Memorendum Regarding the Revision of the VMT Urbanization Plan
On April 13, the Mont-Tremblant City Council announced plans to revise completely their Urbanization Plan —set for public release in 2025—along with 12 draft bylaws (working documents) intended to replace or supplement existing regulations in support of the proposed strategic directions. Several aspects raise concerns, particularly those regarding the already fragile watershed environments and effective water management.
INTRODUCTION
Our comments come under two themes:
holistically;
specific feedback regarding certain sections of the zoning bylaw on environmental performance.
1. HOLISTIC FEEDBACK
A Plan Based on Sound Policies
The project to overhaul the urbanization plan (“Plan d’Urbanisme Pré-projet de règlement Avril 2026 - Version de travail pour commentaires”, hereinafter referred to as the “Document”) highlights very sound land planning policies, notably:
Preserving the environment is a theme that can be found throughout the document;
The recognition of Mont-Tremblant as a community of mountains and forests;
The concept of integrated projects in non-urban locations to achieve a proper balance between environmental preservation and sustainable development;
Sound water management;
Above all, watershed-based land management, a concept that has existed for several years and is finally integrated into the City's new urban planning framework.
Need for Better Governance
(i) Adopt Key Performance Indicators (KPIs)
The Document does not explain how our elected officials and municipal staff will be held accountable for compliance with the sound policies on which this Document is based. There should be a section that identifies KPI’s reflecting good governance. For example, it would be important to include:
The number of refused applications for regulatory exemptions (aks, “dérogations mineurs”) compared to the number of total exemptions requested annually;
Mandatory environmental protection training programs for elected officials and municipal staff, as well as the public disclosure of passing rates;
The creation of a dashboard to show success rates for each action implemented to safeguard watershed protection policies;
The implementation of a policy to address the housing shortage by reducing short-term rentals in the overall housing supply — in fact, according to Les Amis de Mont-Tremblant, Ville de Mont-Tremblant is the most notoriously-known city in Quebec and the second most notoriously-known in Canada with 16.37% of all available long-term housing being dedicated to short-term rentals made available on apps such as AiirB&B or VRBO.
(ii) Lack of Protection of the Plan’s Long-Term Sustainability and Risk Management
The Document does not disclose how the revised urbanization plan can survive political changes or the sudden populist desires of our elected officials. What ensures that during a future election, the former council dedicated to environmental protection will not be replaced by a council that favours development to increase the tax revenues? Without such protection, a land use planning scheme is nothing more than a wish list.
We also suggest that our elected officials commit to identifying the risks of non-compliance with the revised urbanization policies, and to establishing controls to avoid these risks. This risk management must include an internal audit process aimed at identifying inefficiencies in the execution of a new urbanization plan, as well as the disclosure of results during minimum annual audits. Of course, the auditor must be completely independent of the City Council and administration.
A Questionable Example
We note the comments of Les Amis de Mont-Tremblant that the plan proposed in the Document does not account for the risk of approving "undesirable" development projects.
The relevant example is the project at 150 Chemin Desmarais, right in the heart of the Lac Tremblant watershed. The project is for the construction of a two-story single-family building, comprising twelve bedrooms and a rooftop pool. After reading the Document, it is difficult to reconcile permitting the construction of a pool on the shores of Lac Tremblant. During filtration cleaning, there is a significant risk that the pool's wastewater will end up directly in the lake. This construction is designated residential, but when it walks like a duck and quacks like a duck, it must be a duck.
2. FEEDBACK ON THE ZONING BYLAW REGARDING ENVIRONMENTAL PERFORMANCE
i - A Broader Scope
This bylaw targets integrated projects (Section 4), but should also include all other conventional projects (subdivisions and developments) within the Lac Tremblant watershed, considering the sensitivity of the environment, its role as the source of drinking water, and its importance in the tourism industry.
Furthermore, the scope of the bylaw (Section 5) should be larger and primarily focused on achieving environmental performance objectives in zones located outside urban boundaries, and secondarily and optionally, on the payment of a sum of money to the city intended for the implementation of an affordable, social, or family housing program.
ii - Include All Zones Within the Watershed
The proposed bylaw on environmental performance targets only five types of zones (Section 16). Other types of zones are present in the Lac Tremblant watershed and could benefit from the proposed measures.
iii - Constraint Zones must Include alleyways
Considering the environmental risks associated with them, the obligation to avoid constraint zones (Section 19) should include alleyways. Furthermore, any project affecting the Lac Tremblant watershed should be avoided where slopes exceed 25% (Schedule A).
iv - Stormwater Management with Broader Scopes
The obligation for a runoff water management system should explicitly include rainwater, drywells (or absorption pits), as well as foundation drainage water. In addition, reference should be made to a “zero surface runoff” objective. Rainwater harvesting (collection, storage, treatment) for irrigation or horticultural purposes remains an optional practice in parallel, but the general management of rainwater should be mandatory.
v - Topographical and Mandatory Scope
Compliance with the natural topography should be mandatory for any project, rather than an optional concept.
vi - Renaturalization must be a Requirement
The rehabilitation of natural environments disrupted by human activities or following a natural event, when the environment is not already undergoing natural restoration, should be mandatory for any project, even at the residential level.
vii - More Significant Regulation on Access Driveway Lengths
The replacement criterion (Section 20) regarding the prohibition of alleyways 300 meters or longer doesn’t go far enough within the Lac Tremblant watershed. Considering the environmental risks associated with them, all access alleyways should be subject to a strict 300-meter limit, without any easing mechanisms. A longer access should be considered a road. Furthermore, if an access alleyway is planned to serve more than three main buildings, road construction standards should apply, with the objective of minimizing the footprint of the associated cut-and-fill work and deforestation.
viii - Updates by Developers/Applicants on Natural Spaces within a Watershed
Upon submission of an eligible project, among the documents to be produced by the applicant/developer, we also recommend an updated calculation of the natural space for the entire sub-watershed, in connection with the cumulative environmental impact assessment and the carrying capacity of the watershed in which the project is located.
ix - Municipal Officer must be Involved
Notwithstanding the applicant/developer's obligations to provide a certification signed by a professional upon project completion, the bylaw should stipulate that a municipal officer must physically inspect the developed areas to certify that the developer's environmental monitoring and audit reports comply with commitments and best practices, or mandate a third party to do so on their behalf. In our view, the City must share accountability for the outcomes upon termination of the agreement with the developer.
x - Need for Better Mapping
Schedule C (Natural Constraints) presents mapping that appears incomplete or inaccurate. Furthermore, known spawning grounds at the outlet of Lac Mercier and Lac Tremblant (Cachée River) do not appear. Additionally, the shoreline protection zones identified in red appear limited or incomplete, which could be misleading regarding the actual shorelines to be protected around lakes and watercourses (shoreline regulation). Finally, the City should adopt a mechanism to review and update the natural constraints map on an annual basis, including a referral process with relevant ministries and the MRC.
CONCLUSION
An urbanization plan reflects the soul of a municipality. A plan of such significance should respect ESG criteria — Environmental, Social, and Governance. These criteria are notably used to hold corporate boards of directors accountable. Therefore, why not adopt them for municipal councils? We would like to see an urbanization plan that ensures better governance.
The commitment to successful environmental performance within watersheds warrants a broader regulatory scope and significant adjustments to ensure the health of our watersheds.