HomeMy WebLinkAboutDSD-2025-388 - A 2025-090 - 10 Abram Clemens Street
Development Services Department www.kitchener.ca
REPORT TO: Committee of Adjustment
DATE OF MEETING: September 16, 2025
SUBMITTED BY: Tina Malone-Wright, Manager, Development Approvals
519-783-8913
PREPARED BY: Tim Seyler, Senior Planner, 519-783-8920
WARD(S) INVOLVED: Ward 5
DATE OF REPORT: September 4, 2025
REPORT NO.: DSD-2025-388
SUBJECT: Minor Variance Application A2025-090 - 10 Abram Clemens St.
RECOMMENDATION:
That Minor Variance Application A2025-090 for 10 Abram Clemens Street requesting
relief from the following Sections of Zoning By-law 85-1:
i) Section 40.2.6 to permit a Floor Space Ratio (FSR) of 0.65 instead of the
maximum permitted FSR of 0.6;
ii) Section 40.2.6 to permit a building height of 16 metres instead of the maximum
permitted height of 10.5 metres; and
iii) Special Regulation Provision 765R Multiple Dwellings, b) to permit a
maximum street line setback along Bleams Road of 9.2 metres and from Abram
Clemens Street of 6 metres instead of the maximum permitted setback from a
street of 4.5 metres;
to facilitate the construction of a multiple dwelling residential development
consisting of 139 townhouse units, in accordance with Site Plan Application
SPF25/041/A, BE APPROVED.
REPORT HIGHLIGHTS:
The purpose of this report is to review a Minor Variance Application to facilitate the
construction of a multiple dwelling residential development consisting of 139
townhouse dwelling units.
The key finding of this report is that the variances meet the four tests of the Planning
Act and staff recommends approval.
There are no financial implications.
Community engagement included a notice sign being placed on the property advising
that a Committee of Adjustment application has been received, notice of the
application was mailed to all property owners within 30 metres of the subject property
*** This information is available in accessible formats upon request. ***
Please call 519-741-2345 or TTY 1-866-969-9994 for assistance.
s website with the agenda in advance of the
Committee of Adjustment meeting.
This report supports the delivery of core services.
BACKGROUND:
The subject property is located on the southwest side of Abram Clemens Street, with
frontage at the Bleams Rd and Abram Clemens Street roundabout.
Figure 1 - Location Map: 10 Abram Clemens Street
Community Areas Urban Structure and is
within the Rosenberg Secondary Land Use Plan
Residential Six Zone (R-6) with Special Regulation Provision 765R
in Zoning By-law 85-1.
The purpose of the application is to review a Minor Variance Application to facilitate the
construction of a multiple dwelling residential development consisting of 139 residential
townhouse dwelling units. The applicant is requesting an increase in FSR to 0.65 rather
than the maximum permitted 0.6, an increase in building height of 16 metres rather than
the permitted maximum 10.5 metres, and an increase to the maximum permitted setback
from a street to 9.2 metres from Bleams Road and 6 metres from Abram Clemens Street
instead of the maximum permitted 4.5 metres.
Figure 2 Proposed overall site plan
The property itself is an irregular shape lot and due to the curvature of the street and the
nature of the layout of the townhouse dwellings the 4.5 metre maximum setback can not
be met. The setback request is being made for specific blocks of townhouses. Block 1 is
nearest to the intersection of Bleams Road and Abram Clemens Street and is requesting a
maximum setback of 9.2 metres from Bleams Road. While Blocks 3-5 and Blocks 6-9,
require a setback maximum of 6 metres rather than the permitted 4.5 metre maximum.
The remaining Blocks meet the required setbacks as outlined in Special Regulation
Provision 765R.
The requested minor variance for an increase in the maximum permitted building height, is
due to the significant grade change on the property. As seen in Figure 3 and 4, the
undeveloped lot has a significant grade change resulting in the buildings that are closer to
Bleams Road not being able to meet the maximum permitted heights. Planning staff are
supportive of the increase in the height for the specific blocks as outlined below due to the
grading on the site. Please see Figures 5 and 6.
