City of Regina
Saskatchewan CA

RPC Public Report.
RPC21-8

3160 Albert Street - Heritage Designation Bylaw Amendment, Zoning Bylaw Amendment (Contract Zone), and Partial Street Closure of Hill Avenue (PL202000128, PL202000160)

Information

Department:Planning & Development ServicesSponsors:
Category:Not Applicable

Attachments

  1. Printout
  2. Appendix A-1
  3. Appendix A-2
  4. Appendix A-3
  5. Appendix B-1 (This file has not yet been converted to a viewable format)
  6. Appendix B-2
  7. Appendix B-3
  8. Appendix C
  9. Appendix D
  10. Appendix E-1
  11. Appendix E-2

Report Body

ISSUE

 

The Applicant and Owner (Carmen Lien) proposes to redevelop the property at 3160 Albert Street to accommodate multi-family land uses (Building, Stacked). The property, particularly the existing dwelling situated thereon, also known as the "Cook Residence," was designated as a Municipal Heritage Property on October 29, 2019 (Bylaw No. 2019-7). The proposed development applications would require amendments to the existing heritage designation bylaw, amendments to The Regina Zoning Bylaw, 2019 (Zoning Bylaw) to authorize the approval of a contract zone agreement to rezone the subject lands, and a street closure bylaw to allow for the sale of a portion of the existing Hill Avenue right-of-way to accommodate the proposed development.

 

Approval of a contract zone requires alignment with policies prescribed by Design Regina: The Official Community Plan Bylaw No. 2013-48 (OCP), including those applicable to built heritage and historic places, land use and built environment and others. The Administration does not support the proposal from a heritage perspective as the proposal does not align with policies pertaining to consideration of changes to heritage properties. Furthermore, although the OCP is generally supportive of residential intensification, policies for development in this location encourage development that demonstrates compatibility with the existing built form and neighbourhood character. The proposal does not sufficiently demonstrate compatibility with the surrounding built environment and Administration’s position is that the proposal is not consistent with the established character of the area and streetscape along the west side of Albert Street. Therefore, Administration recommends denial of the proposed applications.

 

Applications required for this proposal are being considered pursuant to The Planning and Development Act, 2007; The Heritage Property Act; The Cities Act, the OCP and the Zoning Bylaw.

 

IMPACTS

 

Financial

The subject properties receive a full range of municipal services, including water, sewer and storm drainage. If the application is approved, the applicant would be responsible for the cost of any new or changes to existing infrastructure that may be required to directly or indirectly support any proposed development in accordance with City standards and applicable legal requirements. The owner/applicant would also be required to enter into a Development Levy Agreement prior to issuance of a development permit and will be responsible for the payment of any applicable levies.

 

Expenses related to the heritage property conservation are eligible for reimbursement under the Heritage Building Rehabilitation Program. No such application has been submitted yet.

 

Accessibility

The development would be required to conform to accessibility provisions of the Uniform Building and Accessibility Standards Act

 

Policy/Strategic

The proposed development relates primarily to the following OCP policies regarding intensification, compatibility of built form, housing, and heritage conservation, which are summarized as follows:

 

 

Section C – Growth Plan

 

Goal 1 – Long Term Growth:  Ensure that sufficient developable land is protected for future city growth.

 

·         Policy 2.2: Direct future growth as either intensification on or expansion into lands designated to accommodate a population of approximately 300,000, in accordance with Map 1 – Growth Plan.

·         Policy 2.3: Direct at least 30% of new population to existing urban areas as the City's intensification target.

 

Goal 3 – Intensification: Enhance the city's urban form through intensification and redevelopment of built-up areas.

 

·         Policy 2.7: Direct future higher density intensification to the CITY CENTRE, existing URBAN CENTRES and CORRIDORS and adjacent INTENSIFICATION AREAS where an adequate level of service and appropriate intensity and land use can be provided.

·         Policy 2.8: Require intensification in BUILT OR APPROVED NEIGHBOURHOODS to be compatible with the existing built form and servicing capacity.

