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14 - June 23, 2026 Public Meeting Agenda Package110c, ElginCounty Elgin County Public Meeting Orders Of The Day Tuesday, June 23, 2026, 9:30 a.m. Council Chambers 450 Sunset Drive St. Thomas ON Note for Members of the Public: Please click the link below to watch the meeting livestream: https://video.isilive.ca/elgincounty/live.html Accessible formats available upon request. Pages 1. Meeting Called to Order 2. Disclosure of Pecuniary Interest and the General Nature Thereof 3. Reports of Staff or Consultants 3.1 Policy Planner- Clovermead Official Plan Amendment 2 4. Public Comments 5. Closed Meeting Items 6. Motion to Rise and Report 7. Adjournment /00 ,000 0 ElginCc),L,inty Report to County Council From: Lindsay King, Policy Planner Date: June 23, 2026 Subject: Clovermead Official Plan Amendment Recommendation(s): THAT the report titled "Clovermead Official Plan Amendment" from the Policy Planner dated June 23, 2026 be received and filed. Introduction: The purpose of this report is to provide planning analysis and a recommendation regarding Official Plan Amendment Application OPA 01-26 for lands municipally known as 11302 and 11460 Imperial Road, located in the Township of Malahide. The application proposes to amend the Elgin County Official Plan to permit a site -specific large-scale agri- tourism use associated with the existing Clovermead Adventure Farm operation within lands designated Agricultural. The subject lands are located within a Prime Agricultural Area, where the Provincial Planning Statement, 2024 (PPS) generally limits permitted uses to agricultural uses, agriculture -related uses, and on -farm diversified uses (OFDUs). While the existing Clovermead Adventure Farm has historically operated as an agricultural and agri-tourism operation, Planning Staff are of the opinion that the scale and intensity of the existing agri-tourism component has evolved beyond what would reasonably be contemplated as an OFDU under the PPS and associated provincial guidance. Accordingly, Planning Staff are of the opinion that the agri-tourism component of the operation is more appropriately characterized as a site -specific non-agricultural use within a Prime Agricultural Area and should be evaluated against the applicable PPS policy framework for non-agricultural uses. The proposed amendment seeks to recognize and appropriately regulate an existing long-established operation through a site -specific policy framework while limiting the extent of the non-agricultural use to approximately 11 hectares of the subject lands in order to maintain the long-term agricultural viability and function of the balance of the property. Pursuant to Section 17 of the Planning Act, Elgin County Council is the approval authority for amendments to the Elgin County Official Plan. Page 2 of 20 Background and Discussion: The subject lands are municipally known as 11302 and 11460 Imperial Road and are located approximately 1.7 kilometres north of the Town of Aylmer within the Township of Malahide. The lands are approximately 21.8 hectares in area and are designated Agricultural within the Elgin County Official Plan (as shown in Appendix A) and Agriculture in the Township of Malahide Plan (as shown in Appendix B). An aerial photo of the site is provided in Figure 1 (and a higher resolution version is provided in Appendix C). Figure 1 - Aerial Photo of Cloveread Adventure Farm The surrounding area is characterized predominantly by agricultural uses, including active farming operations, agricultural buildings, and scattered rural residential uses. Approximately 50% of the subject lands will continue to be actively utilized for agricultural purposes, including apiculture operations, crop production, orchards, and limited livestock -related activities. Page 3 of 20 The subject lands contain the existing Clovermead Adventure Farm operation, a long- established agri-tourism use associated with an active agricultural operation that includes agricultural education, farm -based recreation, food service, seasonal attractions, and agricultural awareness programming centred around beekeeping and pollination. Figure 2 - Clovermead Adventure Farm Map The Elgin County Official Plan contains policies intended to protect agricultural lands, support agricultural operations, and maintain rural character. Section 5.5 of the Official Plan provides that development within the Rural Area shall first and foremost protect agricultural land, agricultural operations, and rural character, while permitting non- agricultural development only where impacts are appropriately addressed and transportation and servicing requirements are satisfied. Furthermore, the Elgin County Official Plan recognizes agri-tourism operations as an important component of the rural economy. Section 