Application for an Official Plan Amendment (OPA 41) Zoning By-law Amendment (ZBA 14), Oriole Park Resort; Amiens Road

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1 September 26, 2018 Page 1 of 44 Staff Report Report No.: PLA Meeting Date: September 26, 2018 Submitted by: Subject: Kelly Henderson Planner Application for an Official Plan Amendment (OPA 41) Zoning By-law Amendment (ZBA 14), Oriole Park Resort; Amiens Road Recommendation: THAT Report PLA be received for information. Purpose: The purpose of this report is to provide Council with background information regarding an Official Plan Amendment and Zoning By-law Amendment for a property located at the southwest corner of Amiens Road and Oxbow Drive. A location map is included as Attachment 1. A public meeting of Council has been scheduled for the evening of September 26, 2018 in accordance with Section 34 of the Planning Act. The purpose of the meeting is to allow the applicant to present the proposal and to solicit feedback from members of the public. Staff will provide an evaluation of the subject application in a subsequent report for Council s consideration following receipt of public and agency feedback through the circulation of the proposal and the associated public meeting. Background: The subject lands currently contain mobile homes and Park Model Trailers, which are permitted to be occupied for eleven months of the year. Currently residents are required to vacate their units for the month of February. The Resort contains approximately 163 units including park model trailers and mobile homes serviced by communal (private) water and sewage treatment facilitates, and an internal road circulation system. The lands also include a variety of residential amenities including a lounge, entertainment centre, laundromat, parks and a pool. The subject lands have previously been through a zoning by-law amendment in 2011, at which time a holding symbol was placed on the property in order to require a vegetative buffer provision to allow development to proceed within 30.5 metres of Oxbow Drive and within 13.4 metres of Amiens Road. At this time the current zoning was not amended to 1

2 September 26, 2018 Page 2 of 44 Staff Report allow any additional uses. The zoning of the property permitted a campground and public/private park use, which has continued to apply to the property. In the past Oriole Park and the Municipality have had on-going discussions to move from 11-month occupancy to year round occupancy. However, the primary concern for Middlesex Centre was the requirement of a Responsibility Agreement (RA) for a year round private communal Sewage Treatment Plant (STP), as this would require the Municipality to be financially responsible if something were to happen to this private system. However, the Ministry of Environment Conservation and Parks (MECP) has now confirmed that the Municipality will not be required to enter into an RA with Oriole Park. As an alternative to the RA and pending approval from the MECP, Oriole Park will be required to provide sufficient financial assurance in the event of default or site closure. Current Application: The purpose and effect of the Official Plan Amendment application is to re-designate the subject property from the Parks and Recreation designation to a Special Policy Area designation to allow a Lifestyle Community including the year round occupation of mobile homes, park model trailers as well as accessory commercial and service commercial uses of the site. The purpose and effect of the Zoning By-Law Amendment application is to rezone the subject property by modifying the current site-specific Parks and Recreation (PR-3) zoning of the lands to permit the year round occupancy of mobile homes, park model trailers as well as accessory commercial and service commercial uses of the site. Currently, occupancy of those uses is only permitted for eleven months of the year. Although no further development is being proposed at this time a concept of the existing development is included as Attachment 2. A Planning Justification report was submitted as part of the application and this is included as Attachment 3. As mentioned the subject property is serviced by communal private services, a servicing brief was submitted as part of the application, which is included as Attachment 4. The lands are surrounded by agricultural and natural areas with some residential properties. A portion of the subject property is regulated by the Upper Thames River Conservation Authority (UTRCA). Significant Woodlands are identified on the subject property and the property is adjacent to wetlands. 2

3 September 26, 2018 Page 3 of 44 Staff Report Consultation: Notice of the application has been circulated to agencies, as well as property owners in accordance to the requirements of the Planning Act. Public Comments: At the time of writing the subject report, no comments or concerns had been received from the public regarding this proposal. Agency Comments: The following comments were received at the time of writing this report: The Municipality of Middlesex Centre s Director of Public Works and Engineering, Corporate Services Director and Fire Chief, have advised of no concerns or requirements for the subject application. The Municipality of Middlesex Centre s Chief Building Official has reviewed the subject application and has some concerns with the Park Model Trailers on the subject property, as they are not built for year round occupancy and are meant for seasonal use only. It is recommended that the re-zoning and Official Plan Amendment are not finalized until the Municipality and applicant have agreed on an alternative for the Park Model Trailers. Additionally the Campground Licensing By-law requires an update should this application be approved. Lastly, staff have confirmed with our Development Charges consultant that the municipal wide development charge would apply to new mobile homes proposed for year round occupancy. The Upper Thames River Conservation Authority have reviewed the subject applications and have no concerns and/or objection, however they do advise that no works shall occur within the Regulation limit (including site grading, earthworks, alteration, etc.) without a Section 28 permit. Additionally, no fill material is permitted to be placed within the Regulation limit. The area of significant woodlands is also to be protected. Financial Implications: None. Strategic Plans: N/A 3

4 September 26, 2018 Page 4 of 44 Location Map Meters Legend Description: Oriole Park Resort File Number: OPA & ZBA 14/18 Created By: Date: 8/24/2018 Scale: 1: 9,028 Assessment Parcels Prepared By: Middlesex Centre

5 Amiens Road Parking Additional Parking September 26, 2018 Page 5 of N45 01'00"E Oxbow Road ORIOLE PARK RESORT MINIMUM 6.0m FRONT YARD SETBACK MINIMUM 6.0m FRONT YARD SETBACK N44 40'27"W MINIMUM 6.0m EXTERIOR YARD SETBACK MINIMUM 6.0m EXTERIOR YARD SETBACK Guest Parking Guest Parking Guest Parking Goa Way Maintenance Storage Shed Service Road Private Parking Tile Bed Security Gate Tile Bed Dog Run Patio Service Building 44 Superintendant Community Centre Betty Blvd Apartment MINIMUM 1.5m INTERIOR YARD SETBACK Garden N45 01'00"E MINIMUM 1.5m INTERIOR YARD SETBACK Tile Bed Sewage Treatment Plant Community Vegetable Garden Tile Bed 50 Saltwater Pool Additional Parking Easy Street Arthur Ave Memory Lane Haviture Way Needmore Road Goa Way MINIMUM 1.5m REAR YARD SETBACK Garden Shuffleboard Waterfall Patio MINIMUM 1.5m INTERIOR YARD SETBACK Golf Cart Trail Golf Cart Trail Water Treatment Plant Garden Patio Arbor Hill Patio Lois lane Additional Parking Park Lane Abbey Road MINIMUM 1.5m INTERIOR YARD SETBACK MINIMUM 1.5m INTERIOR YARD SETBACK N45 02'25"W PART OF LOT 1, CONCESSION 2 Key Plan THORN DR SPRINGWELL Revision No. AURA DR HWY 402 RD AMIENS RD ORIOLE DR Date LANDSDOWNE PARK CRES OXBOW RD Subject Lands GLENDON DR Issued / Revision KOMOKA RIVER THAMES Date File No. Plan Scale Drawn By Checked By Other north Subject Lands north May 09, 2018 Y445 'A' 1:750 L.M. By N45 05'10"E File Name Dwg No. 2 Scale Bar N:\Y445'A'\Oriole Park Resort Site Plan- MAY dwg

