The Friends of the Tay…

The Friends of the Tay Watershed respectfully submit the following comments regarding Ontario’s Bill 98, Building Homes and Improving Transportation Infrastructure Act, 2026.

The Friends of the Tay Watershed Association is an incorporated charitable organization composed of residents, lake associations, community groups, and government and non-government partners dedicated to the protection and stewardship of water and related natural resources within the Tay watershed in eastern Ontario. The watershed spans approximately 95 kilometres and lies within both the Rideau Canal system and the Rideau Valley Conservation Authority watershed jurisdiction.
The Tay watershed includes the Tay River, Tay Canal, numerous tributaries, wetlands, and more than 45 lakes. It crosses six municipalities — Township of Rideau Lakes, Township of South Frontenac, Township of Central Frontenac, Township of Tay Valley, Township of Drummond/North Elmsley, and the Town of Perth — and extends across Lanark, Frontenac, and Leeds and Grenville counties.

Healthy lakes, rivers, wetlands, and shorelines are foundational to the environmental, social, and economic sustainability of rural Ontario communities. Natural shoreline buffers and vegetated areas play a critical role in filtering runoff, reducing erosion, improving water quality, absorbing floodwaters, maintaining fish and wildlife habitat, and protecting biodiversity. These natural systems are increasingly important as rural municipalities face growing development pressures and the impacts of climate change.

The watershed also supports a significant seasonal and permanent waterfront economy. According to the Federation of Ontario Cottagers' Associations, waterfront property owners across Ontario contribute more than $700 million annually in property taxes to municipalities and spend approximately $11.44 billion annually in Ontario communities, supporting over 150,000 jobs. In eastern Ontario, waterfront property owners represent a major economic driver for local contractors, trades, tourism operators, restaurants, marinas, retailers, and service providers. In rural municipalities such as Tay Valley and Rideau Lakes, healthy lakes and protected shorelines are directly linked to tourism, recreation, municipal tax assessment, property values, and local business sustainability.

The Friends of the Tay Watershed are concerned that Bill 98 weakens several important environmental planning and watershed protection tools that rural municipalities and conservation authorities rely upon to protect lakes and rivers and which cottagers and waterfront property owners value.

1. Loss of Local Environmental Planning Tools
Bill 98 proposes to prohibit municipalities from requiring certain enhanced green development standards through planning tools such as Site Plan Control. This includes measures such as permeable pavement, bioswales, tree planting, electric vehicle infrastructure, bicycle parking, and other low-impact development features.
This proposal undermines the policy direction within the Provincial Planning Statement, 2024, which states that planning authorities shall reduce greenhouse gas emissions and prepare for the impacts of climate change through green infrastructure and low-impact development approaches. Removing these tools limits the ability of municipalities to protect water quality, manage stormwater, reduce flooding risks, and strengthen climate resilience.
In rural lake communities, cumulative impacts from unmanaged runoff, vegetation loss, and potential for shoreline alteration can significantly affect lake health, fisheries, and recreational water quality over time. Maintaining healthy lakes is contingent on maintaining a natural 3 meter shoreline zone.

2. Waterfront and Shoreline Vulnerabilities
The proposed standardization of land use planning frameworks across Ontario risks eliminating locally tailored shoreline and waterfront policies developed by the Tay Valley Township (TVT) to address unique watershed conditions. TVT relies on customized shoreline setbacks, lake capacity policies, riparian buffers, and environmental designations to manage development around sensitive lakes, wetlands, and waterways. A standardized province-wide approach does not adequately reflect the environmental realities of rural watersheds.
The Friends of the Tay Watershed are also concerned about proposed reforms to Site Plan Control, including the possibility of reducing or eliminating municipal review authority. Site Plan Control is one of the primary tools that the TVT can use to protect shoreline vegetation, stormwater management, drainage patterns, and water quality near lakes and rivers. Weakening these protections risks long-term degradation of water quality, biodiversity, fisheries, and recreational opportunities that are critical for contributing to the economic health of the region.

3. Encumbered Parkland and Natural Heritage Concerns
The proposed parkland framework would permit developer-identified lands, including privately owned public spaces and encumbered lands, to count toward municipal parkland dedication requirements. It remains unclear how these changes will result in meaningful or accessible public green space. There is concern that wetlands, shoreline buffers, and natural heritage lands adjacent to lakes and waterways could be counted toward parkland obligations without ensuring long-term ecological protection or true public access. This approach may unintentionally increase development pressure on environmentally sensitive lands while reducing opportunities for genuine community green space.

4. Erosion of Conservation Authority and Municipal Oversight
The Friends of the Tay Watershed remain concerned about the continuing reduction of conservation authority involvement in planning and development review — a trend that began with Bill 23 and continues through Bill 98.

The technical expertise provided by the Rideau Valley Conservation Authority (RVCA) is essential for evaluating flood risks, erosion hazards, watershed impacts, stormwater management, and environmental sustainability. Limiting conservation authority participation weakens science-based decision-making and reduces independent oversight in environmentally sensitive areas.
We are also concerned about the proposed standardized “complete application” framework, which may restrict municipal flexibility to require studies appropriate to local conditions. Rural municipalities must retain the authority to request environmental and watershed studies where site-specific concerns exist.
Additionally, while the Province proposes standardized digital planning systems, smaller municipalities may face unnecessary costs and administrative burdens if required to replace systems that are already functioning effectively.

At the same time, we recognize and support proposals encouraging communal drinking water and wastewater systems in rural hamlets, which may help reduce sprawl and support more sustainable and affordable rural housing development.

The Friends of the Tay Watershed share concerns raised by Environmental Defence Canada, Ontario Federation of Agriculture, (OFA), Federation of Ontario Cottagers Association (FOCA), and many rural Ontario municipalities that Bill 98 removes important environmental and local planning tools without adequately addressing the broader barriers to housing development.

Healthy watersheds are essential infrastructure for rural Ontario. Weakening shoreline protections, conservation authority oversight, and municipal planning authority risks long-term impacts to water quality, biodiversity, flood resilience, recreation, tourism, municipal finances, and property values throughout the Tay watershed and beyond.

Recommendations
The Friends of the Tay Watershed recommend that the Province of Ontario:
- Maintain municipal authority to adopt stronger local environmental and green development standards that reflect watershed conditions and rural realities.
- Preserve shoreline, waterfront, and natural heritage land use designations within municipal official plans.
- Protect and strengthen shoreline setback and vegetated buffer requirements to reduce runoff, erosion, flooding, and nutrient loading into lakes and rivers.
- Ensure wetlands, riparian areas, and natural heritage lands are not treated as substitutes for meaningful public parkland dedication.
- Restore and protect the planning and technical review role of conservation authorities, including the RVCA, in development applications affecting watersheds and flood-prone areas.
- Maintain municipal authority to require site-specific environmental and watershed studies where local conditions warrant additional review.
- Recognize that rural watersheds require place-based planning approaches rather than standardized province-wide land use rules.
- Ensure cumulative environmental impacts on lakes, wetlands, biodiversity, and water quality are fully considered before development approvals are granted.
- Protect municipal flexibility to address lake capacity, carrying capacity, shoreline sensitivity, and stormwater management through local bylaws and official plans.
- Continue supporting communal servicing solutions that promote sustainable rural housing while limiting sprawl impacts on lakes and natural areas.
- Support long-term watershed stewardship, monitoring, and science-based planning in partnership with municipalities, conservation authorities, and community organizations.