5.14 contemplates agri-tourism operations primarily as on -farm diversified uses, generally limited to less than one hectare in size where located within agricultural areas. However, the Official Plan also recognizes that larger -scale agri-tourism operations may occur where impacts to farming operations and rural character are addressed. Planning Staff are of the opinion that the scale, intensity, and visitor -oriented infrastructure associated with the Clovermead Adventure Farm operation have evolved beyond what would reasonably be contemplated as an on -farm diversified use under both provincial and County policy. The proposal includes organized admissions infrastructure, formalized parking, site circulation improvements, servicing upgrades, and destination - based seasonal programming that collectively exceed the scale reasonably contemplated for a secondary and limited on -farm diversified use. Accordingly, Planning Staff are of the Page 4 of 20 The applicant is proposing to formalize and improve an existing overflow parking area currently utilized to accommodate seasonal demand associated with the operation. Planning Staff note that the proposed parking expansion area has historically functioned as overflow parking and is intended to improve site organization, traffic circulation, and operationally safety rather than facilitate unrestricted expansion of the use. Figure 4 - Cloveread Splashpad Page 5 of 20 Section 4.3.3 of the PPS generally limits permitted use within the Prime Agricultural Areas to agricultural uses, agricultural -related uses, and on -farm diversified uses (OFDUs). Planning Staff are of the opinion that while portions of the Clovermead Adventure Farm operation and are of the opinion that the agri-tourism component no longer reasonably fits with the policy intent of an OFDU. �a 4 >m i w owm dw n eJw � tw .. r rvs eInns rrr .d ° Wy ? Yw xAM. e, or � o 4:4' ���lllllf 18,ry16ad IMOfI' 4 4 as a �mvFm:. M MANOR .L h xw L + arty l;Av iwa � �� _ %md 6vrziey} u.,xxi L de mryn.vi3vniwrv. grymdmmufinwrmmiu® —J, rev �tlIIAN ,vA 9 r x'N dttlP -i iWv_ �ryan'att iMaxarq. Nfl 4 � .„ rrV �u d'e ,.... ... Eartr.�Jil u.,ruronrttr asnvCimvrwmm d xi:;wf wll4rgi s 1-1— +V if * sr$ Page 6 of 20 Planning Staff acknowledge that the operation remains functionally tied to agriculture and continues to support agricultural awareness, pollination education, and agricultural tourism associated with an active farming operation. However, the operation has evolved into a large-scale, destination -based agri-tourism use characterized by dedicated visitor infrastructure, organized admissions, seasonal attractions, parking areas, food service components, and site servicing demands that exceed what would reasonably be considered secondary and limited in scale. The proposal includes continued operation of an established destination agri-tourism use, upgrades to site circulation and parking, servicing improvements, and a new admission building intended to better organize and safely accommodate existing visitor demand. Collectively, these characteristics are more appropriately reflective of a site -specific non- agricultural use than an OFDU as contemplated by the PPS. Accordingly, Planning Staff are of the opinion that the appropriate policy framework for evaluating the proposal is Section 4.3.5 of the PPS respecting non-agricultural uses in Prime Agricultural Areas. Section 4.3.5.1 of the PPS permits non-agricultural uses in Prime Agricultural Areas provided specific policy tests are satisfied, including that- 1 . The lands do not comprise a specialty crop area; 2. The use complies with the Minimum Distance Separation (MDS) formulae; 3. There is an identified need for the use within the planning horizon; 4. Reasonable alternative locations have been evaluated and there are no reasonable alternative locations in lower priority agricultural areas; and 5. Impacts on surrounding agricultural operations are avoided or, where no possible, minimized and mitigated. Planning Staff have evaluated the proposal against the above criteria, as follows in Table 1. PPS Policy Test Planning Analysis The lands do not The subject lands are not located within a Speciality Crop Area compromise a as defined by the PPS. The Agricultural Impact Assessment specialty crop area submitted in support of the application confirms that the lands do not contain specialty crop lands. Planning Staff are satisfied that the proposal satisfies this criterion. Compliance with Supporting materials submitted by the applicant confirm Minimum Distance compliance with applicable MDS requirements. Planning Staff are Separation (MDS) satisfied that the proposal does not create adverse land use Formulae conflicts associated with livestock operations and complies with the intent of the PPS to maintain agricultural