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1 February 14, 2017 Development Review (Rural Services) City of Ottawa 110 Laurier Ave West, 4 th Floor Ottawa, ON K1P 1J1 Attention: Reference: Lorraine Stevens 6622, 6638, 6650 Bank Street Proposed Kenny U-Pull Industrial Development Zoning Amendment to Remove Holding & Site Plan Application Planning Rationale Letter Our File No.: On behalf of American Iron & Metal (AIM), Novatech has prepared this Planning Rationale letter in relation to a proposed industrial development at the above-noted location. The proponent is planning to develop the site as a self-serve used auto parts facility, under the banner of Kenny U-Pull, to serve customers in the Ottawa and surrounding region. Kenny U-Pull is owned and operated by the parent company American Iron & Metal, based in Montreal. The subject lands are zoned RH3[732r]-h and RH3[733r]-h (Rural Heavy Industrial Zone, Subzone 3-holding) in the City of Ottawa Comprehensive Zoning By-law No The RH3 zone is considered appropriate to accommodate the proposed use, and the conditions for removing the holding provision are set out in the 732 and 733 rural zone special exception provisions. The conditions set out in 732 and 733 are the same, and are summarized as follows: That the City has approved an Environmental Impact Statement that demonstrates that site does not contain endangered species and significant features; That the City has approved a Hydrogeological Assessment and Terrain Analysis demonstrating that the proposed development can be supported on private services; and That the Owner has constructed a well that demonstrates the adequacy of the aquifer with respect to water quality and quantity to support the development. This letter report demonstrates how the proposal is consistent with applicable policies of the Provincial Policy Statement and the City of Ottawa Official Plan. Moreover, this Planning Rationale letter fulfills the planning justification to support lifting of the holding provision. This letter also fulfills the requirements for Site Plan approval, and provides details on how the proposed development complies with the requirements of the RH3 zone and how it represents good site planning. A pre-consultation meeting was held with the City of Ottawa and a list of required studies and plans in support of the applications was provided (dated June 10, 2016). M:\2017\117009\DATA\CORRESPONDENCE\LETTERS\PLANNING RATIONALE LETTER_KENNYUPULL_FEBRUARY DOCX.PAGE 1

2 Property Description & Local Context The subject lands are located in Part of Lot 13, Concession 6 (Osgoode), and consist of two properties (6638 and 6650 Bank Street), together with a portion of a third property (known as 6622 Bank Street) that are being assembled as one in order to accommodate the land requirements of the project. The first two properties are described as being Parts 4-6 and Parts 7-9 on Plan 4R-25595, and the third parcel is currently the subject of a severance application for the purpose of a lot addition to the abutting parcel known as 6638 Bank Street. The total site area represents an area of approximately 5.6 hectares, with approximately 188 metres of frontage along Bank Street. A 30- metre wide hydro easement crosses the properties in a northwest-southeast orientation. The entirety of the lands, including lands immediately to the north and south, are designated General Rural Area on Schedule A of the City of Ottawa Official Plan, with abutting properties to the west and northwest being designated Rural Natural Features and Significant Wetlands, respectively. On the east side of Bank Street, lands are also designated General Rural Area, with a Limestone Resource Area designation on lands located some 400 metres further to the east. Bank Street is identified as a Scenic Entry Route on Schedule J of the Official Plan in recognition of it being a principal road used by visitors and business travelers arriving in Ottawa from the south. The site is located approximately midway between Greely and Metcalfe, at about 1.2 kilometres south of the Greely hamlet boundary. This stretch of Bank Street is characterized as being predominantly industrial, as reflected in the predominance of industrial land use and associated RH-zoning along both sides of Bank Street. There are also some commercial uses, together with very few residential uses in the vicinity of the site. Most of the land uses along this section of Bank Street are on lot sizes that can accommodate various types of industrial uses that require efficient highway access and considerable land area for outdoor storage space. Examples of existing industrial uses include an autobody shop/auto sales, open storage areas, heavy equipment yards, and industrial/commercial use buildings (refer to Figure 1). The site has been previously cleared and filled and is predominantly vacant with virtually no trees remaining on the property The site is devoid of any surface water features. M:\2017\117009\DATA\CORRESPONDENCE\LETTERS\PLANNING RATIONALE LETTER_KENNYUPULL_FEBRUARY DOCX.PAGE 2

