3 RETAIL BUSINESS HOLIDAYS ACT THE LOCAL MUNICIPALITY AS AN APPLICANT
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- Esmond Sullivan
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1 Clause No. 3 in Report No. 5 of Committee of the Whole was adopted, without amendment, by the Council of The Regional Municipality of York at its meeting held on November 21, RETAIL BUSINESS HOLIDAYS ACT THE LOCAL MUNICIPALITY AS AN APPLICANT Committee of the Whole recommends adoption of the following recommendation contained in the report dated November 7, 2013 from the Regional Solicitor and the Executive Director, Corporate and Strategic Planning: 1. RECOMMENDATION It is recommended that: 1. The Regional Clerk circulate this report to the Clerks of the local municipalities and give notice that the next deadline for the submission of Retail Business Holiday Act exemption applications is February 18, PURPOSE This report advises Council of the option available to local municipalities within a regional municipality to file an application for exemption from the Retail Business Holidays Act to allow retail businesses in all or part of a local municipality to be open on statutory holidays. 3. BACKGROUND The Retail Business Holidays Act requires businesses to be closed on certain statutory holidays The Retail Business Holidays Act (the Act ) requires businesses to be closed on public holidays unless they are exempted. The holidays to which the Act applies are:
2 Clause No. 3 2 Report No. 5 Committee of the Whole - New Year s Day - Family Day - Good Friday - Easter Sunday - Victoria Day - Canada Day - Labour Day - Thanksgiving Day - Christmas Day Boxing Day and the Civic Holiday in August are not public holidays under this Act and therefore an exemption is not required for those days. The Act sets out statutory exemptions for certain types of businesses and also provides that the council of a local municipality within a regional municipality may apply for an exemption from the Act allowing businesses to remain open for the maintenance or development of tourism. Council may permit businesses within an applicant municipality to be open on holidays if the tourism criteria are met The Act provides that Council may permit retail business establishments to open on holidays for the maintenance or development of tourism. A bylaw may be passed only if there is compliance with the tourism criteria set out in Ontario Regulation 711/91 Tourism Criteria (the Regulation ) under the Act. A copy of the regulation is appended to this report as Attachment 1. Section 2 (2) of the Regulation provides that area can be exempted if: all of the retail businesses in the area are within two kilometres of a tourist attraction; the area does not exceed that necessary to encompass all of the retail businesses for which the exemption is sought; and at least 25% of the retail businesses in the area are directly associated with the tourist attraction or rely on tourists visiting the attraction for business on a holiday. For the purposes of Section 2, a tourist attraction is defined as: natural attractions or outdoor recreational attractions; historical attractions; and cultural, multi-cultural or educational attractions. There is an exception for not meeting the two kilometre distance requirement. The Regulation sets out that the two kilometre restriction does not apply to a retail business located in a local municipality that has a population of less than 50, 000. The applicant is still required to meet the other tourism criteria in the regulation.
3 Clause No. 3 3 Report No. 5 Committee of the Whole At its September meeting Council requested a report on local municipal area exemptions At the September meeting of Committee of the Whole, four applications for exemption were heard and considered. During this meeting, staff advised Council that local area municipalities can apply to the Region for area exemptions which could simplify the process and minimize the number of individual applications. Council requested a follow up report to outline the process by which a local municipality could submit an application for exemption from the Retail Business Holidays Act. 4. ANALYSIS AND OPTIONS The council of any of the local municipalities within the Region may apply to exempt a specific area or the entire municipality from closing on public holidays Under the Act, the council of any of the local municipalities within the Region may apply for an exempting bylaw to allow retail businesses to be open on any of the following public holidays: New Year s Day, Family Day, Good Friday, Victoria Day, Canada Day, Labour Day and Thanksgiving Day. Local municipalities have the opportunity to apply for a bylaw exempting a defined area or the entire municipality from closing on public holidays. The local municipality cannot apply on behalf of a business. The application must only be for all or any part of the municipality and in most circumstances the tourism criteria must be met for a defined area to qualify for exemption consideration. The Towns of Georgina and Whitchurch-Stouffville are currently the only local municipalities within the Region to apply and receive an exemption for all of the businesses within its municipal boundaries for certain public holidays. Many of the historic downtowns throughout the Region and the Vaughan Mills Mall Campus were the subject of an area application by their respective local municipalities and received an exemption affecting the defined areas set out in their respective applications. The two kilometre restriction set out in the Regulation does not apply to retail businesses located in a local municipality having a population of less than 50,000 Section 4 of the Regulation states the two kilometre restriction does not apply to a retail business establishment located in a local municipality with a population of less than
