Posts Tagged ‘preservation’

Update: Moonlight Movies will happen at 9:30pm on Thursday and Friday night (July 30th and 31st) at Old Market Square.  more info…


This has been a very busy summer for me, and I think the pace is accelerating.  What started as a few outings a week has become a marathon of summer activities.  My daughter has been even busier than I have, having gone out to somewhere exciting almost every single day since June.  She’s gone to the zoo a couple of times this summer, to the Children’s Museum, to Folk Fest, to Kids Fest… she actually missed the kids shows at Fringe due to scheduling conflicts; my 16-month old daughter has more scheduling conflicts than I’ve ever had.  This past weekend we had Ballet in the Park, Sesame Street Live, a social gathering, strawberry picking, a beach visit, a farm visit, and a family dinner.  Coming in August: Folklorama, a trip to another beach, a trip to the Whiteshell, and perhaps a return visit to Hecla (her third trip to the island).  This in addition to her trips down Corydon, in the Exchange, to the Forks, to the dog park, etc.

Even if I took every day off for the rest of the summer, I don’t think we’d be able to show my daughter everything we’d like her to see in and around Winnipeg.  ChrisD.ca just reminded me via Twitter about the Winnipeg Beach boardwalk; we haven’t been there at all this year.

Over the next week or so, I’m going to talk about some of these jewels of Winnipeg.  I won’t focus on their history or take any photos, because there are already some very good people doing just that (Mr. Christian, Bryan Scott).  But I’ll talk about what’s happening now, what we’ll hopefully see in the near future, and I’ll mention the hazards ahead.

Rorie Street – from Bryan Scott, Winnipeg: Love and Hate

Jewel #1: The Exchange District

The Exchange District is North America’s most extensive collection of turn-of-the-20th-century architecture, and is also a place that is becoming livelier by the day.  New businesses are moving in, more residents are on their way, and the cultural events keep growing.  There are many jewels in Winnipeg, but the Exchange District is the jewel that’s most likely to put us on the map.  In fact, the Exchange District is the downtown of the month for the International Downtown Association.

Cultural Centre of Winnipeg

The Exchange District is teeming with events, particularly in the summer, but with galleries, music venues, and theatres offering year-round entertainment.  This summer has already seen the Winnipeg Jazz Festival, the Soca Reggae Festival, and the Fringe Festival in the heart of the Exchange District.

There are also festivals at other times of year in the Exchange, including the Winnipeg Symphony Orchestra’s New Music Festival and Manitoba Theatre Centre’s Master Playwright Festival, which features the work of a different playwright each year.  2009 was MillerFest (Arthur Miller), and 2010 will see ChurchillFest in honour of Caryl Churchill.

Heritage Under Siege

A portion of the Exchange District, around 20 blocks, is a National Historic Site.  In theory, this should offer protection to heritage buildings, but there is definite concern among many heritage-minded Winnipeggers that many of the buildings could be demolished simply because they are not deemed “interesting” or “historic” enough.  For instance, the Grain Exchange Annex will soon be demolished to create a loading zone and surface lot.  The reasoning used by the city, the property owner, and even Heritage Winnipeg was that the building was not significant enough, and that it was built in 1920 as opposed to 1913 (the “upper limit” for the described characteristics of the national historic site), so it was not considered historic.

Other buildings that could be at risk are any that currently have no designation, along with any with Grade III designation.   Grades I and II are more secure for the time being, but Grade II buildings can be demoted to Grade III status through city council.  Familiar buildings on the Grade III list include:


McDermot Avenue streetscape

Bailey’s Restaurant, a building built in 1900, isn’t even on the historic buildings list, which means that it has no heritage protection at all.

Despite the increasing vitality and reputation of the Exchange District, this jewel of Winnipeg is not safe from demolition by neglect or the cancer of parking lots.  Here are some excellent articles on the constant attack on the Exchange District:

Under Siege (Bryan Scott)
Community News – Hydro (substation plans) (Residents of the Exchange District)
Small Storefronts Serve big purpose in Exchange District (Robert Galston)

The Liveable Neighbourhood

The Exchange District, while only home to around 600 people at present, is slowly gaining in residential population and in services.  Most Winnipeggers have heard of the new condos being built along Waterfront Drive (The Strand, The Excelsior, Sky Waterfront Condominiums, Ship Street Village), but not as many people are aware of The Edge on Princess.  This is a heritage building converted to New York style loft apartments, with bachelors priced at $750/month, including heat, water, and electric.  One bedrooms are priced at $950-1,150 and there are also some two bedroom units available.  Another interesting project is YouCube, which promises a total of 18 townhouse condos priced between $196,450 and $300,000.

