceiling heights in the basement (staff indicated that this is a
building code matter).
• Feedback about allowing detached ADUs at the regulatory exterior side setback
rather than in alignment with the house on a corner lot.
• Questions about electrical capacity in neighbourhoods (indicated that Enova is
circulated through the process).
• Concern about parking — where vehicles would be stored (over -use of on -street
parking) or illegal widening/parking on the lawn.
• Questions about the rules in a dual zone lot (NHC and RES)
• Questions around group homes and whether more than one unit can be used for
the group home with the same operator.
• Property owner perspective concerns about privacy and overlook — placement of
units, overlook into the rear yard (sides of long additions).
• Concerns about servicing capacity — sanitary, SWM — area is very flat (e.g.,
some places may not work).
• Opposition to growing at all — questioning why we need to grow.
• From a developer perspective, allow for narrower lots - triplex rules are too
restrictive and can be functional on smaller lots. Consider flexible street frontage
if all the other requirements can be met.
• Avoid variance from a process perspective.
• Side yard setback for a parking lot should be 0.6m
• From a developer perspective, 4 doors at the front should be permitted as it can
be challenging from a floor plan perspective. Stairs may project in the front yard.
• Interest in shared driveways between two properties to have a narrower
driveway.
• Concern about neighbourhood character — moved to the neighbourhood for the
density, and it is proposed to change (parking, number of people).
Page 255 of 343
Open House at Forest Heights — January 31, 2024
• General supporting feedback
• Suggestion to allow the Additional Dwelling Unit detached in the exterior yard,
including the front yard.
• Suggestion to allow a prefabricated tiny home for faster approval process.
• Concern about the overall impact on greenspace and parking around the city.
• Concern with shadow impacts for the additional dwelling units detached.
• Supporting the geographical approach to parking requirement.
• Concern about property values if neighbouring properties build four units.
• Concern about impacts to on -street parking and that visitors to their home would
not have access to on -street parking.
Development Industry Workshop at Forest Heights — January 31, 2024
This workshop was attended by 20 participants in the development industry. The format
included table discussions with each group discussing each theme. The following are
staff notes from the workshop.
Theme 1: Lot Width and Lot Area
• Parking will drive lot width
• Access to Janeway lot width is not relevant
• Rely on coverage
• Consideration for character of neighbourhoods
• Allow higher heights rather than size requirements.
o 12.1 m
o Leave "as is"
o 12-13 m height
o Prefab
o Flat roof
• More rear lanes in new subdivisions to allow for narrow lots
• Builders see several additions or conversions for family arrangements.
• Keep the main lot area and reduce width.
• 13.1 m width comfortable for tiny homes
• 1.1 m walkway
• Reduce frontage to reduce side setback
• Need to shrink house
• Acquiring land -> more lots enabled
• See need for 2.5 m side yard setback
• Conversions need more space
• 40 ft will still need a variance
Theme 2: Parking
• Parking requirements should be different in different locations of the city
Page 256 of 343
• Bicycle parking can also be based on location
• Parking is a market-driven component
• Cars can be parked in the front as the legal parking space and tandem parking
can be considered
• Car share idea to reduce the number of cars
• Propose creative parking lot design to reduce hard surface
• Remove all the parking requirements and keep it to the market demand
• Parking can be on a rate of 0.5 per dwelling. This will balance the demand.
• Create accessible units, especially the ground floor unit, to be barrier -free and
have accessible parking space.
• Class A bicycle parking was not supported.
• Do not formalize the bicycle parking requirement.
• Parking rate should be reduced from the current By-law requirement.
• Permit system for street parking
• Shared parking/ shared car
• To make those units affordable, parking rate should be reduced.
Theme 3: Backyard Homes
• Existing garage to ADU
• Common space (amenity) — suggest 7 ft x width of house
• Flexibility
• 2 storey — egress - 7.2 m v 23 ft
• 2 units make sense technically.
• Cost of foundation
• Increase maximum footprint.
• Staircases take up space
• 80 m sq not enough
• Access is a problem
• How does it fit with urban design
• 2 storeys is viable
• Maintain it as subordinate, don't destroy the intent of additional units
• Trees
o Use existing streets
o Protect trees
• Corner lots good for ADUs
• ADU above garage -> demand
• Separation distance between primary and ADU -> OBC?
• 4' setback — closer?
• More height is beneficial
• RIENS rules limiting height based on the height of the principal dwelling is a
constraint
• Lot width -> pie shaped lots
• 6 m setback for parking
• School board DCs
Page 257 of 343
• Development Charge for 4t" unit — $40,000 CAD
• Storm water, infiltration galleries
• Green space
• Funding to take down old buildings
• Privacy, activity, shadow [vegetable garden]
o One storey is fine [preferable]
o Not in favor of 2 storeys
• Not maximizing the property
• Cap at 20ft flat roof
• Below grade
• Permitting 3 units in ADU — going beyond
• Impossible with townhouse
• Less concerned with number of units
• Laneway housing -> 2 storeys is okay
• Exterior side yard -> okay!
Theme 4: Building Design
Number of doors on front facade:
• Current rules noted as not being flexible. Don't limit number of doors but perhaps
limit the way the doors are facing.
• Concern of tear downs and rebuild. Make it easier to retrofit existing buildings.
• Cross comment of rebuilds being designed to fit the community and offer more
flexibility in design.
• Can you save the original house and focus on ADU at 3 units?
• Can the City push to develop properties that have existing laneways in the rear?
• Allow multiple doors. Doors and entrances must be fire rated and effects egress
(Building Code issues).
• Common corridor in a building is wasted space.
• More flexibility of door layout.
• Natural layout of a building usually results on doors along the sides or rear of a
building.
• No opinion on doors. Supported one door.
• One door is restrictive.
• Can you have one door but a projecting vestibule with access to other units?
• One door can result in unfunctional front door.
Access and building projection:
• Many existing homes don't have existing weeping tiles.
• Slab on grade is preferred instead of pushing people into the basement resulting
in more vertical projection.
• Try to preserve original house and focus on new build.
• Difficulties with mechanical units projecting into access area while maintaining
proper access widths.
• Mandate a clear egress width.
Page 258 of 343
• Door along the side of the house beside mechanical works.
• Grading and external stairs.
• Mobility concerns.
• More allowance for new mechanical works.
• Cluster mechanical to one side of the building with access on the other all while
considering setbacks.
• Door swing should be prioritized where doors are located not for the whole
walkway.
