Agenda Item # Page # PREVIOUS REPORTS PERTINENT TO THIS MATTER RATIONALE

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1 Y Agenda Item # Page # /L. MOTTRAM FROM: SUBJECT: R. W. PANZER GENERAL MANAGER OF PLANNING AND DEVELOPMENT APPLICATION BY: KAP HOLDINGS INC. 186 %t 188 HURON STREET PUBLIC PARTICIPATION MEETING ON MONDAY DECEMBER 7:OO P.M. 1 RECOMMENDATION That, on the recommendation of the General Manager of Planning and Development, the following actions be taken with respect to the application of KAP Holdings Inc. relating to the properties located at 186 and 188 Huron Street: (a) (b) the request to amend the Official Plan Section North LondonlBroughdale Neighbourhood policies to add a sentence to the fourth paragraph as follows: Within the portion of the community at the northeast corner of Huron Street and Audrey Avenue, triplex dwellings in a single family house form may also be permitted, BE REFUSED; and the request to amend Zoning By-law No to change the zoning of the subject property from a Residential R1 Special Provision (RI-5(3)) Zone which permits single detached dwellings to a Residential R2 (R2-6) Zone to permit single detached, semidetached, duplex and converted dwellings (2 units max.); and to a Residential R3 (R3-4) Zone to permit single detached, semi-detached, duplex, triplex, and converted dwellings (3 units max.) BE REFUSED. PREVIOUS REPORTS PERTINENT TO THIS MATTER l None RATIONALE 1, The subject properties are located a block west from the Richmond Street corridor, are well within the interior of the neighbourhood, and have frontage and access on local streets. There is nothing particularly unique nor are there any special attributes which would warrant a site specific amendment to the Official Plan policies for this area The requested amendments to the Official Plan and Zoning By-law would constitute spoy zoning, and are not considered appropriate in isolation from the surrounding neighbourhood. The current Official Plan policies and zoning for this area are appropriate, promote neighbourhood stability, and allow redevelopment of residential properties in a manner which is compatible with the surrounding neighbourhood. 1

2 ~ ~ ~~ ~ Agenda Item # Page # BACKGROUND /L. MOTRAM I1 REQUESTED ACTION: An amendment to the Official Pian Section North, London/Broughdaie Neighbourhood policies to add a sentence to the fourth paragraph as follows: Within the portion of the community at the northeast corner of Huron Street and I Audrey Avenue, triplex dwellings in a single family house form may also be permitted. The, purpose of the Official Plan amendment is to allow for the construction of two triplex dwellings facing Huron Street. I Date Application Accepted Sept. 1, 2005 Agent Zelinka Priamo Ltd. An amendment to the Zoning By-law to change the zoning of the subject property from a Residential R1 Special Provision (RI-5(3)) Zone to a Residential R2 (R2-6) Zone to permit single detached, semi-detached, duplex and converted dwellings (2 units rnax.); and to a 1 Residential R3 (R3-4) Zone to permit single detached, semi-detached, duplex, triplex, and converted dwellings (3 units max.). The purpose of the zoning change is to permit construction of two duplexes on Audrey Avenue and two triplexes on Huron Street within buildings having a single family house form. SITE CHARACTERISTICS: Current Land Use - Residential Frontage Huron St metres (44 ft.); 188 Huron St metres (60 ft.) Depth Huron Street - 54 metres (178 ft.); 188 Huron Street - 54 metres (178 ft.) Area Huron Street square metres (7,832 sq.ft.); 188 Huron Street square metres (10,680 sq.ft.) Shape - regular SURROUNDING LAND USES: North - residential South - residential East - residential West - residential I OFFICIAL PLAN DESIGNATION: (refer to map on page 4) 1 Low Density Residential 11 EXISTING ZONING: (refer to map on page 5) 11 Residential R1 Special Provision (RI-5(3)) ll I II 2

3 . Subject Site: Huron St Applicant: KAP Holdings Inc. Roll Number: B File Number: LOCATION MAP CORPORATION OF THE CITY OF LONDON Prepared By: I D -Planning Planner: LM Created By: LM Date: 11/28/2005 Scale: 1: 1200 N A USubject Site r] Park Parcel 4 Buildings fi Addresses LEGEND

