DRAFT July 20th ASSESSING THE POTENTIAL IMPACT OF ADDITIONAL RETAIL-COMMERCIAL USES IN THE STOCKYARDS AREA - Woolwich Township
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ASSESSING THE POTENTIAL IMPACT OF
ADDITIONAL RETAIL-COMMERCIAL
USES IN THE STOCKYARDS AREA
DRAFT July 20th
PREPARED FOR:
THE PLANNING
PARTNERSHIP
REGION O FPEEL CUSHMAN & WAKEFIELD 1
FOXWOOD
July 20, 2018
Mr. Ron Palmer
The Planning Partnership
rpalmer@planpart.ca
Regarding: Stockyards Area Retail-Commercial Analysis
Dear Ron,
This report provides an assessment of the potential impact of permitting additional retail-commercial
uses in the Stockyards area. The current land uses within the Stockyards are examined. A primary
trade area is then established, and the existing retail inventory is determined. The current trade area
population is used to determine the amount of existing retail space per capita. A population growth
projection leads to conclusions regarding the extent of future retail space that may be demanded
within the primary trade area, while an assessment of current site coverage considers the ability of
DRAFT July 20th
existing centres to accommodate this additional density. Finally, conclusions are drawn with respect
to the proposed additional retail development that is contemplated for the Stockyards area.
We are pleased to discuss this work with you at your convenience, in our ongoing support of your
project work on behalf of the Township of Woolwich.
Respectfully submitted,
Cushman & Wakefield Ltd.
Andrew Browning
Vice President
Valuation & Advisory
andrew.browning@ca.cushwake.com
416 359 2510
THE PLANNING PARTNERSHIP CUSHMAN & WAKEFIELD
STOCKYARDS AREA RETAIL-COMMERCIAL ANALYSIS
TABLE OF CONTENTS
Existing Land Use ................................................................................................................................... 1
Overview ............................................................................................................................................. 1
Summary of Observations .................................................................................................................. 3
Impact of Potential Additional Retail-Commercial Supply ...................................................................... 4
Introduction ......................................................................................................................................... 4
Determining a Suitable Trade Area .................................................................................................... 4
Existing Retail Inventory within Trade Area ........................................................................................ 5
Retail Space per Capita within Trade Area ......................................................................................... 6
Potential for Additional Retail-Commercial Space within the Trade Area .......................................... 7
Conclusions......................................................................................................................................... 9
DRAFT July 20th
THE PLANNING PARTNERSHIP CUSHMAN & WAKEFIELD
STOCKYARDS AREA RETAIL-COMMERCIAL ANALYSIS
EXISTING LAND USE
Overview
On November 17, 2016, Cushman & Wakefield (Andrew Browning, Vice President) completed a tour
of the Stockyards area. This involved a “drive-by” inspection of all properties in the study area, as
well as an interior examination of some properties, where it was necessary to identify certain
tenancies1.
A total of 24 properties were identified – some of which represent multiple buildings on a single parcel
of land, or larger development. The buildings numbered on the map below correspond with the
figures used in the exhibit that is presented on the following page.
DRAFT July 20th
1
Note that while we utilize the word “tenants”, it is also meant to refer to “occupants” in the case of owner-occupied premises.
The phrase “tenants” is used for convenience purposes.
