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DSD-2025-486 - B 2025-033 - 104 Brentwood Avenue (2)
Staff Report r JR Development Services Department www.kitchener.ca REPORT TO: Committee of Adjustment DATE OF MEETING: December 9, 2025 SUBMITTED BY: Tina Malone -Wright, Manager, Development Approvals 519-783-8913 PREPARED BY: Brian Bateman, Senior Planner, 519-783-8905 WARD(S) INVOLVED: Ward 10 DATE OF REPORT: November 24, 2025 REPORT NO.: DSD -2025-486 SUBJECT: Consent Application B2025-033 — 104 Brentwood Avenue RECOMMENDATION: That Consent Application B2025-033 for 104 Brentwood Avenue requesting Consent to create a lot and retain a lot each having a lot width of 7.6 metres on Brentwood Avenue, a lot depth of 36.6 metres, and a lot area of 277.9 square metres to allow each half of a proposed Semi -Detached Dwelling, having 3 Additional Dwelling Units (ADUs) (Attached) to be dealt with independently, BE APPROVED subject to the following conditions: That the Owner's solicitor shall provide draft transfer documents and associated fees for the Certificate of Official to the satisfaction of the Secretary -Treasurer and City Solicitor, if required. 2. That the Owner shall obtain a tax certificate from the City of Kitchener to verify that there are no outstanding taxes on the subject property(ies) to the satisfaction of the City's Revenue Division. 3. That the owner provides a digital file of the deposited reference plan(s) prepared by an Ontario Land Surveyor in PDF and either .dwg (AutoCad) or .dgn (Microstation) format, as well as two full size paper copies of the plan(s). The digital file needs to be submitted according to the City of Kitchener's Digital Submission Standards to the satisfaction of the City's Mapping Technologist. 4. That the Owner provide a Building Location Survey and/or Reference Plan, prepared by an Ontario Land Surveyor, to confirm the boundaries of the new lots and that the location of the foundation, with respect to the proposed new lot lines, conforms with the Zoning By-law to the satisfaction of the Manager, Development Approvals. *** This information is available in accessible formats upon request. *** Please call 519-741-2345 or TTY 1-866-969-9994 for assistance. Page 111 of 187 5. That the Owner obtains Demolition Control Approval, in accordance with the City's Demolition Control By-law, to the satisfaction of the City's Director, Development and Housing Approvals. 6. That the Owner obtains a Demolition Permit, for the existing detached dwelling proposed to be demolished, to the satisfaction of the Chief Building Official, and removes the existing dwelling prior to deed endorsement. 7. That the Owner shall: a) Prepare a Tree Preservation Plan for the Severed and Retained lands, in accordance with the City's Tree Management Policy, to be approved by the City's Manager, Site Plans, and where necessary, implemented prior to any demolition, grading, servicing, tree removal or the issuance of building permits. Such plans shall include, among other matters, the identification of a proposed building envelope/work zone, a landscaped area and the vegetation to be preserved. If necessary, the plan shall include required mitigation and or compensation measures. b) That the Owner further agrees to implement the approved plan. No changes to the said plan shall be granted except with the prior approval of the City's Manager, Site Plans. 8. That the Owner pay to the City of Kitchener a cash -in -lieu contribution for park dedication of $11,862.00. 9. That the Owner provides a servicing plan showing outlets to the municipal servicing system to the satisfaction of the Director of Engineering Services. 10. That the Owner submit a Development Asset Drawing (digital AutoCAD) for the site (servicing, SWM etc.) with corresponding layer names and asset information to the satisfaction of the City's Director of Engineering Services, prior to deed endorsement. 11. That the Owner makes financial arrangements for the installation of any new service connections to the severed and/or retained lands to the satisfaction of the City's Director of Engineering Services. 12. That any new driveways are to be built to City of Kitchener standards at the Owner's expense prior to occupancy of the building to the satisfaction of the City's Director of Engineering Services. 13. That the Owner provides confirmation that the basement elevation can be drained by gravity to the street sewers to the satisfaction of the City's Director of Engineering Services. If this is not the case, then the owner will need to pump the sewage via a pump and forcemain to the property line and have a gravity sewer from the property line to the street to the satisfaction of the City's Director of Engineering Services. Page 112 of 187 14. That prior to final approval the Owner submits the Consent Application Review Fee of $350.00 to the Region of Waterloo. REPORT HIGHLIGHTS: • The purpose of this report is to assess a request to sever a parcel of land that would allow each half of a proposed Semi -Detached Dwelling with 3 attached ADUs be dealt with independently. • The key finding of this report is the proposal is considered good planning. Semi - Detached Dwellings are a permitted use in the zone category applicable to the subject property and there are no variances required to facilitate the proposed lotting fabric nor the use of a Semi -Detached Dwelling with ADUs. Staff is therefore recommending approval of the Consent Application subject to conditions. • 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 and this report was posted to the City'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 Brentwood Drive near the intersection of Jackson Avene close to Eastwood Collegiate Institute. The neighbourhood is comprised of a mix of low and mid -rise residential uses. The subject property contains an existing detached dwelling (see Figures 1 and 2) that is proposed to be demolished to construct a Semi - Detached Dwelling with 3 Additional Dwelling Units (ADUs) (Attached). The subject property is identified as `Community Areas' on Map 2 — Urban Structure and is designated `Low Rise Residential' on Map 3 — Land Use in the City's 2014 Official Plan. The property is zoned `Low Rise Residential Four Zone (RES -4)' in Zoning By-law 2019- 051. This zone permits the use of a Semi -Detached Dwelling with up to 3 ADUs providing the zoning regulations can be met. The purpose of the application is to sever a parcel of land to permit each half of a new Semi -Detached Dwelling, with 3 ADUs (Attached) in each side, to be dealt with independently (see Figure 3). Page 113 of 187 r �J �itiY ®d m® b s® © S f V 7x3J tiY. ti WD E n of °. r y , IA Ll pp h^ TM - a _ ,.�1 '�. .• "R Thi• i _ F' R T R - .. z< iJrt .CT 15& L T I PNt if48} E A• AREA.1ft11FW ygEb,-i071r' SEVERELi PARCFI. AREA -277.91 rn] n .H YT E -Et ' t ------------- Lii Y E -L BRENTWOOD AVENUE �MIL7 MII*J MG4 n =,'I -.k] 3jJ:. ZONING: RESIDENTIAL IRES-41 SElIIII-DErACHI D RE@NIRED PREIPUMED-A- PROPIOEED "6' 4°I114JV .i� 1X1lR�LN1 -'l,S+� -I77.Vhn° -'l.Fr.11 �' JMi -7Sm -t!E&. N4 f.IN:JV Fli 4'Y141 L' +7Jk3n -Lt—-al— MNIMJV .k.N1 .'FIUll +7:iM -}SU P-S- -75tH-I]Atm NNIMJV klkr: Ji1U[TJFB +].LH -LN9n -1Jm/M1 NW.1+d'lJM lli' 1F.Y:lAf]E +ii% -CA .i>i 1[�IN: Ysi.Ns.:rre] I'RUNi'e>aYb. i:'ran SEVERANCE SKETCH ,ALL OF LOT 156• REGISTERED PLAN 651 CITY OF KITCHENER REGIONAL MUNICIPALITY OF WATERLOO a YAN RNRT043 RVEMO MC. KEY MAP kT � ._A SUBJECT PROPER7f l�1.... PAN 9a5 JSCGId4 Eln nj 'I E PAROL AREA -277-%m' X SURVEYCH." CE* T'f'v'k"_. �.Nss Nl Laws Uklaer.. Vli}sLReEttii NOTES: 1. 7NM m IL7R ArLLAM Qf NIIItE1<AIdlItlLlD MW ME LAM Fdlt REAL E&WE TRAIIX FE On MOPHOPMEL 2 W NI ECT LW 19 NE WMEn RE9 D&MLK 541 SENkO AOf 3 DETAN9 IONTHE PIAN ARE iJ-IL`+A1'N iN NRR+ AN Dem aE eDwE rm TO F FEr dY n wnrrs. B°r a-XA& l d N EhCsX*d0 N THr NETCH AEE Afff"WTE ANDRAW NOT NEEN 4FAIFIED W 9.]Rd".. i SEE ATTYLFE➢ k15TQFNANFSAKEADDFJ aF QAMWR i{Nall Harten V ..arrarten— -in aa—nherbcn_mkn ..