Text and Map Amendment - Wetlands

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This planning application is now closed. The amendments came into effect January 10, 2025 when notice was published in the NL Gazette.

Council is considering a text and map amendment to the Envision St. John's Development Regulations regarding wetlands. The proposed text and map changes are in response to Council adopting the Wetlands Study Phase 2A on November 28, 2023.

At the November 28, 2023 regular meeting, Council adopted the Wetlands Study Phase 2A and resolved to protect Lundrigan’s Marsh and wetlands with a Wetlands Ecosystem Services Protocol for Atlantic Canada (WESP-AC) score of 6 or higher. As a result of the November 28, 2023 Council resolution, changes to Section 4.10 “Waterways, Wetlands, Ponds or Lakes” and Appendix C, Map 4 “Waterways and Wetlands” of the Envisions St. John’s Development Regulations are proposed.

Wetlands that scored 6 or higher in the Wetlands Study Phase 2A and Lundrigan's Marsh are protected and shown in red on the revised Map 4. Wetlands that obtained a score less than 6 are shown as unprotected on Map 4. Wetlands that still require a field assessment score based on the WESP-AC are titled Wetlands - Further Study Required on Map 4.

The proposed changes to the Development Regulations can be found in the draft amendment.

Review the materials on this page and provide your feedback or ask a question.

Return to Planning St. John's main page.

Council is considering a text and map amendment to the Envision St. John's Development Regulations regarding wetlands. The proposed text and map changes are in response to Council adopting the Wetlands Study Phase 2A on November 28, 2023.

At the November 28, 2023 regular meeting, Council adopted the Wetlands Study Phase 2A and resolved to protect Lundrigan’s Marsh and wetlands with a Wetlands Ecosystem Services Protocol for Atlantic Canada (WESP-AC) score of 6 or higher. As a result of the November 28, 2023 Council resolution, changes to Section 4.10 “Waterways, Wetlands, Ponds or Lakes” and Appendix C, Map 4 “Waterways and Wetlands” of the Envisions St. John’s Development Regulations are proposed.

Wetlands that scored 6 or higher in the Wetlands Study Phase 2A and Lundrigan's Marsh are protected and shown in red on the revised Map 4. Wetlands that obtained a score less than 6 are shown as unprotected on Map 4. Wetlands that still require a field assessment score based on the WESP-AC are titled Wetlands - Further Study Required on Map 4.

The proposed changes to the Development Regulations can be found in the draft amendment.

Review the materials on this page and provide your feedback or ask a question.

Return to Planning St. John's main page.

This planning application is now closed. The amendments came into effect January 10, 2025 when notice was published in the NL Gazette.

Please use this space to ask questions regarding this application and we will provide an answer. All questions will be posted as submitted. Some questions may require coordination with internal departments and additional time may be needed to post a response. 

The Q & A section will remain open while the application is active. 

If you prefer to provide comments or questions using mail or email, please do so to the Office of the City Clerk, including your name and address, e-mail cityclerk@stjohns.ca or write to P.O. Box 908, St. John’s, NL, A1C 5M2. Be sure to include the name of the application in your submission. 