Figure 3 Existing grading conditions - 10 Abram Clemens Street
Figure 4 Existing grading conditions - 10 Abram Clemens Street
Maximum building heights requested per block:
Block 1 - 16 metres (in Red)
Block 2 - 14 metres (in Blue)
Block 3 - 13.5 metres (in Green)
Blocks 4 and 5 - 13 metres (in Yellow)
Blocks 6-9 - 12.85 metres (in Orange)
Blocks 10-13 - 12.2 metres (in Purple)
Blocks 14-21 - 12 metres (in Pink)
Figure 5 Grading for specific townhouse blocks within the Site Plan
Figure 6 Grading for specific townhouse blocks within the Site Plan
REPORT:
Planning Comments:
In considering the four tests for the minor variances as outlined in Section 45(1) of the
Planning Act, R.S.O, 1990 Chap. P 13, as amended, Planning staff offers the following
comments:
General Intent of the Official Plan
The intent of the Low Density Residential Twoland use designation is to accommodate a
full range of low density housing types including single detached dwellings, duplex
dwellings, townhouse dwellings and low-rise multiple dwellings. The maximum Floor
Space Ratio (FSR) and building height is regulated through the Zoning By-law. Official
Plan policies do permit site specific increases within low rise residential zones to a Floor
Space Ratio (FSR) up to a maximum of 0.75, where it can be demonstrated that the
increase is compatible. Planning Staff have worked with the applicant through the Site
Plan Application process to achieve a site layout that can accomplish compatibility and
can demonstrate that it can be developed in a manner that does not cause adverse
impacts. Planning Staff are of the opinion that the proposed development meets the
general intent of the Official Plan.
General Intent of the Zoning By-law
Floor Space Ratio
The intent of the regulation for a maximum Floor Space Ratio of 0.6 for multiple dwellings
is to regulate the overall massing of buildings on site and to ensure there is adequate
space on-site for off-street parking, amenity areas, waste storage, snow storage, hydro
transformers, community mailbox, bicycle storage, and other various site features. The site
plan provided demonstrates that there is adequate space on site for the aforementioned
items and through the Site Plan process staff have reviewed the plan to ensure the site
functions. Staff is of the opinion that the requested variance for an increase in Floor Space
Ratio meets the general intent of the Zoning By-law.
Building Height
The intent of the maximum building height is to ensure that the overall building height does
not negatively impact adjacent properties and cause overlook issues, and shadow
impacts. Because of the slope of the overall property the increases in building height are
requested in order to maintain a consistent building height throughout the development.
The requested maximum height is only required for one of the proposed townhouse blocks
with the remaining blocks gradually declining in height as the grade levels out. The overall
multiple dwelling development is being constructed to feel uniform in nature and through
the site plan process the heights and massing have been carefully reviewed and accepted.
Staff is off the opinion that the requested variance for an increase in Building height meets
the general intent of the Zoning By-law.
Streetline setback
The intent of the streetline setback as outlined by Special Regulation Provision 765R is so
that the development maintains a consistent street line presence. Because of the
curvature of the road, the townhouse blocks cannot meet the setbacks as outlined in the
special provision. Staff are satisfied through the detailed design that the proposed
townhouses will maintain a street presence with proposed porches and entryways, as well
there are no driveways that are proposed along Abram Clemens Street as the driveway
and garages are accessed through the interior roadways.
Is/Are the Effects of the Variance(s) Minor?
The effects of the increase in Floor Space Ratio (FSR), height and maximum street line
setback are considered minor, as the increased floor space on site can be accommodated
while providing for the necessary site features as well as maintaining the required side and
rear yard setbacks. The increased floor space is not expected to increase impacts to the
surrounding neighbourhood beyond what is permitted with a 0.6 Floor Space Ratio
permitted as-of-right. The height increase and street line setbacks are all due to the unique
shape and grade of the subject property and are not expected to impact the surrounding
neighbourhood.
Is/Are the Variance(s) Desirable For The Appropriate Development or Use of the Land,
Building and/or Structure?
