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Here’s why that’s a serious problem:

It’s out of scale for a rural area

  • This is a city-style subdivision being dropped into a quiet rural landscape.
  • With 29 large homes, multiple driveways, and a new road, it doesn’t fit with the scattered farms, forests, and cottages nearby.
  • It introduces suburban sprawl into an area meant for low-impact, rural living.


It threatens the health of the Rideau River

  • The homes would be built right along the shoreline of the Rideau River — a Canadian Heritage River and part of a UNESCO World Heritage Site.
  • The developer plans to clear trees and build septic systems close to the water, which can lead to runoff, pollution, and shoreline erosion.
  • This stretch of river is largely natural today — this project would change that forever.


There’s been no consultation with Indigenous communities

  • In direct contradiction to the resolution passed by Merrickville-Wolford Council, the Algonquins of Ontario have not been consulted. 
  • The applicant’s archeological report is deeply flawed, referring to the wrong region of Ontario and also ignores a 2005 Stage 1 and 2 archeological assessment that identified significant Indigenous artefacts on the land proposed for development. 


It puts species and natural areas at risk

  • The land is home to wetlands, woodlands, and wildlife, including turtles and other species at risk.
  • The developer's own studies show these habitats exist, but the proposal doesn’t include meaningful protection.
  • Once the forest is cleared and the wetlands are disturbed, they can’t be replaced.


It doesn’t follow good planning or climate policy

  • The land is currently zoned for rural and natural heritage protection. The developer wants the rules changed to allow this.
  • It will create 29 private wells and septic systems, with no municipal services — which is not sustainable long-term.
  • There’s no affordable or diverse housing. These are high-end homes for a few, not a benefit for the broader community.


It sets a dangerous precedent

  • The applicant’s property is not within Merrickville Wolford designated settlement areas.
  • If this development goes ahead, it opens the door to more subdivisions along the Rideau River.
  • Bit by bit, the shoreline will be privatized and built up — and the natural character of this area will be lost.


This proposed development is wrong for this land, wrong for the Rideau River, and wrong for our community’s future.

Formal Critiques of the Proposal

Response from Adjacent Landowners

This letter, submitted by direct neighbors and close by residents to the proposed subdivision, outlines their strong opposition to the development at 819 County Road 23. They raise serious concerns about the project's impact on local wildlife, wetlands, and shoreline stability, and argue that the 29-lot plan is far too large for the area. The letter highlights flooding risks, the presence of species at risk, and the inconsistency of the proposal with the rural and natural character of the Rideau corridor. They commissioned their own expert Hydrogeological and Planning studies which raise significant issues with the application. 


They call on Council to reject the proposal in favour of more responsible, environmentally sound planning in settlement areas that have already be identified for growth.


Technical Review by the Rideau Valley Conservation Authority

This document contains the formal review from the Rideau Valley Conservation Authority (RVCA) regarding the proposed 29-lot subdivision at 819 County Road 23. While not outright opposing the development, RVCA raises serious technical concerns that must be addressed before the project can proceed.


Key concerns include:

  • Inadequate slope stability assessment near the Rideau River, especially in high-risk erosion zones.
  • Stormwater plans that fail to manage total runoff volumes, putting the river and wetlands at risk.
  • Loss of important tributaries and headwater drainage features, which could increase flooding and degrade water quality.
  • Shallow geotechnical investigations that don’t meet best practices and leave critical soil conditions unexplored.
  • Need for stronger shoreline and vegetation protections to preserve slope integrity and prevent erosion.


RVCA recommends further study, plan revisions, and stronger environmental safeguards to ensure the development won’t compromise public safety, natural heritage, or watershed health.