• Can mechanical works be elevated?
• Allowance in zoning to allow for pop outs.
• Trees vs. Parking. Provide opportunities to plant more trees.
• Private trees should be allowed to be removed.
• Shared trees and needing to preserve the canopy may limit uptake.
• More options for tree replacements.
• No arborists should be needed. Adds to cost.
• Can trees be replaced?
• Private trees should be dealt with privately.
• Private landscaping is encouraged and incentivized.
• Make the expectations clear.
• Permits slow the process down.
• Bad thing to take down large -diameter trees. Toronto requires permit for private
trees over 0.3m diameter to be removed.
Servicing:
• Concern for SWM and increased impervious areas. Triggered through the
Building Permit process.
• Green roofs could be a SWM solution.
• Checklist for owners: Have you thought about these things?
• Where are downspouts going?
• Make it clear when servicing upgrades are required.
• Potentially oversize services during upsizes.
• For properties that don't have lot certification the developer should be notified
prior to issuing an ADU building permit.
Other:
• Maximum height of buildings should be increased.
• Height restrictions result in accessibility issues. Easiest way is slab on grade.
• Get the real estate community involved.
• Can you get a cross-section of the development community to do test project.
• Set up an online tool to do mock up site layouts of each property.
• Less trips to CofA
• Time is important.
• Make it very clear what the requirements are.
Page 259 of 343
• Monitor where the City is seeing increased re -development clusters.
• More public awareness.
• To increase uptake, reduce red tape... Parking!!
• Get rid of the requirement to eliminate Committee of Adjustment for existing
building layouts that don't meet bylaw.
• This will be successful if it is creative.
General feedback about how the City can support uptake:
• Get real estate industry involved
• Pilot program
• Online tool -> automate
• Simple library for ADUs
• Direct link to zoning requirements by property
• Flexibility so that it doesn't go to Committee of Adjustment
• Approval process is time consuming and expensive
• Clearer regulations
• Where severances are happening? Where is density going? (analyze planning
trends)
• Public awareness / questions on what going
• Eliminate the need for minor variance for addition to existing building setbacks
• Templates
o Good to have
o May not always work
o Need to consider site constraints
Page 260 of 343
From: Lingard, Norman <norman.lingard@bell.ca>
Sent: Wednesday, November 29, 2023 12:56 PM
To: Katie Anderl
Subject: Enabling Four Units Everywhere (OPA/ZBA)
You don't often get email from norman.lingard(ftell.ca. Learn why this is important
Good afternoon Katie,
Thank you for circulating Bell Canada on the City of Kitchener's OPA and ZBA. Bell appreciates
the opportunity to engage in infrastructure and policy initiatives across Ontario.
While we do not have any specific comments or concerns pertaining to this initiative at this time,
we would ask that Bell continue to be circulated on any future materials and/or decisions related
to this matter.
Please forward all future documents to circulations(a)wsp.com and should you have any
questions, please contact the undersigned.
Yours truly,
Norm Lingard
Senior Consultant — Municipal Liaison
Network Provisioning
norman.lingard(a�bell.ca 365.440.7617
Please note that WSP operates Bell Canada's development, infrastructure and policy tracking
systems, which includes the intake and processing of municipal circulations. However, all
responses to circulations and requests for information will come directly from Bell Canada, and
not from WSP. WSP is not responsible for the provision of comments or other responses.
This email message, and any attachments, may contain information or material that is confidential, privileged and/or subject to
copyright or other rights. Any unauthorized viewing, disclosure, retransmission, dissemination or other use of or reliance on this
message, or anything contained therein, is strictly prohibited and may be unlawful. If you believe you may have received this
message in error, kindly inform the sender by return email and delete this message from your system
Page 261 of 343
From: Shaun Wang <shaun.wang@enovapower.com>
Sent: Thursday, December 14, 2023 11:24 AM
To: Katie Anderl
Cc: Gaurang Khandelwal; Arwa Alzoor; Greig Cameron
Subject: RE: Circulation for Comment - Enabling Four Units Everywhere (OPA/ZBA)
You don't often get email from shaun.wang@enovapower.com. Learn why this is important
Katie,
In Kitchener, the City allows up to 3 units per residential property (i.e. 3 Units Everywhere).
It can be either a triplex building or duplex building with a detached backyard small unit.
Our current service requirement: "one hydro service connection with multiple meters (ganged) allowed".
There will be only one service connection from hydro owned transformer to the property (ESA requirement, one service
per property).
The customer can install one ganged multiple -meter base (typically 2-4 meters) at the connection point thus each unit
can be individually metered/billed.
To enable the 4 units Everywhere project, we should be OK without changing the current hydro connection
requirement.
Regards,
Shaun Wang P.Eng. I Manager of System Planning and Customer Connections
Enova Power Corp
301 Victoria St. South, Kitchener, ON N2G 41_2
Office Number: 519-745-4771 x6312
shaun.wang@enovapower.com I enovapower.com
From: Katie Anderl <Katie.Anderl@kitchener.ca>
Sent: Monday, December 11, 2023 10:47 AM
To: Greig Cameron <greig.cameron@enovapower.com>; Shaun Wang <shaun.wang@enovapower.com>
Cc: Gaurang Khandelwal <Gaurang.Khandelwal@kitchener.ca>; Arwa Alzoor <Arwa.Alzoor@kitchener.ca>
Subject: FW: Circulation for Comment - Enabling Four Units Everywhere (OPA/ZBA)
Some people who received this message don't often get email from katie.anderl(@kitchener.ca. Learn why this is important
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you
recognize the sender and know the content is safe.
Good morning,
Page 262 of 343
I wanted to reach out to your directly on the City of Kitchener's Enabling 4 Units Everywhere project to see if you had
any comments or feedback. Through this project we are looking at creating zoning regulations that would allow up to 4
dwelling units on a residential lot.
Over the last few years we have seen incremental increases in homeowners duplexing, triplexing and adding tiny homes,
and wanted to get your thoughts on how this has been going — and if there is anything that we need to consider as we
create regulations for 4 units.
I'd be happy to chat by phone, or arrange for a teams call if there is anything you would like to discuss or feel is
important for us to be aware of as we create regulations.
Thanks!
