ACO Presentation to Heritage Kitchener re: 30-40 Margaret Street Development

The ACO was asked by The Olde Berlin Town Neighbourhood Association to help them understand how the development at 30-40 Margaret might affect the Heritage Conservation District.


The basis of our presentation is (1) the Civic Centre Neighbourhood District Plan should be more closely adhered to than is proposed by the developer because of how important this site is to the character of the District; (2) the proposed building stepbacks are not adequate to meet the requirements of the site specific policies and guidelines, including the possible isolation of 54 Margaret.


The pdf document below explains what we felt would ensure that the character of the District is conserved.  We believe that the role of the ACO is to have public discussion of the issues that affect built heritage.

For more see Submissions to the 30-40 Margaret Heritage Impact Assessment Review on the Olde Berlin Town Neighbourhood Association’s blog.

Note: Once the pdf document loads, you will see only the first page.  Click on any text on this page and you should see in the bottom left corner that there are 8 pages.  Use the down arrow for the remaining part of the document.


ACO Presentation to Heritage Kitchener, June 4 2019

We Need Your Help!

The ACO Provincial Policy Committee wants you to respond to the call for comments from the Provincial Government on Bill 108. The Government of Ontario has proposed changes to the Ontario Heritage Act through Bill 108.

Part of Bill 108 proposes changes to the Ontario Heritage Act. We need to speak out against this flawed proposal right away.  June 1 is the deadline for comments and the government wants to pass the Bill by June 11.

Our concern is that Bill 108 would take away local communities’ right to say what is important to them, and what parts of the past the community values and wishes to pass on to future generations.

It would give this authority to the Local Planning Appeals Tribunal (LPAT), who can undo the work of democratically elected councils — and the Municipal Heritage Committees and trained heritage planning staff who support them. LPAT will have the final say on approving, revoking or amending heritage protection bylaws.

Compounding the problem: No current LPAT members have any background in heritage. Nor are they required to have heritage expertise or an understanding of the values of the community they are judging.

We don’t need this radical departure. The current regulations 9/06 and 10/06 work. They provide criteria that help ensure decision made by communities on heritage properties are objective and consistent across Ontario. The specialist Conservation Review Board (CRB) reviews municipalities’ work and provides an expeditious, low-cost alternative to lengthy LPAT appeals. Don’t change a rule book that’s working.

What’s the rush? Take time to properly consult with the heritage and municipal sectors and get this right.

Take Schedule 11, Ontario Heritage Act, out of Bill 108.

What you can do:

  • Review an unofficial blacklined version of the Ontario Heritage Act, with the proposed amendments, prepared by Osler Hoskin Harcourt LLP.
  • Leave an officially registered comment through the online consultation of the Environmental Registry of Ontario. But hurry! The deadline for comments is June 1.
  • Express your concern about these arbitrarily imposed changes to the Ontario Heritage Act to your local MPP.  Check here for your local MP’s contact information.
  • Write a letter to the editor of your local paper.

Thank you –  if you have questions, please contact Alex MacKinnon at

For a plain language description of Bill 108, click here.

Posts on this blog are meant as a forum for ideas and issues surrounding heritage architecture.

You can comment on any post or if you have something new to say, you can send your contribution to

Kitchener’s Urban Design Manual: Charette for Victoria Park Secondary Plan

By Gail Pool

The City of Kitchener is undertaking a large-scale revision of its Urban Design Manual.  As part of the process, the planning staff is meeting with various groups on Secondary Plans.

On February 20th, an urban design Charette was held for the Victoria Park Secondary Plan.  About 10 people were present.  Most of us, including myself, are residents of the area.

In order to help me understand the direction of the plan and give voice to the participants, I decided to write up some comments while it is fresh in my mind.

My own views

The document that was examined, Design for Residential Infill in Central Neighbourhoods, is a key document for the areas around the Urban Growth Centres (areas in light green below).  An earlier version of the document left out the phrase “Residential Infill,” which suggests a change in direction. 