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5 BONUS 2, wfi COUNCIL APPROVED ZONING FORTHE SUBJECT SITE R15(3) LEGEND FOR ZONING BYiL.4 W Z-I Rl -SINGLE DETACHED DWELLINGS R2 - SINGLE AND TWO UNIT DWELLINGS R3 -SINGLE TO FOUR UNIT DWELLINGS R4 - STREET TOWNHOUSE R5 -CLUSTER TOWNHOUSE R6 ~ CLUSTER HOUSING ALL FORMS R7 -SENIOR'S HOUSING RE -MEDIUM DENSITYLOW RISEAPTS. R9 ~ MEDIUM TO HIGH DENSITY APTS. R10 -HIGH DENSITYAPARTMENTS R11 -LODGING HOUSE DA - DOWNTOWN AREA RSA - REGIONAL SHOPPING AREA CSA - COMMUNITYSHOPPINGAREA NSA - NEIGHBOURHOOD SHOPPING AREA BDC - BUSINESS DISTRICT COMMERCIAL AC -ARTERIAL COMMERCIAL HS -HIGHWAY SERVICE COMMERCIAL RSC -RESTRICTED SERVICE COMMERCIAL CC -CONVENIENCE COMMERCIAL SS -AUTOMOBILE SERVlCE STATION ASA -ASSOCIATED SHOPPING AREA COMMERCIAL OR - OFFICE/RESIDENTIAL OC -OFFICE CONVERSION RO ~ RESTRICTED OFFICE OF -OFFICE RF - REGIONAL FACILITY CF ~ COMMUNITY FACILITY NF - NEIGHBOURHOOD FACILITY HER ~ HERITAGE DC -DAYCARE OS ~ OPEN SPACE CR -COMMERCIAL RECREATION OB -OFFICE BUSINESS PARK LI -LIGHT INDUSTRIAL GI -GENERAL INDUSTRIAL HI - HEAW INDUSTRIAL EX - RESOURCE.%TRACTIVE UR ~ URBAN RESERVE "h' - HOLDING SYMBOL. '0' - DENSITY SYMBOL FOR TOWNSHIP ZONES PLEASE SEE THE RELEVANT ZONING BY-LAW FOR A DESCRIPTION OF REGULATIONS CITY OF LONDON DEPARTMENT OF PLANNING AND DEVELOPMENT I ZONING BY-LAW NO. Z.-I I SCHEDULEA I mi3 MAPIS AN UNOFFlClALD(TRACTFROUTHE2ONINGBY-LAW WlTh ADDED NOTATlOhS "H' -HEIGHT SYMBOL 8" ~ SYMBOL 7" -TEMPORARY USE SYMBOL FILE NO LM MAP PREPARED: 2005 Nov MEtEB....

6 Huron Street Figure 6. Site Plan Urban Design Report for the Redevelopment of 186 and 188 Huron Street Prepared by: Zelinka Priamo Ltd. For KAP Holding Inc. September 2005