 

Section D5 – Land Use and Built Environment

 

Goal 1 Complete Neighbourhoods: Require that NEW NEIGHBOURHOODS, NEW MIXEDUSE NEIGHBOURHOODS, INTENSIFICATION AREAS and BUILT OR APPROVED NEIGHBOURHOODS are planned and developed to include the following:

 

·         7.1.5 A diversity of housing types to support residents from a wide range of economic levels, backgrounds and stages of life, including those with specific needs;

·         7.1.8 A distinctive character, identity and sense of place;

·         7.1.9 Buildings which are designed and located to enhance the public realm, and contribute to a better neighbourhood experience;

 

Goal 6- Built Form and Urban Design: Build a beautiful Regina through quality design of its neighbourhoods, public spaces and buildings.

 

·         7.38 Consider impacts of alterations, development, and/or public realm improvements on or adjacent to an HISTORIC PLACE to ensure heritage value is conserved.

 

Section D6 – Housing

 

Goal 1- Housing Supply and Affordability: Increase the housing supply and improve housing affordability.

 

·         8.6 Support the conversion of non-residential and heritage buildings to new residential uses where appropriate.


Section D8 – Culture

 

Goal 1- Support Cultural Development and Cultural Heritage: Enhance quality of life and strengthen community identity and cohesion through supporting cultural development and cultural heritage.

 

·         10.2 Consider cultural development, cultural resources and the impact on HISTORIC PLACES in all areas of municipal planning and decision-making.

 

·         10.3 Identify, evaluate, conserve and protect cultural heritage, HISTORIC PLACES, and cultural resources, including but not limited to PUBLIC ART identified on Map 8 – Cultural Resources, to reinforce a sense of place.

 

·         10.4 Protect, conserve and maintain HISTORIC PLACES in accordance with the "Standards and Guidelines for Historic Places in Canada" and any other guidelines adopted by Council.

 

The applicants proposal aligns with some general policies in the OCP, but challenges policies more specific to the neighbourhood. The proposal would help to achieve infill targets to accommodate 30 per cent of new housing within the existing built area, encourage housing diversity, and contribuite to a strong relationship between buildings and the public realm. However, the OCP does not support the proposed residential intensification in this location. The subject property is located within the "Built or Approved Neighbourhood" area of Map 1 – Growth Plan (Appendix E-1), which are "comprised of lands that are predominantly built or approved residential areas that will be subject to additional change through limited intensification in accordance with the OCP." While the OCP provides the flexibility to consider intensification on any site within the "Built or Approved Neighbourhood" policy area, intensification is not explicitly encouraged as a primary development objective as would be the case in an "intensification area" or "urban corridor." The OCP requires that any intensification within this policy area must be demonstrated to be compatible with the surrounding built form and servicing capacity.

 

The subject property is in the Lakeview neighbourhood, which is identified as a potential heritage district policy area (Appendix E-2). Therefore, retention of neighbourhood character, compatibility of built form, and heritage conservation are the paramount policy objectives for the neighbourhood. This is of particular importantance in this case given the building has heritage designation. As detailed in the Discussion section of this report, the applicant's proposal challenges many criteria used to assess these policy objectives and the Heritage Designation Bylaw.

 

Rehabilitation of designated heritage properties can be an expensive proposition for property owners. The City currently provides up to 10 years in property tax exemptions to support conservation and is exploring additional options for incentives through a policy review that will be brought in front of City Council in October. Additional development can be a means to increase the financial viability of a heritage rehabilitation project. Any new development on the site would need to strongly align with heritage principles and demonstrate compatibility with surrounding built form to be supported. In the Administration's opinion, the current proposal does not align with the Standards and Guidelines for the Conservation of Historic Places in Canada, which is the accepted national standard for assessment of changes to historic places.

 

OTHER OPTIONS

 

Alternative options would be:

 

1.      Approve the applications. Approve the application as proposed if City Council determines that the proposal aligns with the OCP and Standards & Guidelines for the Conservation of Historic Places in Canada. If City Council decides to approve the proposal, the referenced applications should be approved as well as the proposed closure of a portion of Hill Avenue and Administration should be instructed to prepare the necessary bylaws and contract zone agreement specifying conditions to give effect to those decisions to be brought forward for City Council's consideration at a separate meeting following the required public notice. This would allow Administration to review and approve permits within its authority to implement the decision of Council.

 

2.      Direct the Administration to consider specific revisions to the proposal and the related applications or obtain more information in consultation with the applicant. Administration would work with the applicant to identify and evaluate alternatives or gather additional information City Council deems necessary. After the information has been gathered, a supplementary report would be provided to City Council for further consideration and decision to approve or deny the proposal. City Council may move to refer the applications back to the Administration, identifying the specific amendments or information Council wishes to have considered when the matter is returned and directing that the supplementary report be considered first by Regina Planning Commission or brought directly back to City Council.