4 Clause No. 3 4 Report No. 5 Committee of the Whole 50,000. The applicant is still required to demonstrate how the retail business relies on tourists visiting an attraction for business on a holiday and in the case of an area exemption that at least 25% of the businesses within the area are reliant upon tourists and the affected area is not greater than needed to encompass the retail businesses. Both the Towns of Georgina and Whitchurch-Stouffville are examples of local municipalities that have a municipal wide exemption and a population below 50, 000. When these bylaws were enacted in 1995, each municipality s population was below the 50,000 threshold set out in the Regulation and therefore it was not necessary for the businesses covered by the application to meet the two kilometre distance requirement. The City of Vaughan had exceeded the population threshold when it applied in 2010 for an area exemption for the Vaughan Mills Mall Campus. The application from the City of Vaughan relied on Canada s Wonderland to meet the tourism criteria. Attachment 2 illustrates how the City of Vaughan defined the area it applied to have exempted, using both a map and text description. The historical downtown areas that are currently exempted, were also subject to the tourism criteria, however, these areas meet the historical and cultural criteria for an attraction and would not have had to rely on an external tourist attraction. A large portion of the Region could be considered to be within two kilometres of a tourist attraction as defined by the Regulation In its decision on the Bramalea City Centre, the OMB stated that a somewhat broader interpretation can and should be applied to the phrase tourist attraction. Staff applied the tourism criteria set out in the Regulation using a broader interpretation of what defines a tourist attraction to produce a map of the Region which provides a general overview of potential tourism exemption areas within the Region (see Attachments 3-12). On the map of York Region and the maps for each of the local municipalities, staff highlighted all locations or areas that could be considered a tourist attraction and meet the tourism criteria. These maps do not contain or mark every known tourist attraction, as the Region does not maintain an inventory of these sites, but it does demonstrate where tourism traffic is likely to travel. This map has been used as a resource by recent applicants that have sought an exemption from closing on statutory holidays, however in preparing the application it is still the responsibility of every applicant to demonstrate not only proximity to a tourist attraction, but the reliance of the applicant upon tourists for business on a statutory holiday.
5 Clause No. 3 5 Report No. 5 Committee of the Whole Businesses located within an exemption area do not have to open on a retail holiday If Council enacts an exempting bylaw for a local municipality, the retail businesses within that exempted area are not required to be open on any holiday, but do have the choice to be open or closed. The application of a local municipality is subject to the same process, fees and charges as individual business applicants The council of a local municipality that wishes to submit an application must first pass a resolution to apply to the Region for an exemption. This resolution of the local council must be submitted with a complete application form, any required and additional supporting documents and the $ application fee. The applicant municipality will be billed the costs of advertising the statutory public meeting after the application has been received and the notice of public meeting is published in the local newspaper. If a bylaw is enacted by Council, the bylaw will only come into effect on the thirty-first day after enactment. Prior to the thirty-first day, the bylaw is subject to a thirty day appeal period during which any person who opposes the bylaw may file an appeal with the Ontario Municipal Board. Council accepts and hears applications for exemption two times a year, in September and April. The next deadline for the submission of exemption applications is February 18, These applications will be heard in early April. 5. FINANCIAL IMPLICATIONS There are no direct financial implications to the Region as a result of this application. 6. LOCAL MUNICIPAL IMPACT As an applicant, local municipalities would have an increased role in the exemption application process and much as the individual applicant, the local municipality would be able to determine how an exemption would best serve its community s needs. Approval of an exemption under the Act is intended to contribute to tourism in the local municipality.
6 Clause No. 3 6 Report No. 5 Committee of the Whole 7. CONCLUSION A local municipality may apply to Council for an exemption under the Retail Business Holidays Act to permit retail businesses within a part or the whole of the municipality to remain open on New Year s Day, Family Day, Good Friday, Victoria Day, Canada Day, Labour Day and Thanksgiving Day. The council of a local municipality that wishes to submit an application must first pass a resolution to apply to the Region for an exemption and submit the resolution with the requisite application form and fee to the Region for consideration. The next deadline for the submission of exemption applications is February 18, These applications will be heard in early April. For more information on this report, please contact Anitra Basant Sisavang, Law Clerk at Ext or Doug Lindeblom, Director, Economic Strategy and Tourism at Ext The Senior Management Group has reviewed this report. (The 12 attachments referred to in this clause are attached to this report.)