compatibility. There is an Planning Staff are satisfied that an identified need exists for the identified need proposal. Clovermead Adventure Farm represents a long - within the planning established agri-tourism operation that provides agricultural horizon education, tourism opportunities, pollinator awareness, school programming, and rural economic activity within Elgin County. Importantly, the proposal is not speculative in nature nor intended to establish a new tourism destination within Prime Agricultural Page 7 of 20 Area. Rather, the application seeks to appropriately recognize, regulate, and safely accommodate an established operation that has demonstrated sustained public demand over several decades. The proposal additionally facilitates operational improvements related to parking, circulation, servicing, pedestrian safety, and visitor management required to support the continued functioning of an existing operation. The Elgin County Official Plan identifies in Section 3.14 that tourism is a "significant contributor to the County's economy" and "strategic priority". Furthermore, Sectio n4.3.6 of the PPS states that "planning authorities are encouraged to support local food, facilitate near - urban and urban agriculture, and foster a robust agri-food network" which is defined as "a network that includes elements important to the viability of the agri-food sector such as regional infrastructure and transportation networks; agricultural operations including on -farm buildings and primary processing; infrastructure; agricultural services, farm markets, and distributors; and vibrant, agriculture -supportive communities." Planning Staff are of the opinion that this represents an identified planning need consistent with rural economic development and placemaking objectives recognized through the Elgin County Official Plan. Reasonable Planning Staff are satisfied that no reasonable alternative alternative locations exist. The operation is functionally dependent upon and locations have integrated with an active agricultural operation, including apiary been evaluated functions, agricultural programming, and farm -based education and there are no activities that require an agricultural setting. Relocation to reasonable settlement areas would not reasonably support the agricultural alternative and operational characteristics of the use and would likely locations in lower introduce land use compatibility concerns related to traffic, noise, priority agricultural animal uses, and seasonal visibility activity. Furthermore, Staff areas. note that Elgin County is predominantly comprised of Prime Agricultural Areas, substantially limiting opportunities to relocate the use to lower priority agricultural lands. Existing agri-tourism components are generally clustered within repurposed farm buildings and consolidated portions of the site, consistent with provincial and OMAFRA guidance encouraging utilization of lower priority agricultural areas where feasible. Planning Staff additionally note that the proposed parking improvements are intended to formalize an area already utilized for overflow parking associated with the operation, rather than introduce a new disturbance area. Impacts on Planning Staff are satisfied that the impacts on surrounding surrounding agricultural operations have been appropriately addressed. The agricultural proposal has been designed to maintain agricultural production operations are on approximately one-half of the property, cluster non-agricultural avoided, activities within a defined area, and avoid fragmentation of the broader agricultural parcel. The recommended site -specific Page 8 of 20 minimized, and permission limits the agri-tourism component to the mitigated. approximately 11 hectares and maintains agricultural lands surrounding portions of the use, thereby assisting in buffering and mitigation potential compatibility concerns. Supporting technical materials, including the AIA and Traffic Impact Study, identify mitigation measures including landscape buffering, site circulation improvements, access upgrades, traffic management, servicing upgrades, and strategic siting of activities toward the interior of the property. The operation remains seasonal and primarily daytime in nature. Property owners within 120 metres of the subject lands were circulated for comment on June 2, 2026 and at the time of writing this report, Planning Staff have not received any comments or objections regarding agricultural compatibility at the time of writing this report. Collectively, Planning Staff are satisfied that impacts have been avoided where possible and otherwise minimized and mitigated consistent with PPS policy direction. The Ministry of Municipal Affairs and Housing (MMAH) was circulated on the application and provided comments for the County's