 

3.      Repeal the Heritage Designation Bylaw. The heritage designation of the property may be repealed, which would allow for outright demolition of the property. This option may be considered if City Council concludes that the property should not be rezoned to allow for multi-family residential development and that investment into the property to ensure continued reuse is not feasible. If City Council decides to remove the heritage designation from the property, the Administration should be instructed to issue and serve notice of City Council's intention to consider a bylaw to repeal Bylaw 2019-7. This would mean that any subsequent development proposals brought forward would need to be compliant with the R1 – Residential Detached Zone in the Zoning Bylaw.

 

COMMUNICATIONS

 

The Applicant and other interested parties will receive a copy of the report and notification of their right to appear as a delegation at the Council meeting when the application will be considered.

 

 

DISCUSSION

 

The Applicant proposes to redevelop the property at 3160 Albert Street to accommodate multi-family land uses. The property, also known as the "Cook Residence," was designated as a Municipal Heritage Property on October 29, 2019 (Bylaw No. 2019-7). Key features of the applicants proposed development are as follows:

 

·         Portions of the existing building would be retained, which includes the front of the building facing Albert Street, less the sunroom to the south, which will be removed. This portion of the building would be relocated on the site to allow for construction of the new foundation and underground garage and then placed on a new foundation to align with the front setback of the property to the north. Approximately 50 percent of the existing building footprint other than the attached garage would be retained, and the rest would be demolished. Appendix A-1 shows the proposed building footprint on a current aerial photo.

 

·         New additions to the building would include development to the rear and the south side of the retained heritage structure. Development behind the heritage front façade would be two storeys in height and consist of four residential units to be accessed from the original entry. Development to the south of the heritage structure would be three storeys and consist of 12 residential units to be accessed from three separate common entries from grade.

 

·         Thirty-four (34) parking stalls are proposed to be accommodated on-site. Twenty-four (24) stalls would be accommodated below grade with an access from the rear alley. Ten (10) stalls would be accessed at surface grade directly from the lane.

 

To this end, the applicant has submitted the following applications requiring City Council's consideration and approval:

 

1.              Amendment to the Heritage Designation Bylaw (2019-7) to remove references to the sunroom, concrete foundation, and glass-bottom bottles. Beyond these items identified by the applicant, Administration has determined that references to setback, windows and rooflines would need to be amended in the Bylaw, and small gable dormer on front façade created by intersecting gable rooflines would need to be removed if the application is approved.

 

2.              Amendment to the Zoning Bylaw authorizing a contract zone agreement to allow for the carrying out of a specific proposal which would include the development of a "Building, Stacked" land use consisting of 16 residential units in this location. If approved, the development would be generally limited to the approved plans.

 

3.              Closure of a portion of the Hill Avenue right-of-way. The applicant has requested to purchase a 3.25 meter wide portion of the boulevard between the subject property and sidewalk to allow for an expanded property and more development area. The City has entered into an agreement for sale of the requested land area with the applicant, conditional on Council passing a bylaw for the closure and sale of the right-of-way in accordance with The Cities Act. As these lands are under the control and management of the City (effectively as the landowner), as the land has been deemed surplus. This application would only proceed if the other bylaw amendments are approved.

 

All three applications requiring Council's approval have been reviewed concurrently. While the proposed amendments to the Heritage Designation Bylaw is a separate matter from the proposed rezoning and street closure applications, and each application should be justified on its own merits, the ultimate purpose of each bylaw amendment is the same, which is to allow the approval of the applicant's proposal. Through this approach, the Administration intends to present all relevant information and the developer's intentions to all stakeholders involved rather than consider each component of the approval separately. If City Council does not support the proposed development, then there is no reason to approve any of the individual bylaw amendments which are required to accommodate the proposed development.

 

If Council approves the applications, the Administration would proceed to review other applications to which it has been delegated authority. These include a consolidation application to legally incorporate the portion of Hill Avenue right-of-way into the subject property; a heritage alteration permit to ensure the details of the development align with the designation bylaw and applicable heritage criteria; and a development permit, which confirms that development conforms to the approved contract and other development requirements, and allowing a partial demolition permit and a building permit to be issued. Permits would also be required to allow for demolition of a portion of the existing structure and for the temporary relocation and storage of the portion of the building that is to be retained on site.