7 / d l e I- ua 2 0 U a 2

8 Agenda Item#. Page# OZ-6997/L. MOlTRAM PLANNING HISTORY On August 8, 2005, the London Consent Authority issued a notice of final decision to grant an application by KAP Holdings Inc. for a severance of the properties located at 186 & 188 Huron Street (Consent Application B.48/05). The decision is subject to the applicant satisfying a number of conditions that once fulfilled will result in four lots for future residential development (2 lots fronting Audrey Avenue and 2 lots fronting Huron Street) and a right-of-way for a mutual driveway between the Audrey Avenue lots. The properties at 186 and 188 Huron Street have a depth of metres (178 feet). The larger property being 188 Huron Street is a full (60 ft. by 178 ft.) lot from the original plan of subdivision (Lot 11 Plan 384 registered in 1880). The lot depth is similar to properties to the east along the north side of Huron Street. They were later divided into half (30 ft.) lots by Plan 453 registered in 1907 which also created the 12 ft. rear laneway to Audrey Avenue. Houses on these lots were built close to the street with shallow front yards and deep rear yards. The deep rear yards of the 186 and 188 Huron Street properties will be utilized to create new lots fronting Audrey Avenue having frontages of 13.1 metres (43 ft.) and depths of 31.7 metres (104 ft.) each. The new lots are in keeping with the size of lots fronting Audrey Avenue. The Planning & Development Department did not oppose the application. The Department provided comments and recommended a number of conditions be attached to the consent. The comments to the Consent Authority indicated that the proposed severed lots have areas, frontages, and depths which comply with the zoning by-law, that the lots would conform to the established lot pattern in the surrounding area, and that it conforms with the Official Plan. The staff position assumed that the lots would be developed for single detached dwellings. The Official Plan land use designation is Low Density Residential; in addition there are special policies which recognize this neighbourhood in north central London near the University of Western Ontario, referred to as the North LondonlBroughdale Neighbourhood policies. The zoning is Residential R1 Special Provision (RI-5(3)) which permits single detached dwellings. The special provision includes regulations on the size of the building through floor area ratios as well as special parking requirements. In this instance, the zoning will permit a single detached dwelling to be built on each lot for a total of four residential dwellings. The neighbourhood north of Huron Street has changed over time from mainly owner-occupied single detached homes to having a high proportion of tenant occupied dwellings. It has also been under pressure for intensification and redevelopment in response to the demand for housing close by the campus of the University of Western Ontario. A number of homes along Broughdale Avenue, at the north end of Audrey Avenue (177, 179, 182, 184, & 186 Broughdale Avenue) have been redeveloped for new, multiple bedroom single detached dwellings for the purposes of providing rental accommodation. Other redevelopment proposals in the neighbourhood have involved a formal request to change the zoning which were not received favourably and did not receive City Council or community support. In February 2001, Municipal Council refused an application by KAP Holdings Inc. relating to a property located at 1124 Sunset Street, located adjacent to the University of Western Ontario approximately one block west and north of the subject properties. The request was to amend the zoning from a Residential R1 Special Provision (RI-5(3)) Zone to a Residential R2 Special Provision (R2-2( )) Zone to permit duplex dwellings with reduced lot frontage and lot area, and to a Residential R3 (R3-3) Zone to permit triplex and fourplex dwellings. Council s decision was subsequently appealed to the Ontario Municipal Board. The OMB overturned Council s decision and allowed the rezoning to an R3 (R3-3) Zone and approved an amended site plan for the development of a fourplex dwelling. The Board agreed with the appellant s planning evidence that the property was unique insofar as it was the largest property on the street and the only property next to a loading dock and garbage dumpster associated with a university residence. The Board did not accept the City s argument that this would set a 8

9 Agenda Item # Page # MLI /L. MOTTRAM precedent for other properties on the street. The Board decision notes that other lots along Sunset Street are smaller and do not directly abut a large institutional building. In a follow-up report dated September 24, 2001 regarding the OMB decision, Planning Staff advised Planning Committee that this decision should not be viewed as a foundation for dismissing the Official Plan policies and zoning by-law regulations which emanated from the North London Broughdale Study and should not be a basis for recommending spot rezoning in areas designated Low Density Residential. The Board s decision was influenced by the fact that the subject site is unique as it is a large site located next to a university residence loading area and portable garbage dumpster. Staff are not aware of any other similar sites in this neig hbourhood. I SIGNIFICANT DEPARTMENTlAGENCY COMMENTS 11 The City s Environmental and Engineering Services Department reports: EESD has not identified any engineering concerns with respect to the aforementioned Official Plan and Zoning By-Law amendment application. Site servicing, grading & drainage, on-site stormwater management requirements and transportation issues will be addressed in detail through the development approval process. PUBLIC LIAISON: Notice of application to amend the Official Plan and zoning by-law was sent to 120 surrounding property owners on October 11, A notice appeared in the Living in the City section of the London Free Press on Saturday October 15, replies received Responses: The Planning Division received seventeen telephone calls and forty-six written responses. The majority of respondents expressed opposition to the application. There were no responses received in support of the application. Comments and concerns are summarized as follows: This is spot rezoning and poor planning to consider proposals on a piecemeal basis It is not good planning to increase the density of the interior of the neighbourhood while there are other opportunities for development in areas already zoned for higher densities It would demolish two existing houses, and replace them with two duplexes and two triplexes It is out of scale and does not fit into the existing established streetscape comprised of A frame single family bungalows with porches It impacts the character of the low density residential area The proposal is over-intensive and will cause parking, garbage and noise problems The existing backyards would be paved over to create a large parking lot, and traffic on the block would increase accordingly The community association has worked with the city s by-law enforcement to find creative solutions to these issues. Problems persist and will only get worse if more overintensification (such as this proposal) is allowed This development proposal would severely impact the neighbourhood, conflicts with the City s planning policies for Broughdale, and violates established principles of good planning 9