Katie
Katie Anderl
Project Manager - Planning I Planning Division I City of Kitchener
S19-741-2200 x7987 I TTY 1-866-969-9994 1 katie.anderl(@kitchener.ca
Woo
From: Christine Kompter<Christine.Kompter@kitchener.ca>
Sent: Thursday, November 16, 2023 11:27 AM
To: —DL—#—DSD—Planning <DSD-PlanningDivision@kitchener.ca>; Bell - c/o WSP <circulations@wsp.com>; Carlos Reyes
<Carlos.Reyes@kitchener.ca>; Darren Kropf <Darren.Kropf@kitchener.ca>; Dave Seller <Dave.Seller@kitchen er.ca>;
David Paetz <David.Paetz@kitchener.ca>; Ellen Kayes <EIIen.Kayes@kitchener.ca>; Enova Power Corp. - Greig Cameron
<greip.cameron@enovapower. com>; Enova Power Corp. - Shaun Wang <shaun.wang@enovapower.com>; Fire
Prevention (SM) <FirePrevention@kitchener.ca>; GRCA - Planning (planning@grandriver.ca) <planning,@grandriver.ca>;
Hydro One - Dennis DeRango <landuseplanninp,@hvdroone.com>; Jim Edmondson <Jim.Edmondson@kitchener.ca>;
Justin Readman <Justin.Read man@kitchener.ca>; Katherine Hughes <Katherine.Hughes@kitchener.ca>; Mike Seiling
<Mike.Seiling@kitchener.ca>; Ontario Power Generation<Executivevp.lawanddevelopment@opp,.com>; Park Planning
(SM) <Park.Planning@kitchener.ca>; Region - Howard Chang (SChang@repionofwaterloo.ca)
<SChang@rep,ionofwaterloo.ca>; Region - Planning < Plan ningApplications@region ofwaterloo.ca>; Property Data
Administrator (SM) <PropDataAdmin@kitchener.ca>; Robert Morgan <Robert.Morgan@kitchener.ca>; Steven Ryder
<Steven.Ryder@kitchener.ca>; Sylvie Eastman <Sylvie.Eastman@kitchener.ca>; UW-WUSA (Feds) (pres@wusa.ca)
<pres@wusa.ca>; WCDSB - Planning <planninp,@wcdsb.ca>; WRDSB - Board Secretary (elaine burns@wrdsb.ca)
<elaine burns@wrdsb.ca>; WRDSB - Planning <planning@wrdsb.ca>
Cc: Katie Anderl <Katie.Anderl@kitchener.ca>
Subject: Circulation for Comment - Enabling Four Units Everywhere (OPA/ZBA)
Please see attached. City staff can reference AMANDA folders 23-126057 & 23-126060. Comments or questions should
be directed to Katie Anderl, Project Manager (katie.anderl@kitchener.ca; 519-741-2200 x7987). A post circulation
meeting will be scheduled for November 29th and meeting invites will be sent to those who should attend.
Christine Kompter
Administrative Assistant I Planning Division I City of Kitchener
200 King Street West, 6th Floor I P.O. Box 1118 Kitchener ON N2G 4G7
519-741-2200 ext. 7425 1 TTY 1-866-969-9994 christine.kompter@kitchener.ca
Page 263 of 343
From: Sylvie Eastman
Sent: Tuesday, February 20, 2024 4:17 PM
To: Katie Anderl
Cc: David Paetz; Khaled Abu-Eseifan; Tammer Gaber; Gaurang Khandelwal
Subject: RE: Circulation for Comment - Enabling Four Units Everywhere (OPA/ZBA)
Hi Katie. We currently upsize main in 3 different circumstances:
1. Capacity Projects. In 2020 a list of —10 "Capacity Projects" were approved to be constructed over —10yrs to
address low pressure in the Bridgeport area. These are upsizing significant mains near the pressure regulating
stations and/or heading towards Bridgeport. These projects have their own budget, but we do the work with
the same resources (i.e. internal and contract staff) as the Gas Pipelines projects, so we manage all gas projects
on a portfolio basis.
2. New Services. In some cases there is insufficient capacity in the main to accommodate a new service, so the
main needs to be upsized. This doesn't happen very often.
3. Replacement Projects. Every year I do some "Replacement Projects" under the Gas Pipelines budget. There are
a few ways a project can end up on my potential replacement list, and once on the list the projects are
prioritized based on a number of factors.
a. Conflict. If the road authority (i.e. City of Kitchener Engineering, Region of Waterloo, or Ministry of
Transportation Ontario) identifies that existing infrastructure is in conflict with proposed work, then I
have to replace/relocate the stuff that is in conflict.
b. Concern Raised by Staff. If KU staff (normally corrosion technologist or C&M supervisor) indicates that
the main is in poor condition.
c. Road Reconstruction. If the road is being reconstructed (i.e. is on capital forecast for City or Region),
then I look at the records and prioritize it based on a number of factors. Depending on other priorities, I
might replace up to about half of the gas mains on streets that are being reconstructed.
If the main is being replaced, then I check to see if I think upsizing is warranted. Some circumstances might
be:
i) The pressure loss (per the model) is very high,
ii) The main appears to be a chokepoint between two larger mains, or
iii) I am aware that densification is desired in the area (e.g. near LRT).
Thanks, Sylvie (she/her)
519-498-9553
From: Katie Anderl <Katie.Anderl@kitchener.ca>
Sent: Tuesday, February 20, 2024 2:51 PM
To: Sylvie Eastman <Sylvie.Eastman@kitchener.ca>
Cc: David Paetz <David.Paetz@kitchener.ca>; Khaled Abu-Eseifan <Khaled.Abu-Eseifan@kitchener.ca>; Tammer Gaber
<Tammer.Gaber@kitchener.ca>; Gaurang Khandelwal <Gaurang.Khandelwal@kitchener.ca>
Subject: RE: Circulation for Comment - Enabling Four Units Everywhere (OPA/ZBA)
Hi Sylvie,
Thanks for the comments and sorry for the delayed reply. We are currently putting together our report for Council
consideration at the end of March.
With respect to your questions:
We cannot predict what the uptake will be, however we expect it will be incremental, especially at first. This has been
our experience with ADU's so far.
Page 264 of 343
With respect to ongoing upgrades to the system and upsizing — do you monitor the system to see where there may start
to be improvements needed? I wonder if this is a next step that would need to be considered in terms of expansion and
growth?
Lots with additional dwellings are not permitted to be severed. However if a severance was proposed it would have to
go through a planning act process and there would be a full review/report and separate service connections would be
required for each new lot.
There are no changes proposed reductions to building setbacks.
