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AGENDA - Special Council - 20130430PUBLIC RELEASE April 26, 2013 TOWN OF AURORA SPECIAL COUNCIL MEETING AGENDA Tuesday, April 30, 2013 7 p.m. Council Chambers I DECLARATION OF PECUNIARY INTEREST AND GENERAL NATURE THEREOF II APPROVAL OF THE AGENDA RECOMMENDED: THAT the agenda as circulated by the Customer and Legislative Services Department be approved. III DELEGATIONS IV CONSIDERATION OF BUSINESS FOR WHICH NOTICE WAS GIVEN V READING OF BY-LAWS RECOMMENDED: THAT the following by-law be given first, second, and third readings and enacted: 5508-13 BEING A BY-LAW to Confirm Actions by Council pg. 163 Resulting from Special Council Meeting on April 30, 2013 VI ADJOURNMENT Special Council Meeting Agenda Tuesday, April 30, 2013 Page 2 of 7 AGENDA ITEMS (Deferred from Council meeting of April 23, 2013 – Item 1(1)) 1. General Committee Meeting Report of April 16, 2013 PR13-021 – Skateboard Park Options pg. 1 RECOMMENDED: THAT report PR13-021 be received; and THAT Council provide staff with an upset limit for design and construction of a skateboard park outside of the Aurora Family Leisure Complex (AFLC). (Deferred from Council meeting of April 23, 2013 – Item 1(3)) 2. General Committee Meeting Report of April 16, 2013 PR13-023 – Award of Tender PRS2013-14 for the Provision of pg. 22 Landscape Grounds Maintenance Services on Municipal Property at Various Locations in the Town of Aurora RECOMMENDED: THAT report PR13-023 be received; and THAT Tender PRS2013-14 for Landscape Maintenance at Various Locations in the Town Of Aurora, for one year ending December 31, 2013 with an upset limit of $62,456.36 (with the option to renew for an additional two, one-year periods), be awarded to Municipal Maintenance Inc.; and THAT Council authorize the Director to renew Tender PRS2013-14 in accordance with this report for an additional two, one-year periods, pending an annual analysis and satisfactory performance review by the Director; and THAT the Mayor and Town Clerk be authorized to execute the Agreement, including any and all documents and ancillary agreements required to give effect to same. Special Council Meeting Agenda Tuesday, April 30, 2013 Page 3 of 7 (Deferred from Council meeting of April 23, 2013 – Item 1(4)) 3. General Committee Meeting Report of April 16, 2013 CAO13-009 – Supplementary Unemployment Benefit pg. 28 Amendments to Policy #17 – Pregnancy and Parental Leave RECOMMENDED: THAT report CAO13-009 be received; and THAT Council approve the revision of Policy #17 – Pregnancy and Parental Leave, as recommended in this report and attached as Attachment #1, including the payment of Supplementary Unemployment Benefits. (Deferred from Council meeting of April 23, 2013 – Item 1(14)) 4. General Committee Meeting Report of April 16, 2013 Memorandum from the Director of Planning and Development Services pg. 37 Re: Revised Elevation Drawings, Planning Report No. PL12-043 Applications to Amend the Official Plan and Zoning By-law Perwick Investments Limited, Files: D09-03-05 and D14-16-05 RECOMMENDED: THAT the memorandum regarding Revised Elevation Drawings, Planning Report No. PL12-043, for the Perwick Investments Limited proposal be received; and THAT the following recommendations outlined in the February 5, 2013 Memorandum be adopted:  THAT Commercial School use be removed from the list of Shopping Centre Commercial (C4) Exception Zone permitted uses outlined in Report PL12-043; and  THAT Retail and Convenience Retail Uses be permitted provided that the combined floor area of all retail uses does not exceed forty percent (40%) of the total commercial floor area; and  THAT Application to Amend the Official Plan File: D09-03-05 be approved, to redesignate the subject lands from “Aurora Promenade General” to “Aurora Promenade General Special” to permit site specific development standards to facilitate a one storey 1,255m2 (13,509ft2) multi-unit retail plaza; and Special Council Meeting Agenda Tuesday, April 30, 2013 Page 4 of 7  THAT Application to Amend the Zoning By-law File: D14-16-05 be approved, to rezone the subject lands from “Office Commercial (C6) Zone” to a site specific “Shopping Centre Commercial (C4) Exception Zone” to permit a one storey 1,255m2 (13,509ft2) multi-unit retail plaza; and  THAT by-laws to adopt the Official Plan Amendment and implementing zoning be presented at a future Council Meeting for enactment. (Deferred from Council meeting of April 23, 2013 – Item 1(17)) 5. General Committee Meeting Report of April 16, 2013 PR13-017 – Diamond Jubilee Park – Follow-up Report pg. 62 RECOMMENDED: THAT report PR13-017 be received; and THAT Council consider renaming an existing municipal Park “Diamond Jubilee Park”; and THAT a park to be renamed be selected from the candidate parks contained in this report; and THAT staff notify all Aurora Recipients of the Queens Diamond Jubilee Medal of the proposed addition of their name to the Park signage. (Deferred from Council meeting of April 23, 2013 – Item 1(18)) 6. General Committee Meeting Report of April 16, 2013 LGL13-004 – Strategic Lawsuits Against Public Participation (SLAPP) pg. 73 RECOMMENDED: THAT report LGL13-004 be received; and THAT the Mayor, on behalf of Council, advocate and write a letter to The Hon. Kathleen Wynne, Premier of Ontario, and to The Hon. John Gerretson, Attorney General of Ontario, urging them to bring forward legislation to implement the recommendations of the Anti-SLAPP Advisory Panel; and THAT the Mayor also send a copy of the letter to the mayors and councils of all other municipalities in the Greater Toronto Area requesting that they write to the Premier of Ontario and the Attorney General in support of the contents of the letter. Special Council Meeting Agenda Tuesday, April 30, 2013 Page 5 of 7 (Deferred from Council meeting of April 23, 2013 – Item 1(21)) 7. General Committee Meeting Report of April 16, 2013 PR13-018 – Award of Request for Proposal No. PRS2013-04 – For the pg. 130 Supply, Delivery and Maintenance of Automated Teller Machines (ATMs) at the Stronach Aurora Recreation Complex (SARC) and the Aurora Community Centre (ACC) RECOMMENDED: THAT report PR13-018 be received; and THAT Request for Proposal No. PRS2013-04 – For the Supply, Delivery and Maintenance of Automated Teller Machines (ATMs) at the Stronach Aurora Recreation Complex (SARC) and the Aurora Community Centre (ACC) be awarded to Access Cash General Partnership (Access Cash); and THAT the Mayor and Town Clerk be authorized to execute the necessary Agreement, including any and all documents and ancillary agreements required to give effect to same. (Deferred from Council meeting of April 23, 2013 – Item 1(29)) 8. General Committee Meeting Report of April 16, 2013 PL13-024 – Simplified Development Agreement Execution pg. 134 2298276 Ontario Limited Lots 1, 2, & 15, Plan 65M-2806 and Lots 102 & 103, Plan 65M-2805 115, 118 & 119 Stemmle Drive and 126 & 130 Brookeview Drive Minor Variance File Numbers: D13-(30-34)-11 RECOMMENDED: THAT report PL13-024 be received; and THAT the Mayor and Town Clerk be authorized to execute the simplified development agreement, including any and all documents and ancillary agreements required to give effect to same. (Deferred from Council meeting of April 23, 2013 – Item 1(30)) 9. General Committee Meeting Report of April 16, 2013 PL13-028 – Simplified Development Agreement Execution pg. 142 Jacqueline Lee Kubica Plan 65M-2725, Part Lot 9 19 Ing Court Minor Variance File Number: D13-(26A&B)-12 Special Council Meeting Agenda Tuesday, April 30, 2013 Page 6 of 7 RECOMMENDED: THAT report PL13-028 be received; and THAT the Mayor and Town Clerk be authorized to execute the simplified development agreement, including any and all documents and ancillary areements required to give effect to same. (Deferred from Council meeting of April 23, 2013 – Item 1(31)) 