10 Agenda Item # Page # OZ-6997/L. MOlTRAM ANALYSIS Existina Situation The homes at 186 and 188 Huron Street are one storey single detached bungalows originally built over a half century ago. A split-level addition was constructed on to the rear of the home at 188 Huron Street as a second dwelling unit created under the former Bill 120 legislation. The applicant's plan for redevelopment includes the demolition of the existing houses and the creation of two new additional lots facing Audrey Avenue. The application for Official Plan and zone change would permit the construction of two duplex dwellings on the new lots fronting onto Audrey Avenue, and two triplex dwellings on the retained lots facing Huron Street. The amendment to the Official Plan policies is intended to be site specific to that portion of the Broughdale community at the northeast corner of Huron Street and Audrey Avenue to permit triplex dwellings in a single family house form. The application was accompanied by an Urban Design Report for the Redevelopment of 186 and 188 Huron Street, prepared by the applicant's agent Zelinka Priamo Ltd. The report includes an inventory of the homes in the area, an analysis of architectural styles and design elements, and characteristics of the neighbourhood generally bounded by Richmond Street, Huron Street, Sunset Street, and the University of Western Ontario. The study indicates the proposed houses would share most of the same design elements and qualities as the existing houses in the neighbourhood; that it would be in keeping with the existing adjacent two storey houses on the northwest and southwest corners of the intersection of Huron Street, St. George Street and Audrey Avenue; and that they would have rear yard parking rather than front yard parking common to the study area. The proposed dwellings are depicted in a colour rendering of the streetscape included within the report. An excerpt of the site plan of the proposed redevelopment of 186 and 188 Huron Street from the Zelinka Priamo study is shown on Page 6 of this report. The application was accompanied by a drawing of the front elevations of the proposed buildings shown on Page 7. It is recognized the character of the neighbourhood has changed over time; particularly the blocks between Huron, Broughdale, Richmond, and Sunset Streets have gone from mainly owner-occupied single detached homes to a high proportion of tenant occupied dwellings. This area has been under pressure for intensification in response to the demand for off-campus housing in close proximity to the University of Western Ontario. While there is pressure for change and new opportunities due to the location adjacent a growing university, this area is also an integral part of a larger neighbourhood to the south and west which includes Regent Street, Sherwood Ave, Victoria Street, and The Parkway. Official Plan The Official Plan land use designation is Low Density Residential which permits primarily lowrise, low density housing forms including single detached, semi-detached, and duplex dwellings. Where appropriate, some multiple-attached dwellings at densities similar to neighbouring detached units may be permitted. There are also special policies which apply to this area which are referred to as the North LondonlBroughdale Neighbourhood policies. Under Section of the Official Plan: It is anticipated that there will be demand for residential intensification and infill development within portions of the North London/Broughdale neighbourhood during the planning period. Area-specific guidelines are required which will direct future residential development to suitable locations, and protect the character of the existing low-rise, low density residential community. Multiple unit residential development is directed to those areas within the Oxfod, Richmond and Adelaide Street North corridors that are designated Multi-Family, High and 10