7 ATTACHMENT 1 Retail Business Holidays Act Loi sur les jours fériés dans le commerce de détail ONTARIO REGULATION 711/91 TOURISM CRITERIA Consolidation Period: From December 1, 1991 to the e-laws currency date. No amendments. This Regulation is made in English only. 1. This Regulation sets out the tourism criteria that must be met before a municipality may pass an exempting by-law under subsection 4 (1) of the Act. O. Reg. 711/91, s (1) A retail business establishment may be exempted if, (a) it is located within two kilometres of a tourist attraction; and (b) it is directly associated with the tourist attraction or relies on tourists visiting the attraction for business on a holiday. O. Reg. 711/91, s. 2 (1). (2) An exemption granted on an area basis may only be given if, (a) all of the retail business establishments in the area are within two kilometres of the tourist attraction; (b) the area does not exceed that necessary to encompass all of the retail business establishments for which an exemption is sought; and (c) at least 25 per cent of the retail business establishments in the area are directly associated with the tourist attraction or rely on tourists visiting the attraction for business on a holiday. O. Reg. 711/91, s. 2 (2). (3) For the purposes of this section, a tourist attraction is limited to, (a) natural attractions or outdoor recreational attractions; (b) historical attractions; and (c) cultural, multi-cultural or educational attractions. O. Reg. 711/91, s. 2 (3). 3. Each retail business establishment that on days other than holidays normally uses a total area of 2,400 square feet or more for serving the public or normally has four or more employees serving the public must, in addition to meeting the tourism criteria set out in subsection 2 (1), provide goods or services on holidays primarily to tourists. O. Reg. 711/91, s The two kilometre restriction set out in subsections 2 (1) and (2) does not apply to a retail business establishment located in a local municipality, including a local municipality located in a district or regional municipality or the County of Oxford, having a population of less than 50,000. O. Reg. 711/91, s (1) Despite any other provision of this Regulation, retail business establishments in a municipality may be exempted for up to five holidays a year during which a fair, festival or other special event is being held in that municipality. O. Reg. 711/91, s. 5 (1). (2) Subsection (1) does not apply to parades. O. Reg. 711/91, s. 5 (2). 6. (1) An application for an exemption under subsection 4 (3) of the Act shall contain the following: 1. A description of the area or the retail business establishment for which the exemption is sought. 2. The justification, in relation to the seasonal nature, if any, of the tourist attraction, for the time period sought in the exemption. 3. Information establishing that the tourism criteria set out in this Regulation are met. O. Reg. 711/91, s. 6 (1). (2) An application in respect of a retail business establishment described in section 3 shall be made only by that retail business establishment. O. Reg. 711/91, s. 6 (2)
8 ATTACHMENT 2 THE REGIONAL MUNICIPALITY OF YORK BILL NO. 20 BY-LAW NO A by-law to amend By-law No. LI to permit retail business establishments to be open on holidays The Council of The Regional Municipality of York hereby enacts as follows: 1. Schedule A to By-law No. LI , being a by-law to permit retail business establishments to be open on holidays, is amended by adding the following: Column 1 (Business) Column 2 (Location) Column 3 (Holidays) Column 4 (Hours) All Written Description of Area to be Exempted VAUGHAN MILLS MALL CAMPUS, including Vaughan Mills Mall and the Outparcels located within the following boundaries: Rutherford to the north, Jane Street to the east, Bass Pro Mills Drive to the south and Highway 400 to the west and more particularly shown on the attached Appendix A All, except Christmas Day Good Friday and Easter Sunday 8 a.m. to 10 p.m. 2. Appendix A shall form part of this by-law. ENACTED AND PASSED this 25 th day of March, Denis Kelly Regional Clerk Bill Fisch Regional Chair Authorized by the Report of the Regional Solicitor, adopted by Regional Council at its meeting on March 25,
