Impact of Big Box Retail Development on the

Toronto Community=s Retail Strips

 The Toronto Community Council recommends that:

(1)City Council authorize the Commissioners of Economic Development, Culture and Tourism and Urban Planning and Development, in consultation with TABIA, to conduct a research study of the cumulative impact of big box retail stores on the former City of Toronto retail strips;

 (2)additional funding in an amount up to $35,000 be allocated to the operating budget of the Economic Development, Culture and Tourism for the research study;

 (3)the research report and recommendations be submitted to the Toronto Community Council for discussion and review; and

 (4)the City Solicitor be instructed to advise the Ontario Municipal Board that a full hearing on Official Plan and Zoning By-law Amendment Application No. 197019 (Home Depot) and Official Plan Amendment No. 87 and Zoning By-law No. 1997-0184 (East Bayfront) should not take place until the research report has been completed and evaluated in the context of the Home Depot application and in the context of the City's land use policies for the East Bayfront and retail activity in general.

 The Toronto Community Council reports, for the information of Council, having referred Recommendation No. (2) to the Budget Committee for identification of source of funds, and report thereon directly to Council.

 The Toronto Community Council further reports, for the information of Council, that it has requested the Commissioner of Urban Planning and Development Services to address the issues raised in the communication (July 8, 1998) from Joanna Kidd and Leslie Woo, Toronto Bay Initiative, in her final report on Official Plan and Zoning By-law Amendment Application No. 197019 (Home Depot).

 The Toronto Community Council submits the following report (July 21, 1998) from the Commissioner of Urban Planning and Development Services:

 Purpose:

 This report has four purposes. The first is to respond to a communication from Nicholas T. Macos dated June 23, 1998. The second is to respond to requests made by Toronto Community Council at its meeting on June 24 and 25, 1998 regarding the impact of big box retail stores on the former City of Toronto's retail strips. The third is to update City Council on the East Bayfront Ontario Municipal Board hearing. The fourth is to update City Council on the status of Official Plan and Zoning By-law Amendment Application No. 197019 for a 9,940 square metre big box retail store at 429 Lake Shore Boulevard East and 324 Cherry Street (Home Depot).

 The report was prepared in consultation with staff from Economic Development, Culture and Tourism and TABIA.

 Financial Implications:

 In response to Toronto Community Council's request from its meeting on June 24 and 25, 1998, funding in an amount up to $35,000 should be allocated to the operating budget of Economic Development, Culture and Tourism, if City Council wishes to proceed with a research study of the cumulative impact of big box retail stores on the former City of Toronto's retail strips. The scope of this study is described in the body of this report.

 Recommendation:

 That additional funding in an amount up to $35,000 be allocated to the operating budget of Economic Development, Culture and Tourism for a research study of the cumulative impact of big box retail stores on the former City of Toronto's retail strips.

 Background:

 At its meeting on June 24 and 25, 1998, Toronto Community Council had before it a report from the Commissioner of Urban Planning and Development Services entitled "Settlement of Certain Issues, By-law No. 1997-0183 (Official Plan Amendment No. 87) and Zoning By-law No. 1997-0184 - East Bayfront (Downtown and Don River)". In addition to adopting the recommendations in that report, Toronto Community Council requested:

"(1)the Commissioner of Economic Development, Culture and Tourism and the Commissioner of Urban Planning and Development Services, in consultation with TABIA, to report on the cumulative impact of big box retail development on the Toronto Community's retail strips; and

 (2)the Commissioner of Urban Planning and Development Services, in consultation with the City Solicitor, report to the Toronto Community Council, at its meeting to be held on July 22, 1998 on the communication (June 23, 1998) from Nicholas T. Macos."

 In 1997 the former City of Toronto passed Official Plan and Zoning amendments for the East Bayfront to permit a wider range of uses. Notices of appeal to By-law No. 1997-0183 (Official Plan Amendment No. 87) and Zoning By-law No.1997-0184 were received from 1227803 Ontario Limited and 1147390 Ontario Limited in May, 1997. A prehearing conference on the appeals is scheduled to begin on August 4, 1998 and if necessary continue on August 5.

 In June 1997, The Home Depot Canada submitted an application (No. 197019) to amend the Official Plan and Zoning By-law for the properties at 324 Cherry Street and 429 Lake Shore Boulevard East for a 9,940 square metre big box retail store. The site is shown on Map 1 attached.