The requested variance is considered desirable for the appropriate development of the
land. The increase in Floor Space Ratio (FSR), building height and maximum setbacks
allows for a design of a complete townhouse blocks, while developing the site with the
permitted building typology of multiple dwellings within stacked townhomes.
Environmental Planning Comments:
All Kitchener Natural Heritage Study and Tree Management Policy issues were addressed
as part of the registration of 30T-09201. The east-west spruce hedgerow was approved for
removal. No trees remain on site. No environmental planning concerns.
Heritage Planning Comments:
The property municipally addressed as 10 Abrams Clemens Street is located adjacent to
1291 Fischer Hallman Road, which is listed as a non-designated property of cultural
heritage value or interest on the City's Municipal Heritage Register. The proposed
application is not expected to have major adverse impacts on the listed property. Thus,
staff have no comments or concerns.
Building Division Comments:
The Building Division has no objections to the proposed variance provided a building permit
for the townhouses are obtained prior to construction. Please contact the Building Division at
building@kitchener.ca with any questions.
Engineering Division Comments:
No engineering comments or concerns.
Parks and Cemeteries/Forestry Division Comments:
All Parks requirements will be addressed through Site Plan Application SPF25/041/A.
Transportation Planning Comments:
Transportation Services have no concerns with this application.
Region of Waterloo Comments:
No comments or concerns.
Six Nations of the Grand River Elected Council Environmental Comments:
Advisory Comments:
Six Nations of the Grand River (SNGR) Territory is within the most highly urbanized land in
consultation or consent of SNGR. The cumulative effects of this intense development has
contributed to significant environmental degradation, and as a result, Six Nations has
experienced severe impacts on its ability to exercise Aboriginal and Treaty Rights that are
not only set out in the treaties themselves but are also recognized and affirmed in Section
35 of the Constitution Act, 1982. These treaty lands are subject to unresolved litigation and
any infringement upon our treaty rights must be fully mitigated by the proponent. The 1701
perpetuity, but this proposal undermines those rights. SNGR must be accommodated to
mitigate any harm to its treaty rights caused by the proponent.
Treaty Rights Compensation
As this development will essentially ensure that this land will never be returned to a natural
state, SNGREC requests that this development be paired with compensation for impacts
to Six Nations Aboriginal and Treaty Rights and to the environment. SNGREC requests
that these compensations come in the forms of affordable units, dedicated units for First
Nations people, and environmental enhancements. Please reach to plan a meeting to
collaborate on determining compensation.
Landscaping
SNGREC requests that only native plant species are used in landscaping efforts. Please
provide SNGREC with a landscape plant list before procurement begins. SNGREC requests
capacity allows.
Planning Staff Response:
at this
time and will work with the applicant during the Site Plan Approval process to address the
landscaping comments.
Six Nations of the Grand River Comments:
If an Archaeological Assessment has not been completed, SNGR requests that a minimum
Stage 1 Archaeological Assessment be conducted. SNGR Archaeological Supervisor, Tanya
Hill-Montour, (tanyahill-montour@sixnations.ca) will require copies of all Archaeological
Assessment Reports related to the project for her review and comments. Should further
archaeological work be required following the Stage 1 assessment, SNGR requests the
participation of a Six Nations archaeological monitor in subsequent stages.
Planning Staff Response:
This site is part of Subdivision Application 30T-08203 and in 2015 when the draft approved
subdivision plan was registered, the Region has confirmed that they have received approved
copies of the Archeological Assessment Report and all clearances have been issued by the
Ministry of Tourism, Culture, and Sport.
STRATEGIC PLAN ALIGNMENT:
This report supports the delivery of core services.
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
of the Committee of Adjustment meeting. A notice sign was placed on the property
advising that a Committee of Adjustment application has been received. The sign advises
Planning Division. A notice of the application was mailed to all property owners within 30
metres of the subject property.