Other condos in the Exchange are Fairchild Lofts at 110 Princess St and Old Market Square Lofts at 283 Bannatyne Ave.  Due to the high price of homes in the Exchange District, the incoming population will be composed mainly of affluent professionals.  However, there will soon be a 100-strong student component as well as the Union Bank Tower is renovated into a space that will include the Red River College hospitality programs as well as the college’s first student residence.

Our Billion Dollar Asset

The Exchange District is on its way to becoming… wait for it… a “world class” destination.  Actually, in this case, there is definitely no exaggeration.  When you take one of the best preserved (for the time being) commercial districts in North America, add in some of the finest cultural institutions in Canada, and include the entertainment and festivals that we see every year, you end up with something that is truly special.  Combined with several other attractions (some of which I’ll be writing about), the Exchange District has the potential to make Winnipeg a tourist destination.  This sounds like fantasy to many Winnipeggers, because we’re so used to the Simpsons’ take on our city:

Now Entering Winnipeg / We were born here, what’s your excuse?

But the reality is that several accidents of history and geography have blessed us with a one-of-a-kind historic commercial district, and the people of Winnipeg have filled the district with culture and excitement and commerce.  Our next steps should be to start leveraging our billion-dollar asset into a genuine international draw.  This isn’t done simply by throwing money at the Exchange, although there are dozens of buildings that could use some money for restoration and renovation.  It’s done by building up the amount of attractions within the district, growing the number and size of festivals and events, and capitalizing on what we already have.  I won’t go into details on this today, but I’m sure we all have a few ideas on what could come next for the Exchange.

I can’t think of a more exciting time for Winnipeg since the turn of the century, when we were the Chicago of the North.  And a large part of that excitement is coming from Winnipeg Jewel #1: the Exchange District.

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This has been a very busy summer for me, and I think the pace is accelerating. What started as a few outings a week has become a marathon of summer activities. My daughter has been even busier than I have, having gone out to somewhere exciting almost every single day since June. She’s gone to the zoo a couple of times this summer, to the children’s museum, to Folk Fest, to Kids Fest… she actually missed the kids shows at Fringe due to scheduling conflicts; my 16-month old daughter has more scheduling conflicts than I’ve ever had. This past weekend we had Ballet in the Park, Sesame Street Live, a social gathering, strawberry picking, a beach visit, a farm visit, and a family dinner. Coming in August: Folklorama, a trip to another beach, a trip to the Whiteshell, and perhaps a return visit to Hecla (her third trip to the island). This in addition to her trips down Corydon, in the Exchange, to the Forks, to the dog park, etc.

Even if I took every day off for the rest of the summer, I don’t think we’d be able to show my daughter everything we’d like her to see in and around Winnipeg. ChrisD.ca just reminded me about the Winnipeg Beach boardwalk; we haven’t been there at all this year.

Over the next week or so, I’m going to talk about some of these jewels of Winnipeg. I won’t focus on their history or take any photos, because there are already some very good people doing just that (Mr. Christian, Bryan Scott). But I’ll talk about what’s happening now, what we’ll hopefully see in the near future, and I’ll mention the hazards ahead.

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As expected, City Council voted 9-6 (Councillor Browaty having excused himself from the debate and vote) to not grant heritage protection to the Grain Exchange Annex.  Winnipeg Free Press

Councillors O’Shaughnessy and Fielding made it very clear that they felt the Annex had no heritage value whatsoever, with Councillor O’Shaughnessy trying to make it quite clear that in his opinion the Exchange District (a billion dollar asset in my opinion) has no value in his mind whatsoever; I assume he’s not a fan of 19th and early 20th century architecture and the tourists and commerce they can bring.