THE PLANNING PARTNERSHIP CUSHMAN & WAKEFIELD 1STOCKYARDS AREA RETAIL-COMMERCIAL ANALYSIS
EXISTING USES IN THE STOCKYARDS AREA
Bldg. # Property Name/Description Tenant Classification(s)
1 Walmart Supercentre (with garden centre and in- General Merchandise/Food
store McDonalds)
2 Multi-tenanted strip plaza Financial/Insurance Services, Food/Beverage
Services, Hair/Beauty Services
3 A&W Food/Beverage Services
4 Multi-tenanted strip plaza Clothing, General Merchandise
5 St. Jacobs Antique Market General Merchandise
6 Value Village Clothing
7 St. Jacobs Outlet Mall – 2-level enclosed Clothing, Food/Beverage Services, General
unanchored shopping centre Merchandise, Hair/Beauty Services, Household
Goods/Appliance Store, Jewellery Store, Other
Retail, Personal/Household Services, Shoe Store,
Vacant
8 Homewood Suites Hilton Hospitality
9 Visitor Centre Personal/Household Services
10 Holiday Inn Express Suites Hospitality
11 Multi-tenanted strip plaza Food/Beverage Services, General Merchandise,
Household Goods/Appliance Store
12 St. Jacobs Furniture House Household Goods/Appliance Store
13
14
15
DRAFT July 20th
St. Jacobs Country Playhouse
Courtyard Marriott (with The Bistro restaurant)
Waterloo North Mennonite Church
Entertainment
Hospitality
Place of Worship
16 Multi-tenanted strip plaza Food, Food/Beverage Services, General
Merchandise
17 TSC Stores Hardware Store
18 Raymond Kuntz Topsoil, Mulches & Gravel Other Retail
19 Marketside Business Centre – Bldg. 1 (front) Business Services , Drug Store, Health Services,
Personal/Household Services
20 Marketside Business Centre – Bldg. 2 (front) Business Services, Vacant
21 Marketside Business Centre – Bldg. 3 (rear) Personal/Household Services
22 Marketside Business Centre – Bldg. 4 (rear) Business Services
23 St. Jacobs Farmers’ Market (includes St. Jacobs General Merchandise/Food
Furnishings and Ontario Livestock Exchange)
24 Max’s Sports World Recreation
THE PLANNING PARTNERSHIP CUSHMAN & WAKEFIELD 2STOCKYARDS AREA RETAIL-COMMERCIAL ANALYSIS
Summary of Observations
The existing land uses in the Stockyards area are predominantly retail-commercial in nature, with
some hotel properties, and a mixed office-industrial business centre. St. Jacobs Farmers’ Market and
the Ontario Livestock Exchange are an anchor use which draw considerable traffic to the area. The
nearby antiques markets play off this consumer dynamic. The retail-commercial uses are in a range
of formats including freestanding stores, strip plazas, power centre-style development, and a two-
level enclosed shopping centre – as well as the indoor/outdoor Farmers’ Market.
The classification of area tenancies indicates a mix of types of retail and service establishments. The
classifications used by Cushman & Wakefield are adapted from those used by the Centre for Studies
in Commercial Activity. There is some difficulty in assigning a category to retailers with a mixed
product offering (such as Walmart – with food, general merchandise, and various other departments;
or Reebok – with shoes and clothing). As well, the range of retail functions within the St. Jacobs
Farmers’ Market is varied.
The most prominent classifications are as follows: Clothing (10); General Merchandise (10); Business
Services (7); Household Goods/Appliance Store (6); Personal/Household Services (5); and
Food/Beverage Services (5). The Clothing retailers are predominantly located within the St. Jacobs
Outlet Mall. The Business Services are mostly located at the Marketside Business Centre.
It is noted that there is an absence of certain retail and service functions that are typically found in a
retail environment, including: Automotive; Books/Office Supplies; Cleaners; Beer Store/LCBO; Music
Store; Other Clothing/Fabric; and Sporting Goods. While there is no dedicated tenant specifically
focused on these retail offerings or services, the Walmart Superstore product mix addresses many of
these categories. Taking this into account, the range of retail offerings and services available in the
DRAFT July 20th
Stockyards area is reasonably complete.
The following is a summary of other notable observations from the analysis of in-place tenancies:
Limited vacancy – There was a limited amount of vacant space observed in the Stockyards area
– most of which is located within the St. Jacobs Outlet Mall (all on the 2nd floor). There was a
single unit currently under renovation (at the time of our inspection) in preparation for a new
tenancy within the Marketside Business Centre, which is technically denoted “vacant” at present.
In total, only three of the 72 units examined in our survey are considered functionally vacant (4%)
– a figure which excludes the unit under renovation.
Emphasis on “value” retailing – It is noted that there is a concentration of “value-oriented”
retailers in this area, including the following: Walmart Supercentre, Dollarama, Value Village, St.
Jacobs Outlet Mall, and various antiques stores – along with the signature St. Jacob’s Farmers’
Market.
Multiple hotel options – there are three hotel options within the Stockyards area: Holiday Inn
Express & Suites, Courtyard Marriott, and Homewood Suites Hilton. These primarily serve the
broader north Waterloo market, as well as the Township of Woolwich.
