Zoning restrictions regarding wetlands protection and watercourses serve general goals for environmental stewardship. But those restrictions also provide enormous value for the municipality itself, by helping to provide storm water management, flood prevention and mitigation, and by reducing the risk of contamination of drinking water supplies.

Why this is important. Much of Saint John sits in an acknowledged, low-lying flood plain, and the City has already felt the cost of its failures to manage wetlands. Significant taxpayer money has been spent on mitigation and response to flooding problems caused by that lack of management. Those are unaccounted and avoidable costs, and continuing to ignore the need for wetlands management leaves the City and its taxpayers facing a real liability.

This is made more urgent because wetland protection has been dropped entirely by the Province (although it may be enforced at some point in the future once acceptable models/data are available).

However, wetlands protection and watercourse management isn’t just about preventing flooding and minimizing costs for taxpayers. it’s also about beautification, public land use, better drinking water, and a healthier environment.

What ZoneSJ gets right. Nothing. ZoneSJ includes no measures to protect wetlands, in effect leaving it entirely to the Province, despite the concerns noted above.

Issues and opportunities. Deferring to the Province on wetlands protection is unacceptable for two reasons:

1. The Province currently has no wetlands protection in place, and everyone knows it.
2. Even once the Province establishes wetlands protection, it may not meet the expectations or specific needs of our community.

Concern has been expressed regarding the impact that wetlands protection could have on Saint John’s growth. However, growth that ignores the risks associated with wetlands is bad growth, and a key imperative of PlanSJ is the need to limit bad growth.

Concern has been expressed regarding liability issues, requirements for fencing, and the diseases associated with wetlands (for example, West Nile virus).

Concerns have been expressed regarding the cost to the City (logistics of delineation, enforcement, and management). However, the City already has GIS staff able to support this requirement, and federal moneys are often available to offset these costs. If appropriate, costs can also be recovered through development fees.

Some of the delineation in this community has already been done by public and private partners. (For example, ACAP has delineated 75% of wetlands in the area.)

And once this work is done, it’s done. The maps and models can be used on an ongoing basis to plan for and regulate future development.

Cheat sheet for your feedback. If you want to provide feedback on this issue, feel free to use or edit the statements below:

Simple version
Please ensure that ZoneSJ includes measures and criteria to manage and protect wetlands and watercourses.

More detailed version

1. There is a short-term requirement for the City to regulate wetlands and watercourses, given the likelihood that this will become an election issue at the provincial level (and will thus be delayed).  
2. ZoneSJ must specify measures and criteria to manage and protect wetlands and watercourses.
3. ZoneSJ should dovetail with or augment Provincial policy, once that policy is enacted. There is nothing preventing the City from taking this authority. (As an example, at one point Hampton imposed a moratorium on floodplain development.)
4. Concerns regarding the cost to the City (logistics of delineation, enforcement, and management) are unjustified. This is a one-off investment. The City already has GIS staff able to support this requirement, and federal moneys are often available to offset these costs. Costs can also be recovered if needed through development fees.
5. Prioritize delineation and protection in watersheds specifically, and focus in those high-priority areas that are responsible for most of the flooding.
6. Request access to ACAP’s data. (ACAP has delineated 75% of wetlands in the area.)
7. Consider the use of rain gardens. State requirements for shrubs, trees in parking lots, etc. Specify requirements for plants that can provide filtering and pollution mitigation.
8. Set standards requiring the incorporation of green spaces in developments below the flood level, to mitigate flooding.
9. Specify requirements regarding setbacks and floodplains, watercourse setbacks and buffers, coastal development/mitigation, and wetlands mapping.
10. Do not permit the use of fill within the floodplain area, except where it is used for floodplain management or for flood proofing, and has been approved by the City.
11. ZoneSJ should address stormwater management, and the incorporation of flood retention ponds.

The deadline for your feedback to the City on ZoneSJ is Friday November 29th. Submit your input to (via webform, or in writing to planning@saintjohn.ca). And copy your councillors.