Adding “infill” to the title infers that what the Victoria Park Secondary Plan needs is residential infill.  What if we are happy with what is now there and just want to improve the character of the neighbourhood? Infill can mean many things and is seen as a way of increasing density. Some jurisdictions do that by changing zoning so that low rise residential can have 4 to 6 units rather than single or duplex units.

While the Victoria Park area can’t be “frozen in time”, the revised title suggests that the direction is to relax the restrictions in the Victoria Park area.  Is thaw the right word here? As nearly every participant at the charette suggested, there is a fear that nearby highrise buildings will overwhelm the Victoria Park area.  There are also concerns that the regulations that restrict high rise development inside the residential zone will be built.  In my view and that of others, we need to not only continue to prevent high rise development inside the Victoria Heritage Conservation District (VPHCD), but also have buffer zones near it.  That way, we can really protect the low-rise historic district rather than infill it. Given that we have seen recent incursions into the Conservation District on Queen Street, with two houses destroyed and two others put at risk, the design needs to be very strong in the face of density pressures. So, rather than promoting infill, why not reinforce the statement that built heritage shall be preserved in the VPHCD? Maps and detailed panels of the Victoria Park Secondary Plan are available here).  Here is one map of the broad zones.

The Secondary Plan boundaries extend beyond the VPHCD but the rules on heritage conservation, e.g., heritage shall be preserved, are still in place.

The panels do not adequately describe the design proposals. However, the Design for Residential Infill in Central Neighbourhoods (p. 1) suggest that:

Kitcheners Central Neighbourhoods have character, historical significance, and provide contrast to the current and future intensification of the Downtown and Major Transit Station Areas (MTSAs). They represent a variety of eras and styles, and if properly planned and conserved, can contribute toward a unique and desirable condition: pockets of low-rise, historical residential neighbourhoods within walking distance of the city core and light rail transit.

I am very concerned with the phrase “pockets of low-rise… neighbourhoods.” There will be many high-density buildings around Victoria Park (some underway and some to be built) in the Urban Growth Centre and they will add thousands of residents and jobs to the area.  I would suggest that you examine the images in the Urban Growth Centres design, where there are many high rise buildings sketched in.  Here is an example of the vision:

While this image is hypothetical (only Charlie West is under construction), it is a design guideline and developers will take notice of such images and say: Look at what they are suggesting, right next to Victoria Park!

Do the residents and citizens of Kitchener really want that?  It is sometimes suggested that Gaukel street be made into a pedestrian/cycling promenade from City Hall to the Park.  Do we really prefer to have five high rise buildings there?

My question is: Can we sustain the beauty of our established historic neighbourhoods and Victoria Park itself, which are very much enjoyed by all residents of the region and beyond?

In my view, we have two very extensive heritage conservation districts on either side of the core. These are not pockets. They appear to be larger than the areas targeted for high density development. I am not opposed to higher density. We are being asked by the Province to increase density in order to save our farmland, (Growth Plan for the Greater Golden Horseshoe) and targets are not always being met. They should be. Rather there needs to be an understanding that the low-rise neighbourhoods are an attractive and important feature of Kitchener’s central area. Low rise, historic districts in downtown Kitchener are not only good for the inhabitants, but they are also good for tourism. They attract people from around the region and beyond, particularly in the summertime when many festivals are organized, bringing in thousands of tourists.

General Discussion

So, with that in mind, what several people suggested was that we ensure that there is:

  • Adequate park space
  • Transitional zones between the high and low density areas

There were concerns voiced about the zoning process. How, for example, did a multi-storey building get built on Courtland across from the school? Several people felt that zoning regulations are too easily over-ridden. One person stated that the development on Victoria Street near West had to be opposed in order to reduce the number of storeys. The development at 242-262 Queen, on the other hand, was originally 8 storeys and was allowed 10 storeys. This was done through bonussing, a hidden strategy that is allowed under zoning.