Thanks,
Katie
From: Sylvie Eastman <Sylvie.Eastman@kitchener.ca>
Sent: Wednesday, November 29, 2023 1:51 PM
To: Katie Anderl <Katie.Anderl@kitchener.ca>
Cc: David Paetz <David.Paetz@kitchener.ca>; Khaled Abu-Eseifan <Khaled.Abu-Eseifan@kitchener.ca>; Tammer Gaber
<Tammer.Gaber@kitchener.ca>
Subject: RE: Circulation for Comment - Enabling Four Units Everywhere (OPA/ZBA)
Hi Katie. A few comments. David normally deals with new business and gas modelling so he may have additional
comments.
1. Do we have any idea what the actual intensification will be? Likely there will be more intensification in certain
areas (e.g. downtown and along LRT), have these been delineated? For example, if all single residential
addresses quadrupled the number of units and residents, this would be a 400% increase and existing gas mains
(along with water, sewer, etc) would be undersized. However, if actual uptake was only ^'S% this would be a
20% increase and given each person is likely to use less gas in future (through more efficient appliances, partly
or entirely switching to electric, etc) I don't think we would see a significant difference.
2. If mains need to be upsized to accommodate the growth, how will these projects be funded? We handle this for
gas with our Conditions of Service, and if a main has to be upsized due to a large development (e.g. huge multi -
residential development), the cost is charged back to the proponent. However, this won't work if the main
needs to be upsized because of 100 smaller developments happening over a period of years. What if the first 99
developments are ok and then the 100th pushes the main into being inadequate, how would we go after the
previous 99 people? Will we collect funds at the application stage and set it aside to fund upsizing services in
aggregate? If we don't end up upsizing services for a certain period of time would we give money back, and how
would we manage that? If we don't charge the people who are intensifying their properties but instead fund it
out of overall rates, is it fair for all ratepayers to effectively subsidize these projects, particularly since the people
adding the units presumably would be profiting from rent etc?
3. Are we planning to allow/encourage the properties to be subdivided? If so, then we will probably need a lot of
easements for gas services. Unlike water & sewers, the gas service piping in private property is owned by KU up
to the meter set. We have never worried about getting an easement for services on private property because
the services were installed at the property owner's request. However, if we will have a bunch of properties that
are not immediately next to a road right-of-way then services would have to go through a third party property
and would need an easement. This would also necessitate a maintenance program to inspect easements on a
regular basis for code compliance (e.g. no structures on top of gas piping etc).
4. Are we planning to change setbacks to allow more space for construction? Excavating right to the lot line could
undermine utilities within the public right-of-way. Shallow utilities (gas, hydro, telecoms) are often close to the
property line.
5. Not related to gas, but just checking you have considered multiple aspects of additional on -street parking and
consulted with relevant stakeholders. This isn't just a matter of whether street parking would provide the
additional spots needed for the 3 additional dwelling units, but also:
a. Garbage collection. Based on my personal experience, garbage is not collected if a vehicle is parked on
the street (i.e. if the truck can't drive immediately next to the garbage). If you want to maintain garbage
Page 265 of 343
collection, this would need to be worked out in the Region's garbage collection contract and I don't
know if additional costs would apply. If you don't want to maintain the current garbage collection
program, again you would need to work out with the Region what the new program would look like.
b. Snow plowing and leaf pickup.
c. Emergency services (i.e. can fire trucks fit down the street if people are parked on both sides). If you
need to make residential streets 1 -way to allow more space for parking, how will this impact emergency
response times?
d. Construction & maintenance services. Would additional on -street parking limit access by repair
crews? This is probably a question for Tammer Gaber
Thanks, Sylvie (she/her)
519-498-9553
From: Christine Kompter<Christine.Kompter@kitchener.ca>
Sent: Thursday, November 16, 2023 11:27 AM
To: _DL_#_DSD_Planning <DSD-PlanningDivision@kitchener.ca>; Bell - c/o WSP <circulations@wsp.com>; Carlos Reyes
<Carlos.Reyes@kitchener.ca>; Darren Kropf <Darren.Kropf@kitchener.ca>; Dave Seller <Dave.Seller@kitchen er.ca>;
David Paetz <David.Paetz@kitchener.ca>; Ellen Kayes <EIIen.Kayes@kitchener.ca>; Enova Power Corp. - Greig Cameron
<greig.cameron@enovapower. com>; Enova Power Corp. - Shaun Wang <shaun.wang@enovapower.com>; Fire
Prevention (SM) <FirePrevention@kitchener.ca>; GRCA - Planning (planning@grandriver.ca) <planning@grandriver.ca>;
Hydro One - Dennis DeRango <landuseplanning@hvdroone.com>; Jim Edmondson <Jim.Edmondson@kitchener.ca>;
Justin Readman <Justin.Read man@kitchener.ca>; Katherine Hughes<Katherine.Hughes@kitchener.ca>; Mike Seiling
<Mike.Seiling@kitchener.ca>; Ontario Power Generation <Executivevp.lawanddevelopment@opg.com>; Park Planning
(SM) <Park.Planning@kitchener.ca>; Region - Howard Chang (SChang@regionofwaterloo.ca)
<SChang@regionofwaterloo.ca>; Region - Planning < Plan ningApplications@region ofwaterloo.ca>; Property Data
Administrator (SM) <PropDataAdmin@kitchener.ca>; Robert Morgan <Robert.Morgan@kitchener.ca>; Steven Ryder
<Steven.Ryder@kitchener.ca>; Sylvie Eastman <Sylvie.Eastman@kitchener.ca>; UW-WUSA (Feds) (pres@wusa.ca)
<pres@wusa.ca>; WCDSB - Planning <planninp,@wcdsb.ca>; WRDSB - Board Secretary (elaine burns@wrdsb.ca)
<elaine burns@wrdsb.ca>; WRDSB - Planning <planning@wrdsb.ca>
Cc: Katie Anderl <Katie.Anderl@kitchener.ca>
Subject: Circulation for Comment - Enabling Four Units Everywhere (OPA/ZBA)
Please see attached. City staff can reference AMANDA folders 23-126057 & 23-126060. Comments or questions should
be directed to Katie Anderl, Project Manager (katie.anderl@kitchener.ca; 519-741-2200 x7987). A post circulation
meeting will be scheduled for November 291h and meeting invites will be sent to those who should attend.