10. General Committee Meeting Report of April 16, 2013 PL13-029 – Simplified Development Agreement Execution pg. 150 Wayne Hinrichs and Stacey Lewis Lot 36 and Part Block A, Plan M-1582; Part 7, 65R-20000 40 Steeplechase Avenue Minor Variance File Number: D13-(11A&B)-12 RECOMMENDED: THAT report PL13-029 be received; and THAT the Mayor and Town Clerk be authorized to execute the simplified development agreement, including any and all documents and ancillary agreements required to give effect to same. (Deferred from Council meeting of April 23, 2013 – Section VI - Item 1) General Committee Meeting Report of April 16, 2013 11. AAC13-05 – Accessibility Advisory Committee Report pg. 158 April 3, 2013 RECOMMENDED: THAT report AAC13-05 be received; and THAT Council adopt the following Accessibility Advisory Committee recommendations from the meeting of April 3, 2013: Delegation (a) Kim McKinnon, representing Concerned Citizens for Accessibility and Mobility, and Community Legal Clinic of York Region Re: Introduction of Organizations and Disability Awareness Week Event THAT Council consider endorsing the Mobility Maze event to be held at the Aurora Community Centre on Wednesday, June 5, 2013. Special Council Meeting Agenda Tuesday, April 30, 2013 Page 7 of 7 (1) Memorandum from the Accessibility Advisor Re: “On-Demand” Accessible Taxis THAT staff be directed to add information to the Town’s website regarding “on-demand” accessible taxicabs toward educating residents on accessible transportation. (4) Correspondence from the Planner Re: Application for Site Plan Approval – Request for Comments (Submission #1) St. Andrew’s College 15800 Yonge Street, Part 3 of Lot 84, Conc. 1, 64R-1463 File Number: D11-15-12 THAT the following comments be forwarded to the Planner as suggestions to: 1. Consider adding accessible parking closer to the front entrance of the building without having to cross a vehicular traffic path; 2. Ensure that all washrooms on the main floor and second floor are accessible with automatic door openers and appropriate barrier-free access; and 3. Ensure that the fire alarm system includes both audible and visual warning signals. (7) Correspondence from the Accessibility Directorate of Ontario Re: Accessibility Advisory Committee Forums 2013 THAT staff be directed to investigate further registration information and details and advise the Committee regarding the Toronto Forum being held on May 22 with respect to attendance by Committee members. 12. Update from Warren Mar, Director of Legal Services/Town Solicitor Re: Bell Canada Telecommunications Tower at 14820 Bathurst Street King Township* *Information to be provided. TOWN OF AURORA ADDITIONAL ITEMS FOR SPECIAL COUNCIL MEETING Tuesday, April 30, 2013 7 p.m. Council Chambers Additional Information Re: Item 12 – LGL13-006 – Bell Canada Wireless Telecommunication Tower 14820 Bathurst Street, Township of King RECOMMENDED: THAT Council resolve into a General Committee Closed Session to consider:  The receiving of advice that is subject to solicitor-client privilege, including communications necessary for that purpose; Re: Item 12 LGL13-006 – Bell Canada Wireless Telecommunication Tower 14820 Bathurst Street, Township of King TOWN OF AURORA ADDITIONAL ITEMS (REVISED) FOR SPECIAL COUNCIL MEETING Tuesday, April 30, 2013 7 p.m. Council Chambers ll APPROVAL OF THE AGENDA Moved by Councillor Buck Seconded by Councillor Thompson THAT the agenda as circulated by the Customer and Legislative Services Department, with the following addition, be approved: Additional Information — Re: Item 12 — LGL13-006 — Bell Canada Wireless Telecommunication Tower, 14820 Bathurst Street, Township of King CARRIED Moved by Councillor Buck Seconded by Councillor Gallo THAT solicitor -client privilege be waived to release confidential report LGL13-006 to the general public. CARRIED TOWN OF AURORA COUNCIL REPORT CONFIDENTIAL CLOSED SESSION REPORT No. LGL13-006 SUBJECT: Bell Canada Wireless Telecommunication Tower 14820 Bathurst Street, Township of King FROM: Warren Mar, Director of Legal Services/Town Solicitor DATE: April30, 2013 THAT Council receive Report No. LGL13-006 for information. PURPOSE OF THE REPORT The purpose of this report is to respond to Council's direction at its meeting of April 24, 2013, "that staff be directed to seek a stop work injunction against the completion of the tower for a length of time sufficient to allow the Town, citizens, and Bell Canada to review options with regards to the tower...". In addition, this report provides an update on the response from Bell Canada regarding the concerns of residents and the Town about the location and height of the cell phone tower. BACKGROUND A summary of the relevant events to date can be found in the attached legal opinion from Bruce Engel[, Partner at WeirFoulds LLP, under the heading "Public Consultation" on pages 3 to 4. COMMENTS Legal Opinion from WeirFoulds LLP As noted above, attached to this report is the legal opinion from Mr. Engell, Partner at WeirFoulds LLP and an experienced litigation lawyer. In summary, Mr. Engell states: "... the Town would have tremendous difficulty putting forward an arguable case Confidential Closed Session April 30, 2013 - 2 - Report No. LGL13-006 for an interlocutory injunction in the circumstances of this matter. If the Town were able to put forward an arguable case, it is our opinion that the Town has virtually no chance of success in obtaining the interlocutory injunction it is considering:" In coming to this conclusion, Mr. Engell also noted that, the prejudice caused by that letter [the 'no comment' email from a Town planner] would not be materially different from silence in the face of notice having been served on the Town. In addition, given that the entire exercise is set up to render municipalities close to powerless on these issues, the harm caused by the letter is mitigated — had the Town objected, the outcome would most likely have been identical" This latter point speaks to the idea that the consultation process with regards to the installation of cell phone towers is actually akin to a question and answer session. According to Industry Canada Client Procedures Circular CPC-2-0-03, proponents are required to serve notice to nearby residents (three times the tower height from the tower location according to Industry Canada) and respond to certain questions. This Industry Canada procedure does not require proponents to reply to questions regarding, for example, disputes about the proponent's service; effects on property values or municipal taxes; or questions regarding whether Health Canada's Safety Code 6, local by-laws, local protocols, or the processes mandated by Industry Canada are valid or should be reformed. l Proponents such as Bell Canada do not have to adhere to the wishes of local municipalities or residents unless they are willing to do so, or unless they agree to do so after Industry Canada intervenes in the impasse process in the face of objections. Ultimately, if the technical justification can be made for a tower, then the process established by Industry Canada ensures that such a justification can always overrule local concerns, since municipalities do not have a substantive role to play in the installation of cell phone towers. With regards to the cost of launching an interlocutory injunction, Mr. Engell notes that, "The costs are difficult to estimate at the outset since the procedures that will be involved are not definite (cross-examinations, adjoumments and so on). However, the Town would realistically be looking at $50,000 to $100,000 for an interlocutory injunction, and that does not include paying any award of costs to the respondents, should the Town be unsuccessful." This amount is consistent with having a minimum of three associates at around $250-$300/hour working together with one partner at $5507$600/hour, plus