One person (living on Theresa?) suggested that the 100 Victoria building has made her backyard open to be seen from that tall building. Other people were concerned about transition zones. For example, the area behind Theresa has a very large parking area (Ukranian Catholic Centre). Should there be a high rise in this area? Currently the area is zoned l-1,1R, 93R, 399U. Medium rise? What would it take for a developer to request a re-zoning to a high-density development through zone changes and bonussing provisions? The City of Kitchener needs to be much more cautious in its development planning.

Other questions were asked about the following:

  • There is a need for more park space due to high-density development surrounding the park
  • Better cycling access, e.g., Queen Street
  • Bike parking requirements for buildings
  • Affordable housing requirements
  • Surface lot re-purposing
  • Better transit stops
  • More green roofs with trees
  • More parkettes, required next to developments
  • More greenery around high-rise developments
  • Rent geared to income; require a certain number/percentage of units
  • Design a good use of the old bus terminal
  • Area along Iron Horse Trail near West and Victoria could be a parkette
  • Wild area between Iron Horse Trail and the Railway could be developed for public park space
  • Better pedestrian amenities, including connecting neighbourhoods with adequate crosswalks, e.g., at the Iron Horse Trail and along Queen Street
  • A suggestion was made that better connections be made between central areas and the park. Perhaps a continuous landscape plan needs to be developed that connects the various areas in the Downtown and along Schneider Creek.



Bill 66 Urgent Action

If you want to comment on Bill 66, Here’s what you can do:

1. Send comments to the Environmental RegistryNote that the deadline for comments is Sunday, January 20th.  

2. Write MPPs. A complete list can be found here.   Kitchener and Waterloo MPPs emails are below and could be copied and pasted into an email.

Amy Fee Kitchener South Hespeler<>

Catherine Fife Waterloo <>

Laura Mae Lindo Kitchener Centre <>

Mike Harris Kitchener Conestogo <> 


 Sample letter:

There are many reasons why I am opposed to Bill 66.  In brief, these are outlined in a Region of Waterloo report, including the following:

  • Lack of prescribed consultation;
  • Risks to health, safety and the environment, including groundwater protection;
  • Non-applicability of Provincial and Municipal plans and policies…

Municipal councils in the Region of Waterloo have overwhelmingly stated their opposition to Bill 66 in its current form.

That opposition is based on the provision that a municipality can pass an Open for Business bylaw.  If such a bylaw is passed, there would be:

  • no need to follow planning documents that have been created over many years;
  • no requirements for public consultation;
  • no appeal could be made against any municipal act 

The impact on the future of our cities, our countryside, our natural resources, and on cultural and natural heritage is clear. These are outlined below.

1. Impact on Planning

If a municipality passed an exemption under Bill 66, zoning by laws would not need to conform to any official plans.  Site plan approval would not be required.  There would be no protection to the natural or built environments.  Famous structures that attract tourists from around the globe could be flattened.  A municipality could demolish any building or cultural feature it wanted.  A bylaw could be passed that is exempt from all planning and environmental law such as the Planning ActPlaces to Grow Act, and the Planning and Development Act.  The planning process is out the window and there is no appeal process.

2.  Impact on the Environment

Urban growth tends to be expansive rather than focused on the existing land that has already been developed in urban areas.  We need to resist that tendency to sprawl, thus putting our agricultural and forest resources at risk. 

More than half of Waterloo Region’s growth comes from building in existing urban areas. This investment in our urban centres means we can keep growing while preserving the rural communities and farms that make Waterloo Region unique. This is not a short-term concern.  We need to protect farmland and natural areas from urban sprawl.  Farmland, cultural and natural landscapes provide urban dwellers with respite from stress.  Natural environments provide us with clean water and clean air.  These are qualities that have made Ontario a wonderful place to live, work and play.