11 AgendaItern#. Page# OZ-6997/L. MOmRAM Multi-Family, Medium Density Residential. Except for lands identified in Policy (a), in Low Density Residential areas fronting onto the Richmond and Adelaide Street North corridors, residential intensification may be permitted through conservation and rehabilitation of the existing housing stock, provided there is adequate space to accommodate required on-site parking and landscaped open space and that intensification is of a scale which is compatible with surrounding land uses. For Low Density Residential areas located outside of the Richmond and Adelaide Street North com'dors, conservation and rehabilitation of the existing housing stock shall be encouraged. In keeping with the low-rise, low density character of these areas, residential uses will be restricted to single detached, semi-detached, duplex and converted dwellings (to a maximum of 2 units). Area-specific zoning regulations such as floor area ratio, maximum dwelling size and on-site parking limitations will be applied in parts of the neighbourhood that may be impacted by residential intensification and infill, to ensure that future development is not out of scale and character with the existing residential community. The following objectives will guide the implementation of Low Density Residential policies for the Old North/Broughdale neighbourhood: i) i) i) iv) the height, bulk and placement of buildings will be in keeping with that of existing development in the surrounding area; all required parking will be accommodated on site and limited in area; development will be sensitive to the orientation of adjacent dwellings and to the continuity of the existing residential streetscape; and, any new lots created through consent will be in conformity with the minimum zoning requirements, and in keeping with the established lot pattern (in terms of frontage, depth, and overall size) in the surrounding areas. These policies were the result of the North LondonlBroughdale Study undertaken by the City's Planning Division approximately ten years ago. The study included public participation and consultation with the Student Housing Advisory Committee, Urban League, builders and individuals active in the area. The purpose of the study was to evaluate the impacts of residential intensification on the neighbourhoods and determine whether existing Official Plan policies and Zoning by-law regulations should be revised. The policies describe the character, important attributes and desired planning objectives for the area, Although they were established as part of a study undertaken ten years ago, they have been effective and continue to be relevant to the planning issues facing these neighbourhoods today. Since that time, the City has responded to other neighbourhoods in north-central London experiencing similar problems to determine if they merit similar policies and zoning restrictions. The subject properties are located a full block west from the Richmond Street corridor, are well within the interior of the neighbourhood, and have frontage and access on local streets. There is nothing particularly unique nor do they have any special attributes which would warrant a site specific amendment to this section to add wording to the effect that: "Within the portion of the community at the northeast corner of Huron Street and Audrey Avenue, triplex dwellings in a single family house form may also be permitted." Zoninn The current zoning is Residential R1 Special Provision (R1-5(3)) which permits single detached dwellings. The special provision includes regulations on the size of the building through floor area ratios, maximum gross floor areas, and special parking requirements. The special provision zoning is in keeping with the North LondonIBroughdale neighbourhood objectives and policies. The newly created lots will conform with the lot frontage and area requirements of the zoning by-law. Based on the proposed lot areas, the zoning will permit a single detached dwelling to be built with a floor area ratio of 45%, or a maximum gross floor area of 200 square metres, 11

12 Agenda Item # Page # /L. MOlTRAM whichever is less. Based on Staffs calculations, the zoning would permit a single detached dwelling with a maximum gross floor area of 187 square metres (2,012 sq.ft.) each for the proposed Audrey Avenue lots, a maximum gross floor area of 196 square metres (2,113 sq.ft.) for the corner lot fronting Huron Street, and a maximum gross floor area of 200 square metres (2,153 sq.ft.) for the inside lot fronting Huron Street. These zone standards would allow redevelopment of the properties for reasonable sized single detached dwellings; and dwellings of this size it is reasonable to assume could accommodate up to five bedrooms each. The zone map on page 5 of this report illustrates the zoning in the surrounding neighbourhood has been applied in a uniform manner. The Residential R1-5(3) zone applies to properties along Huron Street and St. George Street to the south, east and west. The Residential R1-4(7) zone, which permits single detached dwellings on slightly smaller lots, applies to the properties along Audrey Avenue and Broughdale Avenue to the north. There is a greater variation of land use and zones along Richmond Street which is a heavily travelled arterial road. However, the zoning of the interior neighbourhoods west of Richmond Street is fairly consistent and reflective of a stable low density residential neighbourhood. The requested amendment is to change the zoning of the subject properties from a Residential R1 Special Provision (RI-5(3)) Zone to a Residential R2 (R2-6) Zone to permit single detached, semi-detached, duplex and converted dwellings (2 units max.); and to a Residential R3 (R34) Zone to permit single detached, semi-detached, duplex, triplex, and converted dwellings (3 units max.). The purpose of the zoning change is to permit construction of two duplexes on Audrey Avenue and two triplexes on Huron Street within buildings having a single family house form. Rezoning the subject properties in isolation from the surrounding area represents "spot" rezoning and should be discouraged. The current zoning for this area is considered appropriate and allows for an appropriate level intensification and redevelopment that is compatible with the surrounding residential neighbourhood. CONCLUSION 'Based on our review of the application, the requested amendments to the Official Plan and Zoning By-law would constitute "spot" zoning, and are not considered appropriate in isolation from the surrounding neighbourhood. The current Official Plan policies and zoning for this area are appropriate, promote neighbourhood stability, and allow intensification and redevelopment of residential properties. 11 PLANNER -IMPLEMENTATION 1 MANAGER r RECOMMENDW BY: A OF IMPLEMENT~TION v R. W. PANZER GENERAL MANAGER OF PLANNING AND DEVELOPMENT November 30,2005 RWPNMFILMllm