The most interesting thing about the debate was the fact that the argument towards demolition was based primarily on Heritage Winnipeg‘s decision to stand with the developer in saying that the Annex was not worth saving.  The dynamic of heritage preservation in this city has been changed, and not for the better, by Heritage Winnipeg’s decision to actively support the destruction of built heritage.  This was an odd choice for an organization whose mission is “to promote and encourage the conservation of historic/heritage structures and sites and attend to those matters which enhance and complement this purpose”.  As Councillor Gerbasi asked, why did Cindy Tugwell not just stay home if she didn’t think the Annex was worth saving?  Why did Heritage Winnipeg go out of its way to promote the demolition of a 1920 office building in good condition?

This odd change in behaviour, which was made with no public comment to Winnipeggers who have supported the organization in the past, comes just after the Dennistoun House situation, where Heritage Winnipeg’s Executive Directory Cindy Tugwell stated publicly that she hadn’t even realized that there was a heritage building facing demolition.

I sent an e-mail to both Cindy Tugwell and the President of Heritage Winnipeg, Penny McMillan, to find out if a representative would speak at council in favour of preserving the Annex.  I received no response to that correspondence, other than seeing that Cindy Tugwell had chosen to speak for demolition, even before the property owner and architect were added to the delegation list.

I don’t say this lightly, but I feel it needs to be said: when the next heritage building is at risk, I have no faith that Heritage Winnipeg will provide any advocacy whatsoever.  It’s not their job to compromise with developers; that is the job of city staff and city council.  The mandate of Heritage Winnipeg, like that of any defence attorney, is to defend their client to the best of their abilities.  When regular citizens are required to speak at council to defend heritage because Heritage Winnipeg has switched sides, it becomes obvious that the organization is no longer serving the purpose for which it is intended.

I would like to see a new organization created to work for the betterment of the Exchange District and the core area as a whole, because it’s clear to me that at the moment there are no citizen-run organizations we can rely on to ensure that we don’t lose the Exchange District piece by piece.  I’m imagining an Internet-based group, which relies on its members to lobby all levels of government when necessary to advance our agenda of a vibrant downtown, modeled on cities that truly know how to foster a healthy urban environment.

Is anyone on the Intranets willing to stand up for downtown Winnipeg and our billion-dollar asset?  I just watched Fight Club, so there’s a chance it may require wearing all black and shaving your heads.  Let me know if you’re interested.

Note: I also want to be clear that I do not fault the property owner, Artis REIT, or the architect, Ray Wan, for their plans.  As a business, even a business with an eye for heritage, Artis REIT is going to make choices that in their mind carry an acceptable amount of risk for a worthwhile return.  In their opinion, this plan was a better horse to bet on than preserving the Annex as part of the new development.  However, that does not mean that the city should absolve itself of any responsibility to negotiate for preservation.  Councillor O’Shaughnessy, as part of his statement, took us on a quick tour of all of the surface lots and new buildings that were a result of the city’s utter failure to preserve its heritage.  He also reminded us that the city made promises to support Artis REIT in the past with a heritage restoration but backed out, resulting in serious losses for the company.  Perhaps it’s no wonder that Artis REIT isn’t asking for a similar plan for the Annex.  Why should they risk their company on a city that isn’t willing to support its unique heritage district?

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Grain Exchange Annex and new parkade can co-exist

WINNIPEG – July 21, 2009 – The plan to build an architecturally-suitable parkade in the East Exchange District is a welcome development, but that doesn’t mean that the Grain Exchange Annex should be demolished, says Regan Wolfrom, a concerned Winnipeg resident.

“The proposed parkade will sit beside the Annex, so there’s no compelling reason to demolish a building in good condition,” Wolfrom says.  “The Exchange District is a billion-dollar asset, and every demolished building strips some of that value away.”

According to architectural renderings, the Annex will be replaced by several surface parking spaces, and an enlarged loading zone is also a possibility.  The parkade will be constructed on the adjacent property, and would not intrude on the existing footprint of the Annex.

“Tearing down a heritage building to expand a loading zone is the old way of doing things,” Wolfrom says.  “The end result will be less potential density and less tax revenue.  How does that make our downtown better?”

The owner of the Grain Exchange Building and the planned parkade is Artis REIT, a Winnipeg-based company that owns several other prominent buildings in the city, including Johnston Terminal and the Hamilton Building on Main Street.  Wolfrom says that he appreciates the work that Artis REIT is doing to preserve Winnipeg’s heritage.

“Artis REIT is a part of the solution in Winnipeg, and I know that they can come up with a viable plan that preserves the Grain Exchange Annex as part of their parkade project.”