consideration. Provincial comments identified considerations respecting agricultural compatibility, Minimum Distance Separation (MDS), the interpretation of permitted agricultural uses under the PPS, and potential natural heritage and natural hazard considerations associated with an intermittent watercourse and regulated floodplain area on the subject lands. The ministry requested notice of Council's decision on the application. Planning Staff have considered the provincial comments as part of the review of the application and note that the applicant has revised the Planning Justification Report to evaluate and justify the proposal as a site -specific non-agricultural use within a Prime Agricultural Area, rather than as an agricultural -related use or a on -farm diversified use. Planning Staff are satisfied that this represents the appropriate policy framework for evaluation and have assessed the proposal against the policy tests established under Section 4.3.5.1 of the PPS. With respect to MDS, the applicant has also provided MDS calculations showing the proposal conforms with MDS formulae, and staff are satisfied that the applicable separation requirements have been addressed and that the proposal will not create adverse compatibility impacts with surrounding agricultural operations. Regarding natural heritage conservation considerations, Planning Staff are satisfied that the proposed development area is substantially setback (approximately 250 m) from the Catfish Creek Conservation Authority regulated floodplain area and associated natural features. Staff also note that the Catfish Creek Conservation Authority shared no concerns with the proposal, and they would be circulated through the subsequent site plan process by the Township of Malahide. Planning Staff are satisfied that the proposal meets the applicable policy tests established under Section 4.3.5 of the PPS for non-agricultural uses within Prime Agricultural Areas. While the proposal represents a non-agricultural use within Prime Agricultural Area, Page 9 of 20 Planning Staff are of the opinion that the proposed site -specific and area -limited approach represents an appropriate and balanced planning response. The recommended Official Plan Amendment recognizes an established and functionally agricultural -related tourism operation while maintaining the long-term agricultural function of the balance of the lands and preventing unrestricted expansion of the non-agricultural component. Financial Implications: There are no direct financial implications to Elgin County associated with the proposed Official Plan Amendment. The applicant will be responsible for implementing any required site improvements, infrastructure upgrades, servicing modifications, and mitigation measures identified through subsequent planning approvals, technical review processes, and applicable development agreements. Advancement of the Strategic Plan: The proposal supports the "Sustainable Community Growth" theme of Elgin County's Strategic Plan by: • Supporting rural economic activity, tourism, and agricultural diversification; • Supporting agricultural awareness, education, and community engagement opportunities; • Facilitating appropriate rural development while maintaining the long-term agricultural function of the subject lands; • Supporting placemaking and destination -based tourism opportunities within Elgin County; and • Encouraging site improvements that improve operational safety, circulation, and servicing for an established rural tourism destination. Planning Staff are of the opinion that the proposal represents a balanced approach that supports rural economic resilience while maintaining the long-term protection for agricultural lands. Local Municipal Partner Impact: The Township of Malahide is the affected Local Municipal Partner. The subject lands are designated Agriculture in the Township of Malahide Official Plan and are subject to corresponding local Official Plan Amendment approval. Additionally, at the Township of Malahide level, the applicant is required to obtain Zoning By-law Amendment and Site Plan Control approvals which will allow the Township further oversight on permissions and site design. As Elgin County is the approval authority for amendments to the Elgin County Official Plan, the County Official Plan Amendment must proceed prior to final consideration of the corresponding local Official Plan Amendment and implementing Zoning By-law Amendment. No concerns or objections have been identified by Township staff through the circulation process. Page 10 of 20 The proposed County Official Plan Amendment will provide the upper -tier policy framework necessary to support alignment between County and local planning documents respecting the long-established Clovermead Adventure Farm operation. Communication