6 September 26, 2018 Page 6 of 44 PLANNING JUSTIFICATION REPORT ZONING BY-LAW AMENDMENT APPLICATION; OFFICIAL PLAN AMENDMENT APPLICATION Amiens Road Middlesex Centre Date: June 2018 Prepared for: Oriole Park Resort Ltd. Prepared by: MacNaughton Hermsen Britton Clarkson Planning Limited (MHBC) 630 Colborne Street, Suite 202 London ON N6B 2V2 T: x223 F: Our File: Y445 A

7 September 26, 2018 Page 7 of 44 Table of Contents 1.0 Introduction Overview Basis of the Applications Site Description and Surrounding Area Description of the Proposal Planning Analysis Provincial Policy Statement, County of Middlesex Official Plan Overview Agricultural Areas Housing and Land Use Policies Natural Heritage Features Servicing Hierarchy Conclusion Municipality of Middlesex Centre Official Plan Residential Policies Parks and Recreation Policies Municipal Infrastructure and Servicing Policies Natural Heritage Implementation Conclusion Middlesex Centre Zoning By-law Proposed Amendments Overview of Official Plan Amendment Overview of Zoning By-law Amendment Summary and Conclusions June 2018

8 September 26, 2018 Page 8 of 44 Table of Figures Figure 1: Location and Surrounding Context... 3 Figure 2: Site Concept Plan... 5 Figure 3: County of Middlesex Official Plan Schedule A Figure 4: Middlesex County Official Plan Schedule C Figure 5: Middlesex Centre Official Plan Schedule A Figure 6: Middlesex Centre Official Plan Schedule B Figure 7: Middlesex Centre Official Plan Schedule C Figure 8: Existing Zoning Figure 9: Proposed Official Plan Special Policy Area June 2018

9 September 26, 2018 Page 9 of Introduction 1.1 Overview MHBC has been retained by Oriole Park Resort Ltd. (the Applicant ) to prepare the following Planning Justification Report in support of an Official Plan Amendment and Zoning By-law Amendment application with respect to the property addressed as Amiens Road in the Municipality of Middlesex Centre (County of Middlesex), hereinafter referred to as the subject lands. The proposed amendments are required to permit the existing seasonal campground (Oriole Park Resort) on the subject lands to be converted into a lifestyle community (thereby permitting year-round occupancy of mobile homes on the subject lands). This planning report has been prepared for submission to the Municipality of Middlesex Centre and includes the following: An introduction and general description of the subject lands including an overview of the residential community on the property; A description of the surrounding uses to provide an understanding of the locational context; A description of the proposed amendments; and A review of the existing Provincial and Municipal policy framework in relation to the proposed amendments, and an assessment of consistency and conformity with Provincial Policy, the Official Plan and Zoning By-law. As part of this planning analysis, the following documents were reviewed: The Provincial Policy Statement; County of Middlesex Official Plan; Municipality of Middlesex Centre Official Plan; and Middlesex Centre Zoning By-law. The subject lands comprise an area of 9.83 hectares, and are located along the western perimeter of Middlesex Centre at the southeastern corner of Oxbow Drive and Amiens Road. As noted, there is an existing seasonal campground on the property which contains individual lots for mobile homes. At present, residents inhabit their dwellings up to 11 months of the year and are required to vacate these units over the month of February. This report supports the planning application and assesses the proposal in the context of the applicable planning framework. June 2018 MHBC 1

10 September 26, 2018 Page 10 of Basis of the Applications The purpose of the proposed amendments, which are described in detail under Section 4.0 of this Report, is to allow Oriole Park Resort to operate on a year-round basis. This residential development currently operates as a seasonal campground with occupancy 11 months of the year. Through an amendment to the Middlesex Centre Official Plan, we are proposing to add a new definition for a Lifestyle Community which would facilitate the conversion of the seasonal campground to a permanent residential community. This proposal does not involve any site alteration or new development. The existing use of the site will remain unchanged, save for the amount of time the use will occur on the subject lands. The approach for the Official Plan Amendment (OPA) is to add a Special Policy Area to the subject lands which would permit a Lifestyle Community to facilitate year-round, or permanent, occupation of mobile homes on the property. With respect to the Zoning By-law Amendment (ZBA), the property is zoned Parks and Recreation with a special provision (Exception) applied to permit a campground and park uses. The requested rezoning would amend this Exception to permit year-round occupation of the campground as defined in the Zoning By-law. June 2018 MHBC 2

11 September 26, 2018 Page 11 of Site Description and Surrounding Area The subject lands are located at the southeastern corner of Amiens Road and Oxbow Drive, approximately 2.0 km west of the community of Komoka. The lands measure approximately 9.83 hectares in area and are generally rectangular in shape. The property has approximately 241 m of lot frontage on Oxbow Drive and approximately 337 m of lot flankage along Amiens Road (refer to Figure 1). The site is accessed from Amiens Road. Figure 1: Location and Surrounding Context Komoka Subject Lands N The subject lands are currently utilized for a seasonal campground featuring mobile homes which are permitted to be occupied 11 months of the year. This campground has operated as a seasonal family campground and trailer park for over 50 years. The Resort contains approximately 163 residential units serviced by communal (private) water and sewage treatment facilities, and an internal road circulation system. Additionally, the development includes a variety of residential amenities including an entertainment centre, lounge area/games room, laundromat, pool and parks. The following identifies the land uses surrounding the subject lands: North: East: South: West: Oxbow Drive corridor, natural environment areas Fernwood Hills event and wedding facility Natural environment areas, agricultural land Amiens Road corridor, natural environment areas, agricultural land June 2018 MHBC 3

12 September 26, 2018 Page 12 of 44 More specifically, lands surrounding the site feature agricultural and natural areas interspersed with rural residential uses. The property is separated from wetland complexes to the north and west by Amiens Road and Oxbow Drive. Directly east of the subject lands is an event and wedding facility. There is a large wooded area to the south of the subject lands which separates the Resort from neighbouring agricultural uses. There are also agricultural fields under active cultivation to the west of the subject lands (on the west side of Amiens Road). A site concept plan is provided on the following page which illustrates the existing conditions of the subject lands. June 2018 MHBC 4