Christine Kompter
Administrative Assistant I Planning Division I City of Kitchener
200 King Street West, 6th Floor I P.O. Box 1118 Kitchener ON N2G 4G7
519-741-2200 ext. 7425 1 TTY 1-866-969-9994 christine.kompter@kitchener.ca
I ii�oi�11; � a 04 1 1�
IJ I I I a r
Page 266 of 343
From: Chris Foster -Pengelly <cfosterpengelly@grandriver.ca>
Sent: Wednesday, December 20, 2023 2:19 PM
To: Katie Anderl
Subject: Enabling Four Units Everywhere - Zoning By-law Amendment ZBA23/035/K/KA, Official
Plan Amendment OPA23/020/K/KA
Attachments: Kitchener-4_Units_Everywhere_grca_comments-20231220.pdf
Hi Katie,
Please find attached GRCAs comments on the above noted proposed amendments.
Thank you,
Chris
Chris Foster -Pengelly, M.Sc.
Assistant Supervisor of Resource Planning
Grand River Conservation Authority
400 Clyde Road, PO Box 729
Cambridge, ON N1 R 5W6
Office: 519-621-2763 ext. 2319
Toll-free: 1-866-900-4722
Email: cfosterpengelly@grand river.ca
www.arand river. ca, I Connect with us on social media
Page 267 of 343
Mand Riker
anion P
December 20, 2023
Administration Centre: 400 Clyde Road, P.O. Box 729 Cambridge, ON N1 R 5W6
Phone: 519-621-2761 Toll free: 1-866-900-4722 Fax: 519-621-4844 www.grandriver.ca
via email
Katie Anderl, Project Manager
Planning Division, City of Kitchener
200 King Street West
Kitchener, ON, N2G 4G7
Re: Zoning By-law Amendment ZBA23/035/K/KA
Official Plan Amendment OPA23/020/K/KA
Dear Katie Anderl,
The Grand River Conservation Authority (GRCA) is in receipt of the draft official plan /
zoning by-law amendments (OPA/ZBA) as part of the City initiated `Enabling Four Units
Everywhere,' received by GRCA staff November 16, 2023.
GRCA has reviewed this proposal under the Mandatory Programs and Services
Regulation (O.R. 686/21), including acting on behalf of the Province regarding natural
hazards identified in Section 3.1 of the Provincial Policy Statement (PPS, 2020), as a
regulatory authority under Ontario Regulation 150/06 and as a public body under the
Planning Act as per our CA Board approved policies.
The GRCA understands that the proposed OPA/ZBA would permit 4 dwelling units on
any lot that would permit a single -detached dwelling, semi-detached dwelling or street
fronting townhouse dwelling. Based on our review of the circulation notice, we have the
following comments:
1. While we recognize that it is not how the Official Plan and Zoning Bylaw are
currently structured, we recommend that the OPA/ZBA highlights the creation of
additional dwelling unit(s) as being restricted / made conditional on meeting
natural hazard requirements, by directly noting that they are subject to the
applicable natural hazard sections of the OP (6.C.2) and zoning bylaw (17.2.1 /
17.2.2).
Page 1 of 2
Member of Conservation Ontario, representing Ontario's 36 Conservation Authorities I The Grand — A Canadian Heritage River
Page 268 of 343
We trust this information is of assistance. If you have any questions or require
additional information, please contact the undersigned at 519-621-2763 ext. 2319 or
cfosterpengelly@g rand river. ca.
Sincerely,
;/ - U--
Chris
Foster-Pengelly, M.Sc.
Assistant Supervisor of Resource Planning
Engineering and Planning Services
Page 2 of 2
Page 269 of 343
From: Lenore Ross
Sent: Wednesday, December 20, 2023 4:30 PM
To: Katie Anderl
Subject: RE: Circulation for Comment - Enabling Four Units Everywhere (OPA/ZBA)
Attachments: OPA ZBA Comments NEW PD By-law.docx
Hi Katie,
Attached are comments for Zoning By-law Amendment ZBA23/035/K/KA and Official Plan Amendment
OPA23/020/K/KA.
Regards,
Lenore
From: Christine Kompter<Christine.Kompter@kitchener.ca>
Sent: Thursday, November 16, 2023 11:27 AM
To: _DL_#_DSD_Planning <DSD-PlanningDivision@kitchener.ca>; Bell - c/o WSP <circulations@wsp.com>; Carlos Reyes
<Carlos.Reyes@kitchener.ca>; Darren Kropf <Darren.Kropf@kitchener.ca>; Dave Seller <Dave.Seller@kitchen er.ca>;
David Paetz <David.Paetz@kitchener.ca>; Ellen Kayes <EIIen.Kayes@kitchener.ca>; Enova Power Corp. - Greig Cameron
<greig.cameron@enovapower.com>; Enova Power Corp. - Shaun Wang <shaun.wang@enovapower.com>; Fire
Prevention (SM) <FirePrevention@kitchener.ca>; GRCA - Planning (planning@grandriver.ca) <planning@grandriver.ca>;
Hydro One - Dennis DeRango <landuseplanning@hydroone.com>; Jim Edmondson <Jim.Edmondson@kitchener.ca>;
Justin Readman <Justin.Read man@kitchener.ca>; Katherine Hughes<Katherine.Hughes@kitchener.ca>; Mike Seiling
<Mike.Seiling@kitchener.ca>; Ontario Power Generation <Executivevp.lawanddevelopment@opg.com>; Park Planning
(SM) <Park.Planning@kitchener.ca>; Region - Howard Chang (SChang@regionofwaterloo.ca)
<SChang@regionofwaterloo.ca>; Region - Planning<PlanningApplications@regionofwaterloo.ca>; Property Data
Administrator (SM) <PropDataAdmin@kitchener.ca>; Robert Morgan <Robert.Morgan@kitchener.ca>; Steven Ryder
<Steven.Ryder@kitchener.ca>; Sylvie Eastman <Sylvie.Eastman@kitchener.ca>; UW-WUSA (Feds) (pres@wusa.ca)
<pres@wusa.ca>; WCDSB - Planning <planning@wcdsb.ca>; WRDSB - Board Secretary (elaine_burns@wrdsb.ca)
<elaine_burns@wrdsb.ca>; WRDSB - Planning <planning@wrdsb.ca>
Cc: Katie Anderl <Katie.Anderl@kitchener.ca>
Subject: Circulation for Comment - Enabling Four Units Everywhere (OPA/ZBA)
Please see attached. City staff can reference AMANDA folders 23-126057 & 23-126060. Comments or questions should
be directed to Katie Anderl, Project Manager (katie.anderl@kitchener.ca; 519-741-2200 x7987). A post circulation
meeting will be scheduled for November 291h and meeting invites will be sent to those who should attend.