disbursements and other time spent by other lawyers who may be called upon to give specific advice as the need arises over the course of 2-3 intense weeks of preparation, plus the r) Confidential Closed Session April 30, 2013 - 3 - Report No. LGL13-006 submission of documents, cross-examinations, and attendance at the injunction hearing. Accordingly, Mr. Engell's estimate of $50,000 to $100,000 for an interlocutory injunction in this matter is entirely reasonable and appropriate given the circumstances. The end of Mr. Engell's opinion does note that Industry Canada has a dispute .resolution process where an impasse is reached and there is a formal objection from. a stakeholder other than the general public. While the outcome may not change, and Industry Canada may deny the request for dispute resolution at this stage, it may be an option for the Town to pursue. According to Industry Canada Client Procedures Circular CPC-2-0-03: "Upon receipt of a written request, from a stakeholder other than the general public, asking for Departmental intervention concerning a reasonable and relevant concern, the Department may request that all involved parties provide and share all relevant information. The Department may also gather or obtain other relevant information and request that parties provide any further submissions if applicable. The Department will, based on the information provided, either. • make a final decision on the issue(s) in question, and advise the parties of its decision; or • suggest the parties enter into an alternate dispute resolution process in order to come to a final decision. Should the parties be unable to reach a mutually agreeable solution, either party may request that the Department make a final decision. Upon resolution of the issue under dispute, the proponent is to continue with the process contained within this document as required." Response from Bell Canada Further to the direction of Council, on April 25 the Mayor, Mr. Garbe, Mr. Ramunno, and I spoke with lawyers and representatives for Bell Canada and Bell Mobility, including Matthew Milligan, Real Estate and Municipal Relations Advisor for Bell Mobility. The written response from Mr. Milligan is attached to this report, together with the site selection report from Proliferate Consulting Group Inc. C > (" PCG') on behalf of Bell. Confidential Closed Session April 30, 2013 - 4 - Report No. LGL13-006 In summary, at the teleconference meeting, Bell stated that King Township owns the notification process in accordance with its protocol, and Bell's obligation is to generally follow the protocol of the municipality in which the infrastructure is located. A site investigation was completed by PCG which concluded that no co - location was feasible and the tower was required at the 60 metre height to meet demand. Bell was not asking for, nor is it now interested in, comments from the Town. As part of the notification process, and since it is neither the local authority with jurisdiction nor an approval authority, the Town was simply being advised in the notice that an open house meeting was being held to explain the tower installation. Bell acknowledged that the protocol for notice followed King's protocol and ended at the municipal boundary. The Industry Canada standard (three times the height of the tower, from the tower location) was applied to Aurora, resulting in about ten residents receiving notices. Town staff asserted that PCG misrepresented to King that the notice limit of 250 metres from the tower location was applied to both King and Aurora. In reply, Bell stated that they were not aware of this representation, but regardless of what was stated by PCG, it did follow the applicable standard set out by Industry Canada and there was no technical violation of the notification process. In the end, however, Bell's position is that it has no plans to alter the structure of the tower in height, massing or location. According to Bell, its research has found that the design of the tower has the least impact from visual and aesthetics perspectives. Officially, Bell did offer to enhance the screening around the ground -related infrastructure and add landscaping along Bathurst Street. Town staff will continue to work with Bell Canada and Industry Canada to see what else can be done to mitigate the visual impact of the tower. LINK TO STRATEGIC PLAN None. ALTERNATIVE(S) TO THE RECOMMENDATIONS 1. THAT Town staff formally request Industry Canada to begin the dispute resolution process to address the Town's objection to the size and location of the Bell Canada cell phone tower. (l Confidential Closed Session April 30, 2013 - 5 - Report No. LGL13-006 FINANCIAL IMPLICATIONS None. Should the Town formally request that Industry Canada begin the dispute. resolution process, the matter will be handled internally by Town staff. PREVIOUS REPORTS There are no previous written reports on this matter. A verbal report was presented to Council regarding this matter on April 24, 2013. CONCLUSIONS According to the Town's external lawyer, an interlocutory injunction to cease Bell's use and operation of the cell phone tower will not be successful In the absence of jurisdiction in this matter, and since the process is not one that allows municipalities to have a formal substantive input on the location of cell phone towers, the Town is left with no realistic legal options other than continuing to lobby Bell Canada and Industry Canada regarding the location and size of the tower. Even though the tower is already built, the Town may request to begin the i formal dispute resolution process with Industry Canada in an attempt to address the concerns of residents. ATTACHMENTS Attachment #1: Legal Opinion from Bruce Engel[, WeirFoulds LLP, dated April 29, 2013. Attachment #2: Letter from Matthew Milligan, Bell Mobility, dated April 29, 2013. Attachment #3: PCG Site Location Report to the Township of King, dated February 13, 2012. PRE -SUBMISSION REVIEW Neil Garbe; Chief Administrative Officer Prepared by. Warren Mar, Director of Legal Services/Town Solicitor uUav�. Nl�. Warren Mar, Director of Legal Services/Town Solicitor Barristers &Solicitors ATTACHMENT 1 WeirFouldsLLP April 29, 2013 VIA E-MAIL Bruce H. Engell T:416-947-5081 bengell@weirfoulds.com File 08337.00001 Mr. Warren Mar Town Solicitor Town of Aurora 100 John West Way, Box 1000 Aurora, ON L4G 6J1 Dear Mr. Mar: Re: Legal Opinion Regarding the Commencement of an Interlocutory Injunction to Halt the Operation and Use of a Bell Canada Cell Phone Tower 14820 Bathurst Street, Township of King, Ontario You have asked for our opinion on a number of issues relating to the potential to seek an interlocutory injunction to halt further construction on and use of a cell phone tower. Conclusion Our overall summary conclusion is that the Town would have tremendous difficulty putting forward an arguable case for an interlocutory injunction in the circumstances of this matter. If the Town were able to put forward an arguable Case, it is our opinion that the Town has virtually no chance of success in obtaining the interlocutory injunction it is considering. The detailed answers to the specific questions you have posed are set out at the end of this letter. Context As a matter of the constitutional division of powers between the federal government and the provincial ones, cell phone towers fall under federal jurisdiction as an integral component of telecommunications. As a result, the Province of Ontario does not have the authority to enact legislation relating to them. The Town, like all municipalities in Ontario, is a creature of the Province — it only has the authority which the Province has chosen to give to it. Since the Province has no authority over cell phone towers, it is also unable to give the Town, or any other municipality, any authority to address cell phone towers, including their size, location