THE PLANNING PARTNERSHIP CUSHMAN & WAKEFIELD 3STOCKYARDS AREA RETAIL-COMMERCIAL ANALYSIS
IMPACT OF POTENTIAL ADDITIONAL RETAIL-
COMMERCIAL SUPPLY
Introduction
Cushman & Wakefield has been asked to consider the impact of the introduction of additional retail-
commercial floor space within the Stockyards area on the broader retail market, which includes north
Waterloo and the Township of Woolwich. The assumption is that this additional retail-commercial
space would not be subject to limitations in terms of the scope of retail or service offerings – a broad
range of general retail and commercial uses would be permitted. Specifically, the following additional
retail-commercial developments/redevelopments are to be considered:
SmartCentres site – 114,000 sf
St. Jacob’s Outlet Mall site – 100,000 sf
St. Jacobs Farmers’ Market site – 25,000 sf
Total – 239,000 sf
Determining a Suitable Trade Area
The Stockyards area is home to destination retail offerings such as the St. Jacobs Farmers’ Market,
St. Jacobs Antique Market, St. Jacobs Outlet Mall, and other retail-commercial uses that compliment
these businesses. It is also the location of a SmartCentres development that is anchored by a
Walmart Supercentre, with remaining undeveloped parcels of land.
DRAFT July 20th
In assessing the extent of the primary trade area for the
Stockyards, it is useful to identify the locations of other
nearby Walmart stores. The following map illustrates the
location of Walmart stores in the Woolwich and
Kitchener-Waterloo area (source:
www.walmart.ca/en/store-finder). On this map, store #4
is the Walmart Supercentre located in the Stockyards,
while store #1 is the next closest location – known as
Bridgeport Supercentre – situated at 70 Bridgeport Road
East, near Weber Road North. These two stores are
approximately 5.5 kilometres apart. Based on this, a
suggested primary trade area for the Stockyards extends
roughly halfway from the Stockyards to Bridgeport Road
(to the south) – or roughly midway between Northfield
Drive West and Columbia Street West – and
encompasses the Stockyards area, the Town of Elmira,
and the largely rural surrounding area.
While the tourist-drawing retail-commercial offerings including the Farmers’ Market and Outlet Mall
draw customers from beyond the primary trade area (as indicated in the King & 86 Retail Centre
Market Analysis and Impact Evaluation study, completed in 2000), the local-serving retail-commercial
uses that are already established in the Stockyards area – and those that are contemplated in any
general retail expansion of the area – will naturally draw upon the local population within a short drive
of the site. Indeed, the 2000 report states that St. Jacobs (the Stockyards area) “serves a very large
regional area and draws a significant portion of trade from tourism which creates a different role and
function, different customer base, and different trade area from that of the King/86 Centre.” (pp. 43).
THE PLANNING PARTNERSHIP CUSHMAN & WAKEFIELD 4STOCKYARDS AREA RETAIL-COMMERCIAL ANALYSIS
As stated in the report, “the focus of testing economic impact effects with the addition of the King/86
Centre is on the Community Core Areas of Elmira, and Uptown Waterloo, and the Conestoga Mall
Regional Shopping Centre in Waterloo.” (pp. 43-44). Therefore, the primary trade area suggested in
our report is in alignment with the analysis undertaken to support the development of the King/86
Centre (now known as SmartCentres Waterloo).
The following map outlines the extent of our suggested primary trade area for local-serving general
retail-commercial uses in the Stockyards area (excluding tourist-oriented uses).
DRAFT July 20th
Existing Retail Inventory within Trade Area
The following inventory of retail space is identified within the primary trade area, which includes the
Stockyards area, Elmira, and a portion of north Waterloo.