Requirements: Notice of the statutory public meeting has been provided in accordance with the Planning Act. Following Council's decision, notice of approval or refusal will be issued in accordance with the Planning Act, including the applicable appeal provisions. Provincial ministries and agencies circulated on the application, including the MMAH, will be provided notice of Council's decision. Pursuant to Section 17 of the Planning Act, Elgin County Council is the approval authority for amendments to the Elgin County Official Plan. Conclusion: Planning Staff are satisfied that the proposed Official Plan Amendment represents an appropriate, site -specific planning response to recognize and regulate a long-established agri-tourism operation that has evolved beyond the scale and intensity reasonably contemplated for an on -farm diversified use under the Provincial Planning Statement, 2024. While the proposal constitutes a non-agricultural use within a Prime Agricultural Area, Planning Staff are satisfied that the application has demonstrated consistency with the applicable policy framework of the PPS, include the policy tests established under Section 4.3.5 respecting non-agricultural uses. Planning Staff are of the opinion that the proposal appropriately demonstrates: • Compliance with Minimum Distance Separation requirements; • No impacts to specialty crop areas; • An identified need to recognize and safely accommodate an existing long- established operation; • No reasonable alternative locations that would appropriately support the functionally integrated agricultural and agri-tourism nature of the use; and • Appropriate avoidance, minimization, and mitigation of impacts on surrounding agricultural operations. The recommended amendment is limited in scope and includes a clearly defined site - specific permission restricted to approximately 11 hectares of the subject lands. This approach establishes clear boundaries for the non-agricultural component of the operation, maintains agricultural production of the balance of the property, supports compatibility with surrounding agricultural uses, and ensures that any future expansion would require additional planning review and review and approval. On balance, Planning Staff are satisfied that the proposal represents an appropriate and carefully bounded planning response that supports agricultural tourism, rural economic activity, and agricultural education while maintaining the long-term agricultural function Page 11 of 20 and viability of the subject lands. Accordingly, Staff are recommending approval of Official Plan Amendment application OPA-01-26. Attachments: Appendix A — Elgin County Official Plan Map Appendix B —Township of Malahide Official Plan Map Appendix C — Location Map Appendix D — Concept Plan / Site -Specific Permission Area (11 ha) Appendix E — Ministry of Municipal Affairs and Housing Comment All of which is Respectfully Submitted Lindsay King Policy Planner Reviewed for Submission Mat Vaughan Director of Planning Approved for Submission Blaine Parkin Chief Administrative Officer Page 12 of 20 . ... ..... . . . ....... . . . . ............. . .... . . . . ....... r. 73 N. . . . . . . ............... . ..... .. . 0 25 50 100 150 73 Meters Site Location Legend County of Elgin Official Plan Subject Site: 340800004009700 & 340800004009800 Land Use Designations X Strategic Employment /A�,/,11/2`//`,"111 1,0000 ElginCour­ity File Number: Settlement Areas Areas Owner: CLOVERMEAD APIARIES LIMITED & St. Thomas Municipal Airport Schedule'A' LITTLE AYLMER FARMS LTD Tier 1 CA: Catfish Creek Conservation Authority County Structure Map Created By: TE EM Tier 2 Provincial Highway Date: 06/11/2026 Date: Mar 16, 2026 Township of Malahicle Tier 3 County Highway 0 Projection: NAD 83 Zone 17N Disclaimer: The County of Elgin takes every precaution to put up-to-date and correct information on all maps published by Corporate Applications, The Corporation of the County Elgin F� Agricultural Pagg_1 Jof 2 crcaT Road However, it does not expressly warranty that the information contained in the map accurate the date of publication. All users may use this information n t their own risk. The Municipality will not Prepared By: Planning and Development entertain any claims arising out of the use of this map or information. S bjet Site i I, �IIII �uu mlllli +� �Y��l III IIIIII` �' 08 %,61, IIIII mll II mllllplQ � � i 91 0 ��[ffnmm W-M.'ariffi, �Irdoi 1., III t LEGEND ®e® ®" SUBJECT LANDS Location Map URCEUSES REIIS�IIOIIII BASE -FEATURES AL FIGHWAKS L NATURALIHIERITAGPROVINCIAL - Scnedule'Q1'— Land Use Plan NATURAL GAS RESERVES COUNTY ROADSMalanide r:xCONSERVATION (LANDS ^^^^ LOCAL ROADS Subject Site: 11302 & 11460 Imperial Road MINERAL AGGREGATE RESOURCES �� "`^^^'^'A'ATIERCDUN26E15'HORFJLIINE File Number: I' AGRICULTURE