THE CORPORATION OF THE CITY OF NELSON

REQUEST FOR DECISION

DATE: February 5, 2018 - Regular
TOPIC: Development Variance Permit Application – 520 Falls Street
PROPOSAL: To facilitate development of a two lot subdivision and a new mixed-
use residential/commercial building
PROPOSED BY: Pam Mierau, Manager of Development Services
_____________________________________________________________________

ANALYSIS SUMMARY:
Development Services has received a Development Variance Permit application to vary
the Subdivision and Development Servicing Bylaw 3170, 2011, as well as the Off-Street
Parking and Landscape Bylaw 3274, 2013 as follows:

1. Variance to the Subdivision and Development Bylaw 3170, 2011, Section 4.2 to
allow for the primary access to the proposed new development be reduced in
width from 20m to 6m.

2. Variance to the Off-Street Parking and Landscape Bylaw, 3274, 2013 Section 6.1
(2) (a), to allow for a reduction from 80 stalls required for the former bowling alley
(as per a covenant from 1987) to 34 stalls (current bylaw requirements for the
existing uses in this development would be 44 stalls).

Approval of the variances by Council would allow for subdivision of the site and
development of the proposed new five-storey mixed-use development including 39 one-
bedroom units for low income singles and couples (low end of market housing) as well
as 123m2 of commercial space at-grade.

BACKGROUND:
The Applicant is requesting a subdivision to create two parcels: one for the existing
commercial building (proposed new east lot) and a new parcel for a proposed mixed-
use residential/commercial building (proposed new west lot). The proposed new
development is for 123m2 of ground floor commercial and five storeys of rental
residential units including 39 one bedroom units with an average unit size of just over
400ft2. These units will provide housing opportunities for three of the priority groups
identified in the Affordable Housing Strategy (2014) (Priority Groups: At Risk Youth and
Young Adults, Low Income Seniors, Homeless and Risk of Homeless).

The subject property is zoned C1 Commercial. The proposed mixed-use

residential/commercial development is a permitted use in this zone. The property is
approximately 3646m2 in area. There is a commercial building existing on the property
which includes the Kootenay Christian Fellowship, Our Daily Bread, the BC SPCA, and
SHARE Nelson. The existing building will be located on the proposed new east lot
(2064m2) and the mixed-use residential/commercial building will be developed on the
proposed new west lot (1582m2).

The Applicant is requesting the following two variances to allow for the proposed
development:
1. Road Width
The Applicant is requesting a reduction from 20m to 6m. The Subdivision and
Development Bylaw requires an R3/R4 Collector Road Standard (20m) for all
roads in the C1 Commercial Zone. All new parcels created via subdivision in the
C1 Zone are required to conform to this road standard. The new parcel created
via the proposed subdivision has two access routes; off Baker Street and off
Falls Street. The Ministry of Transportation and Infrastructure has determined
that the Baker Street access can only be used for emergency vehicles given the
limited distance to the Baker Street/Hwy 3A intersection. Primary access to the
proposed new mixed-use building will be via Falls Street either around the
existing building to the rear of the lot via a 6m lane or through Herridge Lane
(4.74m wide).

Reducing the primary access from 20m to 6m requires a variance to the

Subdivision and Development Bylaw. Staff have referred this variance to a
number of internal and external agencies. The only concern identified relative to
road width was from Nelson Fire and Rescue Services. The Applicant has
accommodated their concerns by providing for a 6m emergency vehicle lane that
consists of access off Falls Street, around the existing building, and across the
southwest portion of the site. This would require the City allowing the Applicant
to use the vacant City-owned parcel as emergency access. This parcel is
currently used by vehicles accessing the Best Western parking lot, as well as
parking for employees and customers of the adjacent business. MOTI has
identified that the Baker Street access can be used as an emergency route.

The Transportation Study prepared by Urban Systems (see Attachment –

Transportation Study) identifies that the traffic volumes forecasted for the
development are well within the range for the existing 6m lane, and further that
construction of a 20m road right-of-way to access the site would require a
significant area of land that would take away from the available land that is
currently proposed for off-street parking on the site.

2. Parking
The Applicant is requesting a parking reduction from 80 stalls to 34 stalls for the
existing building. The new development meets the parking requirements.