or other aspects relating to their installation and use.. T:416-365-1110 F:416365-1876 4100 - 66 Wellington Street West, PO Box 35, Toronto -Dominion Centre, Toronto, Ontario, Canada. M5K 1 B7 w .weirfoulds.com Barristers & Solicitors WeirFouldsuP The only regulatory framework governing where .cell phone towers can get erected is the framework that emanates from the federal level. That framework is dealt with by Industry Canada, with licenses issued to cell phone service providers on an overall basis — there is no specific permit or license granted for each cell phone tower that a service provider wishes to build. Instead, Industry Canada has set up two regulatory approaches: a safety standard and a public consultation protocol. The public safety standard is referred to as Safety Code 6 by Health Canada. Industry Canada maintains, "that there is no scientific or medical evidence that a person will experience adverse health effects from exposure to radio frequency fields, provided that the installation complies with Safety Code 6. The public consultation protocol (Client Procedures Circular CPC-2-0-03, Issue 4, "Radiocommunications and Broadcasting Antenna Systems") first addresses alternatives to the construction of'a new cell phone tower. The protocol requires sharing of existing cell towers were possible and then the location of new facilities on existing buildings and structures. Once those alternatives have been explored, the protocol addresses the public consultation process in relation to the construction of a new cell phone tower. Industry Canada encourages local municipal protocols for public consultation but also provides a default protocol in the event that a local municipality has not set up one of its own. In this instance, the Township of King (the "Township") and the Town of Aurora (the "Town") both have their own protocols in place. Since the cell phone tower in question is in the Township, Bell followed the protocol of the Township and not the Town. Industry Canada's Circular notes "conclusion of local consultation may include such steps as obtainingfinal concurrence for the proposal via the relevant committee, a letter or report acknowledging that the relevant municipal process or other requirements have been satisfied, or other valid indication, such as the minutes of a town council meeting indicating —approval. Compliance with informal city staff procedures... will not normally be sufficient" One further point of note — Industry Canada's procedure includes a dispute resolution process where parties have reached an impasse: "Upon receipt of a written request, from a stakeholder other than the general public, asking for Departmental intervention concerning a reasonable and relevant concern, the Department may request that all involved parties provide and share all relevant information... The Department will make a final decision." The mechanism is referred to in the Township's protocol and the Town's protocol. 2 Barristers & Solicitors Weir o Ulds' np Public Consultation As we understand it, the public consultation process in this instance included the following: 1. On May 11, 2012, the Town was notified via email to its Planning Department and to the Town Clerk that Bell was proposing to place a 60 metre cell phone tower at 14820 Bathurst St in the Township, about 25 metres from the boundary between the Township and the Town. The notice also informed the Town of an open house on June 12, 2012, to provide further information and receive comments. 2. Notice of that June 12, 2012 open house was also given to at least 10 residences in the Town. 3. On May 15, 2012, a Planner for the Town responded to the email acknowledging receipt of the notice stating, "[tjhe Town of Aurora has no comment on the proposal ° The proposal was not forwarded to Council and Council took no position on it. There is no indication of any further notice given to the Town regarding the proposal. 4. The June 12, 2012 open house was attended by seven members of the public, including three Town residents. However, due to an illness of Bell's consultant, they were told the meeting would not proceed, their names and addresses were taken down , and they were advised that everyone previously notified would be re -notified of a new date. 5. Apparently, a new notice was sent out to the same people who were sent the notice of the June meeting. This notification was for a new public meeting date of August 14, 2012. The Town did not receive this notice. Only two members of the public attended. 6. In a letter to Township Planning staff dated August 20, 2012, Bell's consultant confirmed that the Township's protocol requirements were met, including the fact that all Township and Town residents within a distance of 250 metres from the tower location were notified (in accordance with the Township's protocol for notification distance). Also in accordance with the Township's protocol, a newspaper ad was run in the local Township paper and a sign was posted at the property. No ad was run in a Town paper since the tower was located in the Township and its protocol applied. The Township's protocol does not call for an ad to be run in a neighbouring jurisdiction's local newspaper even in instances where the notification area crosses municipal boundaries. 7. On October 15, 2012, the Township's Committee of the Whole approved a recommendation to inform Industry Canada that the Township's protocol was complied with. (^1 Banisters & Solicitors - - I I Vii FO 1 ldsu-p This was adopted by its Council on October 29. On November 19, 2012, Township Planning staff informed Industry Canada that the Township's protocol was complied with. 8. Over the past several weeks, Bell completed the construction and installation of the tower. According to Bell, the tower is not yet active (transmitting), but will be soon. 9. Once construction was underway and completed, Town residents in the subdivision on the east side of Bathurst St. complained about the tower. These Town residents include those who allegedly did not receive notification due to the fact that they were supposedly outside of the notification area. The complaints about the tower are mainly about its size and height (60m), and secondarily about the health impacts of such a tower located close to a residential subdivision. There are general complaints that proper notice was not served and that Town Planning staff did not properly handle the notice received (e.g., the response of .no comment" was not appropriate, notice should have been placed in an Aurora paper, Council should have been notified, and the notification area should have been wider). 10. The residents' concerns culminated in the matter being addressed at Council's regular meeting on April 23, 2013 and at a special Council meeting on April 24, 2013. 11. As part of that special Council meeting, Council instructed staff to seek further information about pursuing an interlocutory injunction to prevent Bell from activating and using the cell phone tower until such time as the Town, residents, and Bell can work together to review options about the tower. Interlocutory Injunctions An interlocutory injunction is an order to restrain or require certain action pending the determination by the Court of a proceeding that is before the Court. It is designed to preserve the status quo until the trial, or other hearing, can be held. To obtain an interlocutory injunction, the Town would have to establish each of the following: (a) . that it has an good case for obtaining relief from the Court after the trial or final hearing .