— NQI GCa68YY. WL FhJa-1 Na. Nell.ffi d TJ, lCJ>':]YI.901 m :yLICXkpEM}i liAGhl1{!fl� I$71SiPjN9I-]31YSYYk9ANIb�E 8 �i Tka�RGX d ilYiT4[Tlb de Idol-,YaolA Figure 3 — Proposed Severance Sketch A Zoning Occupancy Permit (see Figure 4) has been issued to validate the use and compliance with the zoning regulations. Note that Demolition Control, a Demolition Permit, demolition of the dwelling and a Building Permit, are required before the Consent receives Final Approval and new dwelling can be built. Page 115 of 187 Certificate Number: 25 110975 Date Issued: October 15, 2025 Address: 104 BRENTWOOD A%'E Permitted L. se: Selrn-detached D",tilling with 3 Additional Ihvelling huts (attached) Total # of Units: 4 Zoning: RES4 Zoning By -lair: 2019-051 Footlirint GFA Muci al Building per Side: 117.46 mr 227-68 in- Required Prm ided Total Parking Spaces per Side: 2 ? Bicvcle Stalls: ' 4 Comments.?Conditions: Iu accordance %with approved Zoning P1urT attached. In accordance with Building Permit 25-119473 — _0L zomainr Oficial for Director of flaw g and Heu=g Policy, DSD Departmmt 1111RO l't:i Ut tiOdCe With authority of the PI na uing Act a certificate of zomn2 occupancy .'enfies that the use is permitted by the Cit; of Kitchener's Zonine By -Law. A certificate of zoning occupancy does not exempt the recipient from obtaining a Vnilding perm:- and ensuring compliance with Building and Fire Cade Regulations, ir:ch,ditlQ eccupanc:* req-airen_ents under the Bm'dinr Code. Figure 4 — Zoning Occupancy Certificate It is noted that the foundation for the future building/dwelling has not yet been poured and surveyed and a Reference Plan and Building Location Survey were not provided and submitted with the Consent Application. Typically, best practices dictate that prior to the Consent of a property proposed to contain an attached dwelling, the foundation is to be set and surveyed so as to accurately capture the new lot line as constructed. The City is cognisant of the construction challenges and excavation costs that this process poses, and as such, will permit Consent Applications to proceed ahead of the foundation being poured and surveyed. The Applicant is submitting this application with confidence that the future foundation will coincide with the aroaosed lot dimensions and setbacks. no maintenance easements are necessary and is proceeding with the application at this time Page 116 of 187 THE CORPORATION OF THE CITY OF IITCHENER ZONING CER TIFIC�ATE �j,�,�.� �5 RFQL�:FIi 8i SECTION 3x{51 OF THE FLLSIZIG_4CI A -ND iC y.7C 4 1 1. •1 lL it � 1', 7.4\iS6 PS-LKM OF ME= OF I.QTCIEENF-t Certificate Number: 25 110975 Date Issued: October 15, 2025 Address: 104 BRENTWOOD A%'E Permitted L. se: Selrn-detached D",tilling with 3 Additional Ihvelling huts (attached) Total # of Units: 4 Zoning: RES4 Zoning By -lair: 2019-051 Footlirint GFA Muci al Building per Side: 117.46 mr 227-68 in- Required Prm ided Total Parking Spaces per Side: 2 ? Bicvcle Stalls: ' 4 Comments.?Conditions: Iu accordance %with approved Zoning P1urT attached. In accordance with Building Permit 25-119473 — _0L zomainr Oficial for Director of flaw g and Heu=g Policy, DSD Departmmt 1111RO l't:i Ut tiOdCe With authority of the PI na uing Act a certificate of zomn2 occupancy .'enfies that the use is permitted by the Cit; of Kitchener's Zonine By -Law. A certificate of zoning occupancy does not exempt the recipient from obtaining a Vnilding perm:- and ensuring compliance with Building and Fire Cade Regulations, ir:ch,ditlQ eccupanc:* req-airen_ents under the Bm'dinr Code. Figure 4 — Zoning Occupancy Certificate It is noted that the foundation for the future building/dwelling has not yet been poured and surveyed and a Reference Plan and Building Location Survey were not provided and submitted with the Consent Application. Typically, best practices dictate that prior to the Consent of a property proposed to contain an attached dwelling, the foundation is to be set and surveyed so as to accurately capture the new lot line as constructed. The City is cognisant of the construction challenges and excavation costs that this process poses, and as such, will permit Consent Applications to proceed ahead of the foundation being poured and surveyed. The Applicant is submitting this application with confidence that the future foundation will coincide with the aroaosed lot dimensions and setbacks. no maintenance easements are necessary and is proceeding with the application at this time Page 116 of 187 `at their own risk'. A new condition is proposed to be added to these types of Consent Approvals as follows: "That the Owner provide a Building Location Survey and/or Reference Plan, prepared by an Ontario Land Surveyor, to confirm the boundaries of the new lots and that the location of the foundation, with respect to the proposed new lot lines, conforms with the Zoning By-law to the satisfaction of the Manager, Development Approvals." Should the common wall of the foundation not be located on the common lot line, or the setbacks of the building/dwelling do not meet zoning requirements, the Applicant will be required to rectify and/or submit new Committee of Adjustment Applications to resolve the errors and/or deficiencies at their own expense. REPORT: Planning Comments: In considering all the relevant Provincial legislation, Regional and City policies and regulations, Planning staff offer the following comments: Provincial Planning Statement (PPS 2024) In considering all the relevant Provincial legislation, Regional and City policies and regulations, Planning staff offer the following comments: Staff are satisfied that the proposed infill severance application is consistent with the Provincial Planning Statement in general and as it related to housing policies in Chapter 2 regarding intensification and facilitating housing options. Section 2.2 1 (b) states that Planning authorities shall provide for an appropriate range and mix of housing options and densities to meet projected needs of current and future residents of the regional market area by permitting and facilitating all housing options required to meet the social, health, economic and well-being requirements of current and future residents. Regional Official Plan (ROP): ROP Urban Area policies state that the focus of the Region's future growth shall be within the Urban Area. The subject lands fall within the `Urban Area' and are designated `Built -Up Area' in the ROP. The proposed development conforms to Policy 2.D.1 of the ROP as this neighbourhood provides for the physical and community infrastructure required for the proposed residential development, including transportation networks, municipal water and wastewater systems, and a broad range of social and public health services. Regional polices require municipalities 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. Staff are satisfied that the proposed severance application adheres to these policies and conforms to the ROP. City's Official Plan (2014) The subject property is identified as `Community Areas' on Map 2 — Urban Structure and is designated `Low Rise Residential' on Map 3 — Land Use in the City's Official Plan. Page 117 of 187 Section 17.E.20 of the Official Plan implements Section 51 of the Planning Act and contains policies regarding infill development and lot creation (Consent Policies). Policy 17.E.20.5 states the following: "17.E.20.5 Applications for consent to create new lots will only be granted where: a) the lots comply with the policies of this Plan, any Community Plan and/or Secondary Plan, and that the lots are in conformity with the Zoning By-law, or a minor variance has been granted to correct any deficiencies; b) the lots reflect the general scale and character of the established development pattern of surrounding lands by taking into consideration lot frontages, areas, and configurations; c) all of the criteria for plan of subdivision are given due consideration; d) the lot will have frontage on a public street; e) municipal water services are available; f) municipal sanitary services are available except in accordance with Policy 14.C.1.19; g) a Plan of Subdivision or Condominium has been deemed not to be necessary for proper