 

1.      Amendment to the Heritage Designation Bylaw (2019-7)

Through Bylaw 2019-7, City Council approved a Statement of Significance (SoS) for the property at 3160 Albert Street. The SoS describes the features of the property that convey its heritage value and the character-defining elements that must be conserved. For any heritage designated property, changes may be approved through a heritage alteration permit, so long as they align with the SoS and other heritage policies. In this case, the applicant has proposed changes to the SoS, which are detailed in Appendix C, to allow the proposed development to proceed. As part of the proposal, references to the "sunroom," "glass bottom bottles," and the "concrete foundation" as heritage defining features in the SoS would be removed. 

 

When considering the proposed amendments to the SoS in isolation of the applicant's redevelopment proposal, the Administration has no major concerns. The proposed changes are not substantive. Removal of the reference to the concrete foundation from the character-defining elements within the designation bylaw is reasonable. If the glass bottle bottoms set within the rear gable are broken or otherwise not feasible to restore, then removal of that reference from the bylaw is also not concerning. Removal of the sunroom is a more significant change but could be considered so long as the remainder of the roofline referenced in the character-defining elements can be retained and visibility from the public right-ofway is ensured. The essential elements of the character-defining features would remain intact without these specific references.

 

However, the purpose of amending the SoS in the bylaw is to facilitate a proposed development. If compromises to the SoS are necessary to support a development that may be supported by the OCP and heritage policies, then Administration would be open to supporting such minor amendments to Bylaw 2019-7. Within this proposal, Administration does not find the compromise to the heritage defining features to be minor or acceptable. Therefore, Administration recommends denial of the amendments to Bylaw 2019-7.

 

Heritage Analysis

As this property has been designated heritage (Bylaw 2019-7), the OCP directs that any changes to the property are evaluated in accordance with Standards & Guidelines for the Conservation of Historic Places in Canada (S&G) and the character-defining elements described within the heritage designation bylaw to determine the impact of the proposal on the degree to which the property would continue to convey heritage value. The S&G is not a rule book and must be applied with sensitivity, understanding that every property is unique in what conservation measures are both appropriate and feasible to ensure heritage value is retained. The S&G indicates that to adapt a historic place changes should take a minimalist approach and that the future intended use of the building should fit its structure and character, rather than adapting the structure to fit its future use. The S&G does not provide guidance on projects where the historic place or portions of the historic place are dismantled or demolished, as these methods do not align with conservation objectives.

 

Administration has concluded that, unlike the requested amendments to the designation bylaw itself, which were deemed to be minor in nature, the proposed interventions to the historic property that is to be retained would be extensive, ultimately compromising its heritage value even further. The largest and most concerning interventions are as follows:

 

·         Relocation: The relocation of the historic place on the property impacts the generous setback, which is noted as a character-defining element in the SoS. The Cook Residence's existing generous setback and situation in the centre of the lot visually accentuates the historic place and marks the corner of the block. The historic place would no longer feature prominently on the lot as result of relocation. The S&G does not support moving a historic place particularly when the current location is a character-defining element.

 

·         Impact to rooflines: The development proposes removing the west elevation and portions of the south elevation, including a large section of the roof. A steeply pitched roof with multiple overlapping gables is an important element of Tudor Revival style. The Cook Residence's roof lines are noted as a character-defining element in the SoS. Their removal serves to substantially change the appearance of the historic place. The S&G states that compromising the building's character-defining roof elements, structural integrity, or overall appearance are not recommended.

 

·         Addition: The proposed addition obscures views of the historic place, and the character-defining roof lines from Hill Avenue and protrudes in front of the historic place. Standard 11 of the S&G advises that additions should be designed in a manner that conserves heritage value and character-defining elements. New construction is to be physically and visually compatible with, subordinate to, and distinguishable from the historic place. New additions are not to obscure, radically change, or have a negative impact on character-defining materials, forms, uses or special configurations.