Regan Wolfrom will be speaking at City Council on Wednesday, July 22nd in opposition to a recommendation from the Standing Policy Committee on Property and Development that delists the Annex portion of the Grain Exchange Building, removing its heritage protection completely and allowing a demolition permit to be granted.

For more information:
E-mail: info@reganwolfrom.ca

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Everyone has a lobby these days, and we’re always hearing about “special interest groups” and “vocal minorities” and so on.  But in Winnipeg, we are too silent on the biggest issue of the day, which is our core area.  We have various groups that are working and advocating on issues in our core area, but I’m not seeing a vocal movement to fight for a stronger urban environment in Winnipeg.

The pending demolition approval for the Grain Exchange Annex is a good example of our problem.  The bloggers who have written about it (Rise and Sprawl, Progressive Winnipeg, Average City, Kenton, The View from Seven, Regan the dirty liberal) are not only in favour of saving the Annex, but are collectively disgusted that the Winnipeg Parking Authority, The Forks North Portage Partnership, CentreVenture and the Exchange District BIZ are all apparently in support of demolishing an historic building within a National Historic Site to build a parkade beside half a block of existing surface parking lots.  So we write on our blogs, and readers comment on our blogs, usually in agreement, but that seems to be the end of it.  We’re not mobilized enough to bring real change to our city.


Now, two things about the Annex:

1.    There is no need to demolish the Annex is order to build a parkade.  Including the Annex in the parkade project is an easy way to dump an historic building that the owners do not find profitable at this time.
2.    Several years from now, when the Annex is long gone, there will be a desire on the part of developers to build commercial space along Lombard Avenue.  At that point, one of the existing surface parking lots will be converted to a new building, creating about the same amount of space as the Annex building before it was demolished.  We will then see approvals at to build a brand new building in our National Historic Site, to make up for space that was lost when City Hall allowed the Annex to be destroyed.

Wouldn’t it make more sense to build parkades on surface parking lots, and save the buildings for the expected increase in demand over the coming years?  If the Annex is unprofitable, couldn’t the city look at incentives for the property owner to save the building until demand increases?

I was torn about Dennistoun House, because there was a true conflict between two important goals: heritage versus increased core density.  But there is no conflict with the Annex: it’s an historic building in a National Historic Site, and there’s plenty of room for parkades beside it.  Even though many people will argue that parkades should never be built (and in an ideal world they wouldn’t be, but that’s not our world), few rational people can argue that there’s any sense in destroying a building we’ll all wish we still had five years from now.

So what can we do to save the Annex?  Heritage Winnipeg has been working to save the building, but that hasn’t been enough.  I personally think the issue with Heritage Winnipeg is that they exist to preserve, but that their mandate does not include economic and social development in the core area.  I think we need to take on a holistic mission to save our core.  We need to get together and build a strategy for saving this city.

There are many people in various groups in this city who care about the core, including members of the Active Transportation lobby, progressive political groups, and environmentalist organizations.  There are also business owners, civic leaders and academics who are passionate about this issue.  Why aren’t we banding together to communicate our common position to the city?

A movement to save our city starts by getting a little face time.  There is an EPC meeting on Wednesday, July 15th, and a city council meeting on July 22nd (a very big city council meeting, with the water utility, the Annex, and other fun).  These are the final meetings before summer break (as I said to Councillor Thomas, it must feel like getting out of school for the summer).  Unfortunately, we cannot have a voice at EPC on historical buildings, so our only chance to speak is at City Council on the 22nd.

Who is willing to speak at council?  If those of us who care about this issue work together, we can rotate our schedules to make sure we always have a voice when these decisions are being made.  I’m thinking about going to City Council, but it’s hard to get the time off (activism was much easier when I was self-employed).

Is there anyone who’s ready to speak for all of us at City Council?

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There has been some discussion in this city about the Smart Bag Co. building (1884) at 145 Pacific Ave.

See Robert Galston’s posts:
Don’t act surprised
A silk gym on a parkade’s head
Saved for now

An application was made for it to be demolished, in order to make way for a 3-level parkade and a high-performance gym.  Sport Manitoba decided to alter its proposal, sparing the heritage property for the time being.  This was in exchange for the building becoming a Grade III listed property, rather than Grade II, Grade III being far less restrictive for developers.