13 Amiens Road Parking Additional Parking September 26, 2018 Page 13 of N45 01'00"E Oxbow Road ORIOLE PARK RESORT MINIMUM 6.0m FRONT YARD SETBACK MINIMUM 6.0m FRONT YARD SETBACK N44 40'27"W MINIMUM 6.0m EXTERIOR YARD SETBACK MINIMUM 6.0m EXTERIOR YARD SETBACK Guest Parking Guest Parking Guest Parking Goa Way Maintenance Storage Shed Service Road Private Parking Tile Bed Security Gate Tile Bed Dog Run Patio Service Building 44 Superintendant Community Centre Betty Blvd Apartment MINIMUM 1.5m INTERIOR YARD SETBACK Garden N45 01'00"E MINIMUM 1.5m INTERIOR YARD SETBACK Tile Bed Sewage Treatment Plant Community Vegetable Garden Tile Bed 50 Saltwater Pool Additional Parking Easy Street Arthur Ave Memory Lane Haviture Way Needmore Road Goa Way MINIMUM 1.5m REAR YARD SETBACK Garden Shuffleboard Waterfall Patio MINIMUM 1.5m INTERIOR YARD SETBACK Golf Cart Trail Golf Cart Trail Water Treatment Plant Garden Patio Arbor Hill Patio Lois lane Additional Parking Park Lane Abbey Road MINIMUM 1.5m INTERIOR YARD SETBACK MINIMUM 1.5m INTERIOR YARD SETBACK N45 02'25"W PART OF LOT 1, CONCESSION 2 Key Plan THORN DR SPRINGWELL Revision No. AURA DR HWY 402 RD AMIENS RD ORIOLE DR Date LANDSDOWNE PARK CRES OXBOW RD Subject Lands GLENDON DR Issued / Revision KOMOKA RIVER THAMES Date File No. Plan Scale Drawn By Checked By Other north Subject Lands north May 09, 2018 Y445 'A' 1:750 L.M. By N45 05'10"E File Name Dwg No. 2 Scale Bar N:\Y445'A'\Oriole Park Resort Site Plan- MAY dwg

14 September 26, 2018 Page 14 of Description of the Proposal The Applicant is seeking permission to provide year-round occupancy to current and future residents of Oriole Park Resort in order to offer additional residential services and respond to changing market conditions. This modification to site operations would allow seasonal camping sites to be replaced with permanent sites intended for mobile homes. Conversion of the campground from 11 months to a year-round Lifestyle Community would not require any additional development or site alteration. Azimuth Engineering (Azimuth) has prepared a Servicing Brief in support of this application. As summarized in the Brief, Azimuth has concluded that the private water and wastewater facilities servicing the site have sufficient capacity to accommodate year-round occupation of the property. The subject lands are currently designated Agricultural Areas in the County of Middlesex Official Plan, Parks and Recreation in the Middlesex Centre Official Plan, and zoned Parks and Recreation (PR-3 (h-7)) in the Middlesex Centre Zoning By-law. The purpose of this Report is to provide the Municipality with planning rationale to support amendments to the Middlesex Centre Official Plan and Zoning Bylaw. Respectively, the following amendments are proposed in conjunction with this proposal: Create a Special Policy Area under Section 11.0 of the Official Plan which would permit the subject lands to be used as a Lifestyle Community. For the purposes of the Official Plan, Lifestyle Communities would allow for year-round occupation of mobile homes on the subject lands; and Amend Section of the Zoning By-law to permit the occupation of mobile homes on a year-round basis on the subject lands. The discussion to follow details the specific amendment requests to the Middlesex Centre Official Plan and Zoning By-law. June 2018 MHBC 6

15 September 26, 2018 Page 15 of Planning Analysis In light of the requested amendments which are described in detail under Section 4.0 of this report, the following discussion details how the applications comply with the Provincial Policy Statement, the County of Middlesex Official Plan, and the Municipality of Middlesex Centre Official Plan. 4.1 Provincial Policy Statement, 2014 The Provincial Policy Statement (PPS) sets the policy foundation for regulating the development and use of land in Ontario. The 2014 PPS was issued under the authority of Section 3 of the Planning Act and came into effect on April 30, Section 3(5) of the Planning Act requires that all decisions affecting planning matters shall be consistent with policy statements issued under the Act. The following table demonstrates how the proposal is consistent with the policies of the 2014 PPS that, in our opinion, are of particular relevance. Table 1: Provincial Policy Statement Policies 1.1 (Managing and Directing Land Use to Achieve Efficient Development and Land Use Patterns) Healthy, livable and safe communities are sustained by: The proposal makes efficient use of the subject lands by facilitating year-round occupation on a site with existing communal services. a) promoting efficient development and land use patterns which sustain the financial well-being of the Province and municipalities over the long term Healthy, livable and safe communities are sustained by: b) accommodating an appropriate range and mix of residential (including second units, affordable housing and housing for older persons), employment (including industrial and commercial), institutional (including places of worship, cemeteries and long-term care homes), recreation, park and open space, and other uses to meet long-term needs; Establishing Oriole Park Resort as a permanent residential development would provide Middlesex Centre with additional housing choice accessible to lower and moderate income households. June 2018 MHBC 7

16 September 26, 2018 Page 16 of Sufficient land shall be made available to accommodate an appropriate range and mix of land uses to meet projected needs for a time horizon of up to 20 years (Sewage, Water and Stormwater) Planning for sewage and water services shall: a) direct and accommodate expected growth or development in a manner that promotes the efficient use and optimization of existing: 1. municipal sewage services and municipal water services; and 2. private communal sewage services and private communal water services, where municipal sewage services and municipal water services are not available; The proposal will facilitate the continued use of an existing seasonal residential development on lands in close proximity to a designated settlement area (Komoka). The provision of year-round occupancy on the site will help the Municipality meet its projected residential needs. Oriole Park Resort is serviced by existing private communal sewage and private communal water facilities, as municipal servicing is not available at this location. The Servicing Brief which accompanies this application describes how existing facilities can accommodate the intended year-round use of the site. Additionally, the Brief confirms that the existing servicing arrangement is financially viable and compliant with regulatory requirements. b) ensure that these systems are provided in a manner that: 1. can be sustained by the water resources upon which such services rely; 2. is feasible, financially viable and complies with all regulatory requirements; and 3. protects human health and the natural environment; Where municipal sewage services and municipal water services are not provided, municipalities may allow the use of private communal sewage services and private communal water services A land use pattern, density and mix of uses should be promoted that minimize the length and number of vehicle trips and support current and future use of transit and active transportation. As noted above, the subject lands are currently serviced by private communal services. Azimuth concludes that these facilities can accommodate the operation of the Resort on a year-round basis. The subject lands are located in the vicinity of other residential uses, as well as local parks and community facilities in the Komoka settlement area. The relative proximity of the site to these features, in conjunction with the variety June 2018 MHBC 8

