May 1, 2020

To whom it may concern:

Re: Request for exemption from Interim Control By-law 78-2019 3690 Munich Court, Windsor, Ontario (the "Property")

OUR FILE: 75450

We are the lawyers for 2498655 Ontario Inc. regarding a request for an exemption from Interim Control By-law 78-2019, which imposed interim control on transport terminals within the City of Windsor for one year from June 3, 2019 (the The following is our submissions for "ICBL"). Council's consideration with respect to our client's request for the Property's exemption from the ICBL.

Council Resolution 291-2019, which approved the ICBL, permits Council to consider an exemption from the ICBL where there is a determination that the creation of a new transport terminal would not conflict with the general purpose and intent of the ICBL. Our client purchased the Property from the City of Windsor (the on January 29, 2016 for the "City") purpose of operating a transport truck terminal and transport storage area. Since that time, it has developed the Property for that purpose and has been working with the City and other regulatory bodies to obtain site plan approval, which necessitated environmental and archeological studies with respect to the Property.

After submitting an initial site plan application to the City, which was approved subject to certain conditions being satisfied, including completion of an Archeological Assessment and Environmental Evaluation Report, the City cancelled the application due to what the City determined was inactivity on the part of our client. This was in fact not the case as our client was going through the necessary channels to comply with the conditions imposed by the City.