and orderly development; and, h) the lot(s) will not restrict the ultimate development of adjacent properties." Zoning By-law 2019-051 The property is zoned `Low Rise Residential Four Zone (RES -4)' in Zoning By-law 2019- 051. This Zone category permits the use of a Semi -Detached Dwelling with up to 3 ADUs (Attached) providing the zoning regulation can be met. A Zoning Occupancy Certificate has been issued confirming the zoning regulations are being met. Planning Conclusions/Comments: With respect to the criteria for the subdivision of land listed in Section 51(24) of the Planning Act, R.S.O. 1990, c.P.13, staff is satisfied that the creation of the severed lot is desirable and appropriate. The uses of both the severed and retained parcels are in conformity with the City's Official Plan and Zoning By-law. Planning staff is of the opinion that the size, dimension and shape of the proposed lots are suitable for the use of the lands and compatible with the surrounding community. The severed lands front onto an established public street and are serviced with municipal services. Staff is further of the opinion that the proposal is consistent with the Region of Waterloo Official Plan, the Provincial Planning Statement, and is good planning and in the public interest. Page 118 of 187 Environmental Planning Comments: Request the standard consent condition to enter into an agreement to complete, submit, obtain approval of, and implement a Tree Preservation and Enhancement Plan (TPEP) for both the severed and retained lots, prior to site alteration, demolition and/or building permit. In this case it would be appropriate to require the TPEP as a condition of Final Approval given that a Demolition Permit is required in advance of obtaining the Certificate of the Official. Although the Applicant may not be actively clearly all of the conditions of this Consent at the time of consideration of Demolition Control/Permit of the existing detached dwelling, the Applicant is advised that the TPEP Condition is still applicable and must be approved prior to Demolition Permit issuance. Heritage Planning Comments: No comments or concerns. Building Division Comments: The Building Division has no objections to the proposed consent. Region of Waterloo and Area Municipalities' Design Guidelines and Supplemental Specifications for Municipal Services (DGSSMS) allows only one service per lot. Separate building permit(s) will be required for the demolition of the existing building, as well as construction of the new residential buildings. Engineering Division Comments: • Severance of any blocks within the subject lands will require separate, individual service connections for sanitary, storm, and water, in accordance with City policies. • The owner is required to make satisfactory financial arrangements with the Engineering Division for the installation of new service connections that may be required to service this property, all prior to severance approval. • Any new driveways are to be built to City of Kitchener standards. All works are at the owner's expense and all work needs to be completed prior to occupancy of the building. • A servicing plan showing outlets to the municipal servicing system will be required to the satisfaction of the Engineering Division prior to severance approval. • A Development Asset Drawing (digital AutoCAD) is required for the new site infrastructure with corresponding layer names and asset information to the satisfaction of the Engineering Division prior to severance approval. • The Owner must ensure that the basement elevation of the building can be drained by gravity to the municipal sanitary sewer. If basement finished floor elevations do not allow for gravity drainage to the existing municipal sanitary system, the owner will have to pump the sewage to achieve gravity drainage from the property line to the municipal sanitary sewer in the right of way. • The Owner shall implement a suitable design solution for a sump pump outlet to the satisfaction of the Director of Engineering. • The side yard currently accommodates overland stormwater flows. A sidewalk is required to the rear yard in accordance with the Zoning By-law. The final grading of this property shall not adversely affect the drainage of adjacent properties or the overall grading control plan. The Owner is responsible to address storm water drainage at the Building Permit stage. Page 119 of 187 Parks and Cemeteries/Forestry Division Comments: Cash -in -lieu of parkland dedication will be required at the time of severance for the severed parcel as 1 new development lot will be created. The cash -in -lieu dedication required is $11,862.00. Park Dedication is calculated at 5% of the new development lot only, with a land valuation calculated by the lineal frontage of 7.6 metres and a land value of $36,080.00 per frontage metre, which equals $13,710.40. In this case, a per unit cap of $11,862.00 has been applied. Transportation Planning Comments: No concerns. Region of Waterloo Comments: Regional staff have no objection to this application, subject to the following condition(s): 1. That the applicant submit the regional consent review fee of $350.00 per application to the satisfaction of the Region of Waterloo. GRCA Comments: No concerns. SNGREC Comments: No comments. 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 — This report has been posted to the City's website with the agenda in advance 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 interested parties to find additional information on the City's website or by emailing the 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 (ROP) • Official Plan (2014) • Zoning By-law 2019-051 Page 120 of 187 N* Region of Waterloo Connie Owen Administrative Clerk, Legislative Services Committee of Adjustment City of Kitchener P.O. Box 1118 200 King Street East Kitchener, ON N2G 4G7 Dear Ms. Owen: PLANNING, DEVELOPMENTAND LEGISLATIVE SERVICES 150 Frederick Street, 8t" floor Kitchener Ontario N2G 4J3 Canada Telephone: 519-575-4400 Fax: 519-575-4449 www.regionofwaterloo.ca Erica Ali, MCIP, RPP File: D20-20/26 KIT January 7, 2026 Re: Comments on Consent Applications — B 2025-032 to B2025-035 (inclusive) Committee of Adjustment Meeting — January 20, 2026 City of Kitchener Page 121 of 187 File: B2025-034/5 Address: 67/71 Blucher St Description: Plan 328, Lot 6; Plan 339, Part lot 4 Owner: Marko Podobnik Applicant: GSP Group Inc c/o Kristen Barisdale The applicant/owner is proposing consent to sever to create a new residential lot and to create reciprocal easements for shared access/servicing. The lot to be severed (71 Blucher) contains an existing linear townhouse building (10 units). The lot to be retained (67 Blucher) contains an existing linear townhouse building (4 units) which would be demolished to in order to develop two 8 -unit linear stacked townhouse (total of 16 units). The subject lands are currently serviced through municipal water and waste services, with access to a local road. Minor variance applications are required to facilitate the consent for the severed lands, pertaining to lot width, and setbacks. The ands were subject to Stamp B Site Plan Approval (SP23/073/B/TS) in Feb 2024 to formalize existing conditions. SP23/084/B/TS conditional site plan approval was granted in March 2024 for the redevelopment of 67 Blucher. The proposed lot configuration is as follows: Retained - B2025-034 - - 67 Blucher — 1,594.68 sqm with 26.8m frontage Severed — B2025-035 - 71 Blucher - — 2,127,47 sqm area with 5.8m frontage The subject lands are designated Built -Up Area (within the Urban Boundary), with an MTSA (Central Station) and Urban Growth Centre (Downtown Kitchener) in the Regional Official Plan (ROP), Low -Rise Residential and Community Area in the City of Kitchener Official Plan, and zoned RES -5. Threats Inventory Database (Advisory) The following information from the Region's Threat Inventory Database (TID) is provided until such time as access is transferred to the City of kKitchener. Noting, there are no medium or high threats identified on or adjacent to the subject