Existing building: The Off-Street Parking and Landscape Bylaw, Section 6.1 (2)
(a), states that the parking regulations do not apply to buildings, structures or
uses existing on the effective date of this bylaw, except that:
(a) Off-street vehicle parking, loading spaces required in accordance with
previous land use regulation bylaws shall be provided and maintained.

In 1987 a covenant was registered on title for this property for a minimum of 80
stalls to be provided to accommodate parking for a bowling alley. A variance
from Council is required in order to reduce the required parking from 80 stalls.
Under the current parking regulations, parking stalls required for the existing
building would be 44 stalls:

KCF 232m2 1 space/10m2 23 stalls

Our Daily Bread 232m2 1 space/30m2 8 stalls
SPCA 185m2 space/30m2 6 stalls
 SHARE store 650m2 1 space/30m2 22 stalls
Minus shared parking provision 25% (15 stalls)
Total Parking Required 44 stalls

A variance to the Off-Street Parking and Landscape Bylaw is required to reduce

the parking for the proposed new east lot from 80 stalls to 34 stalls. The
Applicant has identified that they currently have 34 parking stalls on-site. Of
these stalls, four are attributed to the SPCA, and 21 attributed to KCF (Sundays)
/ SHARE Store and ODB (Monday to Saturday) which they state have been
sufficient for each occupancy. As they have historically not used all of the parking
stalls, they were comfortable enough to have separately leased the remaining
nine stalls for several years. The lease on these stalls expires this April.

Proposed new development: the proposed mixed-use development includes 39

studio and one bedroom units which have a parking requirement of 1 stall per
unit plus 0.2 visitor stalls. The 123m2 of commercial requires 1 stall per 30m2.
Within the downtown core, for mixed use developments that include residential,
“the required number of vehicle parking spaces may be reduced to 50% of the
total number that would otherwise be calculated.” (Off-Street Parking and
Landscape Bylaw, Section 7.3 (2)). In addition, the Bylaw also allows for a
reduction in the parking stall size for up to 30% of the parking stalls required –
stalls can reduced to 2.5m x 5.3m from the standard 2.75m x 6m. Total parking
stalls required for the development is 25 stalls.

39 stalls x 1 stall per unit = 39 stalls

39 stalls x 0.2 stalls per unit = 7.8 stalls
123m2/30m2 = 4.1 stalls
50.9 stalls required x 50% = 25 stalls required

The Applicant is proposing that the size of six of the parking stalls be reduced to
2.5m x 5.3m. As per the Bylaw (Section 7.6(2)(c), the size of up to 8 stalls could
be reduced.

A variance to the Off-Street Parking and Landscape Bylaw is not required as the
Applicant is providing 25 stalls on-site for the proposed new development.

Transportation Study
A Transportation Study was conducted by Urban Systems (Attachment – Transportation
Study), which found that at build-out the proposed residential/commercial development
would add an estimated 19 vehicle trips during the morning peak hour and 22 vehicle
trips during the afternoon peak hour. When the new development traffic is combined
with the existing volume of 13 vehicles per hour on the 6m lane, it is estimated that 32
vehicles will use the 6m lane during the morning peak hour and 35 vehicles will use it
during the afternoon peak hour. The projected volume of increased traffic is not
considered significant, will have minimal impact on the adjacent intersections, and is
well below the typical threshold of 100 trips per peak hour that would require traffic
capacity analysis.

Funding
The total cost of this project is estimated at $10M and will be primarily funded by BC
Housing. It is anticipated that CBT will also be providing funding, and Kootenay
Christian Fellowship is contributing $300,000 in land costs.
Policy
Staff have reviewed the application against the objectives and policies outlined in the
Affordable Housing Strategy Update 2014 as well as the Official Community Plan
(OCP). The proposal to rezone is consistent with the following:
 Affordable Housing Strategy #17: Leverage underutilized land and buildings
towards increasing the supply of affordable housing.
 OCP Objective (p.26): To provide a diversity of housing options that are
appealing, attainable, and affordable to all citizens, of all ages, abilities, and
income levels.
 OCP Objective (p.31): To infill key vacant or underutilised mixed-use parcels
within the Downtown to reinforce its position as the nucleus of the City.
 OCP Objective (p.46): Encouraging the development of a range of affordable
housing for people with special needs at locations near bus routes and
community services/amenities.
 OCP Objective (p.46): To encourage affordable, multi-unit housing to be located
in areas without steep slopes, within reasonable walking distance of services
such as a commercial area, a bus line, a park or recreation centre, and/or near
medical facilities.