("arguable case"); (b) that the final relief in question would include injunctive relief ("permanent injunction"); (c) that if an interlocutory injunction were not granted, the Town would suffer irreparable harm ("irreparable harm"); and 4 Barristers & Solicitors - - 1 ► Vii 1 O U JdSLLP (d) that the balance of convenience favours granting the injunction the Town seeks ("balance of convenience"). Arguable Case In order to seek an interlocutory injunction, the Town would first have to commence proceedings seeking relief, and seeking the interlocutory injunction on an interim basis to preserve the _Town's position until the matter can be heard on its merit. As a result, an interlocutory injunction can only be in aid of a claim for more permanent relief — it is not a freestanding matter, and it is cannot be sought to preserve rights until something happens in which the Court is not .involved. in this instance, the Town cannot seek an interlocutory injunction to allow time for the Town, residents and Belli to work together to review options about the tower. In the circumstances, it is our opinion that the Town does not have an arguable case to seek relief after a trial. Essentially, Industry Canada has set up a consultation process that leaves municipalities powerless. While it does require a consultation process, and prefers that service providers not ruffle feathers if avoidable, it is clear that municipalities are not given any substantive role in determining if a tower is to be put in a certain location. 1 We also note that Industry Canada's procedures, and both the Township and Town's protocols provide a dispute resolution mechanism: Industry Canada will hear and finally determine any dispute that results in an impasse. Any claim by the Town will likely be met by the objection that the Town was obliged to bring the dispute to Industry Canada and that it failed to do so. A Court is likely to rely on that argumeni to rule that any proceedings by the Town are premature. We also have no doubt that if the Town brought the dispute to Industry Canada, that the final determination would be against the Town. There are a few procedural objections that might be identified and there are two substantive objections to the cell tower. Substantively there are objections to the visual impact of the 60 m tower and concerns about the safety of a cell tower near residential uses. As we understand it, the cell tower will transmit about 1% of the permissible level of electromagnetic radiation permitted under Safety Code 6. As a result, there is no credible basis for a health and safety objection. The concerns about visual impact are understandable, but in the context of cell phone towers, they would not attract any attention from Industry Canada or a judge. The policy framework 5 Barristers & solicitors WeirFouldsup provides that cell towers are necessary facilities and need to be located to order to provide comprehensive service. There are about 21 other cell towers in the Town.. In addition, you have advised that apparently Industry Canada records show'f or 2 cell towers being installed per Week in southern Ontario. Bell would also have provided Industry Canada with the required technical report and justification for the location and height of this tower. As a result, a court is unlikely to be convinced there is something unacceptable about constructing this particular tower. As a result, the most the Town could rely on are procedural irregularities in the consultation process. However, since there do not appear to be any substantive prohibitions on putting this tower in this location, it is our opinion that a court would not give much credence to any such irregularities. In respect of any procedural irregularities, it is our opinion that none of them rise to a level sufficient to base a legal proceeding to invalidate what was done. It is undisputed that the Town's Clerk and Planning Departments received notice of the proposal and of an open house to discuss it. This would give Bell the ability to argue, convincingly, that if the Town's Council did not get the opportunity to comment or object to the proposal, this was due entirely to the Town's own processes, and Bell cannot be saddled with any internal process issues at the Town. In the . end, whether Bell relied on an absence of response from the Town (after notice of the proposal was given), or on a specific response (such as that from the Town planner), Bell would be able to point to there being no objection from the Town, despite notice being given. Permanent Injunction Closely related to the first element we considered, there is a need to show that at the trial or hearing of the main proceeding, the Town would be entitled to seek a permanent order requiring work to cease on the tower, or even for its removal. In our view, the Town is unlikely to be able to put forward a claim for a permanent injunction in relation to this tower. Since the complaint is a procedural one, not a substantive one, then a court would be driven to ordering that the consultation process be undertaken afresh. Unfortunately, redoing the consultation process would not result in the cell tower being required to- be moved to a different location because there does not appear to be a substantive basis on which to argue that it cannot be put there. As a result, in our opinion, the Town would have great difficulty satisfying a judge hearing a motion for aninterlocutory injunction that the Town has an arguable case for a permanent injunction respecting this cell tower. Barristers & Solicitors WeirFouldsnp Irreparable Harm The Town would also have to satisfy a judge that unless further work on the cell tower is enjoined that the Town would suffer irreparable harm, that is, harm which cannot be compensated in damages. In our opinion there is no evidence of irreparable harm in this circumstance. The health and safety argument will not be successful, given the emission levels measured against Safety Code 6. Given the ubiquity of cell towers in Ontario, in our opinion that argument would go nowhere. The visual intrusion argument is undercut by the fact the tower has already been built — in our view it would not be possible to show that there is any harm, relating to visual impact, caused by making the tower operational compared to having it remain, but be inoperative. Certainly, any such harm would not rise to the level of irreparable harm. Balance of Convenience Essentially this element of the test weighs the impact on some parties of granting an injunction against the impact on other parties of not granting an injunction. Bell claims there is an area that is underserved in the absence of this cell tower and it appears to have already invested substantially all of the costs of putting this tower in place to remedy that deficiency. These factors would be weighed against the benefits that would accrue to the Town of granting the injunction. Given the discussion above respecting safety and visual impact, in our opinion, a court would find that on the facts of this matter, the balance of convenience favours Bell and accordingly no injunction would be available under this last component of the test. In addition, the Town could face a claim for damages should it turn out that it obtained an interlocutory injunction which in the end should not have been granted. It is unclear what business losses Bell could assert, but there is that risk of exposure for the Town. Specific Issues and Opinions 1. Does the May 15, 2012 response from a Town Planner prejudice the Town's position (or act as an estoppel), since this was construed as showing that the Tow_ n had no objection to the proposed tower? 7 Banisters & Solicitors V YeirFo1. ldsuP (a) The response would undoubtedly be used to resist any legal proceedings taken by the Town. However, the prejudice caused by that letter would not be materially different from silence in the face of notice having been served on the Town. In addition, given that the entire exercise is set up to render municipalities close to powerless on these issues, the harm caused by the letter is mitigated — had the Town objected, the outcome would most likely have been identical. 