3.  Impact on Heritage

The impact on built heritage and cultural landscapes is obvious since Bill 66 circumvents planning by municipal government. There are many examples where protection of our built heritage has been put at risk despite good planning.  An Open for Business bylaw could bypass the Planning Act and Provincial Policy Statement.  The latter states clearly that “Significant built heritage resources and significant cultural heritage landscapes shall be conserved.”

The bill also impacts on archaeological heritage.  Ontario has a rich history of occupation that dates back at least 12,000 years. The archaeological assessments completed each year in advance of development help fill in the gaps in the story of our province, Indigenous Peoples and more recent settlers. 

Archaeology gives a voice to many who have been written out of the history of our province. Indigenous and descendant community participation in the process of archaeological investigation has recently amplified that voice. Bill 66 threatens to allow municipalities to opt out of the research that comes from excavations prior to construction. 

The Ontario Archaeological Society has stated clearly: “Under Bill 66, a municipality will be able to circumvent… the Provincial Policy Statement… and Official Plan requirements…. The protection of heritage is a mandatory provincial interest under the Ontario Heritage Act, not a decision of convenience at a municipal level. Bill 66 needs to be amended to restore the requirements that protect our heritage for the generations to come.”

The Architectural Conservancy of Ontario has stated that Bill 66 would allow the development of major employment and economic growth opportunities.  We could see many more demolitions of heritage buildings.  In the past, demolitions have taken place despite protections, including Carnegie libraries, fire stations, city halls and other valuable buildings of historic and cultural significance.  Should a builder decide to demolish an historic building, under an Open for Business bylaw, there would be nothing anybody could do to protect it.

Under Bill 66, the lack of heritage protections would mean that we further write out of our history the richness of Indigenous Peoples as well as those settlers whose descendants form a majority of today’s population.

Bill 66 puts the cultural and natural landscapes of Ontario at risk.  I ask that you reject this bill in its current form.


ACO’s Carnegie Library Series

Post card of the Kitchener Public Library, demolished in 1963. Photo courtesy of the Kitchener Public Library.

The ACO North Waterloo Region Branch recently held the first of a series on the Carnegie Libraries in the Region of Waterloo.  Our first presentation was by Erin Smith: Andrew Carnegie’s Gift to the Region: understanding the eight Carnegie Libraries of Waterloo Region.”  Below are some details of the talk, including the slides that were presented.  We hope to be able to have slides available for future talks that we sponsor.

The Talk

The talk began with an overview of the Carnegie libraries funding program, then focused on the eight Carnegie funded libraries in Waterloo Region, seven of which are still standing, three of those still used as libraries.

Smith explained the Carnegie library model came at a transitional time in North America, and Ontario specifically, when a new physical structure for our libraries offered an answer to the challenge of defining how a library should look and function. They accelerated the movement toward a standardization for libraries at the time.

Waterloo Region is interesting, said Smith, because the period when the area’s Carnegie libraries were funded and built, between 1902 and 1922, offers a comprehensive representation of Carnegie libraries over time, covering the entire period of Carnegie’s grant program in Canada.

The Speaker

Erin Smith is a heritage planner with the City of Brampton who has a Masters in Historic Preservation from the University of Texas School of Architecture where she began her research into Carnegie libraries. She has local experience as she studied urban planning at the University of Waterloo and worked several summers at the Region of Waterloo in their heritage planning section. Her recent thesis research focused on monitoring how heritage properties have been redeveloped along Waterloo Region’s ION Rapid Transit System. Her Instagram posts can be found at @alovelettertolocales.

A self-proclaimed Carnegie libraries ‘geek’, Smith’s presentation, Andrew Carnegie’s Gift to the Region: understanding the eight Carnegie Libraries of Waterloo Region, began with an overview of the Carnegie libraries funding program, then focused on the eight Carnegiefunded libraries in Waterloo Region, seven of which are still standing, three of those still used as libraries.

Click on the link below for her slides. A new window will open and you can see the more than 80 slides she presented.