 At its meeting on July 17, 1997, the Land Use Committee of the former City of Toronto adopted, among others, the following recommendations from a preliminary report on the application:

"(1)That the Planning Advisory Committee be requested to hold a public meeting in the area to discuss the application and to notify tenants and owners within 120 metres of the site and local resident and business associations of the meeting.

 (2)That the applicant submit to the Commissioner of Urban Development Services the following additional information:

 (a)a study that analyses the impact of such use on the economic viability and planned function of shopping districts in the area, including retail strips, and concludes that the development will not have a negative impact;

 (b)a study that analyses the capacity of the existing road and transportation systems and concludes that the system is adequate;

 (c)a study that analyses the impact of such uses on adjacent uses; and

 (d)a study that identifies how the development will conform with City Council's Design Guidelines for Big Box Retail and how the owner will ensure public access to the water's edge."

 On January 22, 1998, The Home Depot Canada appealed its applications to the Ontario Municipal Board for failure of the City to enact an Official Plan and Zoning By-law amendment.

 At the August 4 and 5, 1998, OMB prehearing conference on the East Bayfront, the Ontario Municipal Board will consider a request to combine the appeal filed by the Home Depot with the East Bayfront appeals. If successful, the request will mean that there will be one hearing dealing with East Bayfront matters, rather than two.

 Comments:

(1)Response to letter (June 23, 1998) from Nicholas T. Macos

 Mr. Macos is legal counsel for one of the appellants to the East Bayfront Official Plan and Zoning By-law amendments. In his letter to Toronto Community Council dated June 23, 1998, he requests that City Council direct the City Solicitor to seek an adjournment of the prehearing conference scheduled for August 4 and 5, 1998. I have compressed Mr. Macos' arguments in favour of a deferral into three categories.

(a)Land use planning policies for the East Bayfront need to be revisited in the context of current development initiatives, such as the 2008 Olympic Bid

 The East Bayfront Working Committee held nine meetings between October 1995 and May 1996. The recommendations contained in the Committee's report were reached through consensus and balanced the interests of those who wanted the area to become a mixed commercial-residential area and those who did not. However more importantly, the recommendations reflected the former City of Toronto's desire to improve business opportunities in the East Bayfront. The adoption of Zoning By-law 1997-0184 was a major component of the East Bayfront initiative. With respect to the Olympic bid, City staff have had preliminary discussions with the Olympic bid team (TO-bid) and will be meeting to discuss this matter further.

 (b)A big box retail store is not an appropriate use for the properties at 429 Lake Shore Boulevard East and 324 Cherry Street

 East Bayfront Zoning By-law 1997-0184 does not allow retail stores in excess of 4,500 square metres. Big box retail stores would only be permitted if City Council were to amend the Official Plan and Zoning By-law. Section 4 of this report outlines the land use policy and site planning issues related to the Home Depot's Official Plan Amendment and Zoning By-law Amendment applications for a big box retail store at 324 Cherry Street and 429 Lake Shore Boulevard East.

 (c)The City should encourage the Home Depot to consider a site near Lower Don Roadway and Commissioners Street

 In December 1995, TEDCO submitted an application to the former City of Toronto to amend the Official Plan to allow, amongst other uses, two big box retail stores on the west side of Lower Don Roadway and Commissioners Street. The two big box retail stores proposed were Price/Costco and Knob Hill Farms.

 At that time, TEDCO considered that such a development would be the catalyst needed to encourage new investment throughout the entire Port Industrial District. While never officially withdrawn, that application became inactive in April 1997, when the TEDCO Board of Directors asked its staff to reconsider whether such a development was the right land use to encourage new investment. The Official Plan Amendment application has not been reactivated.

 (2)Background and Planning Issues Related to the Home Depot=s Application

 (a)Background

The Home Depot Canada is seeking an amendment to the City of Toronto Part I Official Plan and Zoning By-law for a big box retail store totalling 9,940 square metres (107,000 square feet). Site Plan approval is also requested. The store will be located on 5.5 hectares (13.6 acres) of land in the East Bayfront. The existing I2 D3 zoning does not allow any retail store. Zoning By-law 1997-0184 (the East Bayfront Amendment) would permit one retail store to a maximum size of 4,500 square metres (48,400 square feet), per property.