17 September 26, 2018 Page 17 of (Long-Term Economic Prosperity) Long-term economic prosperity should be supported by: b) optimizing the long-term availability and use of land, resources, infrastructure, electricity generation facilities and transmission and distribution systems, and public service facilities; of amenities within the Resort, contributes to the minimization of vehicle trips. The proposal will optimize the longterm availability and use of the land for residential purposes by facilitating the increased viability and continued use of the subject lands as a year-round residential community. Section 2 of the Provincial Policy Statement (PPS) contains policies related to the wise use and management of resources. This section addresses matters such as natural heritage, water, agriculture, mineral aggregate resources, and cultural heritage and archaeology. 2.1 Natural Heritage Natural features and areas shall be protected for the long term Development and site alteration shall not be permitted in: a) significant wetlands in Ecoregions 5E, 6E and 7E1; and b) significant coastal wetlands Development and site alteration shall not be permitted in: a) significant wetlands in the Canadian Shield north of Ecoregions 5E, 6E and 7E1; b) significant woodlands in Ecoregions 6E and 7E (excluding islands in Lake Huron and the St. Marys River)1; c) significant valleylands in Ecoregions 6E and 7E (excluding islands in Lake Huron and the St. Marys River)1; d) significant wildlife habitat; e) significant areas of natural and scientific interest; and f) coastal wetlands in Ecoregions 5E, 6E and 7E1 that are not subject to policy 2.1.4(b) Development and site alteration shall not be permitted in fish habitat except in accordance with The proposal will not result in any form of development or site alteration at this time. Accordingly, the natural features on the subject lands will be protected. Development or site alteration is not proposed within any of the listed features as a result of this application. Development or site alteration is not proposed within any of the listed features as a result of this application. Development is not proposed within any fish habitat. June 2018 MHBC 9

18 September 26, 2018 Page 18 of 44 provincial and federal requirements Development and site alteration shall not be permitted in habitat of endangered species and threatened species, except in accordance with provincial and federal requirements Development and site alteration shall not be permitted on adjacent lands to the natural heritage features and areas identified in policies 2.1.4, 2.1.5, and unless the ecological function of the adjacent lands has been evaluated and it has been demonstrated that there will be no negative impacts on the natural features or on their ecological functions. 2.2 Water Development and site alteration shall be restricted in or near sensitive surface water features and sensitive ground water features such that these features and their related hydrologic functions will be protected, improved or restored. Development is not proposed within the habitat of any endangered or threatened species. Development or site alteration is not proposed on adjacent lands to the natural features identified under policies 2.14, 2.1.5, and as a result of this application. Development or site alteration is not proposed in or near sensitive surface water features and sensitive ground water features as a result of this application. Mitigative measures and/or alternative development approaches may be required in order to protect, improve or restore sensitive surface water features, sensitive ground water features, and their hydrologic functions. In light of these considerations and our broader evaluation of the Provincial Policy Statement, it is our opinion that the proposal satisfies, and is consistent with, the policies of the PPS. 4.2 County of Middlesex Official Plan Overview The County of Middlesex Official Plan (Middlesex Official Plan) was approved by the Minister of Municipal Affairs and Housing on December 17, 1999 and was amended by Official Plan Amendment No. 2 on July 11, The Middlesex Official Plan provides the overall land use policy direction for the County of Middlesex and the various settlement areas. Sections 1.0 through 4.0 of this Plan contain general policies related to land use development. June 2018 MHBC 10

19 September 26, 2018 Page 19 of 44 The subject lands are designated Agricultural Area on Schedule A (Land Use), as illustrated on Figure 3. Additionally, the subject lands contain Significant Woodlands along a portion of the northern perimeter as identified on Schedule C (Natural Heritage Features). Figure 3: County of Middlesex Official Plan Schedule A Subject Lands N Agricultural Areas Section 3.3 of the Middlesex Official Plan provides policy direction for lands designated Agricultural Areas. Section notes that: The purpose of the Agricultural Areas designation is to protect and strengthen the agricultural community, a major economic component within the County, while recognizing the potential for a limited amount of development in existing locally designated hamlets. The Agricultural Areas policies protect agricultural lands from the intrusion of land uses that are not compatible with agricultural operations. Despite being located within the Agricultural Area, the subject lands are not used for agricultural purposes, and are designated Parks and Recreation under the Middlesex Centre Official Plan, as discussed in Section 3.3 of this Report. In our opinion, the existing use of the subject lands is compatible with the surrounding agricultural uses to the south and west. Further, the June 2018 MHBC 11

20 September 26, 2018 Page 20 of 44 campground on the subject lands is self-contained, and will not intrude into the surrounding agricultural areas. General policies for this designation are provided under Section 3.3.2, as follows: It is the policy of County Council that the Agricultural Area in Middlesex County shall be preserved and strengthened with the goal of sustaining the agricultural industry that is so vital to the Middlesex economy. The proposal to facilitate a permanent residential community on the subject lands will not hinder the preservation of agricultural lands in the County. The subject lands have been used as a campground for over 50 years, and are not well-suited for agriculture due to their size, and siting adjacent to protected Natural Heritage features. Accordingly, in our opinion, permitting the existing campground use to operate on a permanent, year-round basis would not conflict with surrounding agricultural lands or the broader goals of the Agricultural Area designation Housing and Land Use Policies Section (Housing Policies) of the Middlesex Official Plan directs that, it is the policy of the County to encourage a wide variety of housing by type, size and tenure to meet projected demographic and market requirements of current and future residents of the County. Establishing a permanent residential community on the subject lands by permitting year-round occupation of mobile homes promotes housing choice to meet the needs of current and future residents of the County. Further, the conversion of the subject lands to a Lifestyle Community will diversify the types, and sizes of permanent housing options within the County Natural Heritage Features Schedule C (Natural Heritage Features) of the Middlesex Official Plan identifies a Significant Woodlands feature along Oxbow Drive at the northern perimeter of the subject lands (refer to Figure 4). June 2018 MHBC 12