Erin Smith’s Slides on Carnegie Libraries

Sears and Trinity United: Symptom of our beliefs

By Jean Haalbloom


Let me be clear. I have no love for the Sears store building at Fairview Park mall in Kitchener. Then again how many Kitchener residents shared a love for Kitchener’s old city hall. Even its architect, the late William Henry Eugene Schmalz, could not convince councillors and Kitchener citizens to stop its demolition. After all, the Market Square shopping mall would revitalize Kitchener downtown; it would stimulate economic development. Instead, what we got was downtown’s demise with a 40-year struggle to recover using taxpayers’ investment dollars.

We are a community that enjoys reinventing ourselves. We pride ourselves on innovation. We were one of the first to develop a method of recycling garbage — the blue box. Then why as a community do we not insist on recycling our old buildings, even those from the 1960s. When we willingly replace our place-making heritage buildings, why do we accept a replay of reasons: doesn’t accommodate the workplace environment; it’s too hard to heat; it doesn’t fit the budget. None of these are heritage related reasons for demolition. Will replacing the Sears building truly make cash registers ring in the long-term? Who knows?

Further, if we pride ourselves on innovation, why do we embrace fake. Everywhere, we see fake muntin bars — those plastic bars that give windows the appearance of six over six panes of glass. And now we are contemplating replacing the Sears building with a fake water tower and smoke stack. And did you hear the sighs in Kitchener’s council chamber — ah yes, terrific, such a great investment offer to this community?

Perhaps, we should borrow a development page from our neighbouring province of Quebec. Year after year, many Quebec teams of architects, engineers, businesses and owners of old buildings are recognized at the annual conference of National Trust for Canada for innovative ways of reusing and restoring historic building. Here is one example: in Quebec City, on the periphery of the historic district sits a decommissioned church; the church is the size of our Trinity United at the corner of Frederick and Duke streets in downtown Kitchener. Concerned that this area of Quebec City had no community centre or place where troubled youth could experience sports, arts and culture, an entrepreneur had a dream of establishing a training ground for performers of the Cirque du Soleil. All he needed was a location. After a structural evaluation of the church’s bones, he learned that the structure offered a perfectly strong frame for the wires necessary to support acrobatics. Today, L’École de cirque de Quebec offers youth opportunities in a remarkable old church building.

So what’s the lesson? Whether or not you are impressed with the history or architecture of Trinity United or the Sears building, they have put their stamp on our sense of place. They demonstrate the tastes of the time. New does not always mean better. For 15 years, ‘new’ generally attracts us. Then our tastes change and new falls into distaste. Surely, we can use our innovative talents and thriftiness to demand reuse instead of destruction.

Jean Haalboom is a Kitchener resident, former city and regional councillor, and member of National Trust for Canada and Architectural Conservancy of Ontario.

Letter about the Sears Building to Kitchener City Council by Karl Kessler

Below is a letter from Karl Kessler sent on November 21, two days after the Council decided to allow demolition of the Sear Building at 200 Fairway Road, Kitchener.  Images of the former and proposed building are above.

Comments on the question of the Sears Building are welcomed in the area at then end of this post.  Should you wish to write a long response, please send your comments to

Greetings –

I attended the meeting of Kitchener City Council this past Monday out of an interest in the future of the former Sears building – out of a personal interest, and also a professional interest as Doors Open Waterloo Region coordinator for the past sixteen years. I also contribute a magazine column on our local architecture.

 The constructive tone and the thoughtful, probing Q&A between council and the delegations was encouraging – thank you for that.

But I believe a few points are worth emphasizing.

Also, some statements were made that I believe should be challenged, and more importantly, re-examined in future discussions around built heritage.

Please take a few moments to read through these, with my thanks for your time.

I welcome your thoughts.