2. The lack of notification to the Town about the new August 14, 2012 meeting: Does this mean that Bell's consultant did not follow the Township protocol in this matter? Is this enough basis for the Town to request that the use of the tower stop until proper notification is made, or did the Town Planners "no comment" remove any requirement for further notice? (a) In our opinion, the structure of the Township's protocol does not require the Town to receive notice of the open house in August (nor of the prior one in June). Instead it required that the proposal be circulated to the Town and that Bell "provide confirmation of this consultation to the Township'. Bell would be able to point to the notice given to the Clerk and Planning Department as consultation. There is an argument that more than just the notice ought to have been provided to the Town, but in our opinion, that argument is unlikely to get very far in a court Proceeding. 3. Did Bell's consultant mislead the Township when it stated in its August 20, 2012 letter that all Township and Town residents within a distance of 250 metres from the tower location were notified (in accordance with the Township's protocol for notification distance). (a) It appears that this statement by Bell's consultant was incorrect. On the Township side notice was given to those 250 metres from the tower location, in accordance with the Township's protocol for notification distance. On the Town side, notice was only given to those within 180 metres of the tower location (being three times the height of the tower),, in accordance with Industry Canada requirements contained in Industry Canada Guidelines CPC-2-0-03. The Town's protocol requires notice to be given to residents that are within a radius of 120 metres or three times the tower height, whichever is greater, from the subject property (not the tower location). (b) However, it is our opinion that any complaint about a defect in that notice would have to be raised by a person other than the Town — it would have to be raised by a resident who did not get notice, but was within 250 metres and therefore maintains that they ought to have received notice. Nevertheless, given the Town's own protocol would only require notice within 180 metres, and Industry Canada's default is 180 metres, it would be very difficult for a resident or the Town to rely on this as a defect warranting judicial intervention. M Barristers & solicitors WeirFouldsup 4. What are the legal processes and requirements to be followed in order to obtain an interlocutory injunction in Federal Court? (a) If the Town had an arguable case for a permanent injunction (as addressed above) and was able to get over the hurdle of showing irreparable harm, then the Town would have to give notice to Bell, Industry Canada, and the landowner in order to minimize any argument about delay. It would then have to issue an originating process in the Federal Court setting out its claim. Presumably, the argument would be that Bell was in breach of the conditions of its licence because of defects in the consultation processes leading to the Township's sign - off on the tower location. (b) The Town would then need to prepare a notice of motion for an interlocutory injunction along with supporting affidavits setting out the events and documents in question. Once Bell and others had a chance to file responding materials, there could be cross-examinations on affidavits and then preparation of written arguments with supporting casebooks. 5. Relatedly, how long would it reasonably take to appear before a Federal Court judge in this matter and how much would you estimate it to cost? (a) Given the difficulty in coming up with an arguable case, it would likely take 2 or 3 intense weeks to prepare the necessary materials. However, depending on how the respondents choose to respond, the motion might not get heard for several months (also depending on the Court's schedule). Since this is not an emergency or urgent matter, it would be scheduled later in the docket in a busy court schedule. (b) The challenge in this circumstance would be to come up with sufficient grounds to make the motion credible at all. From what we have seen so far, there is no basis to proceed. (c) The costs are difficult to estimate at the outset since the procedures that will be involved are not definite (cross-examinations, adjournments and so on). However, the Town would realistically be looking at $50,000 to $100,000 for an interlocutory injunction, and that does not include paying any award of costs to the respondents, should the Town be unsuccessful. 6. What common law tests would have to be met by the Town in its arguments in favour of granting an interlocutory injunction? (a) The tests are noted earlier in this letter and explained in more detail herein. Barristers & Solicitors WeirFouldsnp 7. Is an interlocutory injunction an appropriate remedy in this situation, and what are the odds of success? What challenges would be faced by the Town in seeking an interlocutory injunction? (a) In our view, an interlocutory injunction is not an appropriate remedy in this situation and the Town would have virtually no chance at success. (b) In a nutshell, the significant hurdles that would be readily apparent to a judge are: under the federal regime, Bell can put up towers where it likes; the Town did not object .to the location; this tower has already been built; the outcome is most unlikely to be any different if the consultation process was done entirely over (and impeccably);, and the Town will suffer no objective harm, let alone irreparable harm. 8. What further action could the Town take to stop the use of the tower by Bell or to have the tower removed? (For example: An application to some federal tribunal governing Industry Canada? An application for judicial review of some type? An application to quash the Township's confirmatory by-law and decision that the Townships protocol was properly met?) (a) In our opinion, Industry Canada provides Bell with its licence with conditions.One of those conditions is to follow an appropriate consultation process before installinga new cell tower. Ultimately, ensuring appropriate community consultation has been undertaken is not the Township's responsibility, it is Bell's. As a result, we see no real value in seeking to quash the Township's decision. (b) The Town could try to the invoke Industry Canada's dispute resolution mechanism. This would allow all the relevant facts and arguments to be marshalled, but in a much less expensive manner - and without exposure to paying court costs to any respondents. The difficulty with beginning this process is that the tower is already built. In our view, there would be little chance of success in this forum, similar to the Town's chances in respect of a court challenge. An Industry Canada challenge might cause Bell to pause, for a time, the completion of the tower, in an effort by Bell and Industry Canada to demonstrate their responsiveness to municipal concerns_ However, any pause would be on the basis that Bell wishes to preserve goodwill and we cannot judge its eagerness to do so in this circumstance. As lawyers we enjoy challenging cases, but there' has to be something to work with. Unfortunately, in our opinion this situation is one where there is no credible basis for the Town to seek an interlocutory injunction in respect of a cell tower which has already been built. If you have any further questions, please let us know. W1 Banisters & Solicitors WeirFouldsLLp Yours truly, WeirFoulds LLP Bruce H. Engell BHEQnb 5383888.1 it E, Attachment 2 April 29, 2013 His Worship Mayor Geoffrey Dawe Town of Aurora 100 John West Way, Box 1000 Aurora, Ontario L4G 6.11 Dear Mayor Dawe: RE: Bell Mobility Inc. ("Bell") Telecommunications Site —Bathurst St., Township of King Thank you very much for the opportunity