21 September 26, 2018 Page 21 of 44 Figure 4: Middlesex County Official Plan Schedule C Subject Lands N Table 1 under Section of the Middlesex Official Plan requires that development within 50 metres of a Significant Woodlands feature requires the completion of a Development Assessment Report (DAR). This proposal will not involve any site alteration or new development, as the intent of the OPA and ZBA applications is only to convert Oriole Park Resort to a year-round campground. The Significant Woodlands feature on the subject lands does not contain any development forms, and the proposal will not result in any further development in proximity of this feature at this time. Accordingly, it is our opinion that a DAR is not warranted in conjunction with this proposal Servicing Hierarchy Under Section of the Middlesex Official Plan it is stated that the County promotes Efficient and environmentally responsible development which is supportable on the basis of appropriate types and levels of water supply and sewage disposal. General policies relating to services are set out in Section of the Plan. Of particular relevance to this proposal are subsections d), and g) as follows: June 2018 MHBC 13

22 September 26, 2018 Page 22 of General Policies The County shall: d) Cooperate with local municipalities, the Province and other public and/or private partners to negotiate innovative arrangements for the provision of water and sanitary sewage systems in the County; g) Encourage the proper maintenance of private sewage treatment systems in the County in order to protect and improve ground and surface water quality and avoid system malfunctions and failures; The Applicant has consulted with County staff and the Ministry of the Environment and Climate Change (MOECC) to advance this conversion proposal. Through discussion between these parties it was agreed that the subject lands could be serviced by the existing communal system on a year-round basis, provided that sufficient financial assurance is provided to the Ministry. In our opinion, this approach represents a practical and innovative arrangement to ensure the provision of private water and sewage systems to the Resort. Additionally, the Servicing Brief which has been prepared for this application addresses the operational and maintenance program in place to minimize the potential for system malfunctions and failures Conclusion Based on an assessment of policy set out within the County of Middlesex Official Plan, it is our opinion that the proposal conforms to the overall land use policy direction of this Plan. In this regard, the proposal is compatible with, and will not be detrimental to the surrounding agricultural uses. The proposal also supports the objective of the County to promote housing choice to meet projected demographic and market requirements. Regarding the natural heritage features on the subject lands, the proposal will not result in any new development or site alteration at this time. Accordingly, the proposal will not impact these features. Finally, the servicing arrangement developed to facilitate the year-round occupancy on the Site is supported in principle by the MOECC. 4.3 Municipality of Middlesex Centre Official Plan The Municipality of Middlesex Centre Official Plan (Middlesex Centre Official Plan) was approved on July 9, 2002, with modifications by the County of Middlesex and changes pursuant to an Ontario Municipal Board Order. The Office Consolidation of the Municipality of Middlesex Centre Official Plan, dated September 29, 2017, integrates several amendments. June 2018 MHBC 14

23 September 26, 2018 Page 23 of 44 Section 1.5 of the Middlesex Centre Official Plan specifies that The Municipality of Middlesex Centre Official Plan is required to conform to the County of Middlesex Official Plan, and Whereas the County Plan contains broad policies involving County responsibilities and Provincial interests, the Official Plan of the Municipality of Middlesex Centre is intended to address local issues, unique characteristics, and special objectives and goals of the local municipality. Furthermore, Section 1.7 of the Plan outlines that, It is the intent of this Official Plan to apply the broad concept of traditional town and country planning as a general guide in the establishment of overall Official Plan principles. Several general principles are defined in this Section to guide the policy direction of the Plan, including the following which have relevance to this proposal: a) To establish as a key priority of this Plan, the protection of agricultural areas for agricultural and resource uses, and enhance the agricultural economy within the Municipality. f) To manage growth and change in an appropriate manner and in appropriate locations, with the intent of maintaining the positive physical character and attributes that Municipal residents currently enjoy. h) To promote efficient, cost effective development and land use patterns to minimize land consumption, reduce servicing costs and encourage intensification. i) To provide an adequate supply and diversity of housing types in appropriate locations within settlement areas. The discussion to follow demonstrates how the proposal is in keeping with the intent of the general principles noted above. The subject lands are designated Parks and Recreation on Schedule A-8 with a portion of land along the northern perimeter designated Natural Environment. Additionally, portions of land along the northern and western perimeters contain a Hazard Lands overlay. The designations applying to the subject lands are shown on Figure 5. June 2018 MHBC 15

24 September 26, 2018 Page 24 of 44 Figure 5: Middlesex Centre Official Plan Schedule A-8 Subject Lands N Residential Policies Section 5.2 of the Middlesex Centre Official Plan sets out general policy objectives for residential activities within Urban and Community Settlement Areas, as well as designated Hamlets. The subject lands are located in proximity to the Komoka Settlement Area, and are approximately 450 metres north of the current Settlement Area Boundary. Notwithstanding that the subject lands are not located within a Community Settlement Area or Hamlet, the following subsections have particular relevance to this proposal as they relate to housing in the Middlesex Centre: a) The Municipality will provide and encourage a wide variety of housing types, sizes and tenures to meet demographic and market requirements for the Municipality s current and future residents. The proposal will provide an alternative form of housing which will support the Municipality s goal to offer a diversity of housing choice to meet the requirements of current and future residents from a demographic and market perspective. g) The Municipality shall encourage housing accessible to lower and moderate income households. In this regard the County of Middlesex through its Official Plan will require that 20 percent of all housing be affordable. In the case of ownership housing the least expensive is considered to be housing for which the purchase price is at least 10 percent below the average purchase price of a resale unit in the regional market area. This June 2018 MHBC 16

25 September 26, 2018 Page 25 of 44 benchmark purchase price figure for 2005 is $195,845 in the Middlesex regional market area. This benchmark figure will change over time as a result of fluctuating mortgage costs, utility rates, and the vagaries of the housing market over which the County of Middlesex and the Municipality have no control. The County will; however, monitor the benchmark on an annual basis. The proposal will provide an alternative form of housing which is accessible to lower and moderate income households. Mobile homes are generally more affordable than more conventional forms of housing. Accordingly, the proposal to establish Oriole Park Resort as a permanent residential community supports the above-noted objective Parks and Recreation Policies Section 8.0 provides the policy direction for the Parks and Recreation designation. Goals and objectives of this designation, which are relevant to this proposal are identified as follows: b) To ensure that recreational development will not interfere or conflict with the agricultural land use activities of the Municipality. As noted in Section 2.0 of this Report, the subject lands have been utilized for campground activities for over 50 years. As a result of their size and location proximate to natural heritage features, these lands are not suitable to be used for agricultural purposes. In addition, the existing mobile home campground does not interfere with the normal farm practices of adjacent agricultural operations. Accordingly, in our opinion, establishing a year-round Lifestyle Community on the subject lands would not conflict with surrounding agricultural land use activities. c) To promote parks and recreational design that is sensitive to the physical characteristics and natural features of their respective sites, and the traditional character of the related settlement areas. There is a woodlot feature along the northern portion of the subject lands which is discussed above under Section of this Report, and further under Section below. This feature is not impacted by the existing use of the site and, as noted, the proposal will not involve any development or site alteration at this time. Accordingly, the proposal will result in the continuation of a Parks and Recreation use on the subject lands in a manner that is sensitive to the surrounding natural features. Section 8.3 of the Middlesex Centre Official Plan defines the permitted uses in the Parks and Recreation designation as follows: a) Public and private parks and open space areas. b) Public and private recreation areas, including golf courses and campgrounds. c) Conservation areas, including uses identified in a conservation area master plan. d) Provincial parks, including uses identified in a parks master plan prepared by the Province. June 2018 MHBC 17