  •  It’s typical, almost to the point of being a rule, that during any given period in the past century or more we feel (often strong) disaffection towards architecture that is about 50-60 years old. On Monday, some delegations alluded to this. Lately, in both my professional and volunteer work, I’ve witnessed a slowly growing interest in, and affection for, mid-twentieth-century buildings. This kind of increasing appreciation also is typical – for example, decommissioned industrial buildings were usually demolished until they, more recently, became coveted. In light of this, it’s worth noting that the newly restored 1960s Waterloo County Courthouse at Weber and Queen streets welcomed hundreds and hundreds of curious and enthusiastic visitors each of the two times it has participated in Doors Open.
  •  Not only are there very few opportunities for designating important buildings in general, but intact examples of buildings similar in style and period to the former Sears are very rare. We are fast approaching a situation in which good examples from this important, striking architectural era have mostly vanished, creating a conspicuous gap in our cultural heritage.
  •  One or two councilors suggested, and one repeated, that Heritage Kitchener considers cases such as the Sears building only with heritage conservation in mind. Of course heritage is their lens, but the goals of municipal heritage committees everywhere exist in, and are tightly constrained by, the “real world”. These committees were deliberately created to speak to situations exactly like that of the former Sears building: to inform us with their expertise and particular perspective, and to help prevent the kinds of infamous losses that were common in the middle of the last century, of which there are numerous local examples. And so to imply that because heritage committees have a vested interest, they should therefore be taken with a grain of salt, is puzzling.
  • Further, if heritage committees come at these kinds of issues leaning towards conservation, property developers in possession of identified heritage assets have often leaned demonstrably, and just as heavily, in the other direction. In order for city staff and council to strike a balance between the two aims, the longstanding tendency towards demolition should be acknowledged just as frankly.
  •  Conserving intact the very best of our built cultural fabric has often been framed as antithetical to the aims and health of commerce. On Monday, this again was the case. Generally, this assertion has not been borne out by results where a bit more imagination, will, and resources are brought to the table.
  •  Discussion on Monday referred often to the grim challenges facing storefront retail in general, and malls in particular. Their future was characterized as fragile at best, imperiled at worst. Why, then, permit the demolition of an already existing heritage façade, recognized as culturally significant, if that demolition is only to serve something identified as so changeable?
  • Increased costs and logistical difficulties are ALWAYS stated as main objections against the case for heritage designation, as no doubt they will be in the future. If these continue to be given primacy when the case for designation is strong, it will also continue to be that little of the best of our built heritage will make the grade for meaningful conservation, and having municipal heritage committees in place may increasingly seem to be without merit.
  •  Several of the logistical objections to designation, such as the poor insulating characteristics of the historical precast façade panels, seemed a bit disingenuous. Interior work could address many such issues.
  •  I may be mistaken, but I believe the original architect was not discussed on Monday evening. If a full consideration of the building’s significance is to be claimed, it seems to me that this item should have been part of the public record.

 Many thanks again for your time, and for your ongoing consideration of the challenges facing our built heritage.

Karl Kessler

ACO’s Lecture Series for 2018/19 kicks off November 8th

Image courtesy of City of Cambridge Archives

The phenomenon of the philanthropy of Andrew Carnegie in funding the construction of libraries virtually across the world and the special gift of the eight buildings endowed to what is now the Region of Waterloo will be the subject of ACO’s educational lecture series this year.

Carnegie himself and the motives behind his benevolence will be discussed as will the Beaux-Arts style popular for public buildings at turn-of-the century and used for the majority of the Region’s Carnegie libraries. A lecture by architect Phillip Carter will examine the creative ways in which his retrofits and additions to Carnegie buildings have extended their lives without compromising the beauty of their original designs.

As the good weather returns next spring, we will be offering a day-long bus tour that will afford us the opportunity of examining especially interesting examples of libraries built through Carnegie’s generosity that continue to serve the evolving needs of the communities where they were built a century ago.

The first lecture takes place Thursday, November 8 and is presented by heritage planner and historic restoration specialist, Erin Smith. 