13 Agenda Item # Page # lL. MOlTRAM Responses to Public Liaison Letter and Publication in "Living in the City" Telephone Written Parkway Sandra Boersen Nathan Garber I 1071 Richmond St. K... Bhatia Peggy Anderson I 83 Victoria St. Stephen Pitel I 164 Sherwood Ave David A. Bratton I325 St. George St. Grant Barker I 1071 The Parkway Rebecca Soltan Jennifer Davies I 521 St. George St. Jane MacDonald & Don Rhynas I 195 College Ave Dr. Pearl Langer I20 Gibbons Place Charles & Jill Wright I 1075 The Parkway Janice Mavne I 1070 Lombard0 Ave 1 Susan Bentley I34 Mayfair Dr. I Bonnie Hawlik / 1102 The Parkwav 13

14 , London City Hall 300 Dufferin Ave P.O. Box 5035 London, Ontario N6A 4L9 Oct Attention Planning Committee Members 0 U.F. RE. KAP Holdings Inc. 186 & 188 Huron Street London Ontario FIL@ - Dear Members, - I strongly oppose and object to this Application to amend the Official' Plan & Zoning By-Law to allow construction of 2 triplexes fronting on Huron Street, and 2 duplexes fronting on Audrey Ave. The total proposed development is for 10 residential units containing 50 bedrooms in 4, 2 story single family dwellings on 4 single family zoned lots. Should the O.M.B. approve 6 bedrooms per unit, this proposed development would contain 60 bedrooms. Existing Official Plan and Zoning By-Law This area under consideration is designated and zoned for Single Family only,and should remain in force. Spot Official Plan & Zoning By-Law Amendments This application is a clear case of a spot proposed Official Plan Amendment and a spot proposed rezoning amendment which will have drastic consequencesnces.granting approval to this proposal would set a bad precedent whereby other landowners will submit similar applications on their properties and expect approvals. This is poor planning in considering proposals on a. piece meal basis having little or no regard for the Official Plan Policies,and Zoning By-Laws in force. The existing Official Plan and Zoning By-Laws are successfully promoting and maintaining neighbourhood stability,the residential character,streetscape,amenities of the area,in this low density residential area.almost 100% of the houses on Huron Street from Audrey Ave. to Richmond St,houses on Broughdale Ave. from Audrey Ave to Richmond St. and the nearby St. George St. houses are all single family bungalows.this application to amend the Official Plan and Zoning By-Laws should be deni.ed. Severance The recent granted 2 severances recognized that the proposed lots conform.to the existing Official Plan and Zoning By-Laws thus permitting only single family houses on these lots. See Consent Authori.ty File Application # B.48/05. I objected to this application on the grounds that a plan of subdivision should be processed to upgrade Audrey Ave. to municipal standards and safety.1 also expressed my concern over the intensification of bedrooms 48 in total that could be proposed on this site.0ther concerns were also expressed. Please refer to my June 21/05 letter enclosed.it appears that Audrey Ave. will not be improved including sidewalks,but you certainly have a proposal for 50 bedrooms, currently at 5 bedrooms per unit. This may increase to 6 bedrooms per unit for a total of 60 bedrooms in 4 single residences on 4 single family zoned 1ots.This is surely over intensification in relation to the existing approved Official Plan, Zoning By-Laws and low density housing in the area. This application should be denied. '