3 Figure 1: Land use context on adjacent and nearby lands (Source: Google Maps, 2016) Proposed Development The project will consist of a regional Kenny U-Pull business, which is owned and operated by the parent company, American Iron & Metal. The Kenny U-Pull business will operate as a self-serve used auto parts facility, where used vehicles are made available to customers for self-service removal of used automobile parts from an inventory of used vehicles stored on site. The facility, to be developed over the entire 5.6 ha parcel of land, will include a 756m 2 building which will include a sales counter and administrative office, together with an attached works garage. The balance of the site will consist of an outdoor, inoperable, used vehicle inventory. A small number of used (uncertified) vehicles will be on display for resale, on an accessory use basis. M:\2017\117009\DATA\CORRESPONDENCE\LETTERS\PLANNING RATIONALE LETTER_KENNYUPULL_FEBRUARY DOCX.PAGE 3

4 Used vehicles arriving at the site will be stored in an open compound at the rear of the building. Prior to being prepared for placement in the Kenny U-Pull used vehicle storage yard, vehicles will be prepared for sale of individual car parts inside the work garage, where all automotive fluids, batteries, mercury switches and tires will be safely removed, in compliance with the Canadian Auto Recyclers Environmental Code (CAREC). Customers will have safe access to approximately 1,600 used vehicles in the storage yard where vehicles will be neatly stored in rows. Once the majority of the parts have been removed from vehicles by customers, the vehicle will be removed from the storage yard and crushed/pressed at the on-site crusher, which is located in the compound at the rear of the building. Crushed vehicles and fluids and tires will all be removed from the site on an on-going basis by an appropriate materials recycler. (a) Inside typical works garage where fluids are removed using specialized fluid extraction equipment. Batteries and tires are also removed from vehicles prior to moving the vehicle to the outdoor used parts inventory (b) Outdoor bulk fluid storage tanks with protective bollards. M:\2017\117009\DATA\CORRESPONDENCE\LETTERS\PLANNING RATIONALE LETTER_KENNYUPULL_FEBRUARY DOCX.PAGE 4

5 (a) Typical transport vehicle arriving with used vehicle (b) Typical vehicles arranged for parts inventory Three entrances from Bank Street are proposed. The primary entrance will be used by haulage vehicles, typically tow trucks and/or flatbed trucks, when delivering used vehicle inventory to the site and for when removing crushed vehicles. Vehicles will pass over a weigh scale, and will be delivered to the compound at the rear of the building. The other two entrances will provide access to customer and employee parking, in a gravel lot designed to accommodate parking for 131 vehicles along the Bank Street road frontage. A proposed 2.4 m chainlink fence will surround the site, with opaque slats providing a visual screen for the section of fence across the front of the storage yard. Customer access to the vehicle inventory will be restricted via the main office and the site will only operate during daytime hours. The development will be serviced with a proposed well and proposed on-site sewage disposal system. The well is located near the front of the property, and is situated over 60m metres away from the septic system, well in keeping with the Ontario Building Code separation distance requirements. The hydrogeological study (Kollaard Associates, 2017) undertaken for the site has determined that the water quantity at the site is more than adequate to service the proposed development, with the water quality deemed acceptable. The vehicle storage yard will consist of a gravel parking lot. Catch basins will collect stormwater from the gravel parking lot which will direct water to the proposed stormwater retention pond (dry pond) which is to be located along the entire length of the southerly property line (approximately 345m). Proposed landscaping details are provided on the landscape plan, which includes a native selection of street trees, together with low maintenance plantings at the front of the building. M:\2017\117009\DATA\CORRESPONDENCE\LETTERS\PLANNING RATIONALE LETTER_KENNYUPULL_FEBRUARY DOCX.PAGE 5