26 September 26, 2018 Page 26 of 44 e) The existing race track in the former Township of Delaware, known as the Delaware Speedway Park. This use and appropriate accessory uses will continue to be permitted; however, proposals to expand the land area associated with this use will be discouraged. In light of these permissions, the existing campground is permitted under the Official Plan. However, an amendment is required to add a Special Policy Area provision to permit a year-round Lifestyle Community on the site. By applying a Special Policy Area to the Parks and Recreation designation on the subject lands, a distinction is established between a conventional residential development, and the type of residential community that is proposed through this application. It is recognized that the proposed amendment is to address a unique situation that may not be appropriate in other areas of the Municipality. Accordingly, the proposed Special Policy Area is site-specific and would not establish a mechanism for similar use types to be permitted as-ofright throughout the Municipality. The appropriateness of this use for the subject lands has been discussed throughout this Report, and is evaluated in further detail in the sections to follow Municipal Infrastructure and Servicing Policies Section sets out the policies relating to servicing in non-settlement areas. Subsection a) prescribes that: The principal means of sewage disposal in agricultural areas of the Municipality is the septic tank and weeping tile system. It is anticipated that such systems will continue to be the principal means of sewage disposal outside of settlements in the foreseeable future, however the consideration of alternative and improved technologies is encouraged. The installation of septic systems is subject to the approval of the authority having jurisdiction. The proposal is facilitated by an existing communal treatment system which is an approved, alternative technology to the septic tank and weeping tile system. Accordingly, the proposal is consistent with the direction of the municipality noted in this policy. The Servicing Brief prepared in conjunction with this application describes the communal system, and how it is an appropriate and acceptable means to service the subject lands on a year-round basis Natural Heritage Schedule B (Greenlands System) of the Middlesex Centre Official Plan delineates Significant Natural Features within the Municipality (refer to Figure 6). The subject lands contain Significant Woodlands along the northern perimeter adjacent to Oxbow Drive. According to Section 3.4 of the Plan...it is the policy of this Plan that development or site alterations within or on lands adjacent to the environmental features, save and except for those uses included in Section 3.5, shall be subject to completion of a Development Assessment Report acceptable to the Municipality. June 2018 MHBC 18

27 September 26, 2018 Page 27 of 44 Figure 6: Middlesex Centre Official Plan Schedule B N Subject Lands In addition, Schedule C (Natural Hazard Lands) of the Plan identifies Hazard Lands along the northern and western perimeters of the subject lands. Natural hazard lands relate to either slope hazard or fill line conditions (refer to Figure 7). According to Section 3.7 alternative developments or site alterations proposed within such lands will be subject to the completion of a Development Assessment Report (DAR) acceptable to the Municipality and the applicable Conservation Authority(ies). Additionally, Schedule C identifies a pond feature in the middle of the subject lands. This feature was a large, artificial swimming area that no longer exists on the site. The purpose of the application, as noted, is to extend the amount of time the existing use of the site operates from 11 months, to year-round. Development or site alteration is not proposed in conjunction with the proposal. The current use of the site does not impact the natural features noted above. Accordingly, it is our opinion that a DAR is not necessary for the application in support of the proposal. June 2018 MHBC 19

28 September 26, 2018 Page 28 of 44 Figure 7: Middlesex Centre Official Plan Schedule C Subject Lands N Implementation Section 10.1 of the Middlesex Centre Official Plan sets out the criteria that must be met to amend the Plan. As noted, the basis of the proposed OPA is to allow for year-round occupation on the subject lands as a Lifestyle Community. Justification for the proposed amendment has been provided throughout this Report, however, a detailed response to each criterion listed under Section 10.1 is provided below. a) Does the proposed amendment relate, and conform to the vision for the Municipality of Middlesex Centre? The proposed amendment relates and conforms to the vision for the Municipality as it facilitates a form of housing tenure which will increase the variety, size and type of housing provided in a manner that is accessible to lower and moderate income households. Additionally, the amendment will facilitate an efficient, cost effective land use pattern as it will allow for permanent residency on lands with existing communal servicing. b) Is there a demonstrated need or justification for the proposed change? There is a demonstrated need and justification for the proposed change. As discussed, the subject lands currently operate as a seasonal mobile home campground on an 11 month basis. This proposal is seeking to convert Oriole Park Resort to a year-round Lifestyle Community to meet the needs of existing and future residents. In effect, the subject lands currently function as a permanent settlement. Accordingly, the proposed change is required to formalize this arrangement. June 2018 MHBC 20

29 September 26, 2018 Page 29 of 44 Further, as demonstrated in the Servicing Brief, the communal treatment system which currently services the subject lands can adequately and justifiably service the site year-round. As noted above, the proposal also conforms to the vision of the Municipality as it will facilitate housing choice that is accessible to lower and moderate income households. c) Is the amendment in keeping with Provincial and County policy? Regarding Provincial policy, the amendment makes efficient use of the subject lands by providing an affordable form of housing. This will contribute to an appropriate range and mix of housing in the County of Middlesex. Additionally, the amendment is based upon the use of communal sewage services and private communal water services which is consistent with the direction of the PPS, where municipal services are not available. The amendment also conforms with County policy in light of the following considerations: The proposed Lifestyle Community is compatible with, and will not impact upon surrounding agricultural uses. The proposal supports the objective of the County to promote a variety of housing types to meet projected demographic and market requirements of current and future residents. Further, the proposal will diversify the types, and sizes of available housing options within the County. Regarding the natural features on the subject lands, the proposal will not impact upon natural heritage features as no new development or site alteration is planned at this time in conjunction with the Lifestyle Community. Oriole Park Resort is serviced by communal water/wastewater treatment facilities consistent with the County s direction for servicing non-settlement areas. d) What are the effects of the proposed change on the demand for Municipal services, infrastructure and facilities? The proposed change will have no impact on the demand for Municipal services as the subject lands are, and will continue to be, serviced by private communal treatment systems. The Servicing Report prepared in conjunction with this application has confirmed that the existing water/wastewater servicing facilities can accommodate year-round occupancy of the Resort. Moreover, establishing a Lifestyle Community on the site should not increase the requirements for municipal infrastructure or facilities currently servicing the property and its residents. e) Can the lands affected by the application be adequately serviced to accommodate the proposed development? Are improvements necessary to adequately service the lands in question? June 2018 MHBC 21