15 Current City Concerns 1 Existing Official Plan and Zoning By-Laws 2 North London Residential Zoning Study 3 By-Law No. C.P The City is promoting neighbourhood stability and to preserve the residential character,streetscape and amenity of the area by determining the appropriate intensity and scale Qf residential redevelopment and conversions. There is concern about the impacts of recent and proposed redevelopments and residential intensification activity in the North London area. Major concerns include existing floor area ratio and parking regulations,parking concerns, loss of residential amenity space,lack of compliance with property standards,and excessive noise and garbage all of which relate to the high concentration of students. Effects of this proposal This proposed redevelopment does not meet nor conform to the City's Official Plan,Zoning By-Laws, nor development policies.this proposal will disrupt the low density residential area,character, streetscape,lack of parking for 60 bedrooms plus visitor parking. This proposal is out of scale,too intensified,high density with all the related problems and negative impact on the surrounding area.the 2 storey plus structures and completely paved backyards do not preserve the existing residential character. These dominating 4 structures will be an eyesore in the heart of this neighbourhood Proposed Intensification This is a highly intensified proposal. To understand the effect consider the following : At 5 bedrooms per unit,this proposal with 2 triplexes containing 6 units in total, generating 30 students. This proposal also has 2 duplexes containing 4 units in total, generating 20 students. The developer is proposing 50 bedrooms with 50 students on 4 single family lots. If the single family bungalows have 5 students each,then 10 bungalows would be required to equal the bedroom numbers and student numbers that are proposed on the applicant's corner property. It's like taking all the bungalows along Huron Street, from the proposed site to Richmond Street, and transferring the bedroom and student numbers on to the corner lot. At 6 bedrooms per unit, 60 students in 60 bedrooms will further intensify this site,with increased negative impact upon the neighbourhood. This proposal is not an appropriate intensity and scale of residential redevelopment and should be denied. Streetscape This proposal is out of character and does not complement or fit into the existing established and preserved streetscape comprising of cute single family bungalows A frame with porches.2 story buildings on this corner does not enhance nor compliment nor preserve the streetscape. Approximately 5 new bungalows were recently built, around the corner from this subject site, on both sides of Broughdale Ave..These houses were built in a single family bungalow structure.these new houses totally fit into the existing residential character and streetscape in terms of complying with the Official Plan and Zoning By-Laws. These houses are 1 story A frame with a porch, not intensified with development,and provide sufficient parking at rear. These houses complement the neighbourhood and are preserving and promoting stability.if these builders built single family 1 story houses in conformity with the Official Plan and Zoning By-Laws,there are no reasons why this applicant KAP Holdings inc. cannot build the same.if it made economic sense to the other builder it should make economic sense to this applicant KAP Holdings Inc.. This area is not transitional. This area is not in decay. The subject property does not justify a spot Official Plan Amendment and Re-

16 Zoning to change the land use to allow for an inappropriate residential intensification, inadequate parking and all the other adverse impacts on the residents and neighbourhood.this proposal should be denied. Scale of Development The 4 proposed Zstory structures is out of scale and overpowering at this corner in relation to the neighbourhood scale. The intensity of development is too high, with inadequate parking and other deficiencies.the structures don,t conform to the Zoning By-Law set back requirements. The lot will be paved for driveways and parking. The scale should be restricted to single, family use in 1 story houses similar to the existing houses and the houses recently built on Broughdale Ave..This proposal should be denied. Lot Sizes The lots on Huron Street are very shallow only 92 feet in depth. All these lots are too small to fully accommodate 2 triplexes and 2 duplexes [min 50 bedrooms,possible 60 bedrooms] What if the bedrooms are shared between 2 students,like in residence at U.W.O. the student population generated would be 100 or more. These lots cannot accommodate the required parking for such an intensified residential proposal. This proposal should be denied. Loss Of Residential Amenity Residential amenities will be 1ost.There will not be any grass areas and no gardens especially in the rear and side back yards.the entire lots will be covered with the building envelopes and paved driveways and parking areas. This proposal is intensified that the density is too high and required parking cannot be provided.excessive noise and garbage will be present all of which relate to the high concentration of students.this development will certainly negativily impact upon the immediate neighbours and the community. This proposal should be denied. Parking This proposed redevelopment site could generate between 50 to 60 plus number of bedrooms and student population, assuming that each student occupies a single bedroom.most students have cars, or a use of a car, therefore adequate parking should be provided on the subject properties. The proposed parking is inadequate, it should be at least doubled, in addition to providing guest parking on each property. Due to intensification proposed floor areas increase significantly as well as the floor areas ratios with parking.the existing floor area ratio and parking regulations in the Official Plan and Zoning By-Laws in the Broughdale neighbourhood should not be amended. Mutual driveways are proposed and cars are not parked in these areas, therefore all the parking is in the rear yards with additional driveways with parking spaces.can you imagine the vehicular conjestion if all students had a car? Huron Street is not an arterial main road like Richmond Street. Bus service in not provided along this portion of Huron Street.Students may walk to campus but they still need parking spaces for their cars. This proposal should be denied. Noise and Garbage The proposed development on this property is intense,generating 50 to 60 plus bedrooms wih a 50 to 60 plus student population.the negative impacts on the residents and the neighbourhood including intensification,scale of buildings,parking concerns,lack of compliance with property standards,excessive noise and garbage all of which relate to the high concentration of students will be continually experienced.this proposal should be denied.