  • Share Hi folks. Thanks again for responding to these questions. In one response, you state, "The City is proposing to update Section 4.10 to accurately reflect and explain the changes that are being proposed to Map 4. " However, the proposed updates to Section 4.10 do MUCH MORE than merely explain the changes introduced by Map 4. The proposed changes ALSO: (a) remove the existing protections of wetlands; (b) introduce a new concept of a scoring system for wetlands; (c) introduce and specify and adopt the weighting scheme used for said scoring system; (d) introduce a rule for how wetlands will be declassified as "protected" in the future; and (e) codify the "cut-off" value for said rule as "6" out of a possible score of "10". None of the items from (a) through (e) above are required to explain Map 4. Map 4 could be explained by merely stating what the data is in Map 4, and without adding the additional changes to the regulations. Could you add some clarity as to whether these two very different and independent aspects of the proposed changes are recognized by Council? Without this full understanding of the technical, independent relationship between the changes embedded within the proposal, then open, informed, and transparent debate could not have taken place on this matter by Council. In light of this, will debate, and an associated public commentary period, be reopened on this topic? Thank you! on Facebook Share Hi folks. Thanks again for responding to these questions. In one response, you state, "The City is proposing to update Section 4.10 to accurately reflect and explain the changes that are being proposed to Map 4. " However, the proposed updates to Section 4.10 do MUCH MORE than merely explain the changes introduced by Map 4. The proposed changes ALSO: (a) remove the existing protections of wetlands; (b) introduce a new concept of a scoring system for wetlands; (c) introduce and specify and adopt the weighting scheme used for said scoring system; (d) introduce a rule for how wetlands will be declassified as "protected" in the future; and (e) codify the "cut-off" value for said rule as "6" out of a possible score of "10". None of the items from (a) through (e) above are required to explain Map 4. Map 4 could be explained by merely stating what the data is in Map 4, and without adding the additional changes to the regulations. Could you add some clarity as to whether these two very different and independent aspects of the proposed changes are recognized by Council? Without this full understanding of the technical, independent relationship between the changes embedded within the proposal, then open, informed, and transparent debate could not have taken place on this matter by Council. In light of this, will debate, and an associated public commentary period, be reopened on this topic? Thank you! on Twitter Share Hi folks. Thanks again for responding to these questions. In one response, you state, "The City is proposing to update Section 4.10 to accurately reflect and explain the changes that are being proposed to Map 4. " However, the proposed updates to Section 4.10 do MUCH MORE than merely explain the changes introduced by Map 4. The proposed changes ALSO: (a) remove the existing protections of wetlands; (b) introduce a new concept of a scoring system for wetlands; (c) introduce and specify and adopt the weighting scheme used for said scoring system; (d) introduce a rule for how wetlands will be declassified as "protected" in the future; and (e) codify the "cut-off" value for said rule as "6" out of a possible score of "10". None of the items from (a) through (e) above are required to explain Map 4. Map 4 could be explained by merely stating what the data is in Map 4, and without adding the additional changes to the regulations. Could you add some clarity as to whether these two very different and independent aspects of the proposed changes are recognized by Council? Without this full understanding of the technical, independent relationship between the changes embedded within the proposal, then open, informed, and transparent debate could not have taken place on this matter by Council. In light of this, will debate, and an associated public commentary period, be reopened on this topic? Thank you! on Linkedin Email Hi folks. Thanks again for responding to these questions. In one response, you state, "The City is proposing to update Section 4.10 to accurately reflect and explain the changes that are being proposed to Map 4. " However, the proposed updates to Section 4.10 do MUCH MORE than merely explain the changes introduced by Map 4. The proposed changes ALSO: (a) remove the existing protections of wetlands; (b) introduce a new concept of a scoring system for wetlands; (c) introduce and specify and adopt the weighting scheme used for said scoring system; (d) introduce a rule for how wetlands will be declassified as "protected" in the future; and (e) codify the "cut-off" value for said rule as "6" out of a possible score of "10". None of the items from (a) through (e) above are required to explain Map 4. Map 4 could be explained by merely stating what the data is in Map 4, and without adding the additional changes to the regulations. Could you add some clarity as to whether these two very different and independent aspects of the proposed changes are recognized by Council? Without this full understanding of the technical, independent relationship between the changes embedded within the proposal, then open, informed, and transparent debate could not have taken place on this matter by Council. In light of this, will debate, and an associated public commentary period, be reopened on this topic? Thank you! link

    Hi folks. Thanks again for responding to these questions. In one response, you state, "The City is proposing to update Section 4.10 to accurately reflect and explain the changes that are being proposed to Map 4. " However, the proposed updates to Section 4.10 do MUCH MORE than merely explain the changes introduced by Map 4. The proposed changes ALSO: (a) remove the existing protections of wetlands; (b) introduce a new concept of a scoring system for wetlands; (c) introduce and specify and adopt the weighting scheme used for said scoring system; (d) introduce a rule for how wetlands will be declassified as "protected" in the future; and (e) codify the "cut-off" value for said rule as "6" out of a possible score of "10". None of the items from (a) through (e) above are required to explain Map 4. Map 4 could be explained by merely stating what the data is in Map 4, and without adding the additional changes to the regulations. Could you add some clarity as to whether these two very different and independent aspects of the proposed changes are recognized by Council? Without this full understanding of the technical, independent relationship between the changes embedded within the proposal, then open, informed, and transparent debate could not have taken place on this matter by Council. In light of this, will debate, and an associated public commentary period, be reopened on this topic? Thank you!