30 September 26, 2018 Page 30 of 44 As noted in the Servicing Brief which accompanies this application, the communal system which currently services the subject lands for 11 months of the year can adequately service the existing use of the site on a year-round basis. Improvements are not necessary to facilitate the proposal. f) What impacts will the proposed development have on surrounding land uses, traffic systems, infrastructure and servicing, settlement or Municipal character, features or structures of cultural heritage importance, and natural environment features? Can negative impacts be mitigated or eliminated? As discussed, with approval of this application the campground on the subject lands will continue to operate in accordance with existing practices. The only change will be the length of use of the property (i.e., 11 months to year-round occupancy). Accordingly, in our opinion, the proposal will have no impact on the surrounding land uses, traffic system and other items noted above. As the subject lands will not be altered, and no new development is proposed at this time, the proposal will not impact upon the municipal character or any surrounding natural heritage features. There are no structures of cultural heritage importance on, or in close proximity to the subject lands Conclusion It is our opinion that the proposal conforms to overall land use policy direction set out in the Middlesex Centre Official Plan. In this regard, the proposal would provide housing for low and moderate income households while diversifying the type and size of housing available in the Municipality. The communal treatment system which currently services the subject lands can adequately and safely service the property on a year-round basis. This represents an alternative and approved servicing technology which is promoted in non-settlement areas. Additionally, as no site alteration or new development is proposed at this time, the proposal will not impact upon the surrounding natural heritage features or agricultural uses. 4.4 Middlesex Centre Zoning By-law The subject lands are zoned Parks and Recreation (PR-3 (h-7)) pursuant to Schedule A of the Middlesex Centre Comprehensive Zoning By-law (refer to Figure 8). Section (b) of the Zoning By-law (ZBL) prescribes that the 3 Exception applied to the site permits the following specific uses on the subject lands: Campground Park, public or private The definition of campground in the ZBL is as follows: 2.30 CAMPGROUND means the use of land, buildings, or structures, and comprising land used for seasonal recreational activity as grounds for camping including the parking of tents, motor homes, travel trailers, or truck campers, and the erection of park model trailers and mobile homes and may include administrative offices, a laundromat and a June 2018 MHBC 22

31 September 26, 2018 Page 31 of 44 private park which is licenced under the provisions of the Municipal Act, 2001, S.O. 2001, c. 25. For the purposes of the definition of CAMPGROUND, seasonal shall mean not yearround. To permit year-round occupation of the mobile homes on the subject lands, in accordance with the requested Official Plan amendment discussed below under Section 4.1 of this Report, an amendment to the existing Exception is requested under Section (b) Permitted Uses. The nature of this amendment is discussed in greater detail under Section 4.2 of this Report. The h-7 holding provision applying to the subject lands relates to development within within 30.5 metres of the Oxbow Road streetline; and within 13.4 metres of the Amiens Road streetline. As stated in Section (c) of the ZBL, the h-7 symbol shall not be removed until: EITHER a 9.2 metre wide band of dense forest OR an evergreen vegetative barrier of 3.1 metre minimum height is provided along the Oxbow Road streetline and the Amiens Road streetline. It being noted that: Each road is independent of the other for development to take place As the proposal does not involve any development on the site, or site alteration at this time, the holding provision is not applicable to this amendment. Should additional development be proposed on the subject lands in the future within the prescribed distances to these roads, the conditions to remove the holding symbol will need to be satisfied. Additionally, Section of the By-law states that where campgrounds are a permitted use in the PR zone, the following provisions apply: A minimum front yard setback and a minimum exterior side yard setback of 6.0 metres (19.8 ft) with respect to the location of any park model trailer or mobile home; and A minimum side yard setback and a minimum rear yard setback of 1.5 metres (4.9 ft) with respect to the location of any park model trailer or mobile home. Based upon our assessment of the existing campground arrangement, the mobile homes on the subject lands comply with these regulations. Further to the provisions and holding symbol related to the campground noted above, a portion of the subject lands along the western and northern perimeters of the property contains a Hazard Lands overlay as identified on Key Map: U-12 of the Zoning By-law. Under the definition of Hazard Lands,...no buildings or structures, with the exception of those designed, used or intended for flood or erosion control purposes, shall be erected or used on lands which exhibit a hazardous condition as a result of instability, susceptibility to flooding, erosion, subsidence, inundation, June 2018 MHBC 23

32 September 26, 2018 Page 32 of 44 or the presence of organic soils or steep slopes unless a permit has been obtained by the conservation authority having jurisdiction. Notwithstanding, it is noted in the ZBL that the extent of such lands is approximate. Mapping obtained from the Upper Thames River Conservation Authority which is of greater accuracy, does not identify any hazards on the subject lands (refer to Appendix A). Additionally, there is currently no development within the aforementioned Hazard Lands overlay and no development or site alteration is proposed in conjunction with this application. As a result, it is our opinion that this policy is not applicable to the proposal. The existing zoning on the subject lands is shown below under Figure 8. Figure 8: Existing Zoning N Subject Lands June 2018 MHBC 24

33 September 26, 2018 Page 33 of Proposed Amendments 5.1 Overview of Official Plan Amendment The proposed amendment to the Middlesex Centre Official Plan would add a Special Policy Area to Schedule A-2 (Komoka-Kilworth Urban Settlement Area & Secondary Plan), and add a corresponding Special Policy under Section 11.0 (Special Policy Areas) of the Official Plan. Figure 9: Proposed Official Plan Special Policy Area SPA # N The County of Wellington has incorporated a special policy in its Official Plan to accommodate an adult lifestyle community as a precedent for this type of amendment. The Special Policy was added to facilitate conversion of the Mini Lakes campground in the Township of Puslinch from a seasonal family campground to an adult lifestyle community. The conversion resulted in occupancy being extended from nine months a year to year-round. The following Special Policy Area (SPA) provision was developed for the Oriole Park Resort based upon the policy structure approved by the County of Wellington: June 2018 MHBC 25