Christine Kompter
Administrative Assistant I Planning Division I City of Kitchener
200 King Street West, 6th Floor I P.O. Box 1118 Kitchener ON N2G 4G7
519-741-2200 ext. 7425 1 TTY 1-866-969-9994 christine.kompter@kitchener.ca
60"0000000
Page 270 of 343
City of Kitchener
Zone Change / Official Plan Amendment Comment Form
Address: City Wide
Owner: various
Application: ZBA23/035/K/KA and OPA23/020/K/KA
Comments Of: Parks and Cemeteries — Design and Development
Commenter's Name: Lenore Ross
Email: Lenore.ross@kitchener.ca
Phone: 519-741-2200 ext 7427
Date of Comments: Nov 29 2023
0 1 plan to attend the meeting (questions/concerns/comments for discussion)
❑ No meeting to be held
❑ I do NOT plan to attend the meeting (no concerns)
1. Documents Reviewed:
OPA/ZBA Circulation letter dated November 16 2023
2. Proposed changes:
The City of Kitchener is proposing to amend Official Plan Policies and Zoning By-laws 85-1 and 2019-
051 to permit up to 4 dwelling units on any lot that would permit a single -detached dwelling, semi-
detached dwelling or street fronting townhouse dwelling. Four units could be configured in many
different ways including but not limited:
- Renovating and/or adding onto an existing single detached, semi-detached or street -fronting
townhouse dwelling so there are 4 units.
- Demolishing and building a new purpose-built 4 -unit multiple dwelling.
- Renovating/adding an addition onto an existing single detached, semi-detached or street -fronting
townhouse to convert to three units and adding a detached additional dwelling until (tiny home).
- Permitting two units in a detached Additional Dwelling Unit (tiny home).
3. Comments & Issues:
Residential Intensification and Tree Assets / Tree Canopy Coverage
It is recognized that the provision of additional housing and residential intensification is a key
Corporate and Council priority. However, the City of Kitchener 2023-2026 Strategic Plan also
highlights some of the competing and conflicting interests that are relevant to the proposed OPA and
ZBA including the Corporate Climate Action Plan 2.0, implementing the tree canopy target plan and
implementing actions from parks master plan. The negative impacts to municipally owned tree assets
and the reduction in local and city-wide tree canopy coverage is of significant concern to Parks and
Cemeteries and if the proposed OPA and ZBA changes proceed, zoning regulations and other bylaw
changes should be implemented concurrently to minimize the impacts to existing tree assets and to
adequately offset / mitigate negative impacts to tree canopy targets and climate implications.
A City for Everyone
Working Together — Growing Thoughtfully — Building Community
auu-
of 343
City of Kitchener
Zone Change / Official Plan Amendment Comment Form
Adequate financial compensation or required mitigation for loss of municipal tree assets should be
formalized and updated to reflect true asset value and current replacement costs. Staff review,
inspection and certification times should be considered in these costs and process options. Zoning
bylaw regulations should be included to require fewer parking spaces; establish maximum numbers
of parking spaces and/or driveway area; limit driveway width changes and curb cut increases to sites
where tree infrastructure is not impacted; and limit front yard building expansions where there are
existing tree assets.
The loss of trees and canopy on private development lands or in shared private ownership as a result
of residential intensification also has a direct relationship to both overall tree canopy targets and to
climate initiatives and different zoning regulations, bylaw changes and tree planting strategies are
required to address this issue.
Application forms should be updated and clearly outline owner responsibilities with respect to
private, shared and municipal trees including required consent and possible consequences.
Parkland Dedication and 4 -units as of right
The current Parkland Dedication Policy allows an exemption for ADU's (currently defined through the
Official Plan and the Zoning Bylaws as 3 units /property) and the Parkland Dedication Policy and Bylaw
2022-101 do not explicitly state a number of ADU's permitted.
The Planning Act through the More Homes Built Faster Act changes allows that there will be no
Parkland Dedication required for up to and including 3 Additional Dwelling Units. The fourth unit,
under Provincial regulations, would be subject to Parkland Dedication. Municipal policies/bylaws can
exempt the 4th unit (or any threshold or type of units for that matter). Bylaw 2022-101 is under
appeal and cannot be revised until the appeals have been resolved. If the 4th unit is considered as an
ADU, no amendment is required to either the Bylaw or Policy document to implement the 4 -unit ADU
change. If the 4th -unit is considered as a multiple dwelling, a change to Bylaw 2022-101 and the Park
Dedication Policy would likely be necessary unless an additional section is included in the Policy to
reduce/exempt all residential development with 4 units or fewer. Legal Services may have additional
commentary.
Regardless of the manner in which the additional 4th unit is categorized through zoning and definitions
(ADU vs. multiple dwelling), if the Parkland Dedication reduction is extended to a 4th residential unit
threshold, there will be a loss of revenue to the City and to available park acquisition and development
funding specifically. This will reduce the ability of the City to provide new and/or enhanced park
facilities for residents and to implement actions identified in the City of Kitchener 2023-2026 Strategic
Plan such as implementing the Parks Master Plan, Parkland Acquisition Strategy and the Grand River
Park strategy.
A City for Everyone
Working Together — Growing Thoughtfully — Building Community
Pauu-
� of 343
From: Jennifer Passy <Jennifer.Passy@wcdsb.ca>
Sent: Wednesday, January 3, 2024 1:53 PM
To: Katie Anderl
Cc: Planning; Waterloo Region District School Board (planning@wrdsb.ca); Lauren Agar
Subject: Enabling Four Units Everywhere
You don't often get email from jennifer.passy@wcdsb.ca. Learn why this is important
Good afternoon Katie,
Thank you for the time to meet with you and other staff and agencies about the proposed policy framework which
would support four dwelling units on any lot that would permit a single -detached dwelling, semi-detached dwelling or
street fronting townhouse dwelling.
We are supportive of the city's initiative to establish opportunities for the development of affordable housing options.
As shared during our call on November 29, 2023, the board's primary interest in this matter relates to the impact of
additional dwelling units on student accommodation. It is unclear how many residential lots in the city could support
four dwelling units, or the number of units which may be created based on evidence from other jurisdictions.
