Comments on Draft Official Plan

The following deputation on the draft Official Plan was presented to Council by Treat Hull on December 9th, 2020. The County is accepting comments on the draft of the new Official Plan until January 15th. Comments can be sent to Michael Michaud, Manager of Planning at A revised version of the draft will be presented for approval at the Council meeting on February 10th.


As a real estate broker, I have to consult the Official Plan several times a week. Given that experience, I thought it was worth documenting some of my personal observations on reading the 2020 Official Plan draft.

These comments are not intended to provide a overall assessment of the draft’s strengths and weaknesses. Instead, I have largely focused on areas where more attention is needed as the new plan is implemented and reviewed.

Relationship with Secondary Plan

As currently framed, the 2020 Draft is limited in scope to rural development.

During the last several years secondary plans have been approved for Picton/Hallowell, Wellington, and Rossmore.

Each of these secondary plans contains language to the effect that if there’s a disagreement between the official plan and the secondary plan, the secondary plan takes precedence. Likewise, the 2020 Draft also contains language that give precedence to the secondary plans over the official plan (

“Where there is a conflict between a policy in this Plan and a policy in an applicable Secondary Plan, the policy of the appicable Secondary Plan shall prevail.”

Because the secondary plans take precedence, it means that any significant new policy directions in the 2020 Draft may only apply outside the major built-up areas.

The 2020 Draft should be revised so that it takes precedence over the Secondary plans, and over time, the Secondary Plans should be reviewed to bring them in line with the 2020 Draft.

Affordable Housing

(Analysis by Treat Hull of Quinte & District Association of Realtors MLS sales data for existing homes sold in September, October, and November for each year.)

Chart shows that the average house price in Prince Edward County increased 25% between the fall of 2019 and the fall of 2020.

Affordable housing is a crisis in the County which is growing worse by the day. On the current demographic and market trajectory, the affordable housing situation will continue to worsen over time. Realistically, the goals set out in the 2020 Draft will slow the decline in affordable housing, but not reverse it.

The 2020 Draft says that the majority of affordable housing will take place in Picton, Wellington, and Rossmore where the secondary plans specify a minimum of 33% of new development shall be affordable.

A goal of 33% new development affordable is extremely ambitions when compared to what’s been achieved in recent history.  Achieving this goal will require bold action by Council to re-direct the character of development on available land in Picton, Wellington, and Rossmore before it is all used up.

Rural Gentrification

Chart shows that County house prices in rural areas have been rising faster than in urban areas.

(Analysis by Treat Hull of Quinte & District Association of Realtors MLS sales data for existing home sales.)

The rapid increase in the price of housing is widely recognized. However, what’s less well known is that the price of housing is increasing most rapidly outside the built-up areas of Picton and Wellington.

Many buyers from Toronto want to escape the crowding and lack of privacy there, leading to high demand for rural homes suitable for renovation.

Affluent baby boomers (and, to an increasing degree, untethered knowledge workers able to work from home) are displacing the traditional occupants of the Countryside. Quite apart from property values, this can make long-term residents feel like strangers in their own community.

Historically, rural areas have provided a significant supply of affordable housing in the County. Over the years, the more successful farmers have bought up multiple neighboring farms, acquiring farmhouses which they didn’t need for their own families and which they rented out. Many of these “surplus” farmhouses are now being bought up and renovated.

While the 2020 draft may be based on sound planning principles, the gentrification of the rural areas and concentration of more affordable housing in the built up areas will be a significant change for long-time residents.


Chart shows the depth at which well water was found in Prince Edward County between 1950 and 2016.

(Treat Hull analysis of 5,839 County wells based on data in the Ontario Provincial Well Records database. Average water found depth shown in feet.)

Sustainability is formally a high priority for the County, reflected in Council’s declaration of a climate emergency.

There is, however, one area where the 2020 Draft is largely silent on what I think could be the largest potential threat to sustainability, namely rural drinking water.

Municipal water supplies in built-up areas are covered in the draft. However, the majority of County residents depend on wells and there’s no discussion in the 2020 Draft of the amount of water stored in the aquifer, the potential impact of climate change and the impact of continued rural development.

There was a “Preliminary Hydrogeological Investigation of Prince Edward County” in 1985 and a “Quinte Regional Groundwater” study in 2004, and neither identified any concern with the adequacy of the supply in the aquifer at the time.

Perhaps a ministry or Quinte Conservation monitors the adequacy of the aquifer to meet change County water demands, but I suspect we’re flying blind on this issue.

This is not to say that there is a looming crisis with respect to the supply of rural drinking water.  The graph (above) actually shows that the level where well water is found is decreasing – the water is higher in the aquifer. The point is that the adequacy of the supply of rural water is a critical sustainability issue and should be a consideration in the County’s official plans which is why it’s included in these comments of the draft Official Plan.


Chart showing internet download speed in Prince Edward County compared to major urban areas.

The discussion of infrastructure in the 2020 Draft covers the conventional components of infrastructure. However, it appears that one critical element may have been omitted.

The County’s built-up areas are reasonably well served by high-speed internet. However, a majority of County residents live outside the built-up areas and they are poorly served by high-speed internet. The average download speed in Toronto is 142 Mbps ( Based on personal experience and anecdotal evidence, the County’s rural residents typically receive something closer to 4 Mbps.

High speed internet (the “information superhighway”) will be as important to future economic development in rural areas as the road network is today.

Transparency and Reporting

The 2020 Draft contains a commitment to develop, maintain and publish metrics which track progress towards the goals in the plan. This is a positive step because in the past there has been little such information available.

To give a personal example, during 2018-2019, I asked County staff for a listing of the housing developments at different stages in the pipeline and found that none was available.

I was able to create such a list for my real estate practice but compiling the list required more than 3 solid person-days of research including reviewing all the minutes and staff reports for the previous 6 years of Public Planning meetings as well as reviewing media coverage of development.

Needless to say, this is beyond what most residents are in a position to do to determine whether we are achieving the goals of our official plan.


Graphic shows a matrix which enable readers to find all the key references in the Official Plan for any issue of interest.

(Thematic Official Plan reading guide, © 2020 Treat Hull & Associates Ltd.)

Ultimately, many residents will be affected by what’s in the plan. But while the 2020 Draft is more readable than the 2018 Draft, it is still too dense and complicated to be read and understood by much of the public.

Most residents will approach the plan with a particular interest in mind rather than an interest in understanding comprehensive policy. However, to understand the approach to any particular topic requires reading the material that is scattered across the plan.

As part of implementation, the County should consider developing a thematic reading guide to make the Official Plan more accessible to residents.


Thank you for the opportunity to present these comments on the draft Official Plan.

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