property. Hydrogeology & Source Water Protection Plan The subject lands are located in a Source Plan Protection Area where restrictions or prohibitions may apply in accordance with the Clean Water Act, Part IV. As such a Notice of Source Protection Plan Compliance (S. 59 Notice) is required as part of a formal application for Consent. Regional Staff are not in receipt of the S. 59 Notice and this will be required as a condition of consent approval if not received by the Region prior to the Decision of the Committee of Adjustment. Fees Regional staff are not in receipt of the required consent review fee of $350 per consent application. The outstanding fee(s) will be required as a condition of consent approval if not received by the Region prior to the Decision of the Committee of Adjustment. Page 122 of 187 Regional staff have no objection to this application, subject to the following condition(s): 1. That the applicant submit the regional consent review fee of $350 per application to the satisfaction of the Region of Waterloo 2. That the applicant submit the Notice of Source Protection Plan Compliance (S. 59 Notice) to the satisfaction of the Region of Waterloo Page 123 of 187 The Region is in the process of updating its Water Supply Strategy. Through this work, concerns have been identified regarding water servicing capacity within the Mannheim Service Area. Regional staff are working expeditiously to evaluate the situation and understand the magnitude of the concerns to be able to provide comments relating to water servicing capacity. As such, the Region is not in a position to support approval of applications, B 2025-032 and B2025-033, at this time, and the following comments are provided for information purposes. Page 124 of 187 File: B2025-032 Address: 776 Rockway Dr Description: Plan 649, Lot 22 Owner: 2832516 Ontario Inc c/o Tara Bruwer-Sutton Applicant: Masri O Inc Architects c/o Reema Masri The applicant/owner is proposing consent to sever to create a new residential lot. The severance will facilitate the redevelopment of each lot with a semi-detached duplex, providing 4 units per dwelling, for a total of 8 units. The existing single detached dwelling will demolished. The subject lands are currently serviced through municipal water and waste services, with access to a local road. Minor variance applications are not required to facilitate the consent. The proposed lot configuration is as follows: Severed — 278.8 sqm area with 7.62m frontage Retained — 278.422 sqm with 7.62m frontage The subject lands are designated Built -Up Area within the Urban Boundary in the Regional Official Plan (ROP), Low -Rise Residential in the City of Kitchener Official Plan, and zoned RES -4. Threats Inventory Database (Advisory) The following information from the Region's Threat Inventory Database (TID) is provided until such time as access is transferred to the City of Kitchener. Noting, there are no medium or high threats identified on or adjacent to the subject property. Hydrogeology & Source Water Protection Plan (Advisory) The subject lands are located in a Source Plan Protection Area where restrictions or prohibitions may apply in accordance with the Clean Water Act, Part IV. As such a Notice of Source Protection Plan Compliance (Section 59 Notice) is required as part of a formal application for Consent. Regional Staff acknowledge receipt of the S. 59 Notice. Fees Regional staff are not in receipt of the required consent review fee of $350 for consent application. The outstanding fee(s) will be required as a condition of consent approval if not received by the Region prior to the Decision of the Committee of Adjustment. Page 125 of 187 File: B2025-033 Address: 104 Brentwood Ave Description: Plan 651, Lot 158 Owner: Veasna Suon Applicant: Masri O Inc Architects c/o Reema Masri The applicant/owner is proposing consent to sever to create a new residential lot. The severance will facilitate the redevelopment of each lot with a semi-detached duplex, providing 4 units per dwelling, for a total of 8 units. The existing single detached dwelling will demolished. The subject lands are currently serviced through municipal water and waste services, with access to a local road. Minor variance applications are not required to facilitate the consent. The proposed lot configuration is as follows: Severed — 277.9 sqm area with 7.6m frontage Retained — 277.9 sqm with 7.6m frontage The subject lands are designated Built -Up Area within the Urban Boundary in the Regional Official Plan (ROP), Low -Rise Residential in the City of Kitchener Official Plan, and zoned RES -4. Threats Inventory Database (Advisory) The following information from the Region's Threat Inventory Database (TID) is provided until such time as access is transferred to the City of Kitchener. Noting, there are no medium or high threats identified on or adjacent to the subject property. Hydrogeology & Source Water Protection Plan (Advisory) The subject lands are located in a Source Plan Protection Area where restrictions or prohibitions may apply in accordance with the Clean Water Act, Part IV. As such a Notice of Source Protection Plan Compliance (Section 59 Notice) is required as part of a formal application for Consent. Regional Staff acknowledge receipt of the S. 59 Notice. Fees Regional staff are not in receipt of the required consent review fee of $350 for consent application. The outstanding fee(s) will be required as a condition of consent approval if not received by the Region prior to the Decision of the Committee of Adjustment. Page 126 of 187 General Comments Any future development on the lands subject to the above -noted consent applications will be subject to the provisions of Regional Development Charge By-law 19-037 or any successor thereof. Prior to final approval, City staff must be in receipt of the above - noted Regional condition clearances. Please accept this letter as our request for a copy of the staff reports, decisions and minutes pertaining to each of the consent applications noted above. Should you require Regional Staff to be in attendance at the meeting or have any questions, please do not hesitate to contact the undersigned. Thank you, Erica Ali, MCIP, RPP Planner Regional Growth, Development and Sustainability Services Regional Municipality of Waterloo Page 127 of 187 November 21, 2025 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 Marilyn Mills Secretary -Treasurer Committee of Adjustment City of Kitchener 200 King Street West Kitchener, ON, N2G 4G7 Dear Marilyn Mills, Re: Committee of Adjustment Meeting — December 9, 2025 Applications for Minor Variance A 2025-117 2922 King Street East A 2025-118 630 Benninger Drive A 2025-119 455 Old Chicopee Trail A 2025-122 117 Samuel Street A 2025-123 20 Gildner Street A 2025-125 50-56 Weber Street West & 107 Young Street A 2025-127 71 Blucher Street Applications for Consent B 2025-032 776 Rockway Drive B 2025-033 104 Brentwood Avenue B 2025-034 71 Blucher Street B 2025-035 67 Blucher Street via email Grand River Conservation Authority (GRCA) staff have reviewed 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 are not subject to Ontario Regulation 41/24 and, therefore, a permission from GRCA is not required. Should you have any questions, please contact me at aherremana-grandriver. ca or 519-621- 2763 ext. 2228. Sincerely, Andrew Herreman, CPT Resource Planning Technician Grand River Conservation Authority Member of Conservation Ontario, representing Ontario's 36 Conservation Authorities I The Grand — A Canadian Heritage River Page 128 of 187 From: Landuse Planning To: Marilyn Mills Subject: KITCHENER - 104 BRENTWOOD AVENUE - B 2025-033 Date: Tuesday, December 2, 2025 10:39:53 AM IYou don't often get email from landuseplanning@hydroone.com. Learn why this is important Hello, We are in receipt of your Application for Consent, B 2025-033 dated 2025-11-21. We have reviewed the documents concerning the noted Plan and have no comments or concerns at this time_ Our preliminary review considers issues affecting Hydro One's 'High Voltage Facilities and Corridor Lands' only. For proposals affecting'Low Voltage Distribution Facilities' the Owner/Applicant should consult their local area Distribution Supplier. Where Hydro One is the local supplier the Owner/Applicant must contact the Hydro subdivision group at subdivision@Hydroone.com or 1-866-272-3330. To confirm if Hydro One is your local distributor please follow the following link: Stormeentre (hydroone.com) Please select "Search" and locate the address in question by entering the address or by zooming in and out of the map. ? a MENU HELP SEARCH hydro�f one Customers Affected:0 >5000 V 501-5000 0 51-500 a 21-50 ( =20 0 Multiple () Crew —Service Area ❑J u si Q Ottaw Montreal �. fluntsedfe 411 40Q 11 � c 5 0Qrlia Kawarha aoa Lakes 0/� § ° & P2i2rIl}b UO . {� Kin. 6ellville V 4 a� O • p 115 inceodwar Watepown a qQ 4 r � n,n-. n Tnrnnfn � V K14Che .r• ° 4 Rochester Mau data 92019 Google 50 km L -----j Terms of Use If you have any further questions or inquiries, please contact Customer Service at 1-888-664-9376 or e-mail CustomerCommunications(?