Evaluation Criteria
Staff have reviewed this variance against the City’s Evaluation Criteria for Development
Variance Permits in order to determine its consistency with the intent of the regulations
and any potential negative impacts on neighbours or the City’s infrastructure. The
following is a summary of the analysis:
a) Compliments the Streetscape or Neighbourhood. The proposed
development would provide for infill development and architectural diversity in the
downtown core.
b) Does Not Unduly Interfere with the Amenities of the Area or Materially
Interfere With, or Affect the Use, Enjoyment, Safety, Aesthetics or Value of
Neighbouring Properties. The proposed development would not unduly impact
the neighbouring properties.
c) Results in Substantial Impacts to Municipal Services. The proposal does not
significantly impact municipal services.
d) Land Use. The proposed development is in alignment with the current zoning on
the subject property.

BENEFITS OR DISADVANTAGES AND NEGATIVE IMPACTS:

If the variance request is approved, the Applicant would be able to develop the
proposed 39 unit mixed-use rental residential/commercial building. The development
will achieve Council objectives by providing housing opportunities for the priority groups
identified in the Affordable Housing Strategy, and by providing infill development in the
downtown core.

LEGISLATIVE IMPACTS, PRECEDENTS, POLICIES:

A Development Variance Permit is required for any development that varies provisions
of the Subdivision and Development Bylaw 3170, 2011 and the Off-Street Parking and
Landscape Bylaw, 3274, 2013. Council approval is required for Development Variance
Permits.
COSTS AND BUDGET IMPACT - REVENUE GENERATION:
The cost of a Development Variance Permit is covered by the fees charged to the
applicant. Revenue is received through building permit fees and servicing cost charges.
Property improvements increase taxes.

IMPACT ON SUSTAINABILITY OBJECTIVES AND STAFF RESOURCES:

This application supports Council’s Healthy Neighbourhoods sustainability objective by
providing diverse and affordable housing opportunities. This will not impact staff
resources.

COMMUNICATION:
Property owners and occupants located within 60 metres of the subject property have
been notified of the application pursuant to the Local Government Act and the
Development Applications Procedures Bylaw. At the time of writing this report, no
written responses have been received.

This application was circulated to MOTI, Provincial Approving Officer, Fortis, Nelson
Hydro, Public Works and the Fire Department with the following comments:
 MOTI/Provincial Approving Officer: Baker Street access only to be used for
emergency access; no access off of Hwy 3A.
 Fire: the two remaining parking stalls on Falls Street need to be eliminated in
order to provide suitable access to the development via Falls Street; emergency
access off of Baker Street must be kept clear of vehicles; both access roads (off
of Baker Street and Falls Street) must be a minimum of 6m, constructed with a
hard surface, be able to bear loads of 20,000 lbs, and kept clear of snow and
vehicles at all times.
 Public Works: infrastructure to the subject property can be installed at a cost of
approximately $135,000 for construction of water, sewer and storm; connection
fees will be an additional $128,271.
 Nelson Hydro: the development will require the extension of three phase primary
underground power to service the new building; a dedicated padmount
transformer and SRW will be required on the site in a location approved by
Nelson Hydro. Connection costs to be determined at installation.

OPTIONS AND ALTERNATIVES:

1. Approve the request for a Development Variance Permit.
2. Deny the request for a Development Variance Permit.
3. Refer the application back to staff for further information.

ATTACHMENTS:
 Location Map
 Site Plan / Proposed Variances
 Supplemental Information
 Transportation Study
 Site Photos
 Public comment
RECOMMENDATION:
That Council pass the following resolution:

That the application for a development variance permit to vary the requirements of the
Subdivision and Development Servicing Bylaw No. 3170, 2011 and the Off-Street
Parking and Landscape Bylaw 3274, 2013 to allow for a two lot subdivision of Lot 1,
Plan EPP 10960, District Lot 95, Kootenay Land District (520 Falls Street) be
APPROVED as follows:
1. Subdivision and Development Bylaw 3170, 2011, Section 4.2: To allow for the
primary access to the proposed new development be reduced in width from 20m
to 6m.

2. Off-Street Parking and Landscape Bylaw, 3274, 2013 Section 6.1 (2) (a): To
allow for a reduced parking rate from 80 stalls to 34 stalls for the existing
commercial building on the site.