RAILWAY NON RESOURCE. USES pace Owner: CLOVERMEAD APIARIES LIMITED & SUBURIBAIN'AREA "(Municipal Boundary LITTLEAYLMER FARMS LTD HOME. BASED INIDUSTIRRA.ILPP.RRK Flood Leine CA: Catfish Creek Conservation AuthorityHIGHWAY M LANDS �I CONSERVATION (LANDS CCCAReguiatiian Limit Created By: TE SPECIFIC POLICY AREAS YWaterbody Date: 06/11 /2026 pIgjlg MINERAILAGGREGATE OPERATION� 0 HAMLET Township of Malahide Page 14 ofF Q;,! CDMMU 111 TY IMPR©VEMENT PR©J ECT AREA g Location Map Legend Subject Site: 11302 & 11460 Imperial Road Subject Site File Number: Owner: CLOVERMEAD APIARIES LIMITED & /% County Road LITTLE AYLMER FARMS LTD CA: Catfish Creek Conservation Authority Created By: TE j% % ° Local Road Date: 06/11/2026 Township of Malahide Buildings The Corporation of the County Elgin M ,pN` \ Prepared By: Planning and Development 0 30 6CPage 15 of �00 - -- d Ey � 3E - "T- o - "�p- a� -�o�� N w ME Q LL=Q J' a L i mayng IemIeN saai16unoA i Old :III iiJj j �I s r--1 ffm "z Iw ;-� Li - - — — —G— —sNuel agtlag ' ^� moIeuglod JaMogPIIM/ _ c peg bulgaeal agtlag " a —.......... a`L ,Q i 0 yLL o� dd e 00 d� .d d� �Q a =d k � a `m - e it I (1 I o� d �o r y m m m m m Q d o y _ rn a a e a0 Ministry of Municipal Affairs and Housing Municipal Services Office Western Ontario 2nd Floor 659 Exeter Road London ON N6E 1 L3 Tel: 519 873-4020 Toll Free: 1 800-265-4736 Fax: 519 873-4018 May 15, 2026 Diana Morris Ministere des Affaires municipales et du Logement Bureau des services aux municipalites de I'Ouest de I'Ontario 2e etage 659 Exeter Road London ON N6E 1 L3 Te1.: 519 873-4020 Sans frais : 1 800-265-4736 Te1ec.: 519 873-4018 Senior Planner 450 Sunset Drive St. Thomas, ON, N5R 5V1 dmorris@elgin.ca Ontario 0 Sent via e-mail only Re: One Window Provincial Review Comments Official Plan and Zoning By-law Amendment Applications — Clovermead Thank you for circulating the draft Official Plan Amendment (OPA) and draft Zoning By- law Amendment (ZBA) applications to the Ministry of Municipal Affairs and Housing. It is recognized that the OPA is exempt from the Minister's approval, and the following One Window comments are provided to the County for its consideration in making decisions on these matters. It is understood that the subject lands are located at 11302 Imperial Road in the Township of Malahide, Elgin County. The purpose of the OPA is to establish a site - specific policy framework to recognize and permit a large-scale, intensive agri-tourism use. The proposal involves a phased expansion and reconfiguration of the existing Clovermead Adventure Farm and Apiary, including improvements to site access, parking, and servicing, with the addition of visitor -oriented facilities. The subject lands support an existing agricultural operation, including apiary activities and crop production, along with agricultural -related and on -farm diversified uses associated with agri-tourism. Agriculture is proposed to remain the primary land use, with agri-tourism and related uses continuing as secondary uses at an increased scale and intensity. The lands are designated "Agricultural Area" in the Elgin County Official Plan and "Agriculture" in the Township of Malahide Official Plan and are located within a prime agricultural area. Page 17 of 20 Consideration has been given to this matter with respect to the policies of the Provincial Planning Statement, 2024 (PPS), and applicable provincial guidance. The following comments identify matters for the County's consideration in reviewing the applications, including areas where additional information may be required to demonstrate consistency with provincial policy. Agricultural Land Use and Compatibility Considerations The applications propose a large-scale and intensive agri-tourism use within a prime agricultural area. The County should assess whether the proposal is consistent with PPS policy direction intended to protect prime agricultural areas for long-term agricultural use and to ensure that on -farm diversified uses remain compatible with, and do not hinder, surrounding agricultural operations (PPS policy 4.3.1). The Planning Justification Report indicates that no livestock facilities are present on or near the subject lands and concludes that Minimum Distance Separation (MDS) requirements are met. However, aerial imagery suggests there may be a livestock operation north of the subject lands along College Line. This is noted for awareness, and the determination of whether an MDS calculation is required remains with the County. The Ontario Ministry of Agriculture, Food and Agribusiness (OMAFA) provides guidance to support the interpretation of PPS policies related to permitted uses in prime agricultural areas. In reviewing the proposal, the County is encouraged to consult OMAFA's Guidelines on Permitted Uses in Ontario's Prime Agricultural Areas, including