�HydroOne.com to be connected to your Local Operations Centre If you have any questions please feel free to contact Land Use Planning. Thank you, Land Use Planning Department Hydro One Networks Inc. Email: LandUsePlanningAHydroOne.com Z Burlir Li Page 129 of 187 From: Joseph. Shadae on behalf of circulations To: Committee of Adiustment (SM) Subject: 519-25-116 - Consent Application B2025-033 - 104 Brentwood Avenue Date: Monday, December 8, 2025 12:09:27 PM Good afternoon, Bell Canada has no concerns with respect to Application for Consent B2025-033, regarding 104 Brentwood Avenue. If you have any questions, please do not hesitate to contact me. Thank you, ShadaeJoseph Page 130 of 187 From: To: Subject: Date: Hello, LANDUSEPLANNING Committee of Adiustment (SM) KITCHENER - 104 Brentwood - B2025-033 Monday, December 15, 2025 10:56:01 AM We are in receipt of your Application for Consent, B2025-033 dated 2025-11-14. We have reviewed the documents concerning the noted Plan and have no comments or concerns at this time_ Our preliminary review considers issues affecting Hydro One's 'High Voltage Facilities and Corridor Lands' only. For proposals affecting'Low Voltage Distribution Facilities' the Owner/Applicant should consult their local area Distribution Supplier. Where Hydro One is the local supplier the Owner/Applicant must contact the Hydro subdivision group at subdivision@Hydroone.com or 1-866-272-3330. To confirm if Hydro One is your local distributor please follow the following link: Stonncentre (hydroone.com) Please select "Search" and locate the address in question by entering the address or by zooming in and out of the leap ? a MENU HELP SEARCH I hyd tune Customers Affected:0 15000 501-5000 0 51-500 0 21-50 V e=20 0 Multiple ® Crew —Service Area u sir Q0ttaw Montreal �� V. ® r Hunt:5veli2 417 417 40Q 17 � o 5 C, rd� � O 4ifi A 0Orlin Kawartha aoa � Lakes vis ° & P2t2rh ,Ugi 0 Kin 9ell�ville � s 115 nflCeo dWaf Watertown '4° ' a 5 Lzramplono Toronto o o Kitchei r � ar,o o o Mississauga a , Hamilton Rochester 4031 Mao data 92019 GDcale 50 km 6____J Terms of Use If you have any further questions or inquiries, please contact Customer Service at 1-888-664-9376 or e-mail CustomerCommunicationsgHydroOne.com to be connected to your Local Operations Centre If you have any questions please feel free to contact Land Use Planning. Thank you, Land Use Planning Department Hydro One Networks Inc. Email: LandUsePlanninggHydroOne_com Burlir Page 131 of 187 January 20, 2026 To: City of Kitchener Planning Staff and Committee of Adjustment urban Cc: Tina Malone Wrigth, Garett Stevenson, Rod Regier, Alyssa insights Bridge, Reema Masri, Client From: Urban Insights Inc. Re: 776 Rockway Drive and 104 Brentwood Avenue CofA Applications (January 20 2026) Request for Decision Next Committee Meeting I represent the property owners for the Committee of Adjustment severance applications at 776 Rockway Drive and 104 Brentwood Avenue, which were recently deferred based on comments received from the Region of Waterloo relating to water capacity constraints. These applications represent a very modest and localized form of intensification—two small infill severances within fully serviced, established neighbourhoods. The scale of development proposed is minuscule in the context of the regional water system, and will result in a negligible increase in demand. These are not large-scale developments which are subject to complex agreements and approvals, but rather, small scale gentle density projects that fit within existing neighborhoods. They are precisely the type of gentle density infill that both municipal and provincial policy frameworks continue to encourage. As a small scale infill project, continued delays will have a detrimental impact on project viability and ability to get needed attainable housing to market. Importantly, the City of Kitchener and this Committee remain the statutory decision-making authorities for these severance applications. While the Region of Waterloo is a commenting agency, it is not the approval authority for these planning decisions. The Region's recent correspondence provides a general caution regarding system capacity, but it does not identify these specific applications as creating an unacceptable or unserviceable impact. In fact, the Region has acknowledged that approvals may continue on a case-by-case basis, particularly for small infill projects with limited or neutral impact on overall demand. In this context, it would be neither proportionate nor consistent with good planning to apply a broad, system -wide constraint to micro -scale severance applications without site-specific analysis, clear servicing refusal, or defined interim rules. These applications can be approved today providing applicable law for a direct building permit approval and issuance process. At this stage, there are two procedural paths available. Either the Committee may approve these applications based on its own planning merits and jurisdiction, allowing the Region to exercise its rights at the servicing stage if necessary, or a continued deferral risks creating an unnecessary lack of decision, which would force the applicants to consider an appeal to the Ontario Land Tribunal. Neither outcome serves the public interest where the planning impacts are minor and manageable. 011 Page 132 of 187 For these reasons, we respectfully request that the Committee proceed to hear and decide these applications at the next available meeting, with full circulation to neighbours and agencies. We will provide additional technical information in advance of that hearing to demonstrate that these proposals represent gentle density infill with no material impact on the Region's broader water capacity challenges. Approving these severances would strike the appropriate balance between responsible infrastructure management and the continued delivery of small-scale housing in established neighbourhoods. Respectfully submitted, URBAN INSIGHTS INC. Urban Planning • Economic Development • Urban Design Ryan O. Mounsey. CEO. BES.MUDS.MCIP,RPP 519-591-6076 www.urbaninsights.ca 40 King Street South, Suite 301 Waterloo, ON N2J1 N8 4 Page 133 of 187 0 Uan Harten LAND SURVEYORS -ENGINEERS February 12, 2026 34492-25 Ryan Mounsey, MCIP, RPP Urban Insights Inc. sent via email Re: Proposed Severance 104-106 Brentwood Avenue, City of Kitchener Sanitary and Water Servicing Review Dear Sir, Van Harten Surveying Inc. was retained by the owner of the subject property to prepare an estimate of the servicing demand in support of the proposed severance application for the subject property. BACKGROUND The property is located on the north side of Brentwood Avenue between Montgomery Road and Jackson Avenue within the City of Kitchener. The property is currently developed with a residential home. The proposed development consists of severing the property into two building lots and constructing a semi-detached unit on each lot. Building plans and a servicing and grading plan have been prepared and submitted to the City for review. Based