Parks Canada Response to Subdivision Proposal

In this detailed response, Parks Canada acknowledges that the proposed development borders the Rideau Canal National Historic Site and UNESCO World Heritage Site, and raises several significant concerns:

  • While the development does not directly impact the canal’s designated heritage features, it falls within the 30-metre buffer zone, which is critical to the canal’s scenic and cultural integrity.
  • Parks Canada recommends that all future development (including decks and pools) be kept outside this buffer and that existing shoreline vegetation be preserved.
  • The agency emphasizes the need to protect scenic views and landscape character, recommending earth-tone materials and traditional architectural styles.
  • Parks Canada requests a heritage impact and visual assessment, including a rendering as viewed from the canal, to evaluate how the development will affect the canal’s setting.
  • It warns that individual shoreline structures (e.g., docks, ramps) will not be permitted for most lots due to sensitive habitat and proximity to the navigation channel.
  • A marine archaeological study is required, as there are known Indigenous archaeological sites on the property.
  • Parks Canada also critiques the stormwater management plan, calling for more rigorous turbidity controls, long-term monitoring, and stronger mitigation to protect aquatic life.


Parks Canada recommends that approval be deferred until all these issues are resolved.


Peer Review – Hydrogeological and Terrain Assessment

WSP Canada Inc. conducted a peer review of the developer’s Hydrogeological and Terrain Evaluation report to assess the feasibility of servicing 29 estate lots with private wells and septic systems. The review identifies several areas of concern:


Soil and Drainage Limitations:

  • The site is underlain by low-permeability silty clay soils, which limit infiltration and create challenges for septic system operation.
  • The shallow depth to the water table in several locations increases the risk of effluent breakout (when untreated or partially treated wastewater surfaces above ground) and surface ponding (when water collects and pools on the surface due to poor drainage), particularly during spring melt or heavy rain.


Septic System Constraints:

  • Several proposed lots lack sufficient space for conventional septic systems, requiring raised systems or innovative designs.
  • These constraints may limit home size or future expansion and increase the risk of system failure if not properly engineered and maintained.


Test Well Reliability Issues:

  • Some monitoring wells installed during site investigations were found to be poorly constructed or placed in backfilled pits, reducing confidence in groundwater level measurements.
  • This raises concerns about the accuracy of conclusions drawn regarding groundwater movement and separation from septic fields.


Groundwater Supply and Quality:

  • The report concludes that there is adequate groundwater quantity for domestic use across the site.
  • While nitrate concentrations are currently within acceptable limits, the cumulative effect of 29 septic systems remains a concern over the long term, especially in shallow bedrock or poorly drained soils.


Risk of Surface Water Contamination:

  • Given the topography and poor drainage, there is potential for overland flow to carry contaminants toward nearby wetlands and the Rideau River.
  • WSP notes that surface water monitoring or mitigation measures were not adequately addressed in the original submission.


Recommendation for Further Work:

  • The peer review supports the concept of private servicing as technically possible, but only with careful design and ongoing oversight.
  • WSP recommends the Counties and Municipality require detailed lot-level design plans, ongoing monitoring, and possibly additional site-specific testing before final approval.


Critical Recommendations

  • Design septic systems with extreme caution — low-permeability soils and shallow water tables demand tailored solutions.
  • Do not proceed without robust municipal oversight, particularly on the seven constrained lots.
  • Ensure buyer transparency about water quality, septic complexity, and treatment needs.
  • Review long-term risks of cumulative septic loading, particularly with potential for secondary dwelling units.
  • Abandon monitoring wells properly and ensure future wells comply with Reg. 903 and consider deeper water quality differences.


While the proposed development may be technically feasible, it is also environmentally fragile.


The subdivision could proceed only if septic system design rigorously accounts for site limitations, and municipalities commit to active enforcement and homeowner education. The proximity to the Rideau River and high water table amplifies the need for precautionary principles.


Peer Review – Environmental Impact Statement

The Ainley Group conducted a peer review of the Environmental Impact Statement (EIS) for the proposed 26-lot subdivision at 819 County Road 23 (Orchards of River Bend) in Merrickville-Wolford. The review assessed the EIS against provincial and municipal policy requirements, technical methodologies, and natural heritage considerations.