6 Planning Rationale Consistency with the Provincial Policy Statement Provincial interests in land use planning are implemented through the Provincial Policy Statement (PPS) issued under Section 3 of the Planning Act. The PPS provides policy direction on matters of provincial interest, including policies that promote building strong sustainable communities, managing/protecting resources, and protecting public health and safety over the long term. Ultimately, the PPS aims to encourage communities that are based on efficient land use, and which are economically strong, environmentally sound, and which foster social well-being. All decisions affecting planning matters made by any planning authority shall be consistent with the policies contained in the PPS. One of the overarching directives of the PPS that relates to this proposed development is to build strong healthy communities by achieving land use patterns that contribute to the financial well-being of cities. Within rural areas, land use is to be balanced with consideration of economic base diversification and new employment opportunities, while considering rural characteristics and issues such as the scale of development, protection of natural features, the provision of appropriate service levels and land use compatibility. The proposed development is ideally suited for the subject lands, in that it contributes to the rural economy at an appropriate, industrially-zoned location. The proposed industrial use is of a scale and nature that will blend in well with, and is compatible with, the existing industrial rural character and uses of the area. Land use compatibility in relation to abutting and nearby land uses is discussed under the section of this report that addresses Official Plan policies. The relevant resource management interests in Section 2 of the PPS have been addressed through preparation of the technical studies prepared in relation to the lifting of the holding application, and to meet the requirements of site plan approval. Specifically, the potential for groundwater impacts and servicing have been evaluated through the Hydrogeological Assessment and Stormwater Management Report, natural heritage considerations have been addressed through the Environmental Impact Statement, and cultural resources have been addressed through Archaeological Assessment. Section 3 policies of the PPS which sets out policies dealing with the protection of public health and safety have been addressed through the preparation of the Environmental Site Assessment. There are no known natural hazards associated with this site that require specific assessment. On the basis of the foregoing and details contained in the above-noted technical reports prepared for these applications, this proposal addresses the requirements of the Provincial Policy Statement. M:\2017\117009\DATA\CORRESPONDENCE\LETTERS\PLANNING RATIONALE LETTER_KENNYUPULL_FEBRUARY DOCX.PAGE 6

7 Conformity with the City of Ottawa Official Plan (Office Consolidation and OPA 150, 2013) Industrial uses are permitted in the General Rural Area designation subject to appropriate zoning. While the current RH3 zoning is considered appropriate to accommodate the proposed use, in the context of abutting and nearby land uses, and policies that govern the appropriateness of the use for this location, the following rationale is provided to demonstrate conformity to the Official Plan: The proposed land use/development is compatible and fits particularly well within the existing rural character of this Bank Street corridor. The site is considered to be ideally located, where land use conflicts are not present and/or could be managed through site design. The following land uses have been considered: o o o The Greely Quarry, owned and operated by Cornwall Gravel Company Ltd, is a licensed Class A quarry located approximately 390 metres east of the site, with intervening land uses and forest cover being present. Section and (Development Restriction on Adjacent Lands) speak to land use compatibility between proposed non-aggregate land uses in the vicinity (i.e. 500m) of existing Bedrock Resource Areas and licensed bedrock quarries, respectively. On the basis of license information available from the Ministry of Natural Resources & Forestry, the licensed limit of the quarry is coincident with the westerly boundary of the bedrock designation. It would also appear that the operation is progressing in the easterly direction, and that access to the site is via Old School Road. Based on a review of the development circumstances in relation to the proximity of the quarry, development of the subject land with an industrial use, situated approximately 390 metres from the Greely Quarry, will not hinder or preclude the continuance of the existing aggregate operation. Further, the proposed industrial development is not considered to be a sensitive land use, and is therefore not considered incompatible with aggregate operations located some 400 metres east of the site. The closest residential use is located immediately across the street. The building, once believed to have been a former motel, now appears to be utilized to accommodate a few affordable housing units. While located almost directly across the road, there are approximately metres between the residential building and the first row of vehicles in the car park. The parking lot, in combination with landscaping and opaque fencing, provides an appropriate intervening land use that will ameliorate the view of used cars. Off-site impacts generated by the use, such as noise and traffic, are expected to be minimal, given site design and spatial separation from the nearest non-industrial use. There do not appear to be any agricultural operations within 1000m of the site that would warrant the application of MDS formula. Section identifies Bank Street is a Scenic Entry Route (Schedule J) and design criteria for development along the Bank Street corridor are provided. While Arterial Road Corridor Design Guidelines have not been prepared by the City, the proposed Kenny U-Pull site has been M:\2017\117009\DATA\CORRESPONDENCE\LETTERS\PLANNING RATIONALE LETTER_KENNYUPULL_FEBRUARY DOCX.PAGE 7