 The Home Depot Canada is the registered owner of the .4 ha (1 acre) property at 429 Lake Shore Boulevard East and has an option to purchase the property at 324 Cherry Street, which is the balance of the 5.5 ha (13.6 acre) site. (see Map 1)

 As part of the Toronto waterfront, the site, and its surroundings, are one of the chief amenities of the City and region. The importance of the site is further magnified given its water's edge location. In February 1998, the general area surrounding the site was identified by the group advancing Toronto's 2008 Olympic bid as being a gateway location for infrastructure and environmental improvements associated with the Olympic initiative.

 (b)Official Plan Policies for Big Box Retail Stores

 Section 9.9 of the Part I Official Plan of the former City of Toronto identifies the importance of retail activity in the city and describes how this activity should be strengthened. In order to support this section of the Plan, there is a restriction on the amount of new retail floor space that may be constructed in most areas of the former City (Section 9.15). Official Plan Amendment No. 643, passed on August 29, 1994 establishes specific policies in the Part I Official Plan to prohibit big box retail stores.

 Despite OPA No. 643, big box retail stores have been permitted in the Old Stockyards District (OPA 63, passed on July 5, 1996). In order for a big box retail store to be permitted in the Stockyards District, the owner was required to apply for a rezoning, and in so doing, demonstrate that:

 (i)the impact of those uses on the economic viability and planned function of shopping districts, including retail strips, was assessed and is found not to have a negative impact;

 (ii)the capacity of the existing road and transportation systems was assessed and was found to be adequate;

 (iii)the impact of such uses on adjacent residential and industrial uses was assessed and was found not to have a negative impact; and

 (iv)the established site plan and design guidelines for the respective areas and Council's general design guidelines for warehouse format stores were taken into consideration.

(c)Comments from the Community

 A public meeting was held in the community on May 26, 1998 at the Enoch Turner School House. Approximately 45 people were in attendance. The opinions from that meeting can be characterized as those who:

 (i)don't like big box retail stores from a city building perspective, that is, it is a suburban phenomenon and should not be allowed in or near the downtown;

 (ii)don't like big box retail stores because they feel it will lead to urban blight;

 (iii)like big box retail stores, but not at this location because it is an important waterfront site;

  (iv)don't think the site plan goes far enough to address environmental objectives for such an important waterfront site; and

 (iv)like big box retail stores and want to see the development proceed because it will create jobs in the community.

 Since the meeting, four letters from the public have been received, as well as one from the Toronto Bay Initiative and one from the Task Force to Bring Back the Don. City staff have also attended a meeting of the Old Cabbagetown BIA and another with hardware merchants. The opinions heard at those meetings were similar to those cited above.

 (d)Impact on the Economic Viability of Existing Shopping Districts and Retail Strips

 At its meeting on June 24 and 25, 1998, Toronto Community Council requested the Commissioner of Economic Development, Culture and Tourism and the Commissioner of Urban Planning and Development Services, in consultation with TABIA, to report on the cumulative impact of big box retail development on the former City of Toronto's retail strips. This section of the report addresses Toronto Community Council's request and City staff's response to the market impact study submitted by the Home Depot's consultant.

 As requested in the Preliminary Report, the applicant has submitted studies related to market impact. The market impact consultant for the applicant (John Winter and Associates Limited) concludes that:

 (i)in the area bounded by Bathurst Street, Lawrence Avenue, the Don Valley Parkway and the Toronto waterfront, including the area south of Gerrard Street to Lee Avenue there is a market for a 9,750 square metre retail store that sells home improvement type merchandise (HITM);

(ii)the greatest trade diversion of such a retail store, that is its competition, would be other Home Depots in the area;

 (iii)other merchants in the immediate area of the proposed Home Depot who sell HITM should not be dramatically affected because their stores serve a distinct Aconvenience@ function;

 (iv)there are a total of 63 such stores in the entire trade area;

 (v)the retail strips on which these stores are located also serve a distinct function and should not become blighted because of the proposed Home Depot;

 (vi)the Home Depot in the Stockyards opened in May, 1995 and all stores in the immediate area that were selling HITM then are still operating today; and

 (vii)not only is there no apparent change in hardware store retailing near the Stockyards Home Depot, there is no discernable change in the mix of stores and services in its general vicinity in the BIA's of Corso Italia, St. Clair Gardens and Junction Gardens.