Entitled, “Andrew Carnegie’s Gift to the Region: Understanding the Eight Carnegie Libraries of Waterloo Region,” this illustrated lecture which examines the Region’s Carnegie libraries 1903 – 1923, spans the entire period of Carnegie’s grant program, thus offering a fairly comprehensive representation of Carnegie libraries over time.
The talk will also place the Region’s Carnegie libraries in the broader timeline of architecture and library development, from the early twentieth century to the present day. The impacts of major paradigm shifts in architecture and planning, resulting in the loss of many of our Carnegie libraries, will be discussed. Lastly, the Carnegie library’s place in the 21st century will be contemplated – the challenges and exciting opportunities facing our Carnegie libraries will be explored.
Go to the Eventbrite site now for your tickets.

Again this year lectures will be hosted at WalterFedy, 675 Queen Street South, Kitchener and begin at 7 pm. Plenty of parking is available and the building is accessible.

Is Heritage at Risk from Development?

At a recent meeting of the Kitchener City Council, there were numerous delegations that questioned the Breithaupt Block 3 building that neighbouring property owners are concerned about.  Is heritage an issue in cases where the character of a neighbourhood is being substantially changed?  What is the importance of having streetscapes that are friendly and express the heritage character of our city?

Two presentations at the meeting raises many questions about the process and are presented below.


I am not a Developer

by Debbie Chapman

After spending many hours last week sifting through the current zoning bylaw document and the proposed CROZBY document, the Official Plan as passed in 2014, the Urban Design Manual, RIENS and PARTS, to get a better idea of the discussion around the BB3 development project and where we, the citizens, fit into the process, I have come out with more questions than answers.

Rather than speak off topic by expressing my concerns about such things as bonusing bylaws, which I think should be eliminated, or guidelines versus bylaws – where guidelines are often ignored by developers and planners – I want to say that what we are witnessing with the BB3 project is an inadequate public involvement process (hence the large number of people lined-up to speak this evening after already deferring the decision once), and a series of unfinished documents that give an edge to the developer at the expense (in this case) of an established neighbourhood.

Talk about the LRT began in 2004 and was further solidified in 2009. The fact that planning documents are still in process gives developers the opportunity to abide by or bounce back and forth between the previous and current bylaws and guidelines. Unless the City is willing to insist on honouring the revised documents – RIENs, CroZby, PARTs and the Urban Design Manual, they should put a moratorium on the BB3 and all further development projects in the Core until the new documents have been instituted – until these documents become binding.

Furthermore, the 2017 Provincial document titled Places to Grow states that: “within the GGH (Greater Golden Horseshoe), this Plan provides that the applicable time horizon for land use planning is 2041” or 2031 for UGC projects (page 8) – so why is the City is such a hurry to approve the many projects in the pipelines – Sixo/Charlie West (24 Gaukel St)/ 471-475 King. St. E. etc without first completing the institutionalizing of the documents in question.  Could it possibly be to allow developers to get that edge?

Somebody recently said to me that people don’t like change. This person was suggesting that because we don’t like change we contest the proposed development projects. My assessment is that people want respect, they want to be at the table participating in the decision making rather than shown bulletin boards of the plan. I’ve yet to hear anybody say they do not want development along the LRT route, but I have heard people say that they want responsible development and that they want to be taken seriously in the decision making process – even if it takes a bit more time.

Would it be unreasonable to ask that development slow down, that unfinished documents be expedited, that is be passed, approved and implemented now and not at the end of the year or some time next year, and that City Council ensure responsible development so that people don’t look back in 30 years and say “what were they thinking”? It is not about a fear of change, but we must be responsible and ensure that neighbourhoods are not negatively impacted, that concerned citizens are brought to the table with developers, planners and the councillors as decisions are being made and not just through information sessions where people often feel that their comments go unnoticed, and finally that the vision of the city we have is reflected in the bylaws that we draft.