to speak to you and Town of Aurora staff on last Thursday's conference call regarding the issues raised by the Town and your constituents in connection with Bell's telecommunications tower, located in the Township of King at 14820 Bathurst St. The tower site was constructed to meet customer demand for improved wireless coverage in the area and will serve the thousands who live in and commute to and through the area. The site location is optimal for providing this improved wireless services and will allow for future co -location with other wireless companies. The height of the tower is required to meet the coverage objectives of the Bell Network. Since this site is located. within the Township of King, Industry Canada requires that Bell consult with it in accordance with CPC-2-M3 and obtain land use concurrence. As part of the municipal consultation process with the Township of King, Bell submitted a site selection report with supporting information to justify the need for installing the tower at this location. The notice provided to the Town of Aurora was based on the information documented in this report. I have attached a copy of the justification report for your reference. As you can see, the report contained a photo rendering of the appearance of the tower and documented Bell's investigations into the possibility of collocating Bell's telecommunications equipment on an existing tower within the area. The closest tower identified as a possible collocation site is 2.2 kilometres away from the tower. After considering various technical issues, it was determined that co -location at this alternate site would not meet Bell's coverage objectives. Bell's review also determined that there were no other feasible structures in the area for Bell to consider as a possible co -locate option. In keeping with Township of King and Town of Aurora objectives to reduce the number of towers, the Bell installation was designed with collocation in mind, and will accommodate another carrier in the future. With respect to the Town's request for a more visually appealing structure, we would like to point out that the installed structure is a shrouded tripole. Unlike a typical lattice design tower, the antennas are installed behind fibreglass panels. The cabling that connects to the ground mounted equipment shelter is contained within the frame of the tower and is invisible from the outside. It has been our experience that a tripole structure is widely considered by municipal officials as the most suitable type of structure for deployment in urban settings. Based on the location and its surrounding land uses, Bell believes this to be the most 1 appropriate type of structure when compared to either lattice or monopole designs since it permits future collocation without adding to the visual clutter normally associated with collocation. The triple support design also allows the skyline to be viewed through the tower's legs which does not occur with a monopole structure. Bell acknowledges the Town's suggestion of a flag pole design as an alternative option, however at 60 metres in height, the diameter of a flagpole would be far more noticeable on the landscape than the current design. In addition a flag that is appropriately sized for a large pole would attract, rather than deflect, attention and create significant noise impacts. As discussed on our conference call, Bell confirms that it is open to providing additional landscaping to mitigate the view of the tower base and equipment shelter, subject to obtaining the necessary permission from the owner of the lands. Although there was only one concern raised about telecommunications and health during the public consultation, we would be happy to provide further information to staff or residents regarding the stringent federal health and safety requirements that Bell is required to comply with as a condition of licence. In this regard, I confirm that the tower is in full compliance with Heath Canada's Safety Code 6 directive with significant room to spare. Your feedback on the public consultation process has been valuable and as we have committed to you, we will be reviewing Bell's processes and templates to ensure that these types of situations do not occur in the future. Likewise we feel that it is important for the Town to act within the appropriate timelines and to comment appropriately on information received from wireless carriers with respect to projects in neighbouring jurisdictions. We understand that the Town will be considering changes to its own internal procedures and look forward to working with the Town in the future to ensure that residents of Aurora have unimpeded access to wireless services. I trust that this letter addresses all of your concerns raised in last week's conference call. I would be happy to further discuss any of the points addressed in this letter at your convenience. I can be reached at 905- 282-2778 or via email at matthew.milligan@bell.ca Yours Truly, Bell Mobility Inc. Matthew Milligan cc: Keith Ranney, Director, Infrastructure Management Michel Dagenais, Vice President, Access Network Engineering Serge Bertuzzo, Director, Regulatory Affairs Noel Peacock, Senior Legal Counsel Stephen D'Agostino, Thomson Rogers 2 Attachment 3 I PROLIRFERATE CONSULT February 13, 2012 Township of King Planning Department 2075 King Road King City, Ontario L7B 1A1 Attention: Mr. Stephen Kitchen, Director of Planning FEB 13 2012 TOWNSHIP OF KING RE: Request for Municipal Concurrence Proposed Bell Canada Wireless Communication Installation 14820 Bathurst Street, King, Ontario Bell Files W2354 Dear Mr. Kulyk: On behalf of Bell Canada, please find enclosed this application for municipal concurrence for a proposed new wireless telecommunication installation in the Township of King. Purpose (� Bell Canada ("Bell") constantly strives to improve coverage and network quality for the sake of j their clients. This document provides information on the selection of the proposed wireless communication installation at 14820 Bathurst Street, and the required public consultation process. Network Requirements and Site Selection The selection of a wireless communications site works similarly to fitting a piece into a puzzle. In this case, the puzzle is a complex radio network, situated in a rural setting. Client demand, radio frequency engineering principles, local topography and land use opportunities working in concert with one another direct the geography of our sites. In order to'achieve a reliable wireless network, carriers must providea seamless transmission signal to alleviate any gaps in coverage. Gaps in coverage are responsible for dropped calls, and unavailable data service to clients. Bell would utilize the proposed site location in order to provide high quality network signal for its 3.5G high-speed wireless voice and data network. In the recent past, due to subscriber feedback, our Network Planning and Engineering departments have become aware of coverage deficiencies in the area of subject property. Proposed Site Location Bell's proposed site location is an agricultural property. The proposed wireless communication facility will be located approximately 25 metres from Bathurst Street (please see the enclosed 1 plan survey for additional details). The installation will be comprised of a 60-metre tri-pole style 21 A Price Street 416:637 8380 (Toronto) j www.Proliferategroup.wm Toronto, Ontario f 778.371 1516 (Vancouver) I Appendix A M4W IZl Canada 416.981.7248 (facsimile MIPRLTINGOLIFERATEGROUPCONSUINC tower and a walk-in equipment cabinet at the base within a secured compound. Lighting and colouring will be in accordance with Transport Canada and NAV Canada regulations for installations of this type. Access to the installation will be via an existing driveway onto Bathurst Street. The location of the proposed driveway is indicated on the