EXISTING RETAIL INVENTORY WITHIN TRADE AREA
Property Name Address Centre Type GLA (sf)*
WITHIN STOCKYARDS AREA
SmartCentres Waterloo 335 Farmer’s Market Rd. Power Centre 181,000
St. Jacobs Factory Outlet Mall 25 Benjamin Rd. E. Retail Mixed-Use 84,500
St. Jacobs Farmers’ Market (bldg.) 878 Weber St. N. Retail Mixed-Use 34,000
Multi-tenanted Strip Plaza 20-30 Benjamin Rd. E. Strip Plaza 30,900
Multi-tenanted Strip Plaza 845 Weber St. N. Strip Plaza 28,000
TSC Stores 849 Weber St. N. Freestanding 22,800
St. Jacobs Antique Market 805 King St. N. Retail Mixed-Use 20,000
SUB-TOTAL 401,200
THE PLANNING PARTNERSHIP CUSHMAN & WAKEFIELD 5STOCKYARDS AREA RETAIL-COMMERCIAL ANALYSIS
ELMIRA
Elmira “Primary Zone” [1] Various Various 603,000
SUB-TOTAL 603,000
NORTH WATERLOO
Conestoga Mall 550 King St. N. Regional 681,100
Bridgeport Plaza 94 Bridgeport Rd. E. Community 212,000
Waterloo Corporate Campus 580 Weber St. N. Neighbourhood 135,000
Home Depot 600 King St. N. Big Box 122,100
Kingspoint Centre & Chapters 576 - 582 King St. N. Power Centre 79,300
Parkdale Plaza 460 - 504 Albert St. Neighbourhood 52,900
Northfield Centre 585 Weber St. N. Neighbourhood 52,400
Multi-tenanted Strip Plaza 30 Northfield Dr. E. Strip Plaza 33,000
Multi-tenanted Strip Plaza 620-628 King St. N. Strip Plaza 26,500 [2]
Multi-tenanted Strip Plaza 560-572 King St. N. Strip Plaza 26,200
King Northfield Centre 583 King St. N. Convenience 26,100
Multi-tenanted Strip Plaza 615 Davenport Rd. Strip Plaza 17,600
SUB-TOTAL 1,464,200
SUB-TOTAL (excl. Conestoga Mall) 783,100
TOTAL TRADE AREA
DRAFT July 20th
TOTAL TRADE AREA (excl. Conestoga Mall)
2,468,400
1,787,300
*GLA – Gross Leasable Area.
[1]
Note: sourced from Elmira Retail Market Demand and Impact Analysis (Tate Economic Research Inc.).
[2]
Note: there is additional GLA on this site, but the floor area is unknown.
Sources: Canadian Directory of Shopping Centres, Municipal Property Assessment Corporation propertyline, Elmira Retail
Market Demand and Impact Analysis (Tate Economic Research Inc.), and Cushman & Wakefield.
The Stockyards has an inventory of approximately 401,200 sf, while Elmira’s retail inventory has been
measured at 603,000 sf, and the portion of north Waterloo that falls within the primary trade area has
an inventory of approximately 1,464,200 sf. Together, the total retail inventory within the primary
trade area is 2,468,400 sf. Conestoga Mall, a regional-scale shopping centre, accounts for a roughly
28% share.
Retail Space per Capita within Trade Area
Current Retail Space per Capita
The trade area has an estimated population of 52,500 (source: MagnifyMaps). Based on a trade area
retail inventory of 2,464,200 sf, this translates to approximately 47 sf of retail space per capita.
However, the presence of the Conestoga Mall regional shopping centre skews any calculation of
retail space per capita within the trade area, since this regional draw attracts residents across a broad
section of Waterloo. When Conestoga Mall is excluded from the calculation, the amount of retail
space per capita within the trade area is adjusted to 34 sf.
THE PLANNING PARTNERSHIP CUSHMAN & WAKEFIELD 6STOCKYARDS AREA RETAIL-COMMERCIAL ANALYSIS
The Stockyards area – in particular the St. Jacobs Farmers’ Market – is also a regional draw; it even
draws visitors/tourists from well beyond Waterloo Region. This has the effect of increasing the
amount of retail space per capita, when the local trade area population is considered (when tourist
inflow is not part of the calculation).
A comparison across municipalities including Waterloo, Kitchener, Cambridge, Guelph, London, and
Brantford, produces an average of around 21.5 sf of shopping centre space per capita; however, this
figure needs to be adjusted upwards to account for downtown retail space and freestanding retail
uses. In conclusion, the figure of 34 sf of retail space per capita for the trade area is considered to be
beyond the upper end of the typical range.
Population Growth Forecast
The Waterloo Region Census Metropolitan Area (CMA) had a population of 583,500 residents in
2016. Amendment 2 (2013) to The Growth Plan For The Greater Golden Horseshoe, 2006, indicates
that the Region of Waterloo will grow to a population of 742,000 by 2031, and 835,000 persons by
2041. This represents an increase of approximately 27% from 2016-2031, and 12.5% from 2031-
2041. Overall, the population is forecast to increase by 43% from 2016-2041. If this same rate of
population growth (43%) is applied to the trade area population, it would result in a 2041 population of
75,075 persons, representing an increase of 22,575 persons.