9 MAP SETTING OUT DEFINED EXEMPTION AREA
10 Attachment 3 Possible Exemption Areas: Combined Attractions Lake Simcoe LEGEND Fox Island Georgina Island Snake Island Existing Cultural or Educational Attraction Pefferlaw Morning Glory Georgina Smith Boulevard McCowan Ro Keswick ion Kennedy ad McCowan Ro Avenue Warden Unionville City of Toronto Ninth Line Milliken McCowan Steeles Avenue West City of Markham Markham Highway 7 John Street Major Mackenzie Drive East York/Durham Line 16th Avenue Elgin Mills East Reesor Kennedy Ro ad enue Warden Av Avenue Woodbine t 19th Avenue Highway 404 Leslie Stree Stouffville Thornhill R:\Economy\2012\ _RetailHolidayActExemptions\Tools\Combined8x11.mxd Highway 48 WhitchurchStouffville Stouffville Langstaff Concord York/Durham Line Highwa y 404 t Avenue reet Yonge St Maple Bayview reet Bathurst St Dufferin Str eet Keele Stree t 0 et Highwa y 40 Weston Ro Centre Stree t 2nd Concess Street Bathurst Yonge Stree 7th Conces Major Mackenzie Drive West Drive Pine Valley Highway 50 Highway 7 Richmond Hill Ballantrae Aurora Vandorf Sideroad Oak Ridges Rutherford Woodbridge Sideroad Bethesda Sideroad Jane Stre 8th Conc ession City of Vaughan Vivian Aurora King City King Teston Davis Drive Bloomington ad Kleinburg St John's 16th Sideroad enue Kirby Nobleton Herald Mulock Drive 15th Sideroad Kipling Av han Albion Vaug Peel Region 10th Concessio n Township of King Highway 27 11th Conc ession 17th Sideroad Mount Albert Mount Albert Sharon Newmarket Keele Stree t sion 18th Sideroad Dufferin St reet Highway 400 ession 12th Conc Davis Drive West Doane Durham Region Highway 9 Schomberg 19th Sideroad Highway 48 t Leslie Stree Queensville Holland Landing r ee t St Simcoe County Ravenshoe East Townline Queensville Sideroad East Gwillimbury e Old Shiloh Boag Yo ng Old Homestead Pollock Glenwoods Avenue Produced by: Office of the Chief Administrative Officer, Geographic Information Services Branch Copyright, The Regional Municipality of York, Decemebr 2012 Copyright, The Regional Municipalities of Durham and Peel, County of Simcoe, City of Toronto *** Includes Queen s Printer for Ontario Highway 48 ad Cook's Bay Sutton Civic Centre Avenue *NAICS Codes for Mining (21), Utilities(22), Construction (23), Manifacturing (31-33), Wholesale Trade (41), Transportation (48-49) were removed **Exemption Area calculated as 2km distance from the attraction property boundary. For definition of attraction categories, please see individual maps Woodbine Black River 14th Avenue Steeles Avenue East Km
11 Newmarket St John's Sideroad Possible Exemption Areas Aurora LEGEND Township of King Wellington Street West Town of Aurora Wellington Street East Vandorf Sideroad Whitchurch - Stouffville Existing Cultural or Educational Attraction *NAICS Codes for Mining (21), Utilities(22), Construction (23), Manifacturing (31-33), Wholesale Trade (41),Transportation (48-49) were removed **Exemption Area calculated as 2km distance from the attraction property boundary Aurora Produced by: Office of the Chief Administrative Officer, Geographic Information Services Branch Copyright, The Regional Municipality of York, October 2013 *** Includes Queen s Printer for Ontario 2013 Bathurst Street Yonge Street Bayview Avenue Bloomington Richmond Hill Leslie Street Highway 404 Woodbine Avenue Km Attachment 4