Key Findings and Issues Identified:

  • Policy Gaps: The EIS did not reference all relevant legislation (e.g., Fisheries Act, Endangered Species Act, Migratory Birds Convention Act) and lacked a clear policy conformity analysis.
  • Methodology Concerns: The report did not adequately describe methods for wetland boundary delineation, vegetation classification, or soil sampling.
  • Existing Conditions: More detail is needed on Rideau River features (morphology, habitat, fish species) adjacent to the site.
  • Species at Risk (SAR): Additional potential species (Spotted Turtle, Small-mouthed Salamander, and several bat species) were not fully considered. Updates are also needed for Black Ash protections and potential bat roosting habitat.


Impact Assessment:

  • Potential effects of upgrading the driveway near the swamp feature on turtles were overlooked.
  • Assessment of significant woodlands requires more rationale to justify “no negative impact.”
  • Tributary 1 should be maintained/enhanced, per Rideau Valley Conservation Authority (RVCA) comments, contrary to the EIS conclusion.


Mitigation and Recommendations:

  • No long-term strategy provided to protect the 30 m development setback after construction.
  • Temporary wildlife fencing for turtle protection during construction should be reconsidered.
  • Inconsistent setback distances for Butternut trees (25 m vs. 50 m) require clarification.
  • Concluding statements should address conformity not only with the Provincial Policy Statement but also with local Official Plans.


Overall Conclusion:

The peer review found the EIS incomplete and recommended significant revisions to address policy compliance, methodology, species at risk, hydrology, and mitigation measures. The consultant must update the EIS in response to these comments before the development can be properly evaluated.


Peer Review – Stormwater Management

Jp2g Consultants Inc. completed a peer review of the stormwater management (SWM) and grading design for the proposed subdivision at 819 County Road 23 (Orchards of Riverbend), Merrickville-Wolford. The review assessed drawings, grading plans, erosion/sediment control plans, and the conceptual SWM report prepared by Kollard and Associates.


Key Findings and Issues Identified:


Design Concerns:

  • The south SWM block has a flat slope and, given the silty-clay soils, minimal infiltration is expected. Standing water and wetland vegetation growth could result. A minimum 0.3% slope is required.
  • 5- and 100-year ponding elevations need to be shown.
  • Each SWM facility must have at least 0.30 m freeboard.
  • Ponding extents must be confirmed in plan view.
  • Cross-sections of SWM facilities are required.
  • Ditches must have a minimum depth of 0.85 m, proper culvert cover, and a complete culvert schedule.
  • Some proposed building elevations (e.g., Lot 4) do not meet minimum requirements above groundwater/ditch levels.
  • Lot line swales do not consistently drain to roadside ditches and must be revised.


Stormwater Report Deficiencies:

  • Clarification is required from the Rideau Valley Conservation Authority (RVCA) about directing roadside ditch flow into wetlands and conveying uncontrolled areas.
  • Detailed culvert designs across wetlands must account for full flows.
  • RVCA may require a formal wetland evaluation.
  • Infiltration design for the south swale is questionable: the assumed percolation rates appear too high for silty-clay soils and do not account for groundwater levels, clogging, or mounding.
  • Calculations supporting peak flow velocity (Table 6-1) need to be provided.
  • Sand filter design is uncertain: a minimum 1 m separation from groundwater is required but not demonstrated.
  • Roadside ditch design must comply with Ministry of Transportation (MTO) standards.


Overall Conclusion:

The peer review found numerous technical deficiencies in the stormwater and grading design that must be addressed at the detailed design stage. Without corrections, risks include inadequate drainage, standing water, wetland encroachment, and ineffective stormwater controls. Jp2g emphasized the need for confirmation from the RVCA and revisions to ensure compliance with provincial standards and site-specific soil/geotechnical conditions.