on a review of the building plans, each side of the semi is proposed to contain two bachelor units, one 1 -bedroom unit, and one 2 -bedroom unit, for 8 units proposed in total. SANITARY There is an existing 300mm sanitary sewer on Brentwood Avenue in front of the subject property. It is proposed to connect each of the severed properties to this sewer with a 1 00m PVC SDR28 572 Weber Street North, Unit 7 2106 Gordon Street 660 Riddell Road, Unit 1 Waterloo, ON, N2L 5C6 Guelph, ON, N1 L 1 G6 Orangeville, ON, L9W 5G5 519-742-8371 519-821-2763 519-940-4110 www.vanharten.com LU • Oy4qHarten RVEYORS - ENGINEERS lateral at minimum 2%. The existing lateral for the former dwelling is to be removed and capped at the main. WATER There is an existing 150mm PVC DR18 watermain on Brentwood Avenue in front of the subject property. It is proposed to connect each of the lot to this watermain with a single domestic service. Each service would consist of a 50mm polyethylene service in the street which would be reduced to a 38mm polyethylene service just inside the street -line. A 38 mm pipe is proposed in the right- of-way as current City standards do not permit the use of 38 mm diameter pipe on the public side. The existing water service is to be decommissioned in accordance with DGSSMS and City standards. Water Demand The estimated water demand was calculated for the property under the proposed condition. Considering a population of 1.78 ppu (Hemson, 2022) and a per capita water usage of 225 L/day (DGSSMS 2026) the expected average daily water demand for this development would be 3,375 L/day or 3.4 cu.m/day. Average day, maximum day and peak hour estimates are provided in the table below inclusive of peak factors and detailed calculations are provided in the attachment. In December 2025, the Region of Waterloo identified a potential water supply constraint issue within the Mannheim Service Area. The Agile Report (January 13, 2026), identified that the Mannheim Service Area is projected to experience an average daily water demand of www.vanharten.com Page 135 of 187 Description PPU Population Average Maximum Peak Hour Day Day (L/s) (L/s) (L/s) Proposed 2 semi- 1.78 14.24 0.04 0.37 0.56 detached dwellings (8 apartments) In December 2025, the Region of Waterloo identified a potential water supply constraint issue within the Mannheim Service Area. The Agile Report (January 13, 2026), identified that the Mannheim Service Area is projected to experience an average daily water demand of www.vanharten.com Page 135 of 187 Oy4qHarten RVEYORS - ENGINEERS approximately 117,441 cu.m/day during 2025. The water demand associated with this development (3.4 cu.m./day) represents approximately 0.003% of the overall projected average daily demand for the Mannheim service area. Sincerely, VAN HARTEN SURVEYING INC. Kristine Campbell, P.Eng. Encl. Water Design Flow Calculation Sheet Encl. Approved Servicing and Grading Plan H:125-344134492-251Letters12026.02.12 Servicing. Docx www.vanharten.com age 136 O Project No: 34492-25 Project Name: Proposed Severance Harten Project Location: 104 Brentwood Avenue, Kitchener Date: 2/11/2026 LAND SURVEYORS — ENGINEERS Update: 2/11/2026 Site Characteristics Site Area = Number of Units = Population per Unit = Site Population = Residential Design Flow Average Daily Demand = Site Population = Average Daily Demand = Site Average Daily Flow = MOE Max. Day Peak Factor = MOE Peak Hour Factor = Peak Max. Day Design Flow = Peak Hour Design Flow = Water Design Flow Calculation 0.055594 ha 8 units 1.78 ppu 15 people Notes: *Per Site Plan 2022 Kitchener Development Charges Study 225 L/cap/day DGSSMS 2026 15 people 3375 L/day 0.04 L/s Flow (L/s) 9.50 0.04 *MOE Design Guidelines, Table 3-3 14.30 *MOE Design Guidelines, Table 3-3 0.37 L/s =Average Daily Flow * Max Day PF 0.56 L/s =Average Daily Flow * Max Hour PF *Water design flow calculations complete with reference to the Region of Waterloo and Area Municipalities DGSSMS (2026) and the Ministry of Environment Design Guidelines for Drinking -Water Systems (2008) H:\25-344\34492-25\Letters\Water and SAN Demand (PPU)_.xlsx Page 137 of 187 Average Daily Flow Max. Day Flow Peak Hour Design Design Guideline (L/s) (L/s) Flow (L/s) DGSSMS/MOE 0.04 0.37 0.56 *Water design flow calculations complete with reference to the Region of Waterloo and Area Municipalities DGSSMS (2026) and the Ministry of Environment Design Guidelines for Drinking -Water Systems (2008) H:\25-344\34492-25\Letters\Water and SAN Demand (PPU)_.xlsx Page 137 of 187 t z 0 art MH . . . . . . . . . ------ 2 n.� wz t z w u < wow0 2n om mu z v �2 UP 0 0 < < > 05 <0 0 d) C6 ooz u >w 0 2 n—H > < 0 u nn d'< w z z W 0- Q �O 2 0, W 0 u) z z z z 0 M -H-H M- o em -EE Ezael< �4 ee 4 H - W, "Eli E 21= oo H -b;! pEz� 2t- Z-! b. 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C O mc >, _ U _0N o N Q +� L Q N_ Q O L L cn Q O .E E O O}' U Q a••+ U- DC m Q U N DC N ClA f6 ME Uq Ill i v, I I C, - 1 OU Lj Now — A Jill e. i00 IN him, QCs Mid! ro, PEI C&A Letter urban+ Date: February 12, 2026 Insights From: Ryan 0. Mounsey. CEO.BES.MUDS.MCIP.RPP. Urban Insights Inc. To: City of Kitchener CofA and Planning Staff Re: 104 and 106 Brentwood Avenue, CofA Application No. B 2025-033 Proposed New Residential (Consent) Lot — Marginal Water Demand Impact Dear Committee of Adjustment ("CofA") and City Staff, A.The Request and New Information The property is located at 104 and 106 Brentwood Avenue shown in Appendix 1, with the severance plan shown in Appendix 2, for reference. I am writing in support of the proposed consent application to create one new residential lot to accommodate a form of gentle -density housing consisting of a semi-detached dwelling with accessory residential units. Based on Regional agency review deferral comments, The Committee of Adjustment received this severance application in December 2025 and the City and Committee chose to defer this Committee of Adjustment application decision to February 17, 2026 CofA meeting. Three months has now passed with limited progress related to development approval protocols. This proposal represents a minor, incremental intensification opportunity within the existing built-up area and is consistent with the Province's direction to optimize infrastructure, support housing supply, and plan efficiently for current and future population growth. This proposal is also supported by the City of Kitchener Official Plan for residential intensification. At the outset, I acknowledge the Region's ongoing concerns regarding water supply constraints within the Integrated Urban System ("IUS"), and in particular the Mannheim Service Area, which has now been evaluated as a distinct service area within the broader system. However, we respectfully submit that this consent application represents a marginal, low -impact servicing scenario and should not be equated with major growth allocations or infrastructure -intensive development approvals. This is a City of Kitchener planning decision, with the Region of Waterloo acting as a commenting agency who has issued a blanket deferral position with respect to development applications across the Mannheim Service Area. 4 Page 148 of 187 Given the demonstrated lag between development approvals and the gradual realization of actual water demand through construction and occupancy, together with ongoing operational adjustments within the Mannheim Service Area, we respectfully request that the Committee of Adjustment approve this minor application. The evidence indicates that this modest scale of development represents a marginal and incremental demand that has no material impact within the system's current capacity context, and that an indefinite deferral of small-scale gentle density applications is neither proportionate nor sustainable. The primary source of available information on the Regional Water Capacity condition is provided in a Peer Review Engineering Study prepared by Agile presented at the January 13 Region of Waterloo Sustainability, Infrastructure and Development (SID) Committee with the website and report links provided