 Upon review of these findings, City staff from Urban Planning and Development Services and Economic Development, Culture and Tourism, have concluded there are two unresolved market impact issues.

 First, the analysis completed by John Winter does not sufficiently detail or demonstrate the impact the proposal is likely to have on the area's retail strips or the downtown. John Winter based his analysis largely on the Retail Analysis & Impact Study commissioned by TEDCO for its Official Plan Amendment application at Lower Don Roadway and Commissioners Street. The analysis (completed by Coopers and Lybrand in November 1996) states that:

 "It should be noted that this study is not intended to represent a detailed impact study, but rather a general analysis of the impact of the Port Centre concept for Official Plan purposes. Based on the planning analysis work undertaken with Hemson Consulting Ltd. and discussions with City Planning Staff, we would recommend that a detailed market impact analysis be required for specific retailers over 8,000 square metres, as part of their rezoning application".

Coopers & Lybrand surveyed 400 households within an approximate ten kilometre radius of the site, and concluded that there was a sufficient market to support a certain amount of "Big Box" retail development in the Port Industrial District without detracting from the planned commercial structure. While a ten kilometre radius is a reasonable trade area boundary for this type of store, evidence from other locations suggests that the greatest density of sales will come from the surrounding neighbourhood. Hence, the competing stores and shopping districts closest to the site usually are the ones most likely to be affected.

 It is staff's opinion that Coopers & Lybrand did not survey enough households within a 5 kilometre radius of the site to permit conclusions to be drawn with a reasonable level of confidence about the shift in shopping behaviour likely to occur within the trade area if a Home Depot were developed at Lakeshore and Cherry Street. In addition, staff cannot determine how much of the HITM market would be available for existing stores and shopping districts.

 The second unresolved market issue concerns the impact of the proposed development on the future development of the surrounding area, and the cumulative impact that such future development could have on the former City of Toronto's retail strips and the downtown. Current planning policies for the East Bayfront encourage mixed industrial and commercial development to serve the city. Zoning By-law 1997-0184 implements this policy objective by broadening the development options available in the East Bayfront, but does not permit the development of a major retail anchor with a region-wide draw such as a Home Depot.

 Trends observed in other cities suggest that big box retail stores stimulate increased interest in developing retail uses on other sites in the immediate area, potentially leading to the unintended evolution of a major shopping destination which can, in turn, detract from the retail vibrancy of a downtown core, shopping centres or retail strips. Because it is not current planning policy to encourage the East Bayfront to become a major shopping destination, the implications of such a trend on the City's retail policies need to be assessed before City Council can consider an approval of this application.

 Therefore with respect to Toronto Community Council's request, the completion of a cumulative impact analysis would permit the City to assess the impact of big box retail stores on the former City of Toronto's commercial structure, and provide a better base of information on which to evaluate the extent to which additional big box retail store development can be permitted without risk to the vitality of the downtown and area retail strips.

 A full study to assess the impact on downtown and local area retail strips would include a large-scale survey of households within Toronto to determine the extent to which people are shopping in big box retail stores versus the downtown, shopping centres and retail strips, and the potential for the market to accommodate increased big box retail store development. Such a survey would cost a minimum of $100,000.

In the short term, it is therefore being recommended that a more limited study be undertaken using a data base on store locations that has been developed by the Centre for the Study of Commercial Activity. The analysis would track changes in store locations and vacancies since 1993, but would not identify reduced sales levels or profit margins. It might also prove feasible to combine this data with other information to estimate the approximate share of the market currently being captured by big box retail stores, and get a sense of the degree of vulnerability of other elements of the commercial structure to further sales transfers.

 TABIA have been consulted and are in agreement with the study approach being recommended. If approved, further discussions on terms of reference for the study will take place with TABIA.

 A maximum of $35,000 would be required to complete this more limited study. Funds are not available in the Operating Budgets of either the Urban Planning and Development Services or the Economic Development, Culture and Tourism Departments.

 City staff will be advising the OMB on August 4 and 5, 1998, that a full hearing of the Board should not take place until this research has been completed and evaluated in the context of this application and in the context of the City's land use policies for the East Bayfront and retail activity in general.