8 designed with consideration given to the criteria set out in Section The scenic entry route criteria speak to such matters as building orientation, outside storage, access and egress, landscaping, fencing, lighting, and signage, all in relation to creating a pleasing streetscape. These design elements have been addressed through a carefully designed site plan, that balances the site s functional space requirements with the City s objectives as they relate to creating attractive development in a rural setting. The proposed building design and positioning, as viewed from the street, is appropriate for the rural industrial environment in that the building location and orientation meet functional requirements and do not detract from the rural streetscape as viewed from Bank Street. The use of landscaping and fencing to screen/buffer views of outdoor storage areas, in combination with front yard setbacks, landscaping and parking lot design, are in keeping with an appropriate level of site design for this rural setting, and contributes towards addressing the design criteria to enhance this entry route into the City. Noise generated from the site is not anticipated to create any adverse effects on adjacent uses, as the site will not generate any significant source of noise. The most probable noise will be associated with vehicle crushing. The crusher is to be located within the compound, at the rear of the building and situated approximately 140 metres from Bank Street. This overall distance, in combination with noise shielding at the crusher site, will ensure that noise associated with the crusher will not exceed provincial noise guidelines at off-site locations. In addition, the activity is required to meet the Ministry of the Environment and Climate Change s Environmental Activity and Sector Registry (EASR) requirements. Bank Street is designated as a major arterial road which is intended to carry higher volumes of traffic. Vehicle ingress and egress is not anticipated to generate traffic-related impacts. On the basis of other Kenny U-Pull operations in other cities, the traffic volume generated by the business is considered to be low. From a customer perspective, it is estimated that the business will generate, on average, approximately 5,000 customers on a monthly basis (+/- 150 customers per day). There is no distinction to be made between weekends and weekdays, as the customer base is consistent throughout the week. Hours of operation are during the day, and the duration of each customer visit is variable, given the self-serve, labour intensive nature of removing vehicle parts. Further, it is estimated that the site will generate 5-6 tow trucks and/or flat-bed trucks arriving at the site per week. In combination with infrequent pick-up of recyclable material, this volume of traffic is not expected to create concern from traffic flow point of view. Supporting studies in relation to the removal of the holding provision and site plan approval have been prepared. The findings of these reports are briefly summarized as follows, which support development of the site in conformity with City requirements: o Hydrogeological Investigation (Kollaard Associates, 2017) The Hydrogeological Investigation carried out by Kollaard Associates involved drilling a test well for the purpose of evaluating the adequacy of the aquifer to support the proposed development with respect to water quality and quantity. The test well was constructed in M:\2017\117009\DATA\CORRESPONDENCE\LETTERS\PLANNING RATIONALE LETTER_KENNYUPULL_FEBRUARY DOCX.PAGE 8

9 accordance with Ministry of Environment and City requirements, and certifications are included in the report. Water pump tests indicate that the well can produce water of adequate quantity to serve the intended use and water quality was found to meet Ontario Drinking Water Standards for health and aesthetic parameters tested for except for aesthetic objectives for hardness and total dissolved solids. Recommendations for suitable water treatment in relation to elevated hardness, total dissolved solids and sodium are included in the report, together with recommendations for wellhead protection and well maintenance. o Environmental Impact Statement (Muncaster Environmental Planning) An Environmental Impact Statement was prepared in 2010 in relation to 3 severance applications that resulted in the creation of 6622, 6638 and 6650 Bank Street (i.e. Parts 1-9 on Plan 4R-25595). The report concluded that there were no significant natural heritage features on the site and that no impact is anticipated on the wetlands northwest of the site. An updated Environmental Impact Statement (EIS) and Tree Conservation Report (TCR) was prepared in 2017 in accordance with the City s guidelines, in fulfilment of the requirements to lift the holding on the subject lands. The EIS and TCR found that the site and the adjacent lands have been highly disturbed through clearing and filling, and that there are no habitat features, significant woodlands, significant wetlands, or Species at Risk utilization on the site. Given localized site conditions and relationship to the adjacent and nearby natural heritage environment, the EIS concludes that proposed development of the site will not have a negative impact on the significant natural heritage features and functions of the general area, including the Osgoode Swamp Natural Area and the Provincially Significant Wetland. The EIS provides a summary of recommended mitigation measures that are to be implemented. o Archaeological Assessment (Past Recovery Archaeological Services Inc, 2016) Since the subject lands are identified in the Official Plan as having archaeological potential, an archaeological assessment has been prepared. On the basis of the Stage 1 assessment, it has been determined that while the property has large portions that possess potential for archaeological resources, recent disturbance over the site has removed all potential, and it is concluded that no further archaeological assessment is required. Pursuant to the terms of the report author s archaeological license, the report was submitted to the Ministry of Culture. The Ministry has since issued a letter dated January 25, 2017 to confirm that the report has been reviewed by the Ministry and entered into the Ontario Public Register of Archaeological Reports. o Stormwater Management Report (Kollaard Associates, 2017) A combined site servicing and stormwater management report was prepared to address the serviceability of the proposed development and to describe the stormwater management design to address the stormwater flows arising from the site under post-development M:\2017\117009\DATA\CORRESPONDENCE\LETTERS\PLANNING RATIONALE LETTER_KENNYUPULL_FEBRUARY DOCX.PAGE 9