 

Successful heritage conservation projects generally must reach a balance between adaptive reuse and preservation of the original structure. Each of the these alterations, when reviewed individually, present significant changes to the historic place. However each one could have been considered on its own if the remainder of the project achieved a high standard of conservation. Taken together, the cumulative impact of the alterations proposed by the applicant will dramatically alter the exterior form of the historic place and compromise its heritage value. The proposed development represents a significant impact on the heritage designation bylaw beyond "minimal intervention." As such, the Administration does not support the application.

 

2.      Amendment to Zoning Bylaw

A contract zone is a site-specific zone that is applied to accommodate unique development opportunities that require additional development control through conditions and direct approval of plans. The OCP allows for contract zones for developments that conform to the general intent of the OCP and which are compatible with existing adjacent development and contribute to the adjacent public realm (Policy 14.42). While the development would meet the requirements of a conventional zone (the RL Zone), the complexities of this development, if approved, are better managed through a contract zone agreement, which would permit only the carrying out of that specific proposal. Evaluation of the suitability of the zoning amendment application for the proposed development includes analysis of heritage and zoning and development-related policies. 

 

Zoning and Built Form Analysis

The land use and zoning details of this proposal are summarized in the following tables:

Land Use Details

Existing

Proposed

Zoning

R1 – Residential Detached Zone (RID – Residential Infill Overlay)

C-Contract

Land Use

Building, Detached

(1 Dwelling Unit)

Building, Stacked

(16 Dwelling Units)

Building Area

402m2

2367 m2

Table 1. Proposed Land Use and Zoning

 

Zoning Analysis

Required (Existing R1 RID Overlay Zone)

Required (Comparable RL Zone)

Proposed

Minimum Number of Parking Stalls Required

1/ dwelling unit

1/ dwelling unit

34 stall(s)

Minimum Lot Area (m2)

325 m2

400 m2

1811 m2

Minimum Lot Frontage (m)

10.5 m

14.6 m

39.6 m

Maximum Height (m)

8.5 m

20 m

9.6 m

Maximum Building Area (FAR)

0.75

3.0

1.3

Maximum Site Coverage

50%

60%

49%

Minimum Setback, Front (m)

11.6m(approx.)

3.0

7.65m

Minimum Setback, Rear (m)

3.5

3.5

6.85

Minimum Setback, Side (north) (m)

1.2

1.2

1.2

Minimum Setback, Side (south) (m)

0.45

0.45

0.45

Table 2. Development Standards Analysis of Proposed Development

 

Table 2 above provides an analysis of the proposed development by comparing it to the existing R1 – Residential Detached Zone (Residential Intensification Overlay), which regulates development of the surrounding neighbourhood. The RL - Residential Low-Rise Zone would be the most appropriate conventional zone to accommodate a low-rise multi-family development in a different circumstance. The standards are provided for reference.

 

The analysis shows that the proposed development would not conflict with any zone standards of the RL – Residential Low Rise Zone, and the proposed development is appropriate for a site with that zone designation. However, since the surrounding property is zoned as R1 – Residential Detached Zone and policy pertaining to this site and surrounding neighbourhood focuses on compatibility of built form and character, the Administration's analysis is based on a comparison with the surrounding R1 – Residential Detached Zone rather than the RL - Residential Low-Rise Zone. The Lakeview neighbourhood is almost exclusively single detached residential. Residential development along Albert Street within the Lakeview and Crescents neighbourhood has a predominant character of large lots, wide setbacks and low-density residential land use. Although detailed architectural character is beyond the scope of conventional zoning or a contract zone agreement, the Lakeview Neighbourhood is also characterized by largely intact original and historical residential architecture.

 

Notwithstanding the proposed multi-family land use, which is not permitted in the R1 – Residential Detached Zone, the proposed building density as measured by floor area ratio; front yard setback; and to a lesser extent, the building height will contrast with the established residential neighbourhood character. First, under the existing zoning, the maximum floor area on the proposed lot is 1358 square metres, whereas the proposed building is 2356 square metres, which is 73.5 percent larger than the standard applied to the surrounding neighbourhood. The building will be larger in comparison to the other buildings in the neighbourhood and will not conform to the existing neighbourhood character in this regard and not consistent with the form and established pattern and character of development.

 

Secondly, the front yard setback deviates from the established character on Albert Street. The RID – Residential Infill Overlay Zone requires the front yard setback to match the abutting front yard setback to maintain consistency on the block face. The historic portion of the building approximately matches the setback to the north (11 metres), but the addition to the south protrudes to 7.65 metres. Other lots on the block face range in front yard setback between approximately 11 metres and nine metres. The front yard setback of the addition deviates from the established neighbourhood character of the block face.