AUTHOR: REVIEWED BY:

______________________________ ____________________________
MANAGER OF DEVELOPMENT CITY MANAGER
SERVICES
Location Map – 520 Falls Street Development Variance Permit Application

Subject
property
520 Falls Street – Site Plan/Proposed Variances

Variance 1

Subdivision and Development

Bylaw 3170, 2011, Section 4.2. To
allow for the access to the
proposed new development be
reduced in width from 20m to
6m.

Variance 2

Off-Street Parking and Landscape

Bylaw, 3274, 2013 Section 6.1 (2)
(a). To allow for a reduction
from 80 stalls required for the
former bowling alley (as per a
covenant from 1987) to 34 stalls
(current bylaw requirements for
this development would be 44
stalls).
 BAKER ST
PROPOSED DEVELOPMENT PARKING BAKER ST

Type of Development: Multi-unit Residential Parking Required

Anticipated Occupants: Low Income Residents - Single or Couples Residential (50% reduction): 23.4 stalls 6.0m
No. of Residential Units: 39 One-bedroom Rental Units Commercial (50% reduction): 2.06 stall
6.0m
No. of Storeys: 3/4/5 Total: 25.46 stalls
Provided: 25 stalls

FIRE LANE / EMERGENCY

GFA Commercial Occupancy: 1328 sq ft (123.5 sq m)

FIRE LANE / EMERGENCY

ACCESS ONLY
GFA Residential Occupancy: 22 717 sq ft (2112.68 sq m) Bike Parking Required
GFA Total (including exterior walkways): 28 711.73 sq ft (2670.19 sq m) Residential: 43 stalls

ACCESS ONLY
Commercial: 7 stalls
Residential Suite Areas (Interior Square Footage): Total: 50 stalls
Suite Type - Typical = 404.3 sq ft Provided: 50 stalls

Total Area = 15 654.1 sq ft

MAIN MAIN

4.74m

4.74m
ENTRY ENTRY
MAIN HERRIDGE
MAIN LANE

4.74m

4.74m
ENTRY ENTRY
PARCEL B HERRIDGE LANE 6.0m

LOADING
0
L1
AL
PARCEL
1 580m 2 B 6.0
m SM
AL
L1
1 9 6.0m

LOADING
2 10 RESIDENTIAL COMMERCIAL
SM LLA1LL 1
m A M 3 1 AMENITY 1328 sq ft 9
580m2 6.0
1L

City of Nelson Zoning Bylaw Requirements Proposed Development (Actual) 0.391 acre SM S LLAL
SM
ASM
L 14L 12
L
RESIDENTIAL COMMERCIAL
AMENITY
ALMA 5L 13 1328 sq ft

KCF/ SPCA/ SHARE/ ODP

LOADING
Zoning Regulation: C1, Core Commercial Zone Zoning Regulation: C1, Core Commercial Zone 0.39 acre SMS LLA1L
6L 14

FALLS ST
ASM 1 1
M

FIRE LANE / MAIN ACCESS

S L L

KCF/ SPCA/ SHARE/ ODP

AMLA 15 GREEN 34 LOADING
SMS 1L7
AEL

FALLS ST
6 SPACE 2 1

FI
R
SAM E L1L8 1

BI

FIRE LANE / MAIN ACCESS

SH GREEN 33

KE
RE
A 34
ASRM 191
7 3

PA
H E SPACE 2

FIAN
S R
RAE E 18

BI ING
32

R
Lot Coverage: 90% Lot Coverage: 45.16% (714.66 sq m) SAH 33

K
KE
REE
SH A R 9 4 3
0 1

PA
SH2 E 31
Lot Area: Min. 278 sq m Lot Area: 1582.43 sq m
32

LA/ M

R
AR

KI
H 5
1 4

NG
NEAIN
S 2 30
20
Lot Width: Min. 7.6m Lot Width: 56.9m

RO
31
6

HI
22 5

/ MAC
21 29

W
G
30
Setbacks: Front lot line = 0m / Rear lot line = 0m / Setbacks: Front lot line = 2m / Rear lot line = 2.75m /

RO
23

HW

AI CE
7 6

HI AY
2 2 28

N S
24 29

W
Exterior & Interior side lot line = 0m Interior side lot line = 0m/ Exterior side lot line = 2.75m