PREVIOUS REPORTS/AUTHORITIES:
Planning Act
Provincial Planning Statement (PPS 2024)
Regional Official Plan
Official Plan (1994 and 2014)
Zoning By-law 85-1
September 3, 2025
Connie Owen
City of Kitchener File No.: D20-20/
200 King Street West VAR KIT GEN
P.O. Box 1118
Kitchener, ON N2G 4G7
Subject: Committee of Adjustment Meeting September 16, City of Kitchener
Regional staff has reviewed the following Committee of Adjustment applications and
have the following comments:
1) A 2025 089 239 Woodbine Ave No Concerns
2) A 2025 090 10 Abram Clemens St No Concerns
3) A 2025 091 234-240 Frederick St No Concerns
4) A 2025 092 184 Woolwich St No Concerns
5) A 2025 093 535 Stirling Ave No Concerns
6) A 2025 094 160 Samuel St No Concerns
7) A 2025 095 66 Geogina St No Concerns
8) A 2025 096 457 Maple Ave No Concerns
9) A 2025 097 4438 King St E & 65 Gateway Park Dr No Concerns
10) A 2025 098 180 Ahrens St W (Dwelling 1) No Concerns
11) A 2025 099 180 Ahrens St W (Dwelling 2) No Concerns
12) A 2025 100 180 Ahrens St W (Dwelling 3) No Concerns
Please be advised that any development on the subject lands is subject to the
provisions of the Regional Development Charge By-law 19-037 or any successor
thereof and may require payment of Regional Development Charges for these
developments prior to the issuance of a building permit.
The comments contained in this letter pertain to the Application numbers listed. If a site
is subject to more than one application, additional comments may apply.
5ƚĭǒƒĻƓƷ bǒƒĬĻƩʹ ЎЉЏЋЏЍЍ ĻƩƭźƚƓʹ Њ
Please forward any decisions on the above-mentioned Application numbers to the
undersigned.
Yours Truly,
Tanikia Kinear, C.E.T.
Senior Transportation Planner
(519) 897-5691
5ƚĭǒƒĻƓƷ bǒƒĬĻƩʹ ЎЉЏЋЏЍЍ ĻƩƭźƚƓʹ Њ
August 28, 2025via email
Marilyn Mills
Secretary-Treasurer
Committee of Adjustment
City of Kitchener
200 King Street West
Kitchener, ON, N2G 4G7
DearMarilyn Mills,
Re:Committee of Adjustment Meeting September16, 2025
Applications for Minor Variance
A 2025-089239 Woodbine Avenue
A 2025-09010 Abram Clemens Street
A 2025-091234-240 Frederick Street
A 2025-093535 Stirling Avenue South
A 2025-094160 Samuel Street
A 2025-09566 Georgina Street
A 2025-096457 Maple Avenue
A 2025-0974438 King Street East & 65 Gateway Park Drive
A 2025-098 to A 2025-100180 Ahrens Street West
Grand River Conservation Authority (GRCA) staff havereviewed the above-noted
applications.
GRCA has no objection to the approval of the above applications. The subject
properties do not contain any natural hazards such as watercourses, floodplains,
shorelines, wetlands, or valley slopes.The properties arenot subject to Ontario
Regulation 41/24and,therefore,a permission from GRCA is not required.
Should you haveany questions, please contact meataherreman@grandriver.caor
519-621-2763 ext. 2228.
Sincerely,
Andrew Herreman, CPT
Resource Planning Technician
Grand River Conservation Authority
From:Jenna Auger
To:Committee of Adjustment (SM)
Subject:RE: ACTION REQUIRED - Committee of Adjustment Application Review – September 16, 2025 Meeting
Date:Monday, August 25, 2025 2:42:24 PM
Attachments:image001.png
Good afternoon,
th
Thank you for circulating the September 16, 2025, Committee of Adjustments agenda for
Kitchener.
Upon review, we note there are no applications that are subject to the Metrolinx review zone.
As such, Metrolinx issues no comments or concerns on this agenda.
Best Regards,
Jenna Auger (She/Her)
Project Analyst, Adjacent Construction Review (ACR)
Development & Real Estate Management
T: (416)-881-0579
20 Bay Street | Toronto | Ontario | M5J 2W3
From: Committee of Adjustment (SM) <CommitteeofAdjustment@kitchener.ca>
Sent: August 22, 2025 3:54 PM
To: Committee of Adjustment (SM) <CommitteeofAdjustment@kitchener.ca>
Subject: ACTION REQUIRED - Committee of Adjustment Application Review – September 16, 2025
Meeting
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Hello,
Please be advised the applications for the City of Kitchener Committee of Adjustment
meeting scheduled for Tuesday, September 16, 2025, have been loaded and circulated
through ShareFile. You should have already received the necessary link.