 

Finally, the height of the proposed building is 1.1 metres higher than the existing zone allows, but Administration views this as a minor deviation that is of a lesser concern to neighbourhood character. The height difference of the three-storey addition is mitigated architecturally by material differentiation of the upper floor. The height of the addition's parapet is approximately equal to the height of the existing front-facing gable, and therefore there is already an established character of building height on this site. However, the height in combination with reduced setbacks and increased building massing together will result in a building that does not conform to the existing neighbourhood character.

 

Transportation

The property is located adjacent to the intersection of Hill Avenue and Albert Street, which is at the edge of the Lakeview neighbourhood. The additional residential units on the property would not significantly contribute to traffic in the vicinity, and the development would not result in any required changes to traffic controls. As such, no formal traffic study was necessary to evaluate the project. Based on industry standards, the Administration estimates the development would contribute approximately 34 vehicle trips per day to the immediate surrounding transportation network.

 

One key concern of local residents was the traffic impact of the development on the existing alley, which is often used for local residents' recreational purposes. The development would make use of the alley for access to all on-site parking. The alley's pavement width is relatively narrow, and there are few places where vehicles can pass each other, especially in winter months, which may result in local conflicts. However, the Administration maintains that the traffic generated by this development will be minor and could be accommodated on the existing road network. The pavement width immediately abutting the subject property may be widened to allow space for passing vehicles. Furthermore, if necessary, the alley may be posted as a one-way to minimize vehicle conflict. The surface parking that directly accesses the lane does not meet City standards, which require 7.5 metres in length rather than 6.0 metres, as shown. If Council wishes to approve the proposed development, Administration would require that this area be reconfigured to meet City standards and possibly allow for additional vehicle passage on the alley.

 

Closure of Right-of-Way and Consolidation

The Applicant, via the City of Regina's Real Estate and Land Development Branch, is also requesting to purchase a 3.25 metres wide portion of the boulevard within Hill Avenue and incorporate within the site to allow additional area for the proposed development. This would increase the developable area by approximately 188 square metres and has the effect of bringing the massing of the building closer toward Hill Avenue as opposed being set back behind a landscaped boulevard, which is unlike the physical character that exists elsewhere in the neighbourhood. Administration has confirmed that the boulevard space is not needed for use by the travelling public and surplus to the needs of the City's infrastructure or any other utility purpose. Closure of the boulevard would not result in any changes to the vehicle lanes or sidewalk. Although there is no technical concern with closure of the right-of-way, City Council should approve the closure only if it agrees with the proposed development. Otherwise, there is no practical purpose to sell the right-of-way, and it should be maintained as such.

 

Community Engagement

In accordance with the public notice requirements of The Public Notice Policy Bylaw, 2020, neighbouring property owners within 75 metres are required to be notified of the proposed Zoning Bylaw Amendment. As this development was anticipated to generate significant interest within the community, property owners as far as 300 metres were directly notified of the proposal by letter. Development notification signage was posted on the subject property upon initiation of the review.

 

Typically for a development of this nature, a public open house would be held to provide the public with an opportunity to learn more about the development. However, as a result of restrictions from public health orders, the City held a virtual event on September 16, 2020. The event allowed an opportunity for the developer to provide information on the proposed project and City staff to answer questions on the policies and process. The public were able to submit questions to a moderator, who distributed questions to the appropriate persons. There were over 300 questions posed from 171 participants at the virtual event.

 

The public also had the opportunity to submit written comments by mail or through the City's website. The City received 1820 submissions. Although the City does not require disclosure of contact information or identity to be considered a valid comment, the City prepared maps showing the distribution of opposition and support of those that chose to submit these details (Appendix B-2 and B-3). Resident location information was included on 579 comment forms with 705 responses providing at least an email address. There were 1105 anonymous responses.

 

Appendix B-1 of this report provides a summary of comments provided and responses by Administration.

 

DECISION HISTORY

 

On October 29, 2019 City Council approved a Bylaw to Designate the Cook Residence at 3160 Albert Street as a Municipal Heritage Property (2019-7).

 

 

Respectfully Submitted,              Respectfully Submitted,

{Signature}

 

 

Prepared by: {Ben Mario, Senior City Planner}