G 3

ACS
23

HWA
5 R 7 27
2 AI 28
Maximum Building Height : Principal = 16m / Maximum Building Height : Principal = 16m 24 ST

C
AY

ES
WASTE/ 8 26
5 LL R 27
RECYCLING 2 MA AI
Accessory = 4.5m Accessory: n/a

S
3A
S ST
WASTE/ 8 26 6.
LL 0m
RECYCLING MA
S

6.0m
6.
Waste and Recycling: Waste and Recycling: 0m VICTORIA S

6.0m
Minimum size: 11m2 Minimum size: 11m2 VICTOR
Clearance above: 4.0m Clearance above: 4.0m 25 14 13

24 15 14 12
25 13
Amenity Areas: Amenity Areas: 23 16
24 15 11
12

15 sq m per dwelling unit = 585 sq m required Total = 591.69 sq m (not including exterior walkway width 22 17
23 16 10
11

required for code - additional 351.89 sq m if included) 21 18

22 17 9
10
19 18 8
21 9

GFA at grade non-residential: Min. 50% GFA at grade non-residential: 50% (123.5 sq m)
20 19 7 8
6
20 7
5 6
4
5
3 4
2 3
N 1
2 PARCEL A
1 PARCEL A
2 062m2
0.5 2acre
062m2
0.5 acre

Architectural
Collaborative SUBDIVISION SUPPLEMENTAL INFORMATION
Architectural
Collaborative
Inc
SUBDIVISION SITE PLAN
SHARE Housing
2018.02.05
SHARE Housing SUBDIVISION SITE PLAN
Architectural
Inc Collaborative
Inc
SHARE Housing
SHARE HOUSING INITIATIVE
VARIANCE APPLICATION
520 FALLS STREET, NELSON, BC

FEBRUARY 5TH, 2018

 N

S T
VERNON

BAKER ST

FALLS ST

KOOTENAY ST

STANLEY ST

JOSEPHINE ST
WARD ST
R S T
BAKE
HERRIDGE LN

RA
ILW
AY

HI
VICTORIA ST

G
ST

HW
AY
3A
GOV
ERN
MEN
T RD
SILICA ST

HIGHW
AY 3A

CARBONATE ST

MILL ST
6
AY
HW
HIG

LATIMER ST

AERIAL PLAN
 BAKER ST PROPOSED
SUBDIVISION
PARCELS

HERRIDGE LANE
PARCEL B
PROPOSED

KCF/ SPCA/ SHARE/ ODP

BUILDING

FALLS ST
GREEN
PROPOSED BUILDING SPACE
(ABOVE)
HI
G
HW
AY

VICTORIA ST
3A

PARCEL A

SITE PLAN
 BAKER ST
EMERGENCY
ROUTE

TYPICAL

FALLS ST
VEHICLUAR
ROUTE

HERRIDGE LANE

VICTORIA ST

CIRCULATION
 BAKER ST
MAIN ACCESS
6.0m
WIDTH
REDUCTION FROM
FIRE LANE / 20m TO 6m
EMERGENCY

FALLS ST
ACCESS ONLY
4.74m 4.74m

HERRIDGE LANE 6.0m

FIRE LANE / MAIN

0 m ACCESS ON
6. FALLS ST

VICTORIA ST

6.0m

VARIANCE 1 - MAIN ACCESS

 PARCEL A
VARIANCE -

80 PARKING
PARCEL B 34 STALLS TO 34
25 STALLS 33
32
PARKING STALLS
31
30
29
28 PARCEL B
27
26 IN CONFORMANCE
WITH CITY
PARCEL A BYLAWS
25 14 13
24 15 12
23 16 11
22 17 10
21 18 9
19 8
20 7
6
5
4
3
2
1