The board continues to collect future residential unit data needed to support our accommodation planning efforts
throughout the region. Based on the significant infill and intensification occurring throughout the city, it would be
helpful to receive additional information related to the assumptions on number of units and locations where these
policies would support more units. Similar information has been requested as it relates to the city's Growing Together
policies.
Together, these policy initiatives may be transformational creating opportunities for more affordable housing. However
for the school board, the implications are currently unknown. With increasing enrolment pressures throughout the city,
more data will assist the board with projections and advocacy for capital funding to support this growth.
Thank you for considering our comments and requests for further information.
Sincerely,
Jennifer
Jennifer Passy, BES, MCIP, RPP
Manager of Planning
Waterloo Catholic District School Board
Phone: 519-578-3677, ext. 2253
Cell: S19 -S01-5285
Note: The offices of the WCDSB are closed on Fridays throughout the summer.
rte"I Waterloo Catholic
ANDistrict School Board
44-1
Disclaimer - This email and any files transmitted with it are confidential and contain privileged or copyright information.
You must not present this message to another party without gaining permission from the sender. If you are not the
intended recipient you must not copy, distribute or use this email or the information contained in it for any purpose
Page 273 of 343
From: WRDSB Planning <planning@wrdsb.ca>
Sent: Wednesday, December 20, 2023 11:51 AM
To: Katie Anderl
Cc: Planning; Jennifer Passy
Subject: Re: [Planning] Circulation for Comment - Enabling Four Units Everywhere (OPA/ZBA)
You don't often get email from planning@wrdsb.ca. Learn why this is important
Katie Anderl
Project Manager - Planning
City of Kitchener
katie.anderl(o)kitchener.ca
December 20, 2023
Re: Zoning By-law Amendment ZBA23/035/K/KA
Official Plan Amendment OPA23/020/K/KA
Enabling Four Units Everywhere
City of Kitchener
Dear Katie,
The Waterloo Region District School Board (WRDSB) has reviewed the City's proposal to amend Official Plan Policies
and Zoning By-laws 85-1 and 2019-051 to permit up to four (4) dwelling units 'as -of -right' on any lot that would permit a
single -detached dwelling, semi-detached dwelling or street fronting townhouse dwelling units on sufficient lot sizes. The
WRDSB offers the following comments:
As discussed during our call on November 29, 2023, the WRDSB's primary interest in this proposal relates to the impact
on student accommodation. Therefore, we encourage the City to include schools and student accommodation in the
"additional considerations" list (slide 6 of the presentation).
We acknowledge that with this proposal and the City's "Growing Together" project, infill and intensification potential within
the City may be transformational. The implications of these changes on school accommodation are currently unknown.
We continue to collect data to support our long-term accommodation plan; therefore, we would appreciate any additional
information the City can supply related to:
• The number and location of lots with the conditions (i.e., sufficient lot size) to allow for four units
• The number of units this could potentially add over time to the City
• Any modelling or assumptions the City has created to determine the potential for uptake (e.g., the conditions in
which developing four units on a lot is economically feasible, where the City has servicing capacity, etc.)
Should these amendments pass, this information will be critical for the WRDSB to advocate for sufficient student
accommodation capital to support the growth of the school -aged population within the City/Region.
Furthermore, parkland and open space are challenges in more dense areas of the City. We have concerns regarding the
adequate provision of parkland to support the number of future residents, which may result in unsanctioned use of school
property during school hours, as we have experienced in other areas of the Region.
Thank you for the opportunity to provide comments on this work. We request to be circulated on any future materials
related to this project. Please feel free to contact us to discuss any of our comments further.
Sincerely,
Page 274 of 343
Lauren Agar
Senior Manager of Planning
T: 519-570-0003 ext. 4596
cc: Jennifer Passy, Manager of Planning, Waterloo Catholic DSB
On Thu, 16 Nov 2023 at 11:26, Christine Kompter<Christine.Kompter@kitchener.ca> wrote:
Please see attached. City staff can reference AMANDA folders 23-126057 & 23-126060. Comments or questions should
be directed to Katie Anderl, Project Manager (katie.anderl@kitchener.ca; 519-741-2200 x7987). A post circulation
meeting will be scheduled for November 291h and meeting invites will be sent to those who should attend.
Christine Kompter
Administrative Assistant I Planning Division I City of Kitchener
200 King Street West, 6th Floor I P.O. Box 1118 1 Kitchener ON N2G 4G7
519-741-2200 ext. 7425 1 TTY 1-866-969-9994 1 christine.kompter@kitchener.ca
2
Page 275 of 343
From: Niall Melanson <Niall.Melanson@kitchener.ca>
Sent: Wednesday, March 6, 2024 2:50 PM
To: Katie Anderl <Katie.Anderl@kitchener.ca>
Subject: RE: Enabling Four Units - DSD-2024-066.docx
Hello Katie
I can advise that on behalf of Engineering I was consulted on regarding the OPA23/020/K/KA for the purpose of
permitting up to 4 dwelling units on lots which permit a single detached dwelling, semi-detached dwelling or street -
townhouse dwelling. I also took part in a community engagement meeting where Engineering specific topics were
discussed. I have reviewed the Staff Report relevant engineering sections and can support the direction and
recommendations.
Engineering can recommend that long term monitoring of our sanitary, stormwater and water distribution networks
continue in order to maintain the functionality of that infrastructure.
Thank you.
Niall Melanson, C.E.T.
Project Manager, Development Engineering, City of Kitchener
niall.melanson@kitchener.ca, 519-741-2200 x 7133
200 King St. W., Kitchener, ON N2G 4G7
Page 276 of 343
From: Nick Gollan <Nick.GolIan @kitchener.ca>
Sent: Monday, March 11, 2024 4:35 PM
To: Katie Anderl <Katie.Anderl@kitchener.ca>
Cc: Bu Lam <Bu.Lam @kitchener.ca>
Subject: RE: draft report DSD -2024-066 Additional Dwelling Units
Hi Katie,
This email confirms that I've reviewed the draft report and participated in discussions regarding sanitary and stormwater
servicing for additional dwelling units. I agree with and support the recommendations of the report, noting that, pending
the results of the Integrated Sanitary Master Plan, we may be bringing recommendations forward in the future to pause
additional development in certain areas where the necessary servicing capacity is not available.