34 September 26, 2018 Page 34 of 44 The following policies apply to the Oriole Park Resort development located at Amiens Road and identified on Schedule A-2 of this Plan as policy area SPA. a) The land designated SPA may be used for a Lifestyle Community consisting of dwelling units, recreational facilities, limited accessory commercial facilities and private community facilities such as halls and administrative services. b) All services within the area designated SPA, with the exception of emergency services, shall be provided by the owners. All internal roads shall be constructed and maintained to provide adequate access for emergency services. By applying a SPA to the Parks and Recreation designation, a distinction is defined between a conventional residential development and a Lifestyle Community. The Residential designation does not permit mobile homes or mobile home parks. Accordingly, by maintaining the Parks and Recreation designation, the policy direction of the Residential designation is upheld. It is recognized that the circumstances relating to Oriole Park Resort are site-specific and may not be appropriate in other areas of the municipality. Accordingly, the Special Policy Area does not establish a mechanism for similar use types to be permitted as-of-right throughout the Municipality. The appropriateness of this use for the subject lands has been discussed throughout this Report. 5.2 Overview of Zoning By-law Amendment With respect to zoning, the property is currently zoned Parks and Recreation with Exception 3 (PR- 3) as noted above under Section 3.4 of this report. The Exception permits a campground use and restricts other uses on the subject lands to park, public or private. Campgrounds are further defined in the ZBL as being a seasonal use rather than a year-round use. To permit year-round occupation of the mobile homes, in accordance with the requested Official Plan amendment described above, an amendment to the existing Exception applying to the subject lands is requested under Section (b) PERMITTED USES as follows: Notwithstanding the definition of Campground under 2.30, which limits the use of mobile homes and park model trailers to seasonal use only, the campground use may permit year-round use of mobile homes and park model trailers, as well as accessory commercial and service commercial uses. As the existing Exception is proposed to be amended the Zoning Schedule will not be altered. June 2018 MHBC 26

35 September 26, 2018 Page 35 of Summary and Conclusions The subject lands have been used as a recreational campground for over 50 years. The proposal to convert the existing campground from 11 month to year-round occupancy will not change the existing use of the site and will not require any servicing improvements, new development or site alteration. In conclusion, it is our opinion that the amendments to the Middlesex Centre Official Plan and Zoning By-law are appropriate for the subject lands and are consistent with the framework of current planning policy. This assessment is based, in part, on the following considerations: 1. The subject lands are serviced by an existing communal treatment system which can adequately and safely service the site on a year-round basis; 2. The subject lands are well suited for a Lifestyle Community as they already operate in this capacity for 11 months of the year; 3. No site alteration or new development is proposed as part of this application. Accordingly, the proposal will not impact upon the surrounding natural heritage features or agricultural uses; 4. The proposal will diversify the types and sizes of available housing options within the County and Municipality; 5. The proposal is consistent with the Provincial Policy Statement; 6. The nature and intent of this proposal is in keeping with the goals, objectives and policy direction of the County of Middlesex Official Plan and the Municipal of Middlesex Centre Official Plan; 7. The proposal will establish an affordable residential community which will be accessible to lower and moderate income households; 8. The Special Policy Area under the Parks and Recreation designation is an appropriate mechanism to implement the proposal as it recognizes the uniqueness of Oriole Park Resort and does not extend permissions to other seasonal campgrounds in the Municipality; June 2018 MHBC 27

36 September 26, 2018 Page 36 of The proposed amendment to the Zoning By-Law will appropriately implement the proposed Official Plan amendment; and 10. The proposal represents good land use planning. Respectfully submitted, MHBC Planning, Urban Design & Landscape Architecture Scott Allen, MA, RPP Partner Eric Miles, MPL Planner June 2018 MHBC 28

37 September 26, 2018 Page 37 of 44 Appendix A Upper Thames River Conservation Authority Map

38 September 26, 2018 Page 38 of 44 Regulation Limit Regulation under s.28 of the Conservation Authorities Act Development, interference with wetlands, and alterations to shorelines and watercourses. O.Reg 157/06, 97/04. Legend Assessment Parcel (MPAC) Watercourse Open Tiled Middlesex NHSS Woodland (2014) Candidate for Ecologicallly Important Ecologicallly Important Significant Ecologicallly Important Wetlands (MNR) Evaluated-Provincial Evaluated-Other Not Evaluated Wetland Hazard Flooding Hazard Erosion Hazard Regulation Limit 2015 The Regulation Limit depicted on this map schedule is a representation of O.Reg 157/06 under O.Reg 97/04. The Regulation Limit is a conservative estimation of the hazard lands within the UTRCA watershed. In the case of discrepancies between the mapping and the actual features on a property, the text of Ontario Regulation 157/06 prevails and the jurisdiction of the UTRCA may extend beyond areas shown on the maps. The UTRCA disclaims explicitly any warranty, representation or guarantee as to the content, sequence, accuracy, timeliness, fitness for a particular purpose, merchantability or completeness of any of the data depicted and provided herein. The UTRCA assumes no liability for any errors, omissions or inaccuracies in the information provided herein and further assumes no liability for any decisions made or actions taken or not taken by any person in reliance upon the information and data furnished hereunder. This map is not a substitute for professional advice. Please contact UTRCA staff for any changes, updates and amendments to the information provided. This document is not a Plan of Survey. Sources: Base data, 2015 Aerial Photography used under licence with the Ontario Ministry of Natural Resources Copyright Queen's Printer for Ontario; City of London. Notes: Amiens Road, Komoka metres Created By: SP May 7, 2018 * Please note: Any reference to scale on this map is only appropriate when it is printed landscape on legal-sized (8.5" x 14") paper. 1: 4,000 Copyright 2018 UTRCA.

39 September 26, 2018 Page 39 of 44 June 13, 2018 AEC Municipality of Middlesex Centre Ilderton Road Ilderton, ON NOM 2A0 Attention: Kelly Henderson, Planner Durk Vanderwerff, MPA, MCIP, RPP Re: Servicing Brief - Oriole Park Resort Dear Sir/Madam: This correspondence has been prepared on behalf of Oriole Park Resort ("Oriole Park" or the "Site") and provides a servicing brief for the sewage works, water supply and stormwater drainage for the Site. This work is intended to support the Official Plan and Zoning By-law Amendment applications to convert Oriole Park Resort from 11-months to year-round occupancy. Based on a review of the servicing concepts, the sewage, water supply and stormwater drainage systems have sufficient capacity to accommodate year-round occupancy. Please contact the undersigned if you have any questions. Yours truly, AZIMUTH ENVIRONMENTAL CONSULTING, INC. Jackie Coughlin, B.A.Sc., P.Eng Partner/ Senior Environmental Engineer cc: Oriole Park Resort, Wendy Nesseth MOECC London District Office, John McGlynn MHBC Planning, Urban Design & Landscape Architecture (MHBC), Carol Wiebe 642 Welham Road, Barrie, Ontario L4N 9A1 telephone: (705) fax: (705) info@azimuthenvironmental.com

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