Translating Population Growth into Future Retail Space Demand
At a rate of 34 sf per capita (the current figure, adjusted to account for Conestoga Mall), the projected
population growth within the trade area of 22,575 persons would generate demand for an additional
767,550 sf of retail space by 2041. A more conservative estimate of 20 or 25 sf of retail space per
DRAFT July 20th
capita would result in demand for between 564,375-677,250 sf of new retail space.
FUTURE SPACE DEMAND
Population Growth sf per Additional Retail
(2016-2041) Capita sf
22,575 34 767,550
22,575 25 677,250
22,575 20 564,375
RANGE (ROUNDED) 565,000-770,000
Potential for Additional Retail-Commercial Space within the Trade Area
Potential at Existing Centres
An analysis of site coverage for the existing retail space across the trade area provides an indication
of which sites may be suited to support additional future density. A benchmark of approximately 25%
site coverage is typical for retail format developments, as this provides an appropriate amount of
parking, along with shipping/receiving, recycling/waste storage, and property setbacks. It is noted
that the majority of existing retail uses across the trade area are in the range of 25% site coverage,
with some exceptions. Most prominently, the SmartCentres Waterloo site (Walmart Supercentre and
other power centre format buildings) has a site coverage of just 16%, indicating that there are lands
currently undeveloped that could support future retail-commercial uses. We have not calculated a
site coverage for the Stockyards/Farmers’ Market site, given the outdoor market function that covers
a portion of the lands, along with the stockyards, and St. Jacobs Furnishings. However, there is a
large parking area that supports the site – a portion of which may be able to be developed, as is
being contemplated (note that a parking needs study is not a component of this assessment).
THE PLANNING PARTNERSHIP CUSHMAN & WAKEFIELD 7STOCKYARDS AREA RETAIL-COMMERCIAL ANALYSIS
EXISTING SITE COVERAGE
Property Name Address GLA Site Site
(sf)* Area Coverage
(ac) (%)
WITHIN STOCKYARDS AREA
SmartCentres Waterloo 335 Farmer’s Market Rd. 181,000 26.7 16%
St. Jacobs Factory Outlet Mall 25 Benjamin Rd. E. 84,500 7.4 26%
St. Jacobs Farmers’ Market (bldg.) 878 Weber St. N. 34,000 28.4 N/A [1]
Multi-tenanted Strip Plaza 20-30 Benjamin Rd. E. 30,900 3.0 24%
Multi-tenanted Strip Plaza 845 Weber St. N. 28,000 6.7 10%
TSC Stores 849 Weber St. N. 22,800 3.0 17%
St. Jacobs Antique Market 805 King St. N. 20,000 2.5 18%
ELMIRA
Elmira “Primary Zone” [2] Various 603,000 N/A N/A [3]
NORTH WATERLOO
Conestoga Mall 550 King St. N. 681,100 58.2 27%
Bridgeport Plaza 94 Bridgeport Rd. E. 212,000 15.2 32%
Waterloo Corporate Campus 580 Weber St. N. 135,000 N/A [4] N/A
Home Depot 600 King St. N. 122,100 9.8 29%
Parkdale Plaza
Northfield Centre
DRAFT July 20th
Kingspoint Centre & Chapters 576 - 582 King St. N.
460 - 504 Albert St.
585 Weber St. N.
79,300
52,900
52,400
7.5
5.0
5.2
24%
24%
23%
Multi-tenanted Strip Plaza 30 Northfield Dr. E. 33,000 4.2 18%
Multi-tenanted Strip Plaza 620-628 King St. N. 26,500 N/A [5] N/A
Multi-tenanted Strip Plaza 560-572 King St. N. 26,200 2.5 24%
King Northfield Centre 583 King St. N. 26,100 2.5 24%
Multi-tenanted Strip Plaza 615 Davenport Rd. 17,600 1.7 24%
*GLA – Gross Leasable Area.
[1]
Note: excluded from calculations due to the nature of uses on the property, including St. Jacobs Furnishings, Ontario
Livestock Exchange, and outdoor farmers’ market function.
[2]
Note: sourced from Elmira Retail Market Demand and Impact Analysis (Tate Economic Research Inc.).
