Thank you for the…

Thank you for the opportunity to comment on Wellington County Official Plan 120 (OPA 120). We have the following requests/comments regarding Wellington County OPA 120:

1. Request that the total number of Households in 2051 for Clifford within Table 6 be increased from 580 to 794, in support of the proposed urban expansion in Clifford, as supported by Town of Minto and further described below.
2. Request that the proposed boundary expansion for the Clifford Urban Area, as originally approved by the April 11, 2023 provincial decision on OPA 119, be re-implemented, which the lower tier municipality is in support of as further outlined below.

Through the County of Wellington Muncipal Comprehensive Review, Clifford (Park St) Developments Inc. have submitted a request to the County of Wellington as follows (and further shown in Attachment 1):

- To redesignate approximately 4.8 hectares (11.9 acres) of land located at 41 Park Street West, Clifford (Town of Minto) from Future Development to Residential;
- To expand the urban boundary of Clifford to accommodate an additional 5.8 hectares (14.3 acres) of the subject lands for Community Area (Residential) uses; and,
- To remove 0.23 hectares (0.56 acres) of the subject lands from the Urban Area of Clifford. The purpose of this reduction is to buffer the proposed development from the existing dwelling located adjacent to the subject lands. There is no concern with MDS as the farmer has ended his dairy operation.

The following is a summary of recent events pertaining to the proposed Clifford boundary expansion, in chronological order:

- April 11, 2023 – The original decision by the Province on Wellington County OPA 119 which was posted on the ERO expanded the Clifford urban boundary.
- November 2, 2023 – the Ministry of Municipal Affairs and Housing sent a letter to municipalities requesting that lower-tier municipalities provide feedback, by December 7, 2023, on the provincial changes made to the various official plans (OPA 119 in the case of Wellington County). This letter from the Ministry is included as “Attachment 2”.
- November 21, 2023 – The Town of Minto Council passed a resolution directing staff to respond to the above-mentioned letter from the Ministry of Municipal Affairs and Housing expressing support to maintain the urban expansion in Clifford. The Town of Minto staff report is included as “Attachment 3”.
- December 6, 2023 – Bill 150 received royal assent, which reversed the modifications made by the Province on Wellington County OPA 119.
- February 6, 2024 – The Town of Minto Council passed another resolution directing staff to request, through the ERO posting for OPA 120, that the Clifford urban expansion be re-introduced. The Town of Minto staff report is included as “Attachment 4”.

The following information further supports requests 1 and 2 mentioned above:

- Table 3 (section 5.1) and Table 4 (section 5.2) of the County’s Final Municipal Servicing Analysis (URL link included) indicate that Clifford will have an excess reserve water capacity of 612 Equivalent Residential Units (ERU’s) by 2051, and excess reserve wastewater capacity of 175 ERU’s by 2051, respectively. Section 5.3 further concludes that Clifford is the only Urban Centre within the Town of Minto that is projected to have sufficient water and wastewater capacity to 2051.
- The Town of Minto Land Budget Table in the Land Needs Assessment (PDF page 219 within the URL link) identifies a total unit potential for the Clifford Urban Centre of 229 units. This number does not include units that can be accommodated in land designated for Future Development, as identified in the second footnote below the table. Considering that between 2021 to 2051, the Household Growth as proposed in Table 6 of OPA 120 is only 190 units (from 390 to 580), this suggests that the entire population growth allocated to Clifford can be accommodated within the existing Community Area land supply, with no changes to the Clifford urban boundary or the Future Development designation which is on a portion of the lands. However, the Town of Minto has an identified need of 18 hectares of additional Community Area lands per Figure ES-3, which assumes that all the Future Development Lands in Minto would be re-designated for Community Area uses.
- The requested increase in the 2051 Household count for Clifford in Table 6 to 794 is calculated by adding 175 (the lesser of water and wastewater excess reserve capacity identified in the Municipal Servicing Analys) and 229 (the number of units feasible on current residential-designated lands as per the Land Needs Assessment) to the 2021 Household count of 390 listed in Table 6 (390+175+229 = 794).
- Provincial policies prioritize growth in areas with existing servicing capacity. If the growth forecast for Clifford in OPA 120 does not facilitate the the re-designation of Future Development lands for Community Area land uses and the expansion of the Clifford urban boundary, this will require additional Community Area land to be accommodated via a larger settlement area expansion in Palmerston and/or Harriston, both of which are noted as having a servicing deficit in 2051, demonstrating that this approach would represent an inefficient growth scheme that will not align with infrastructure capacities, will not optimize the use of existing infrastructure, and instead will require and prioritize new infrastructure and capacity upgrades in Palmerston and Harriston over the optimal use of existing infrastructure capacity available in Clifford. Clifford is the only Urban Centre which will have excess reserve servicing capacity by 2051, and therefore there is an opportunity to designate the subject land for residential uses, which are planned to be developed in a timely manner, to provide for the appropriate and optimal use of the available excess reserve servicing capacity.

Thank you for your consideration of our comments.

Andrew Eldebs, P.Eng
Clifford (Park St) Developments Inc.