the criteria used to evaluate whether proposed uses qualify as agricultural -related uses or on -farm diversified uses. The proposed agri-tourism components may be characterized as agricultural -related uses and/or on -farm diversified uses and should be assessed against the relevant definitions and criteria in the PPS. The proposes uses are considered to be agricultural related should demonstrate that they are directly related to and service farm operations in the area as a primary activity, support agriculture, benefit from proximity to farm operations, and provide direct products and/or services to farm operations. Where a proposed use does not meet the criteria for an agricultural -related use, it may instead be considered an on -farm diversified use, provided that all applicable criteria for that category are satisfied. Uses considered to be on -farm diversified should demonstrate that they are secondary to the principal agricultural use of the property, limited in area, and related to agriculture, supportive of agriculture, or able to coexist with agriculture without conflict. While agri- tourism uses may qualify as on -farm diversified uses, the County should be satisfied that the scale and form of development continue to support agriculture as the principal land use on the property. Page 18 of 20 The proposal indicates that on -farm diversified uses would exceed the two percent lot coverage benchmark referenced in OMAFA guidance for interpreting the "limited in area" criterion. While this benchmark is not a strict cap, it is intended to help ensure agriculture remains the primary land use, minimize the amount of land removed from agricultural production, and reduce off -site impacts. The County should evaluate the proposal on a site -specific basis, including the total area rendered unavailable for agricultural production by the on -farm diversified use, including buildings, parking, servicing, access roads, and related features. An Agricultural Impact Assessment (AIA) has been submitted in support of the application. Subject to the County's discretion, the scope of the assessment may be tailored to the type, complexity, and scale of the proposed agricultural -related or on - farm diversified uses, as well as the anticipated magnitude of impacts. The County should ensure that the assessment adequately identifies potential impacts on the agricultural system and includes appropriate measures to avoid, minimize, or mitigate impacts, consistent with OMAFA guidance. See Agricultural Impact Assessment (AIA) Guidance Document for further information. Natural Heritage and Natural Hazard Considerations It is noted that no Environmental Impact Study (EIS) or equivalent natural heritage assessment was included with the circulated materials. As a result, it is unclear whether potential impacts to natural heritage features and their ecological functions have been appropriately evaluated. Available information indicates the presence of an intermittent watercourse adjacent to the subject lands, with a portion of the property regulated by the Catfish Creek Conservation Authority and a floodplain identified south of the site. The Planning Justification Report indicates that the proposed development is located outside the identified natural hazard lands and associated regulated area. However, under the PPS and the Fisheries Act, watercourses, including intermittent streams, are considered fish habitat unless demonstrated otherwise. No information has been provided to characterize the watercourse or confirm the absence of fish habitat. As the potential for fish habitat and associated functions cannot be ruled out, development and site alteration within or near the drainage area of the watercourse may impact hydrology, water quality, and thermal regimes, which could affect potential fish habitat. The County should treat the adjacent watercourse as potential fish habitat unless demonstrated otherwise, confirm the presence and extent of fish habitat, determine whether a scoped assessment by a qualified professional is required, and consider the potential impacts to the watercourse from development within the drainage area as part of the application review. We trust these comments will assist the County in its consideration of the draft OPA and associated ZBA. Provincial staff are available to discuss these comments. If there are Page 19 of 20 any questions, please contact the undersigned. By copy of this letter, the Ministry requests that the County provide notice of decision on these applications. Kind regards, David Stubbs Senior Planner (acting) Ministry of Municipal Affairs and Housing Municipal Services Office — Western Cc: Alicia Csoff, County of Elgin Anna Drake, OMAFA Fathima Shamla, MNR Monika Macki, MECP Michael Kilgore, MTO Erick Boyd, MMAH Page 20 of 20