VARIANCE 2 - SUBDIVIDED PARCEL PARKING

 BEDROOM BEDROOM
LIVING LIVING

KITCHEN KITCHEN

BATH BATH

TYPICAL SUITE LAYOUT

PERSPECTIVE VIEW - LOOKING WEST
PERSPECTIVE VIEW - LOOKING NORTHEAST
PERSPECTIVE VIEW - LOOKING SOUTHEAST
 BAKER ST

6.0m

FIRE LANE / EMERGENCY

ACCESS ONLY
MAIN MAIN
ENTRY ENTRY

4.74m

4.74m
HERRIDGE LANE
6.0m
0

LOADING
LL1
m A 1 9
L1
6.0 SM
A L 2 RESIDENTIAL COMMERCIAL
SM LL1
SM
A
L1
4 AMENITY 1328 sq ft
A L
3
SM LL1
A 15 LOADING

KCF/ SPCA/ SHARE/ ODP

SM L
AL 6

FALLS ST
1
SM L1

FIRE LANE / MAIN ACCESS

AL GREEN 34
SM 17
E SPACE 2
AR

FI
18

BI
SH E 33

KE
RE
H AR 19 3

PA
S E 32
AR

LA

R KI
S H 4

NG
NE
20 31
5

/M
21 30
RO

AI
6
22
HI

29

N
W
G

23

AC
7
HW

28
24

CE
AY

25 R 27
AI

SS
T
3A

S
WASTE/ L8 26
RECYCLING AL
SM
6.
0m

6.0m
VICTORIA ST

25 14 13

24 15 12

23 16 11

22 17 10

21 18 9

19 8

20 7

1
N

SITE PLAN
Site Photos – 520 Falls Street Development Variance Permit

Entrance to site (6m lane)

Existing parking in rear
parking lot

Exit via Baker Street

Emergency Vehicles Only
Exit via Herridge Lane
Development Services

From: David Paetkau <dpaetkau@wildlifegenetics.ca>

Sent: Thursday, January 25, 2018 2:24 PM
To: Development Services
Subject: Variance application 520 Falls St.

To Whom It May Concern: 
 
I support the principle of what the KCFS is trying to do with 520 Falls, but I think vehicle access (specifically egress) is not 
adequately addressed in the proposal that the city mailed to us (Wildlife Genetics, the owners of 182 Baker St.). Given 
that egress through the Best Western parking lot is of uncertain legal status (marked as Emergency Only on your map), 
this plan depends on the use of Herridge Lane for egress from either of the newly subdivided lots in the proposal. This 
lane is blocked almost daily, often for hours at a time, by trucks making deliveries to the Savoy. Indeed, our workplace 
does not have a Baker Street entrance, so we routinely have periods where a semi prevents access to our only entrance, 
inconveniencing staff, couriers and users of the Carshare vehicle that parks in our lot. Even when open to traffic, 
Herridge Lane only provides seasonal access to many vehicles, being too steep to be used by small cars or delivery 
trucks on slushy days; last week a garbage truck got jammed sideways across the entrance to our parking lot, blocking 
the lane for a good length of time, and the lane hasn’t been plowed yet this year, so for effectively all of January small 
cars would have had no chance of making it up the slope towards Falls Street. 
 
It is unclear to me how a residential building can be added in a location where legal vehicle access is narrow (narrower 
than shown on the map once posts protecting gas lines are considered, to the point of being dangerous for pedestrians 
when drivers get impatient), routinely blocked by delivery vehicles, and seasonally unusable for many vehicles. I’m open 
to suggestions, but the only option I see right now would be to formalize access to Baker Street from the western 
terminus of Herridge Lane, via the Best Western lot; otherwise conflicts in the lane will get worse, and there will be 
many times when residents have no legally regular means of egress. 
 
David Paetkau 
 
David Paetkau, PhD 
President 
Wildlife Genetics International Inc. 
Suite 200 ‐ 182 Baker St. (Box 274) 
Nelson, BC  V1L 5P9 
250‐352‐3563x222 
wildlifegenetics.ca 
 

1
Development Services

From: Tim Pearkes <tim@pearkesfernandez.com>

Sent: Friday, January 26, 2018 12:00 PM
To: Development Services
Subject: 520 Falls Street - Development Variance Permit - copy attached for your ready
reference
Attachments: DOC012618.pdf

On behalf of NDN Partners Inc., please note that we have no objection to the access size variance request.

Could you please provide some additional information with respect to the parking reduction variance request?
We would like to know how many residential units and the approximate square footage of residential space is
contemplated on however many stories and the type of commercial use contemplated. We note that the second
variance only refers to 34 stalls to accommodate "existing commercial uses".

As you are well aware, parking is at a premium and we already have a task to preserve our own spaces for our
tenants. We would like more information before commenting on the second variance requested.

Thank you.
--
Tim Pearkes

NDN Partners Inc.

Suite #8 – 266 Baker Street
Nelson, BC V1L 4H3
250.352.2883 (o)