12 LEGEND Existing Cultural or Educational Attraction Cook's Bay Keswick Georgina Possible Exemption Areas East Gwillimbury Ravenshoe *NAICS Codes for Mining (21), Utilities(22), Construction (23), Manifacturing (31-33), Wholesale Trade (41),Transportation (48-49) were removed **Exemption Area calculated as 2km distance from the attraction property boundary Boag Produced by: Office of the Chief Administrative Officer, Geographic Information Services Branch Copyright, The Regional Municipality of York, October 2013 *** Includes Queen s Printer for Ontario 2013 Holborn Simcoe County Dufferin Street Township of King Bathurst Street Green Lane West R:\Economy\2013\ _RBHAMunicipalMaps\Tools\EastGwillimbury_Combined.mxd Holland Landing Yonge Street 2nd Concession Newmarket Green Lane East Leslie Street Sharon Queensville Highway 404 Woodbine Avenue East Gwillimbury Warden Avenue Queensville Sideroad Doane Mount Albert Davis Drive Kennedy McCowan Herald Whitchurch - Stouffville Highway 48 Mount Albert Centre Street Ninth Line 0 1,000 m East Townline Durham Region Attachment 5
13 Park LEGEND Existing Cultural or Educational Attraction Possible Exemption Areas Georgina *NAICS Codes for Mining (21), Utilities(22), Construction (23), Manifacturing (31-33), Wholesale Trade (41),Transportation (48-49) were removed **Exemption Area calculated as 2km distance from the attraction property boundary Produced by: Office of the Chief Administrative Officer, Geographic Information Services Branch Copyright, The Regional Municipality of York, October 2013 *** Includes Queen s Printer for Ontario 2013 Fox Island Snake Island Lake Simcoe Georgina Island Metro North Simcoe County Cook's Bay The Queensway North Keswick Woodbine Avenue Warden Avenue Civic Centre Baseline Old Homestead Pollock Glenwoods Avenue Kennedy McCowan Sutton Latimer Georgina Frog Stoney Batter Highway 48 Morning Glory Old Homestead Smith Boulevard Snoddon Old Shiloh Weir's Sideroad Pefferlaw Attachment 6 Victoria Leslie Street R:\Economy\2013\ _RBHAMunicipalMaps\Tools\Georgina_Combined.mxd Ravenshoe East Gwillimbury Ravenshoe Durham Region
14 LEGEND Existing Cultural or Educational Attraction *NAICS Codes for Mining (21), Utilities(22), Construction (23), Manifacturing (31-33), Wholesale Trade (41),Transportation (48-49) were removed **Exemption Area calculated as 2km distance from the attraction property boundary Produced by: Office of the Chief Administrative Officer, Geographic Information Services Branch Copyright, The Regional Municipality of York, October 2013 *** Includes Queen s Printer for Ontario 2013 Possible Exemption Areas Township of King Simcoe County Attachment 7 Yonge Street Bathurst Street Green Lane 12th Concession Highway 9 19th Sideroad 18th Sideroad Schomberg Lloydtown Aurora Highway 9 Newmarket Peel Region Albion Vaughan 11th Concession 10th Concession 17th Sideroad Highway 27 15th Sideroad Nobleton King Vaughan 16th Sideroad 8th Concession Kipling Avenue King Kirby Township of King 7th Concession Pine Valley Drive Weston City of Vaughan Highway 400 Jane Street King City Keele Street Km Dufferin Street Wellington Street East Bathurst Street Aurora Yonge Street Richmond Hill
15 19th Avenue Durham Region York/Durham Line Milliken Attachment 8 Stouffville Stouffville Whitchurch - Stouffville Reesor Ninth Line Highway 48 McCowan Kennedy Warden Avenue Elgin Mills East Major Mackenzie Drive East nald Do 16th Avenue City of Markham Cousens Parkway Markham Unionville Highway 7 Highway 407 Eleventh Concession 14th Avenue Steeles Avenue East Possible Exemption Areas City of Markham City of Toronto Woodbine Avenue Highway 404 Leslie Street LEGEND Yonge Street Existing Cultural or Educational Attraction Richmond Hill *NAICS Codes for Mining (21), Utilities(22), Construction (23), Manifacturing (31-33), Wholesale Trade (41),Transportation (48-49) were removed **Exemption Area calculated as 2km distance from the attraction property boundary Produced by: Office of the Chief Administrative Officer, Geographic Information Services Branch Copyright, The Regional Municipality of York, October 2013 *** Includes Queen s Printer for Ontario 2013 Highway 7 Bayview Avenue Yonge Street Thornhill City of Vaughan John Street Steeles Avenue East R:\Economy\2013\ _RBHAMunicipalMaps\Tools\Markham_Combined.mxd 0 1,000 2,000 m