 (e)Impact on the Existing Road and Transportation Systems

 In the Preliminary Report on the application, two transportation related issues were identified: how access to the site from the existing signalized intersections would be accommodated; and the need to consider protecting a right-of-way across the properties for the potential future extension of Queen's Quay East to Cherry Street. City staff have also asked the applicant to ensure that the design of any improvements would make the streets safe for pedestrians, cyclists and motor vehicles.

 The applicant=s transportation consultant (BA Group) has presented several options to change the geometry and operations of the two signalized intersections abutting the site. The most recent intersection geometry and signal operations are generally acceptable to City staff. City staff and the applicant will enter more detailed discussions in order to ensure that the streets are designed in such a way as to be safe for pedestrians and cyclists. The applicant will be required to pay the full cost of all transportation related improvements.

 Between 1989 and 1992, staff from the former City of Toronto undertook a number of studies that looked at alternative street alignments for Queens Quay East through the East Bayfront. Several of the alignments would have extended east across the Parliament Street Slip and through the site. This proposed extension of Queen's Quay East has not been pursued. The applicant's current site plan proposes this area as a 38 metre wide water's edge promenade, including an extension of the Martin Goodman Trail. Such a use advances several Official Plan objectives related to the waterfront and public access to the water's edge.

(f)Impact on Adjacent Industrial and Commercial Uses

The introduction of a big box retail store into the East Bayfront will impact on adjacent land uses. As noted in subsection 2(d) of this report, trends observed in other cities suggest that big box retail stores stimulate increased interest in developing retail uses on other sites in the immediate area, potentially leading to the unintended evolution of a major shopping destination. The applicant's land use planning consultant (Dillon Consulting) supports that observation in its conclusions below:

 (i)the development potential of the subject properties for most land uses is constrained because of excessive noise from the Gardiner Expressway and the rail sorting yards, soil contamination and to a lesser degree active industrial uses in East Bayfront and the Port Industrial District;

 (ii) a large retail store could overcome these constraints;

 (iii)adjacent properties will largely benefit from the improvements;

 (iv)the use is compatible with surrounding uses; and

 (v)the use could trigger a market response to the adjacent properties to the west at 333 and 351 Lake Shore Boulevard East.

 Based on the results of the economic impact study recommended in this report, City staff will have to determine what measures should be taken to either accommodate requests for similar applications on abutting lands, or conversely, develop policies prohibiting any further big box retail development.

 (g)Site Planning and Urban Design

 The applicant=s urban design consultant (Sterling Finlayson Architects) undertook a study to determine how the development would conform with the former Toronto City Council's Design Guidelines for Big Box Retailing and an identification of how the development would meet City Council's objectives regarding water's edge access. The six major sections of the site plan and urban design study were:

 (i)designation of a principal street frontage for the development;

 (ii)location of the majority of parking spaces on the site;

 (iii)location of loading spaces on the site;

 (iv)screening of parking and loading facilities from adjacent public spaces;

 (v)methods of public access to the inner harbour; and

(vi)water's edge landscaping proposals.

 In addition to being analysed in the context of the City's guidelines for big box retail stores, this development is also being analysed in the context of its prominent water=s edge location. As such, the applicant has been asked to address such issues as the long view of the development from the Inner Harbour, the relationship between the building and the water=s edge promenade, building elevations and landscape details. These matters are still being discussed with the applicant.

 (h)Impact on the Environment

 The nine principles for regenerating the waterfront as outlined by the Royal Commission on the Future of the Toronto Waterfront are clean, green, connected, open, accessible, useable, diverse, affordable and attractive. These principles, while not specifically identified in the Official Plan, are captured by policies for the Environment (Section 2) and the Waterfront (Section 14). City staff have asked the applicant to meet these principles by suggesting the following site improvements.

 (i)Storm Water Management

 Conventional storm water management practices in the city are designed to deal more with the quality, rather than the quantity, of stormwater discharged into the sewer system.