Kind regards,
Nick Gollan, C.E.T. (he/him)
Manager, Planning and Programs I Sanitary and Stormwater I City of Kitchener
519-741-2200 ext. 7422 1 TTY 1-866-969-9994 1 nick.gollanakitchener.ca
From: Katie Anderl <Katie.Anderl@kitchener.ca>
Sent: Friday, March 8, 2024 2:11 PM
To: Nick Gollan <Nick.Gollan@kitchener.ca>
Subject: draft report
This version includes the section that you had previously reviewed. Its under the March 25 PSIC agenda in escribe if you
wish to see any of the appendices
Thanks!
Katie
Katie Anderl
Project Manager - Planning I Planning and Housing Policy— Development Services Department I City of Kitchener
519-741-2200 x7987 I TTY 1-866-969-9994 1 katie.anderl@kitchener.ca
Page 277 of 343
From:
Tim Benedict
Sent:
Tuesday, March 12, 2024 7:47 AM
To:
Katie Anderl
Cc:
Gaurang Khandelwal
Subject:
RE: 4 units project - final comments
Over the past four months Building has been engaged with Planning staff around the potential of adding additional
dwelling units (up to 4 units) to many residential properties in Kitchener.
We regularly meet with the Kitchener Development Liaison Committee as well as joining Planning at one of their
industry/public engagement sessions on January 31, 2024. The building industry welcomed the proposed changes and
provided feedback which Planning has addressed while balancing neighbourhood concerns.
The Building Division feels like the proposed regulations give the option for many different types of built form and look
forward to working with industry and residents in adding much needed additional dwelling units throughout the City of
Kitchener.
Regards
Tim Benedict, CET, CBCO (he/him)
Manager I Building Division I City of Kitchener
519-741-2200 x 7645 1 TTY 1-866-969-9994 1 tim.benedict@kitchener.ca
SAVE Try �`V�E
Go online and use your credit card to pay
I;L, p to $x,000) for F)uilding permits, surveys,
drawings and environmental reports.
For more information, visit
kitchener.ca/payon I i ne
From: Katie Anderl <Katie.Anderl@kitchener.ca>
Sent: Monday, March 11, 2024 11:35 AM
To: Tim Benedict <Tim.Benedict@kitchener.ca>
Cc: Gaurang Khandelwal <Gaurang.Khandelwal@kitchener.ca>
Subject: RE: 4 units project - final comments
Hi Tim,
Here is the final draft of the report — and I can also send the by-laws if you wish to review those as well. They are also in
escribe
Thanks,
Katie
Page 278 of 343
From: John Lubczynski <JLubczynski@regionofwaterloo.ca>
Sent: Tuesday, March 12, 2024 1:09 PM
To: Katie Anderl <Katie.Anderl@kitchener.ca>
Cc: Alyssa Bridge <ABridge@regionofwaterloo.ca>
Subject: Regional Letter of Support - Kitchener's Enabling Four Units Initiative
You don't often get email fromilubczynski(@regionofwaterloo.ca. Learn why this is important
Hi Katie,
Attached is our letter of support regarding the City's Enabling Four Units initiative.
Thanks very much for consulting with us on this important project. Please reach out if you have any questions.
Regards,
John
John Lubczynski, MPI., MCIP RPP
Senior Planner
Planning, Development and Legislative Services
Regional Municipality of Waterloo
150 Frederick Street, 8th Floor
Kitchener ON Canada N2G 4.13
Tel. 519-575-4532
JLubczynski@regionofwaterloo.ca
Page 279 of 343
Region of Waterloo
Katie Anderl
Project Manager (Planning)
DSP Department - Planning & Housing
Kitchener City Hall, 6th Floor
200 King Street West, P.O. Box 1118
Kitchener ON N2G 4G7
Dear Ms. Anderl:
PLANNING, DEVELOPMENT
AND LEGISLATIVE SERVICES
Community Planning
150 Frederick Street 8th Floor
Kitchener Ontario N2G 4A Canada
Telephone: 519-575-4400
TTY: 519-575-4608
Fax: 519-575-4466
www.regionofwaterloo.ca
John Lubczynski - 519-575-4532
File: ZBA23/035/K/KA
OPA23/020/K/KA
March 12, 2024
Policy Division
Re: City of Kitchener's Enabling Four Units Initiative
Zoning By-law Amendment - ZBA23/035/K/KA and
Official Plan Amendment - OPA23/020/K/KA
Thank you very much for the opportunity to comment on the City of Kitchener's Enabling
Four Units initiative. Regional staff have been actively participating in your consultation
process and would like to offer the following letter of support.
This initiative seeks to permit up to four dwelling units on any lot that allows a single -
detached dwelling, semi-detached dwelling or street fronting townhouse dwelling,
subject to regulations. The additional units could be located in existing buildings,
additions to new buildings, or new buildings in the backyard. The proposal would also
permit the construction of a new purpose-built residential building on a lot having up to
four dwelling units.
We commend the City for undertaking this important project to build more homes in
existing low-rise residential areas. This work will spur gentle intensification and help
meet the growing demand for new housing across the city. It will also increase housing
options, including more rentals, affordable and attainable units, and housing close to
schools, public transit and other community services to accommodate the needs of all
households. This initiative will not only help generate new housing supply, it will also
lead to more equitable and inclusive communities.
4616500
Page 280 of 343
As you may recall, Regional Council adopted Regional Official Plan Amendment No. 6
(ROPA 6) in August 2022. This amendment came into effect in April 2023 following its
approval by the Minister of Municipal Affairs and Housing.
ROPA 6 strengthens and modernizes the ROP in several key areas, including climate
action, equity and inclusion, and supporting the development of "missing middle"
housing in our communities. If implemented, the City's Enabling Four Units initiative
would directly support the achievement of all these policy goals.
In particular, permitting up to four units on a residential lot would directly conform to,
and implement the policy direction set out in ROP Policy 2.D.5.1, which states:
2.D.5.1 Area municipalities will establish policies in their official plans and
implementing zoning by-laws, to permit missing middle housing on a
residential lot located within an Urban Area or Township Urban Area.
Under the ROP, "missing middle housing" refers to a range of multiple unit housing
including, but not limited to multiplexes, stacked townhouses, apartments, and other
low-rise housing options. If approved, the City's proposed four units initiative would
directly align with this policy by targeting the smaller end of the missing middle housing
spectrum, which the City has referred to as the "missing little".
In closing, thank you again for consulting with us, and we look forward to collaborating
with the City on the implementation of this initiative moving forward. Please reach out to
us if you have any questions.
Yours truly,
C
Jon Lubczynski, MCIP, RPP
Senior Planner
cc. Alyssa Bridge, Region of Waterloo
4616500 2
Page 281 of 343