This drawing (not a final version, so there is definitely room for some good ideas) seems to indicate that only the façade of the 1884 structure will be kept.  The demolition of the Smart Bag Co. building is phase two of the project, so it may not happen if the funding doesn’t materialize.  However, this doesn’t change the fact that the city appears to be using the Grade III listing for the preservation of façades as opposed to buildings.  Of course, it is possible that City Council will reject the application for demolition of the Smart Bag Co. building, if the demolition is sent to Council for a vote.  (see the RRC addendum below to understand my wariness of the process)

The three grades of listed properties

Here is the description of the three protection grades, from the City of Winnipeg’s Planning, Property and Development Division:

Grade I buildings are Winnipeg’s outstanding examples of architectural and historical merit, which are to be preserved in perpetuity. Restoration and maintenance of the entire interior and exterior of these structures are the only types of work permitted. In general, alterations, deletions, and additions to these buildings are considered unacceptable.

Grade II buildings include the majority of Winnipeg’s heritage stock. Sympathetic alterations and additions to the exterior and listed interior elements of these buildings may be allowed in order to maintain the economic viability of the structure. In certain instances, the adaptive re-use of listed interior elements may be permitted.

Grade III buildings have been identified as moderately significant heritage examples worthy of listing. Suitable exterior alterations and modifications may be permitted. There is usually no restriction on interior alterations.

Very few buildings in Winnipeg are listed as Grade I, including the Walker Theatre, the Grey Nun’s Convent (St. Boniface Museum), the Union Bank Building (home of the planned RRC expansion), and the Upper Fort Garry Gate.

It will be interesting to see what happens with the Union Bank Building; the Red River College expansion should need to follow very strict guidelines due to the building being a National Historic Site (which should carry more weight than its Grade I designation).

But as a Grade III property, what can happen to the Smart Bag Co. building?  Here’s what The Historic Buildings By-Law (1474/77) says about Grade III:

(c) Grade III; the objectives of which are:

(i) to prevent demolition, removal, alteration or repair of the building, erection or structure unless and until shown to be necessary to the satisfaction of the Designated Committee in cases of removal,
alteration, or repair and Council in the case of demolition, and

(ii) to regulate any necessary demolition, removal, alteration or repair of the building, erection or structure so as to preserve the special architectural or historical interest as far as possible, and

(iii) to record, or preserve where possible, components deemed to have special architectural or historical interest prior to, or in the course of, any necessary demolition, removal, alteration or repair.

So what does this mean?  It means that the building can be altered to preserve its architectural or historical interest as long as it meets the approval of the Standing Policy Committee on Property and Development.  Grade III structures can be demolished or removed through a vote of Council, while the Grades I and II require delisting or at least a downgrade to Grade III.

This means that as long as the committee is satisfied that there is a satisfactory level of preservation involved extensive changes to the interior and the exterior can be approved.  The big question in my mind is where the line is between alterations and partial demolition.  I could not find an explanation of this in The Winnipeg Building By-Law (4555/87).


A trend that has emerged in the past decade in development is façadism, where the façade of a historical building is preserved while most of the building is demolished.  This has become popular in Europe and in some American cities.  The best example of façadism in Winnipeg was actually caused by a fire, as opposed to a wrecking ball: the St. Boniface Cathedral (1908).

In 1968, the cathedral caught fire and was mostly destroyed.  Rather than demolish the ruins, which were still quite impressive, renowned architect Etienne Gaboury designed a reconstruction that preserved what had remained after the fire.  The end result is a unique landmark that is probably one of the best examples of façade preservation on earth.

The St. Boniface Cathedral is a much different case than most instances of façadism, as the structure was not demolished by choice.  Most orphaned façades are on purpose.

Some people view façadism as a compromise between preservation and development.  I personally view it as development that pretends to preserve history, while in reality takes life out of the buildings and leaves empty fronts.  The parts of a heritage building that are demolished are gone forever, and the remnants look more like movie set pieces than living history.

I’m not saying that I am condemning façadism in all its forms, but I am saying that it isn’t preservation when almost all of the building is demolished.  In fact, many preservationists view façadism as a danger to their efforts, because what looks at first like a compromise is really a loss for preservation.  A project that takes a historic structure and leaves only its façade is demolition and new development, not restoration or preservation.  In addition to the loss of history, façadist construction is often very unappealing, in my opinion:

Façade #1Façade #2Façade #3

Can this really be called preservation, when it more closely resembles a living death?  I’m not sure the designers and builders of the original structures would appreciate these frankensteins.