included plan survey. The property's legal description is Part of the Lot 18, Concession 2, Township of King, Regional Municipality of York. The location of the proposed site is shown on the aerial photo, below. The geographic coordinates for the site are as follows; NAD83 N43059' 07.5", W79`29' 34.0" Description of Proposed System Bell proposes to implement a 60-metre tri-pole style tower communication structure. The radio equipment cabinets for the proposed installation would occupy a cast reinforced concrete slab area of approximately 4.4 square metres in size. The height and colour of the tower will be in 21A Price Street 416.637 8380 (Toronto( Toronto, Ontario 778.371.1516 (Vancouver( M4W 1Z1 Canada 416.981.7248 (focsimile( www. prol iferateg roup.corn Hft I 0 I Proposed Wireless Telecommunication Antenna Installation Bell Canada 14820 Bathurst Street, King, Ontario Additional Photo -Simulations of Proposed Installation Simulation of proposed installation, looking south Simulation of proposed installation, looking north M 1 PRtOLIFFERATE CONSU Surrounding wireless communication facilities and Request for co -location The site as proposed will achieve the necessary engineering coverage objectives for our network. Below is a map depicting the location of the nearest existing telecommunication installation: Bell: dark blue Rogers: red Telus: green Wind: light blue The closest existing non -Bell installation is located 2.2 kilometres south of the proposed location (Rogers Communication's site code C0734). This is a watertower installation. It is located too far from the service target area to be a viable alternative to a new installation. There are no existing structures in the vicinity that are of sufficient height to satisfy network engineering requirements. Therefore, a new installation is required. Radio Frequency Plots The following RF plots depict the current level of service and the proposed level of service: 21 A Price Street 416.637 8380 (Toronto) www.proliferategroup.com Toronto, Ontario 778.371.1516 (Vancouver) M4W 1Z1 Canada 416.981 7248 (facsimile) 0 CONSULTING GROUP INC Current level of service. This indicates that the area around the proposed installation is deficient in the provided service levels. This can result in slow wireless data speeds and dropped calls. The proposed installation will satisfy network engineering requirements and will improve coverage and capacity in the service target area. Distance to Adjacent Structures 21 A Ni.- Toronto, O M4W I Z IN MIPRLTINGOLIFERATE GROUP INC. CONSU There are no existing structures on the property. The nearest existing structure is a residence approximately 135 metres to the east northeast. Health Canada's Safety Code 6 Compliance Bell attests that the radio antenna system described in this notification package will comply with Health Canada's Safety Code 6 limits, as may be amended from time to time, for the protection of the general public including any combined effects of additional carrier co -locations and nearby installations within the local radio environment. For more Information on Safety Code 6, please visit the following Health Canada site: www.healthcanada.gc.ca/radiation. Control of Public Access The site facility would include a locked, alarmed and electronically monitored mechanical equipment cabinet, which would be situated within a fenced compound. Canadian Environmental Assessment Act Bell attests that the radio antenna system described in this notification package will comply with the Canadian Environmental Assessment Act, as this facility is exempt from assessment. Transport Canada's Aeronautical Obstruction Marking Requirements Bell attests that the radio antenna system described in this notification package will comply with Transport Canada / NAV Canada aeronautical safety requirements. The structure lighting system to be used for this installation will include upward facing directional baffles as part of the lighting module that will direct light upward to air traffic and away from the view of those residents, pedestrians and motorists on the ground. For additional detailed information, please consult Transport Canada at: www.tc.gc.ca/CivilAviation/Regserv/Affairs/cars/PART6/Standards/Sta ndard621.htm Transport Canada has been consulted with and indicated that no special lighting or painting is required. Engineering Practices Bell attests that the radio antenna system described in this notification package will be constructed in compliance with the National Building Code of Canada and comply with good engineering practices including structural adequacy. Local Land Use Requirements Wireless facilities are exclusively regulated by the Federal Government and as a result are not required to obtain municipal permits of any kind, 21A Price Street 416.637 8380 (Toronto) www proliferategroop.com Toronto, Ontario I 778.371. 1516 (Vancouver) j M4W 1Z1 Canada 416.981.7248 (facsimile) MIPROLTINGUKRATE CONSUGROUP INC. The Township of King has adopted a telecommunication tower protocol. Accordingly, Bell will be following this protocol for public consultation. Industry Canada's Spectrum Management Please be advised that the approval of this site and its design is under the exclusive jurisdiction of the Government of Canada through Industry Canada. Bell Canada is participating in this consultation in accordance with Industry Canada's guidelines CPC-2—M3. Industry Canada Toronto District Office Room 909, 9th Floor 55 St. Clair Avenue East Toronto, Ont. M4T SM2 Telephone: 416-973-8215 Fax:416-954-3553 Email: spectrum.toronto@ic.gc.ca Public consultation In accordance with the Township of King telecommunication tower protocol, a public consultation package will be provided to all Township landowners within a distance of 250 \ / metres from the proposed installation. A copy of this application package will also be provided / to Aurora authorities. The Township's protocol includes a requirement for a public information session, and that this requirement can be waived at the discretion of the Director of Planning. We estimate that only approximately 4 households are located within King Township are within the notification radius. In our opinion, effective and thorough public consultation for this proposed installation can be achieved by the combination of a mail -out, a sign posted on the property and a newspaper ad placed in a local newspaper. Comments from the public could be solicited in writing by mail or email, and a copy of each, with Bell's response, could be provided to the municipality. In our opinion, an information session would not be necessary to ensure the public has an opportunity to learn about the proposed installation and provide comment. Accordingly, we request a waiver from this requirement. Contact Information As a representative of Bell Canada, you can contact me at the following: Bell Canada c/o Sean Galbraith Municipal Affairs Manager Proliferate Consulting Group, Inc. 21 Price Street ( t Toronto, ON M4W 1Z1 21A Price Street 416.637 8380 (Toronto) www.proiiferategroup.com Toronto, Ontario 778.371 1516 (Vancouver) M4W IZl Conodo 416,981 7248 (facsimifel Bdl O RIPRLTINGOLIFC-RATE GROUP INC. CONSU (647) 728-7785 (work) (416) 732-5069 (cell - better) or via email at sgalbratth@proliferategroup.com Conclusion Bell Canada feels that the proposed site is well situated to provide and improve wireless data services in the targeted area. The proposed site has been situated and designed to have minimal impact on surrounding land uses. We look forward to working with you to improve telecommunication services in the community. Best regards, Sean Galbraith, MCIP, RPP Municipal Affairs Manager Proliferate Consulting Group, Inc. (Agents for Bell Canada) 21A Price Street ( 416.637 8380 (Toronto) ` www.prolifeiategroup.com Toronto, Ontario 778.371.1516 (Vancouver! BdI M4W 1Z1 Canada 416.981,7248 (facsimile) f