“Development” – a Contemporary Fable

Peter Eglin

Presentation to Kitchener City Council, June 25, 2018

The Province tells cities to “intensify” – build up, not out. An LRT system for K-W is approved, the government money promised. Developers smell a bonanza. The City salivates at the prospect of growth in tax revenue and “development”. The Planning Department is enjoined to plan. The public are “consulted”. Some neighbourhoods mobilize in self-defence. Liberal, electoral, representative democracy is in action.

What does this actually mean in practice? The following is how it appears to me.

The developers have unfettered access to the city planners, through whom they can bring pressure to bear on the councillors, who depend on planning staff, including those councillors that are already, shall we say, developer-friendly. Countless “guidelines” are drawn up setting out visions of best practices like RIENS, PARTS, Tall Buildings and the Urban Design Manual. But the documents that count – the Official Plan, the secondary plans and the zoning bylaws – are either under appeal, not yet drawn up or reviewed, or under extensive revision. In any case, they are riddled with loopholes whereby the desired standards can be set aside if the developer adds a few trees, a few residential units, a bit of public art. If not exactly written by the development industry they are effectively written for the development industry. Make concessions to Perimeter and to Google so we get their goodies, and tell the residents to be thankful that we have such corporate benefactors at all. What a vision of a decent and just society!

And how naïve! We in Kitchener have no guarantee that Google won’t decide tomorrow to move back to Waterloo where they originally came from and where the real tech action is. What we do know, and should expect, because it’s simply the nature of the capitalist enterprise, is that the developers and their business partners will do everything in their power to get around and subvert every stipulation that reduces their profits. This, I take it, explains the frenzy of “development” currently occurring. While CRoZBy, PARTS, RIENS and the rest wait in limbo to be implemented, developers are ramming through their projects to take advantage of the slacker rules of the existing regulations. And all the while, appealing umpteen sections of the 2014 Official Plan.

Providing bike racks, green space, community space and children’s play space in abundance, and constructing environmentally sound, energy efficient and artistically attractive buildings should simply be a taken-for-granted requirement of any so-called “development”, and not treated as bait to be rewarded with bonuses.

The Province’s plan for intensification extends to 2041. What’s the almighty hurry to get it all done now?

It’s not your city, councillors. It’s not the Planning Department’s city. Above all, it’s not the developers’ city. It’s our city. It’s the city of its residents. Your job, your mandate is to listen to us. In a real democracy listening wouldn’t mean “consulting” now and again. It would mean “following orders,” orders given by the residents. But we have a liberal, electoral, representative, first-past-the-post democracy in which, given prevailing participation rates, each of you needs the support of no more than 15% of your ward’s electorate (less than 2% of the city electorate) to be set free to do as you like.

So here’s what I think you should be doing: in BB3 and the “developments” to come, either require the developers to abide by CRoZBy, PARTS, RIENS, Tall Buildings, the Urban Design Manual and the rest as if they were in place, minus the bonuses, or put a moratorium on all such developments until they are in place; above all, listen first and foremost to what the community of residents wants.

Appendix on Affordable Housing: the 40-40-20 Rule

In their just-published report on security of employment in the Greater Toronto-Hamilton area by the PEPSO research group from McMaster University under the auspices of the United Way, we read that in 2017 55% of workers were in Stable Employment Relationships – that is, full-time, permanent jobs with benefits (an increase of 5% over 2011). This means that 45% of workers are NOT in stable employment relationships. In fact, 37% of workers aged 25-65 in the GTHA are in some form of precarious employment.[1] The equivalent study by the United Way in the United States reports “43 percent of households … don’t earn enough to afford a monthly budget that includes housing, food, child care, health care, transportation and a cell phone.”[2] And this is happening in what’s called a ‘booming economy’. In the face of such facts, a year ago the Dutch city of Amsterdam “committed to creating more housing for people with low- or mid-level incomes. To realize this, the municipality is implementing a ratio for new construction projects – 40 percent social housing, 40 percent mid-level rents and 20 percent expensive housing.”[3]

The City of Kitchener should adopt the 40-40-20 rule for new construction projects.

[1] See also