 This development, located on the waterfront at the mouth of the Don River and the Martin Goodman Trail/Waterfront Trail, presents a very good opportunity to implement best practices for stormwater management in an urban setting. The degraded water quality of the Don River is largely due to the effects of stormwater runoff. The fundamental principle that the applicant should apply to this site is to manage rainwater as a resource rather than a waste. In so doing, the applicant should examine: how the roof can be used to significantly reduce the quantity of roof runoff, including the creation of a "living roof" as discussed below; through the Site Specific Risk Assessment (SSRA) process for dealing with contaminated soils, take into account the flow of groundwater and local infiltrated rainwater through the soils; consider on-site treatment of all stormwater through natural processes; propose a means of removing oil and grit from parking lot runoff; consider porous alternatives to traditional asphalt paving which are environmentally and aesthetically more appropriate; propose ways of storing site runoff on site for later use as irrigation water on site and in so doing, provide an opportunity to demonstrate stormwater gardens, and in partnership with the City, a residential/commercial landscaping alternative. These stormwater management practices are under discussion with the applicant

 (ii)Living Roof Demonstration

A living roof is made up of selected, hardy plants which are planted in about 150mm (6 inches) of soil on a building roof. These plants replace a traditional tar roof treatment with plants which produce oxygen and are much cooler than a traditional roof. In addition, the living roof absorbs water and the water not used by the plants is released much more slowly into the storm water system. The roof also acts as an insulating layer to the building and helps absorb noise. A living roof has recently been installed over the roof of the new Mountain Equipment

Co-op store on King Street West.

 The Home Depot is being asked to install a living roof over the roof of its store. The details of this request are being discussed with the applicant.

 (iii)Tree Canopy Throughout the Entire Site

 City Parks staff, in a draft report to the Declaration on the Environment Implementation Task Force in 1993, identified that the former City of Toronto=s waterfront lands averaged only 3% tree canopy cover compared with an average 20-25% for the City overall. The environmental impacts of insufficient tree canopy cover are felt in many ways, but are most notable in air quality and global warming.

 The applicant can significantly increase the amount of tree canopy on the site if trees are planted in the parking lot. City staff are not concerned if parking spaces are lost because parking supply on big box retail sites often exceeds actual demand. The details of the landscaping of the site, including increasing the tree canopy, are being discussed with the applicant.

(iv)Water's Edge Promenade

 The proposed water's edge promenade will be able to accommodate a number of open space, habitat and recreational functions. Discussions are underway with Parks Planning staff from Economic Development, Culture and Tourism to consider the dedication of approximately 30 metres of the promenade to the City. The Task Force to Bring Back the Don has recently requested a wider water's edge corridor (minimum 50m) with an ecologically appropriate landscape treatment.

 No matter who retains ownership of the water's edge promenade, the applicant will be required to contribute money towards improvements to the satisfaction of City Council. Details of the width, design and implementation of the water's edge promenade are being discussed with the applicant.

 Conclusions:

 This report responds to the letter from Nicholas T. Macos, responds to Toronto Community Council=s request regarding the economic impact of big box retail development, and updates City Council on the status and issues regarding the Home Depot Official Plan and Zoning By-law Amendment applications. The report recommends that funding in an amount up to $35,000 be allocated to the operating budget of Economic Development, Culture and Tourism, if Council wishes to proceed with a research study of the cumulative impact of big box retail on the Toronto Community's retail strips.

 Contact Name:

 Blair Martin

Telephone 416 392-1317

Fax 416 392-1330

e-mail: bmartin@city.toronto.on.ca

 The Toronto Community Council reports, for the information of Council, having also had before it during consideration of the foregoing matter, the following communications, and a copy thereof is on file in the office of the City Clerk:

 -(July 6, 1998) from the City Clerk;

-(June 23, 1998) from Nicholas T. Macos;

-(July 8, 1998) from Ms. Joanna Kidd and Ms. Leslie Woo, Toronto Bay Initiative;

-(July 21, 1998) from Mr. Christopher J. Williams, Aird & Berlis; and

-(July 15, 1998) from Ms. Joice Guspie, Old Cabbagetown BIA.

 The following persons appeared before the Toronto Community Council in connection with the foregoing matter:

 -Mr. Paul Dineen, Chair, Old Cabbagetown Business Improvement Area;

-Mr. Dalton C. Shipway, Chair, Watershed=s United;

-Ms. Marilyn Roy, Toronto Bay Initiative;

-Mr. Christopher J. Williams, Aird and Berlis, Barristers and Solicitors;

-Mr. Nicholas T. Macos, Morrison, Brown, Sosnovitch, Barristers and Solicitors;

-Mr. Tim Bermingham, Blake, Cassels, Barristers and Solicitors;

-Mr. Neil Robinson, Toronto, Ontario; and

-Mr. Steven Longo, Goodman and Carr, Barristers and Solicitors.