10 conditions. In general, the development will be serviced with a private well and an on-site sewage disposal system, consisting of two Ecoflow treatment units and a shallow buried trench. Sanitary flows from the garage, will be directed to a separate storage tank, such that it will not be combined with flows to the septic system. On the basis of the building size and use, fire-fighting water storage facilities are not required, and have not been proposed. The stormwater management design will direct stormwater to the storage swales along the rear and south boundary by sheet flow and catch basins and storm sewer. Stormwater quantity control will be achieved by restricting the runoff rate by means of an outlet structure. Quality control will be achieved through vegetative filtration and an AquaSwirl oil/grit separator to remove suspended sediments. The Stormwater Report provides recommendations for maintenance of the oil/grit separator and for sediment and erosion control measures that are to be implemented prior to and during construction. o Phase 1 Environmental Site Assessment (DST Consultants, 2017) A Phase 1 ESA was carried out by DST Consultants, in accordance with standard ESA procedures, to evaluate actual and potential environmental concerns at the site and surrounding properties. Based on the results of the site visit and review of historical documentation, one area of potential environmental concern was identified. On the basis of further analysis carried out by DST, the report concludes that no further environmental investigation is required. o Geotechnical Study (DST Consultants, 2017) A geotechnical investigation was carried out by DST Consultants to provide geotechnical recommendations regarding development of the site. The report provides geotechnical recommendations in relation to the slab-on-grade building, customer parking and storage yard area, weigh scale, and installation of municipal services. Conformity with the City of Ottawa Zoning By-law The City of Ottawa Consolidated Zoning By-law No , zones the subject property as Rural Heavy Industrial Zone, RH3[732r]-h and RH3[733r]-h, and permits a range of industrial uses. Among the uses permitted in the RH zone, waste processing and transfer facility and retail store uses would capture the essence of the uses proposed by this development. The sale of a limited number of used (uncertified) vehicles and a limited supply of select automobile parts from within the sales office building are regarded as being accessory to the principal uses on the property. Accordingly, the proposed development conforms with the permitted use provisions of the RH zone. M:\2017\117009\DATA\CORRESPONDENCE\LETTERS\PLANNING RATIONALE LETTER_KENNYUPULL_FEBRUARY DOCX.PAGE 10

11 The proposed site plan has been designed to comply with the performance standards for the RH3 zone. Compliance with the Zone provisions, prescribed on Table 221 (RH Zone Provisions) and 221A (RH Subzones) of the Zoning By-law, is demonstrated in the table below. Rural Heavy Industrial, Subzone 3 (RH3) Required Provided Minimum Lot Area 1000 m 2 56,663 m 2 Minimum Lot Width 30 m 188 m Minimum Front yard Setback 15 m 27 m Minimum Rear yard Setback 15 m 270 m Minimum Corner yard Setback 15m N/A Minimum Interior yard Setback i) Abutting an Industrial Zone 3 m 130 m on north side 22 m on south side ii) Other cases 10 m n/a Maximum Principal Building Height 15 m 6 m Lot Coverage (%) (maximum) 50% Approx. < 2% Outdoor Storage (a) outside storage is not permitted within any required front yard or corner side yard (b) outside storage must be screened from abutting residential uses or zones & public streets by an opaque screen at least 1.8 m in height from finished grade Outdoor storage of vehicles is proposed at rear of building and not within the front yard. The storage yard would be shielded from street view by the building, and by a 2.4m high chainlink fencing with opaque screening. Compliance with Section 4 of the City s Zoning By-law , specifically the parking and loading requirements is demonstrated in the following table: Parking Requirements Required Provided Parking Spaces Parking Space Width (min and max) Retail Store/Office (3.4 / 100m 2 of gfa): 12 Works Garage (1 / 100 m 2 of gfa) 4 Waste Processing & Transfer Facility non required 2.6 m (min) 2.75 m (max) 131 (includes 4 accessible spaces) 2.6 m (3.66 m for accessible space) Parking Space Length (min) 5.2 m 5.5 m Double traffic lane driveway (min width) Loading Space Requirements: (758 m 2 GFA) 6.7 m 7.5 m 1 loading space 1 loading space Since there is no parking rate for waste processing and transfer facility, the parking rates have been established on the basis of the applicable parking rates for uses occurring within the building. The parking rate for the sales counter and office is based on the parking rate for a retail store and the parking rate applied to the works garage is based on the applicable parking rate required for an M:\2017\117009\DATA\CORRESPONDENCE\LETTERS\PLANNING RATIONALE LETTER_KENNYUPULL_FEBRUARY DOCX.PAGE 11