below: • Meeting Link: https://pub- regionofwaterloo.escribemeetings.com/Meeting.aspx?Id=94e4b6a1-1817-42d5-9974- b56fbaf2c3b6&Agenda=Merged&fang=English • Agile Report Link: https://pub- regionofwaterloo.escribemeetings.com/filestream.ashx?Documentld=15483 In addition to the Agile Report, please see this technical information prepared by Kristine Campbell P.Eng. from Van Harten Land Surveyors Engineers (Provided in Appendix 3). • A Sanitary and Water Servicing Review was prepared by Van Harten Surveying Inc. (February 12, 2026) to quantify the servicing demand associated with the proposed severance and gentle -density development at 104-106 Brentwood Avenue. • The review confirms that the site is located on an existing serviced urban street with a 150 mm municipal watermain and a 300 mm sanitary sewer, and that the proposed development can be accommodated through standard domestic connections in accordance with City servicing standards. • A 38 mm pipe is proposed in the right of -way as current City standards do not permit the use of 38 mm diameter pipe on the public side. • Based on accepted population and per -capita usage assumptions, the study estimates an average daily water demand of approximately 3.4 M3 /day for the full 8 -unit proposal. • Importantly, the memo concludes that this incremental demand represents only —0.003% of the Mannheim Service Area's projected 2025 average daily demand of 117,441 m3/day. Based on this information, the proposed severance, and development, constitutes a marginal, low -impact servicing scenario that would not have any measurable effect on the overall Mannheim water supply system. IJ Page 149 of 187 B. The "Agile Report" - January 13 2026 (refer to link above) In 2025, the Mannheim Service Area is projected to experience an average daily water demand of approximately 117,441 m'/day, compared to a total sustainable supply capacity of 125,712 m'/day, resulting in a modest theoretical surplus of roughly 8,271 m'/day before any operational resiliency buffer or maintenance outages are applied. This assessment, which shows that the Mannheim Service Area system, is effectively operating at about —89% availability on average (because —11% is offline). This system is in the process of being improved'. This same 'system' is also informed by measured real-world SCADA (Supervisory Control and Data Acquisition) demand and production data, together with updated sustainable capacity estimates, rather than a purely hypothetical model. The Agile Report further notes that actual available capacity may differ from theoretical margins due to facilities being periodically offline for renewal or unplanned shutdowns, and because approved development applications do not translate into immediate water demand, as growth is realized gradually through construction and occupancy over time. B.1.What this Agile Report Means The Region's peer-reviewed evidence (The Agile Report) shows that Mannheim's system constraint is a macro -level infrastructure and operational resiliency issue, driven by overall service -area demand, offline maintenance requirements, and long-term growth realization, rather than the marginal impact of individual low -demand infill projects. In practical terms, a small number of minor lot severances—particularly for modest, low -flow residential connections—do not materially change the system -wide capacity balance in the near term, because water demand is realized gradually through phased construction and occupancy, not immediately upon planning approval. With this information, it is our project team belief that our proposed development believes that the Committee of Adjustment is in a reasonable position consider that a limited number of small-scale severances represent an incremental demand, and should be evaluated proportionately within the broader regional capacity framework, rather than treated as equivalent to major new servicing commitments. ' https://www.therecord.com/news/waterloo-region/waterloo-region-spends-l5-million-to-add-more-water- supply/article Oa4f6f5d-bfO9-5dcb-b4ae-bac62b9baele.html IAI Page 150 of 187 C. Additional Supporting Information to advance the Consent Application C.1. This Consent Application Does Not Constitute a Form 1 Approval or Servicing Expansion The proposed severance is a 'land division' (severance) approval under Section 53 of the Planning Act. It is not: • an application for a new municipal watermain extension, • a servicing agreement, • a registered plan of subdivision, or • a Form 1 authorization for new regulated drinking water infrastructure. In fact, this severance (subdivision of land) meets the intent of the official plan, it is: • The proposed consent represents an orderly and appropriate subdivision of land under Section 53, maintaining the existing residential lotting pattern and neighbourhood character. • The severance supports Provincial Planning Statement (2024 PPS) objectives by enabling gentle density and efficient use of serviced urban land within the settlement area. • The new lot is suitable and desirable for low-rise residential use, providing a compatible form of incremental intensification. • Municipal servicing impacts are modest, relying on a standard residential connection, with detailed confirmation appropriately addressed through the building permit process. • Overall, the proposal reflects good planning, advances housing supply objectives, and is in the public interest as a small-scale, low -impact consent application. As confirmed in the Region's own water supply framework, Form 1 is associated with the authorization of new or modified municipal waterworks, not the creation of a single low-rise residential lot. Based on this, this consent should be evaluated as a planning -level, marginal impact development approval, rather than as a major servicing trigger. C.2. The Proposal Represents a Minor Residential Demand User (15-38 mm Service Connection) The proposed development would be serviced by a standard 38 mm (1.5" residential water service connection, which is typical of low-rise housing forms and fundamentally different from larger connections required for mid -rise or high -demand development. This is not a: • 50 mm connection, • 100 mm connection, • 150 mm connection, or • nor a development requiring new municipal system expansion. The water demand associated with a semi-detached and accessory units is modest in scale and represents gentle intensification consistent with established servicing patterns. Page 151 of 187 C.3. PPS 2024 Supports Optimizing Existing Infrastructure and Timely Growth Accommodation As part of The 2024 Provincial Planning Statement, there are several policy objectives to balance including: • Planning authorities shall provide for an appropriate range and mix of housing options and densities to meet projected needs of current and future residents of the regional market area by: promoting densities for new housing which efficiently use land, resources, infrastructure and public service facilities, and support the use of active transportation (2.2.1.c, Housing). • infrastructure and public service facilities shall be provided in an efficient manner while accommodating projected needs (3.1.1. General Policies for Infrastructure and Public Service Facilities). • Before consideration is given to developing new infrastructure and public service facilities: the use of existing infrastructure and public service facilities should be optimized (3.1.2.a, General Policies for Infrastructure and Facilities). • to accommodate forecasted growth in a timely manner (3.6.1.a, Sewage, Water and Stormwater). • to integrate servicing and land use considerations at all stages of the planning process (3.6.1.d, Sewage, Water and Stormwater). • Planning authorities may allow lot creation where there is confirmation of sufficient reserve sewage system and reserve water system capacity (3.6.7 Sewage, Water and Stormwater). The proposed consent aligns with this specific policy intent by: • Advancing a small-scale, infrastructure -efficient form of housing within the existing serviced area and in a timely manner as new service improvements are on the way to improve the Mannheim Service Area operational capacity. • Optimizing existing infrastructure for the efficient use of land for residential intensification. • The existing Mannheim System average daily usage is below the sustainable supply capacity of 125,712 m3 / day with 8,271 M3 /day. • The proposed incremental demand represents only —0.003% of the Mannheim Service Area's projected 2025 average daily demand of 117,441 m3/day, confirming that the proposed development constitutes a marginal, low -impact servicing scenario that would not have any measurable effect on the overall Mannheim water supply system. C.4. A Marginal Consent Approval Does Not Materially Alter Regional System Risk The Agile assessment, in review, confirms that the Mannheim capacity constraints are driven by: • sustainable supply downrating, • operational maintenance outages, and • long-term infrastructure renewal requirements. 