17 Other Concerns 1. The developer is proposing his own minimum By-Law Zoning standards to accommodate his proposed intensified residential redevelopment.this should not be permitted. 2. The proposed Official Plan Amendment is too general allowing" triplex dwellings in a single house form may also be permitted". My concern is adjacent owners may apply for a triplex in their houses, that would conform to the amendment if approved. 3. The developer may change his plans and request approval for 4 triplexes, one on each of his 1ots.The Zoning By-Laws implements the Official Plan, and since the Official Plan, if approved,permits triplexes on the subjects property the rezoning would be in conformity and implement the Official Plan.The Official Plan and' Zoning By-Laws should not be amended,and the proposal should be denied. 4. The developer will seek "minor" adjustment approvals from the London Consent Authority.The developer will then resubmit a proposal to the City Council and Planning Committee for approval. 5. This developer will appeal the Municipal Council for the City of London's decision to the Ontario Municipal Board,if City Council denies the proposed amendment to the City's Official Plan and Zoning By-Law. The City should be prepared to defend it's position to "promote neighbourhood stability,and to preserve the residential character, streetscape and amenity of the area by determining the appropriate intensity and scale of residential redevelopment and conversions". Conclusions 1. The proposed Official Plan and Zoning by-law amendments for 2 triplexes and 2 duplexes, for a total of 50 to 60 units with 50 to 60 students, on the small corner lots, are contrary to the Official Plan and Zoning By- Laws. Only low density single family uses are permitted. 2. Spot Official Plan and Spot By-Law Amendment approvals are bad planning practices and should be avoided. 3. The existing Official Plan and Zoning By-Laws are successfully promoting 'and maintaining neighbourhood stability,residential character, streetscape and other amenities associated with low density residential uses. Our area is not in decay. 4. Severance was granted for the building of 4 single family houses in conformity with the Official Plan and Zoning By-Laws. See my June 21/05 letter. 5. This proposal is intensified and does not promote neighbourho0.d stability, 6. This proposal does not preserve the residential character. I. This proposal does not preserve the streetscape and amenities of the area. 8. This proposal is not an appropriate intensity and scale of residential redevelopment and conversions. 9. The lots are small, 2 lots fronting on Huron Street are only 92 feet deep.in order to maximize the density and building envelope the deve.loper is proposing a mutual drive way for 2 lots [ both 42.9 feet wide and 104 feet deep] that front on Audrey Ave. Lot are too small to provide 100% parking for all the students. The building set backs are substandard. IO. There will be,little or no residential amenities in the side or rear yards where it is private, since the areas will be paved for driveways and parking. 11. Not enough parking is proposed. I think only 3 parking spaces are provided per unit,for a total of 12. There are 50 to 60 bedrooms with a 50 to 60 student population If all students have cars where will they park on these

18 lots? In addition visitor parking spaces are also required. Where will they be located on these lots? 12. Excessive noise and garbage all relate to high concentration of students and the neighbourhood will certainly experience the negative impacts from the proposed intense development of this site. 13. Other builders have rebuilt single family homes on Broughdale Ave. near this applicants' property. These houses complement the style, structure, residential character and streetscape of the area, adding to the stability and viability of this area.these developments conform to the Official Plan and Zoning By-Laws. 14. This North London/Broughdale Neighbourhood is not in transition,and certainly not in decay and accordingly can not, and does not support,nor justify the proposed land use change and redevelopment of residential intensification on the property of Kap Holdings Inc. at 186&188 Huron Street. 15. The application to amend the Official Plan and Zoning By-Law submitted by Kap Holdings 1nc.for 186 and 188 Huron Street should be denied. Yours sincerely Joseph Stepaniuk I would like to have these comments appended to the staff report Thank you. Cc Councillor Joni Baechler Cc Councillor Rob Alder CcBroughdale Community Association Mrs. M Blosh