If you wish to make comments, provide advice, or request the imposition of any conditions
on any of these applications, please provide the Committee with a written report.
Please note: If you have comments, your written report must be sent to
CofA@kitchener.ca no later than 12 noon on Friday, August 29, 2025.
If you have no comments for the Committee's consideration, you do not need to respond.
Connie Owen
Administrative Clerk | Legislated Services | City of Kitchener
519-741-2203 | TTY 1-866-969-9994 | cofa@kitchener.ca
This e-mail is intended only for the person or entity to which it is addressed. If you received
this in error, please contact the sender and delete all copies of the e-mail together with any
attachments.
From:Tierra Henhawk
To:Committee of Adjustment (SM)
Cc:Tanya Hill-Montour
Subject:RE: ACTION REQUIRED - Committee of Adjustment Application Review – September 16, 2025 Meeting
Date:Monday, August 25, 2025 10:39:19 AM
Good morning,
Please find SNGR comments via email
Would the City of Kitchener have any GIS data or archaeological potential mapping that
could be shared in support of development application reviews?
A2025-089 - 239 Woodbine Ave
Could you please confirm whether an archaeological assessment has been completed for the
site located at 239 Woodbine Ave? If available, we would appreciate receiving any related
documentation or reports.
A2025-090 - 10 Abram Clemens St
If an archaeological assessment has not been completed, SNGR requests that a minimum
Stage 1 Archaeological Assessment be conducted. SNGR Archaeological Supervisor, Tanya
Hill-Montour, (tanyahill-montour@sixnations.ca) will require copies of all Archaeological
Assessment Reports related to the project for her review and comments. Should further
archaeological work be required following the Stage 1 assessment, SNGR requests the
participation of a Six Nations archaeological monitor in subsequent stages.
A2025-091 - 234-240 Frederick St
Could you please confirm whether an archaeological assessment has been completed for the
site located at 239 Woodbine Ave? If available, we would appreciate receiving any related
documentation or reports. If no archaeological assessment has been completed, SNGR would
like a standard archaeological warning clause applied to the file.
A2025-092 - 184 Woolwich St.
Could you please confirm whether an archaeological assessment has been completed for the
site located at 239 Woodbine Ave? If available, we would appreciate receiving any related
documentation or reports. If no archaeological assessment has been completed, SNGR would
like a standard archaeological warning clause applied to the file.
A2025-093 - 535 Stirling Ave. S
Given the significant prior disturbance to the area, an archaeological assessment is not
deemed necessary for this site.
A2025-094 - 160 Samuel St.
Given the significant prior disturbance to the area, an archaeological assessment is not
deemed necessary for this site.
A2025-095 - 66 Georgina St.
Given the nature of the proposal, we have no objections or concerns at this time.
A2025-096 - 457 Maple Ave.
Given the significant prior disturbance to the area, an archaeological assessment is not
deemed necessary for this site.
A2025-097 - 4438 King St. E. & 65 Gateway Park Dr.
Given the nature of the proposal, we have no objections or concerns at this time.
A2025-098 - 180 Ahrens Street West Dwellings 1-3
Could you please confirm whether an archaeological assessment has been completed for the
site located at 180 Ahrens Street West? If available, we would appreciate receiving any related
documentation or reports.
Nya:weh! / Thank You!
Sincerely,
Tierra Henhawk
Archaeology Community Monitor Administrative Assistant
Six Nations of the Grand River (SNGR)
Lands and Resources Department
2498 Chiefswood Road, Ohsweken ON
(T) 519-445-2205 ext: 5465
Lands & Resources Department (T) 519-753-0665
acmaa@sixnations.ca
Confidentiality Notice: This e-mail including any attachments, is for the sole use of the intended recipients and may
contain private and confidential information. Any unauthorized review, use, disclosure or distribution is prohibited. If
you are not the intended recipient or this information has been inappropriately forwarded to you, please contact the
sender by reply e-mail and destroy all copies of the original.