1.1 Page 152 of 187 It is also noted in the Agile Report that offline capacity averages approximately 11% annually due to planned maintenance requirements, with short-term outages exceeding 25% in isolated weeks, reflecting broader system -wide operational constraints rather than project -specific demand impacts. These operational challenges are now being actively addressed through near- term Regional investments and treatment capacity restoration initiatives at the Mannheim Water Treatment Plant, which are intended to improve overall system resiliency over time including this spring. Regional Council decisions and actions show that water system constraints are being improved with the first round of improvements available this springz. C.S. Short Term Improvements are Under Way from Region of Waterloo Special Council Meeting — February 6 Special Council Meeting Regional Council held a Special Meeting on February 6, 2026 to address the emerging water capacity constraint in the Mannheim Service Area and to consider an urgent operational response at the Mannheim Water Treatment Plant. At this meeting, Council approved a new capital project titled the Pilot — Mannheim Temporary Side Stream Treatment, also referred to as the Mannheim Containerized Filtration Solution, with a total authorized budget of $15,162,200, funded from the Water Capital Reserve Fund'. This decision included procurement approvals for specialized filtration equipment, construction services, and associated electrical and engineering work, reflecting the Region's active and immediate investment in restoring lost treatment capacity within the Mannheim system. "This project is a promising innovative solution to add additional capacity in the Mannheim Service Area, until such time that the long-term solution being implemented at the Mannheim Water Treatment Plant (WTP) is complete. Early contractor involvement and advance procurement were required to mitigate schedule risk." (COR - TRY -26-004, February 6 2026 Regional Council). As part of this investment, the Region is committed to install three temporary ultrafiltration container units at the Mannheim Water Treatment Plant, each providing an estimated 50 L/s of flow capacity, to address existing sedimentation and treatment constraints. The first pilot container is anticipated to be installed by June 2026, with the remaining units expected to be operational by July 2027, subject to MECP approvals and implementation requirements. "Staff therefore recommend that Council approve the additional capital expenditure and contract awards as outlined in this report. Subject to Council approval, the work of this contract will begin immediately upon approval. The first container is anticipated to be installed by June 2026, pending confirmation of a number of variables. Based on the result of the pilot, receipt of MECP approvals, confirmation of electrical needs, and other z https://pub-regionofwaterioo.escribemeetings.com/FileStream.ashx?Documentid=15801 3 https://www.therecord.com/news/waterloo-region/waterloo-region-spends-l5-million-to-add-more-water- supply/article Oa4f6f5d-bf09-5dcb-b4ae-bac62b9baele.html II Page 153 of 187 factors to be worked through, it is anticipated that the remaining containers will be installed and operational by July 2027. If successful, the pilot project is expected to add approximately 50 L/s, while the full implementation is expected to add up to 300 L/s of restored capacity." (COR -TRY -26-004, February 6 2026 Regional Council). If successful, the pilot phase is expected to restore approximately 50 L/s of capacity, while full anticipated implementation could restore up to 300 L/s of additional capacity in the Mannheim Service Area. This Regional Council -approved initiative confirms that the Region is actively advancing near-term operational improvements to address the water capacity shortfall. C.6. The Engineering Submission by Van Harten Land Surveyors Engineers An Engineering Technical Memo has been prepared (see Appendix 3) to evaluate the water service connection requirements for the proposed development. This letter, prepared by Van Harten Land Surveyors Engineers confirms that: • A 38 mm pipe is proposed in the right of -way as current City standards do not permit the use of 38 mm diameter pipe on the public side. • The estimated water demand was calculated for the property under the proposed condition. Considering a population of 1.78 ppu (Hemson, 2022) and a per capita water usage of 225 L/day (DGSSMS 2026) the expected average daily water demand for this development would be 3375 L/day or 3.4 cu.m/day. • The water demand associated with this development (3.4 cu.m./day) represents approximately 0.003% of the overall projected average daily demand for the Mannheim service area. Based on this information, the proposed water service connections represent a minor water connection to the water system and will not have any detrimental impact to the Mannheim Service Area water capacity. D. Closing In closing, on behalf of our full project and ownership teams, we respectfully submit that the proposed consent represents a modest, low risk (no tangible impact) and incremental form of gentle -density intensification that will generate only a marginal water demand impact within the broader Mannheim Service Area. The proposed development represents approximately 0.003% of the overall projected average daily demand for the Mannheim service area. The proposal relies on a standard 38 mm (a 1.5 inch service) residential service connection, does not require any trunk infrastructure expansion, and does not constitute a Form 1 approval or major servicing commitment. E:3 Page 154 of 187 Importantly, the available evidence also demonstrates that water demand associated with approved development is realized gradually through phased construction and occupancy (there is a time lag or gap between approval and occupancy), rather than immediately upon planning approval. At the same time, the Region has now initiated active operational improvements to restore treatment capacity, including the recently approved $15.16 million Mannheim Containerized Filtration Solution, which is expected to add meaningful short-term capacity beginning in 2026. In this context, and with a continued indefinite deferral of minor consent applications, risk creating a disproportionate barrier to modest housing delivery, despite their limited servicing footprint. Accordingly, we respectfully request that the Committee of Adjustment approve this consent application as an appropriate, low -impact form of residential intensification that can proceed under constrained conditions, subject to detailed servicing confirmation through the building permit process. This represents a reasonable, proportionate and coordinated planning response that supports gentle density housing delivery while broader regional water supply solutions continue to advance. Sincerely, Ryan Mounsey, CEO.BES.MUDS.MCIP.RPP 40 King St. South, Suite 301 Waterloo, N2J 1N8 CC. Client, Project Team (incl. Masri 0. 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