16 LEGEND Existing Cultural or Educational Attraction *NAICS Codes for Mining (21), Utilities(22), Construction (23), Manifacturing (31-33), Wholesale Trade (41),Transportation (48-49) were removed **Exemption Area calculated as 2km distance from the attraction property boundary Green Lane West Green Lane East East Gwillimbury Possible Exemption Areas Newmarket Produced by: Office of the Chief Administrative Officer, Geographic Information Services Branch Copyright, The Regional Municipality of York, October 2013 *** Includes Queen s Printer for Ontario 2013 Township of King Bathurst Street R:\Economy\2013\ _RBHAMunicipalMaps\Tools\Newmarket_Combined.mxd Highway 9 Yonge Street Newmarket Eagle Street Bayview Avenue Prospect St. Aurora Davis Drive Gorham Street Mulock Drive St John's Sideroad Leslie Street m Highway 404 Whitchurch - Stouffville
17 16th Sideroad LEGEND Existing Cultural or Educational Attraction *NAICS Codes for Mining (21), Utilities(22), Construction (23), Manifacturing (31-33), Wholesale Trade (41),Transportation (48-49) were removed **Exemption Area calculated as 2km distance from the attraction property boundary Produced by: Office of the Chief Administrative Officer, Geographic Information Services Branch Copyright, The Regional Municipality of York, October 2013 *** Includes Queen s Printer for Ontario 2013 City of Vaughan Teston Bathurst Street Township of King Jefferson Sideroad Gamble Aurora Yonge Street Bayview Avenue Lake Wilcox Stouffville 19th Avenue Richmond Hill Bethesda Sideroad Elgin Mills East Vandorf Sideroad Possible Exemption Areas Richmond Hill Bloomington Leslie Street Highway 404 City of Markham Attachment 10 Whitchurch - Stouffville Major Mackenzie Drive West Major Mackenzie Drive East Dufferin Street Rutherford 16th Avenue Woodbine Avenue aff Highway 407 R:\Economy\2013\ _RBHAMunicipalMaps\Tools\RichmondHill_Combined.mxd Highway 7 Highway ,000 m
18 Dufferin Street Kirby Richmond Hill Langstaff Highway 7 15th Sideroad King Bathurst Street Gamble Yonge Street Jefferson Sideroad eet City of Markham Attachment 11 15th Sideroad King 7th Concession 8th Concession Possible Exemption Areas City of Vaughan Township of King 10th Concession 11th Concession King Vaughan Keele Street Jane Street Highway 400 Weston Pine Valley Drive Kipling Avenue Highway 27 Huntington Cold Creek Albion Vaughan Teston Nashville Kleinburg Major Mackenzie Drive West Nobleton King City City of Vaughan Rutherford Highway 50 Highway 400 Peel Region Highway 407 Highway 427 Steeles Avenue 0 1,000 2,000 m LEGEND Existing Cultural or Educational Attraction *NAICS Codes for Mining (21), Utilities(22), Construction (23), Manifacturing (31-33), Wholesale Trade (41),Transportation (48-49) were removed **Exemption Area calculated as 2km distance from the attraction property boundary Produced by: Office of the Chief Administrative Officer, Geographic Information Services Branch Copyright, The Regional Municipality of York, October 2013 *** Includes Queen s Printer for Ontario 2013 R:\Economy\2013\ _RBHAMunicipalMaps\Tools\Vaughan_Combined.mxd City of Toronto
19 Herald Mount Albert R oad LEGEND Existing East Cultural Gwillimbury or Educational Attraction *NAICS Codes for Mining (21), Utilities(22), Construction (23), Manifacturing (31-33), Wholesale Trade (41),Transportation (48-49) were removed **Exemption Area calculated as 2km distance from the attraction property boundary Mount Albert Herald Davis Drive Attachment 12 Possible Exemption Areas Whitchurch-Stouffville East Townline Produced by: Office of the Chief Administrative Officer, Geographic Information Services Branch Copyright, The Regional Municipality of York, October 2013 Newmarket *** Includes Queen s Printer for Ontario 2013 Highway 404 Vivian Whitchurch - Stouffville St John's Sideroad Aurora Ballantrae Durham Region Aurora Woodbine Avenue Warden Avenue Kennedy Bloomington Vandorf Sideroad McCowan Highway 48 Ninth Line York/Durham Line Richmond Hill Bethesda Sideroad Stouffville Stouffville R:\Economy\2013\ _RBHAMunicipalMaps\Tools\Whitchurch_Stouffville_Combined.mxd 19th Avenue City of Markham 0 1,000 2,000 m
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