From: Committee of Adjustment (SM) <CommitteeofAdjustment@kitchener.ca>
Sent: August 22, 2025 3:54 PM
To: Committee of Adjustment (SM) <CommitteeofAdjustment@kitchener.ca>
Subject: \[External\] ACTION REQUIRED - Committee of Adjustment Application Review – September
16, 2025 Meeting
Hello,
Please be advised the applications for the City of Kitchener Committee of Adjustment
meeting scheduled for Tuesday, September 16, 2025, have been loaded and circulated
through ShareFile. You should have already received the necessary link.
If you wish to make comments, provide advice, or request the imposition of any conditions
on any of these applications, please provide the Committee with a written report.
Please note: If you have comments, your written report must be sent to
CofA@kitchener.ca no later than 12 noon on Friday, August 29, 2025.
If you have no comments for the Committee's consideration, you do not need to respond.
Connie Owen
Administrative Clerk | Legislated Services | City of Kitchener
519-741-2203 | TTY 1-866-969-9994 | cofa@kitchener.ca
From:Emmett Vanson
To:Committee of Adjustment (SM)
Subject:SNGREC Environmental Comments for Sept 16 Committee of Adjustments
Date:Monday, August 25, 2025 11:58:56 AM
Attachments:image.png
Sekon (Hello),
Included are my environmental comments on behalf of Six Nations of the Grand River Elected
Council (SNGREC) regarding all applications included for the Sept 16 Kitchener Committee of
Adjustments.
The following Preamble applies to all applications:
Haldimand Tract and 1701 Nanfan Treaty Preamble
Six Nations of the Grand River (SNGR) Territory is within the most highly urbanized land in
Canada. Development has occurred on Six Nations’ traditional territory without consultation or
consent of SNGR. The cumulative effects of this intense development has contributed to
significant environmental degradation and, as a result, Six Nations has experienced severe
impacts on its ability to exercise Aboriginal and Treaty Rights that are not only set out in the
treaties themselves but are also recognized and affirmed in Section 35 of the Constitution Act,
1982. These treaty lands are subject to unresolved litigation and any infringement upon our
treaty rights must be fully mitigated by the proponent. The 1701 Nanfan Treaty guarantees
SNGR’s right to harvest and hunt on this property for perpetuity, but this proposal undermines
those rights. SNGR must be accommodated to mitigate any harm to its treaty rights caused by
the proponent.
160 Samuel St.
No Comment
239 Woodbine Ave.
No Comment
10 Abram Clemens St.
Treaty Rights Compensation
As this development will essentially ensure that this land will never be returned to a
natural state, SNGREC requests that this development be paired with compensation for impacts
to Six Nations Aboriginal and Treaty Rights and to the environment. SNGREC requests that these
compensations come in the forms of affordable units, dedicated units for First Nations people,
and environmental enhancements. Please reach to plan a meeting to collaborate on determining
compensation.
Landscaping
SNGREC requests that only native plant species are used in landscaping efforts. Please
provide SNGREC with a landscape plant list before procurement begins. SNGREC requests that
the proponent uses Kayanase Plant Nursery for procurement of plants if Kayanase’s capacity
allows.
4438 King Street East & 65 Gateway Park Drive.
Treaty Rights Compensation
As this development will result in a large amount of emissions and waste through
demolition and paving, SNGREC requests that this development be paired with compensation
for impacts to Six Nations Aboriginal and Treaty Rights and to the environment. SNGREC
requests compensation in the form of offsite environmental enhancements. Please reach out to
lrlust@sixnations.ca to collaborate on determining compensation.
535 Stirling Ave. S.
Bird and Light Friendly Design
SNGREC requests that the building is designed using bird and light friendly practices. This
includes minimizing reflective surfaces, creating visual markers on windows, and directing light
downwards. Large windows are shown on the sunroom in Figures 2 and 3. Please treat these
windows to minimize bird kills.