[3]
Note: excluded from calculations due to wide range of retail building typologies (main street, freestanding, plazas, etc.).
[4]
Note: excluded from calculations due to mixed uses on the site (including office).
[5]
Note: excluded from calculations due to additional unknown GLA on this site.
Sources: Canadian Directory of Shopping Centres, Municipal Property Assessment Corporation propertyline, Elmira Retail
Market Demand and Impact Analysis (Tate Economic Research Inc.), GeoWarehouse, The Planning Partnership, and
Cushman & Wakefield.
THE PLANNING PARTNERSHIP CUSHMAN & WAKEFIELD 8STOCKYARDS AREA RETAIL-COMMERCIAL ANALYSIS
Potential on Vacant Designated Lands
Based upon the trade area boundary developed by Cushman & Wakefield, The Planning Partnership
completed an analysis of the development capacity of vacant designated commercial sites in north
Waterloo (including some sites that are located outside the boundary, but in proximity). These sites
are all identified on the City of Waterloo Official Plan Schedule A1: Commercial Land Uses. Based
upon a typical site coverage of 25% for retail-commercial development, the analysis concluded a total
capacity of approximately 287,400 sf of GFA across eight sites. These sites are as follows:
VACANT DESIGNATED SITES
Address Designation Property Area (sf)* Potential GFA (sf)
500 Glen Forest Blvd. Convenience Commercial 27,459 6,865
485 King St. N. Corridor Commercial 156,507 39,127
551 King St. N. Corridor Commercial 177,712 44,428
10 Northland Rd. Corridor Commercial 91,063 22,766
20 Northfield Dr. E. Corridor Commercial 43,486 10,872
255 Northfield Dr. E. Mixed-Use Neighbourhood Commercial 318,074 79,519
580 Coldstream Dr. Convenience Commercial 34,014 8,504
Beaver Creek Meadows Mixed-Use Neighbourhood Commercial 301,389 75,347
District Plan
TOTAL (ROUNDED) 287,400
DRAFT July 20th
*Note: Vacant portion of the site.
Source: The Planning Partnership and City of Waterloo.
Conclusions
The three proposed development/redevelopment sites within the Stockyards area total 239,000 sf of
GLA. This amounts to a 31%-42% share of the future space demanded within the primary trade area,
based on the projected population growth of 22,575 persons. It is the opinion of Cushman &
Wakefield that this amount of new retail-commercial space would not have an undue impact on the
retail market in the primary trade area, and is small in scale compared to the extent of future retail-
commercial space that will be warranted across Waterloo Region through 2041. Further, given that
much of the existing (built) retail environment appears to have limited opportunity to accommodate
additional density (reflected in an existing site coverage of around 25%), the lands within the
Stockyard area represent a good opportunity to provide space for future retail development that will
be required over time to support anticipated population growth. Lands in north Waterloo within the
primary trade area would only accommodate up to 287,400 sf of growth – if all sites were built out at a
site coverage of 25%. This represents a roughly 37%-51% share of the future space demanded
within the primary trade area, based on the projected population growth of 22,575 persons.
Together, the three proposed development/redevelopment sites within the Stockyards area
plus the vacant designated commercial sites within the primary trade area in north Waterloo
can accommodate approximately 68%-93% of the future required retail-commercial space that
will be required to meet projected trade area population growth through 2041.
Notably, the King & 86 Retail Centre Market Analysis and Impact Evaluation study, completed in
2000, concluded that 305,000 sf of gross floor area “can be accommodated in the market without
compromising the economic viability of Community Core Areas, or Regional Shopping Centres.” (pp.
xii). To date, the SmartCentres development totals 181,000 sf, meaning that 124,000 sf of
development potential remains unfulfilled.
THE PLANNING PARTNERSHIP CUSHMAN & WAKEFIELD 9STOCKYARDS AREA RETAIL-COMMERCIAL ANALYSIS
It is also noted that the Market Analysis and Planning Assessment Service Commercial Use
Permissions King/86 Power Centre report, completed in 2011, concluded that “the inclusion of a
broader range of Service Commercial uses at the King/86 Power Centre would not alter the planned
function of the power centre nor is it forecast to impact or adversely affect the planned function of
other commercial areas in Woolwich, Waterloo, or the Region.” (pp. 20).
DRAFT July 20th
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