12 automotive service station (2 bays). While the proposed number of parking spaces seems excessive in relation to the required number of spaces, the proposed use is such that a typical customer visit could last for longer durations, as compared to a typical retail store. The labour intensive nature of removing certain auto parts suggests that customer visits could last several hours. Finally, Bank Street cannot accommodate off-site parking, so all parking must be accommodated on the property. Pursuant to the conditions as set out in the 732 and 733 special exceptions provisions, an application to lift the holding requires the completion of an Environmental Impact Statement and Hydrogeological Assessment. The findings of these reports, as summarized above, satisfy the condition to lift the holding provision from the subject lands. Suitability of the Proposed Site Plan The proposed use is appropriate for the location and is considered compatible with uses in the immediate area. The site plan has been developed to address functional site requirements, while at the same time incorporating design measures to address aesthetics, safety, and land use suitability. The site plan incorporates the following key features that reflect good site planning: Building placement and orientation meeting functional requirements and do not detract from the rural streetscape as viewed from Bank Street; Landscaping at the building and in the parking lot has been provided, on basis consistent for a rural industrial site. Enhanced plantings of landscape material at the front of the proposed building will soften the building façade and create a pleasant entranceway; Outdoor storage areas are adequately buffered and spatially separated from Bank Street to ensure that noise generated from the compound (i.e. use of the crusher) is minimal and that the crusher is hidden, as viewed from the street; Loading area and outdoor storage areas are located to the rear of the building; Vehicular access is designed to carefully control the number of access points to ensure public safety and functional site servicing; Considerable off-street parking is provided to satisfy anticipated parking needs for this type of use; While the presence of an existing hydro easement across the site has the effect of limiting development within the easement, a 6m wide access along the centre of the easement, complete with access gates, has been maintained. Approval from Hydro may be required to park vehicles within the easement while maintaining the access; Individual water and sewage servicing and stormwater management can be achieved, in keeping with provincial and municipal standards and best management practices; The site will be operated during daytime hours only. There will be minimal light spillover with the use of full cut off fixtures and submission of a Site Lighting Certification. M:\2017\117009\DATA\CORRESPONDENCE\LETTERS\PLANNING RATIONALE LETTER_KENNYUPULL_FEBRUARY DOCX.PAGE 12

13 Conclusion The proposed Kenny U-Pull development at 6622, 6638, and 6650 Bank Street is consistent with the Provincial Policy Statement and meets the intent and purpose of the City s Official Plan. Furthermore, the proposed building meets all required provisions of RH3 zone in the City of Ottawa Zoning By-law. The requirements for lifting the holding provision have been satisfied through preparation of the applicable technical reports, confirming that there are no natural heritage considerations (including species at risk) and that groundwater quality and quantity requirements are found to meet provincial guidelines. The applicable requirements for stormwater management and individual rural well and septic servicing can be met, as outlined in supporting studies undertaken as part of the site plan process. The choice of lot size and location for the proposed use is appropriate and compatible with the surrounding rural land use context and represents good planning. Sincerely, NOVATECH Steven Pentz, MCIP, RPP Senior Project Manager Planning & Development cc: Mathieu Germain, AIM Bill Kollaard, Kollaard Associates M:\2017\117009\DATA\CORRESPONDENCE\LETTERS\PLANNING RATIONALE LETTER_KENNYUPULL_FEBRUARY DOCX.PAGE 13