Please see the City of Toronto’s bird friendly practices for glass and for lighting as
guidelines and implement them thoroughly across the entire design:
https://www.toronto.ca/wp-content/uploads/2017/08/8d1c-Bird-Friendly-Best-Practices-
Glass.pdf
184 Woolwich St.
Environmental Impact Study (EIS)
SNGREC requests an EIS for this property to evaluate downslope impacts and impacts to
the wetland on the property (as identified via GRCA mapping). SNGREC believes that this should
have been required before tree clearing on the property, and thus requests enhanced
environmental compensation from the proponent for this development. This requirement could
be solved by sufficient environmental compensation such as habitat creation and construction
of artificial habitat structures (i.e. bat boxes).
Tree Replacement
SNGREC requests a 10:1 tree replacement ratio for all trees removed regardless of DBH
and 1:1 for any dead trees/snags removed as these are an important habitat feature. A high tree
replacement ratio helps to restore lost ecological function and considers time for regrowth and
reduced survivability due to deer browsing and tree die-off. The goal of an increased tree
replacement ratio is also to create habitat and strengthen ecological resilience. On this site, this
would include trees removed before approval of this application. If accurate tree counts are not
already recorded, SNGREC will accept a liberal estimate (higher count). SNGREC acknowledges
that this site would not fit this level of tree replacement and thus requests offsite tree planting.
Further, the higher tree replacement ratio better compensates for the long lasting,
permanent impact of the development that will no longer be able to be used by Indigenous
people. The removal of or damage to the natural environment has an immense negative impact
to Six Nations of the Grand River Aboriginal and Treaty Rights in this area. Planting additional
trees and improving the environment helps make up for the negative impacts from development
on these rights.
Planted trees must be site-specific native species and should be planted as close to the
site as possible without impacting existing features and ecosystems, as should any future
landscaping species be native species.
Please consider planting plugs or other earlier-growth trees to help increase the feasibility
of planting additional trees. SNGREC requires planting best practices are used and suggests
collaboration with Kayanase Plant Nursery for recommendations and guidance.
Please be advised, if tree offset is not feasible onsite, SNGREC expects offset plantings to
take place as close as reasonably possible to the impacted site. SNGREC encourages
collaboration with the Grand River Conservation Authority, City of Kitchener, Region of Waterloo,
or RARE to achieve these offset plantings. Lastly, the Six Nations of the Grand River
Environmental Levy may be considered should closer sites be unavailable. SNGREC expects that
the tree replacement is paired with a robust and complete monitoring and maintenance plan
complete with contingency actions to ensure successful establishment of the trees for long term
success.
Wetland Buffer Encroachment
SNGREC requests that any encroachment into the wetland buffer (as shown for the
proposed driveway) is compensation for with enhancement or creation of wetlands.
To minimize the required compensation, SNGREC suggests changing the driveway
location to fit closer to the north edge of the lot and to have the garage and parking on the north
side of the property.
Landscaping
SNGREC requests that only native plant species are used in landscaping efforts. Please
provide SNGREC with a landscape plant list before procurement begins. SNGREC requests that
the proponent uses Kayanase Plant Nursery for procurement of plants if Kayanase’s capacity
allows.
Bird and Light Friendly Design
SNGREC requests that the building is designed using bird and light friendly practices. This
includes minimizing reflective surfaces, creating visual markers on windows, and directing light
downwards.
Please see the City of Toronto’s bird friendly practices for glass and for lighting as
guidelines and implement them thoroughly across the entire design:
https://www.toronto.ca/wp-content/uploads/2017/08/8d1c-Bird-Friendly-Best-Practices-
Glass.pdf
https://www.toronto.ca/wp-content/uploads/2018/03/8ff6-city-planning-bird-effective-
lighting.pdf
180 Ahrens St.
No Comment
457 Maple Ave.
No Comment
Thank you for taking my comments. I look forward to hearing and collaborating more on these
applications. Please do not hesitate to reach out if you have any questions or concerns.
Niá:wen (thank you),
Emmett Vanson, BSc. (he/him)
Land Use and Stewardship Technician
Six Nations of the Grand River Elected Council Lands and Resources Department
lrlust@sixnations.ca
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