Originally, I believed that an attempt to convert a structure such as Smart Bag Co. into a parkade or a sports facility would require delisting, as the only retrofit I can imagine would include the removal of most of the original structure, perhaps preserving the façade alone.  I see now that delisting is not required; however, City Council approval of partial demolition is required.  That is the life and death cycle of a Grade III building; I wouldn’t call it protected — I’d call it buffered.

Middle ground

So is there a middle ground between façadism and preservation?  Is there a way to redevelop a heritage building, rather than only saving the front or forcing it to stay exactly the same?  I’m not sure.

On the one hand, it’s important to preserve our city’s history by keeping the best examples of the past in their original state.  However, if we save all of our historic buildings just as they are, we’ll end up with two hundred beautiful heritage buildings, but half of them will be empty.  Our city cannot sustain the complete preservation of so many buildings in their original states.

(a beautiful photo from Bryan Scott – Winnipeg: Love and Hate)

One proposed project that is receiving some criticism is the renovation of the Masonic Memorial Temple (1895) on Donald.  The existing historic building has very few windows due to its former use for Masonic rites, so the plan that was approved by the city includes a glass addition that will protrude from the North Wall and hang over the sidewalk from the second floor.  Is this an innovative way of improving space in a historic building, or the defacement of a treasured landmark?  I suppose it’s all a matter of opinion.

Corner rendering #1

Corner rendering #2

Can an existing building of historic value be redeveloped?  I think it can be.

The best example of a redevelopment (as opposed to pure façadism) is the Red River College Princess Street Campus.

(Images taken from http://www.architecture.uwaterloo.ca/faculty_projects/terri/sustain_casestudies/princess.html)

Five historical buildings were partially demolished (a bank from the 1960s was demolished with some materials reused), while their fronts were preserved and restored, and large portions of the original buildings were retained.  In addition, a neighbouring warehouse building on William Avenue was completely renovated and joined to the structure.  I find the interior of the RRC building to be more interesting than the façades, because I’ve always had an interest in the more utilitarian parts of heritage buildings.

Here is an excellent diagram that’s part of an article from Canadian Architect:

(More info on the original buildings can be found at http://www.heritagewinnipeg.com/advocacy/redRiver.htm)

In essence, Red River College’s Princess Street Campus is part façadism and part something else.  And it’s that something else that is very exciting.

Rather than removing the existing buildings entirely, the structures were joined together along with new construction to create a blend of old and new.  The original buildings by themselves did not meet RRC’s needs, and they had been vacant and neglected for thirty years.   So by redeveloping as opposed to completely demolishing, the end result was far more palatable than façades alone.  Not everything was saved, but the Grain Exchange trading floor is there, as are some original vault doors.  Doug Corbett, George Cibinel and their team came up with an architectural design that gave the old buildings a second life and created a building that respects the history of the Exchange District.

Perhaps the solution to our preservation problems is to choose the best option for each situation.  For Red River, the vacant buildings on Princess were reused as much as possible.  For the Former Union Bank Building, full preservation is the best idea.  So what about little old Smart Bag Co.?  Hopefully the final proposal will take a page from architects like Etienne Gaboury and the team at Corbett Cibinel; with a little daring, we can have something the breathes new life without snuffing out the history.

RRC Addendum

Note: this might be an error on my part, but it appears that the Red River College Princess Street Campus was constructed without proper delisting of two Grade II buildings, as their alterations were more extensive than a Grade II listing should allow.  The Historic Buildings By-Law still lists 160 and 164 Princess St as Grade II, which I believe means that these changes should not have been allowed.

(b) Grade II; the objectives of which are:

(i) to preserve the entire exterior of the building, erection or structure
and such of its interior elements as are specified in the listing, and

(ii) to ensure that all repairs thereof are appropriate to their special
architectural or historical interest, and

(iii) to prevent or regulate demolition, removal, alteration or repair of the
remainder of such interior in the manner described in subsection

The three Grade III buildings may have had proper approval by Council (I haven’t checked at this point) for their partial demolition, but I don’t know how permits could have been given for 160 and 164 without reclassifying them as Grade III or delisting them.  What does this mean for the Former Union Bank Building?  Can its Grade I interior be altered without proper historical appropriateness?

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