    Sam B. asked 11 months ago

    The proposed amendment is in response to Council's adoption of Wetlands Study Phase 2A and Council's previous decision to protect wetlands with a WESP score of 6 or higher. Section 4.10 of the Development Regulations speaks to waterways, ponds, lakes and wetlands. Subsection 1 which includes a table, is being updated to reflect Council's decision with respect to wetlands. The information regarding waterways, ponds and lakes will remain in text, without the presence of the table. This is shown in the draft amendment document. The remaining sections of 4.10 will remain but be renumbered accordingly. 

    Council is aware of the proposed amendment as it went before Committee of the Whole in March, 2024 for initial consideration. 

  • Share Am I understanding correctly that your plan is to eliminate protected status on most of our city's wetlands? I'm quite shocked, as I've read several reports about how essential wetlands are to maintaining a healthy planet. Why is the proportion so drastic? It feels a lot like this is driven by greed and short term profits, not by current wisdom. on Facebook Share Am I understanding correctly that your plan is to eliminate protected status on most of our city's wetlands? I'm quite shocked, as I've read several reports about how essential wetlands are to maintaining a healthy planet. Why is the proportion so drastic? It feels a lot like this is driven by greed and short term profits, not by current wisdom. on Twitter Share Am I understanding correctly that your plan is to eliminate protected status on most of our city's wetlands? I'm quite shocked, as I've read several reports about how essential wetlands are to maintaining a healthy planet. Why is the proportion so drastic? It feels a lot like this is driven by greed and short term profits, not by current wisdom. on Linkedin Email Am I understanding correctly that your plan is to eliminate protected status on most of our city's wetlands? I'm quite shocked, as I've read several reports about how essential wetlands are to maintaining a healthy planet. Why is the proportion so drastic? It feels a lot like this is driven by greed and short term profits, not by current wisdom. link

    Am I understanding correctly that your plan is to eliminate protected status on most of our city's wetlands? I'm quite shocked, as I've read several reports about how essential wetlands are to maintaining a healthy planet. Why is the proportion so drastic? It feels a lot like this is driven by greed and short term profits, not by current wisdom.

    EHolland asked 11 months ago

    Thanks for your submission. No, that is not the City's intention. 

    The intent of the wetlands study and associated amendment is to give more certainty to wetland protection. Going back to the St. John's Development Regulations, 1994, they protected only about 20 named wetlands in the City. With the wetlands study of a few years back, it added thousands of wetlands to be protected, but also left uncertainty as to how the City would evaluate any application to remove wetland protection and allow new development.

    The current study evaluated wetlands in areas that are facing or may face development pressure, and used a new wetland ranking system that is calibrated for Newfoundland conditions. Council has decided that wetlands ranked 6/10 or higher will be protected..

    The aim is to protect our important and significant wetlands while also allowing new development in areas that make sense.

  • Share So sorry not a lot of time at the moment to do some digging but wondering what the city stands to gain from removing protected status from so many wetlands? on Facebook Share So sorry not a lot of time at the moment to do some digging but wondering what the city stands to gain from removing protected status from so many wetlands? on Twitter Share So sorry not a lot of time at the moment to do some digging but wondering what the city stands to gain from removing protected status from so many wetlands? on Linkedin Email So sorry not a lot of time at the moment to do some digging but wondering what the city stands to gain from removing protected status from so many wetlands? link

    So sorry not a lot of time at the moment to do some digging but wondering what the city stands to gain from removing protected status from so many wetlands?

    Marcia asked 11 months ago

    The intent of the wetlands study and associated amendment is to give more certainty to wetland protection. Going back to the St. John's Development Regulations, 1994, they protected only about 20 named wetlands in the City. With the wetlands study of a few years back, it added thousands of wetlands to be protected, but also left uncertainty as to how the City would evaluate any application to remove wetland protection and allow new development.

    The current study evaluated wetlands in areas that are facing or may face development pressure, and used a new wetland ranking system that is calibrated for Newfoundland conditions. Council has decided that wetlands ranked 6/10 or higher will be protected..

    The aim is to protect our important and significant wetlands while also allowing new development in areas that make sense.

  • Share Are holding ponds relaxing wetlands? What is the cost and size of a constructed holding pond that would provide ecological benefits matching 1 hectare of wetland? And what is the list of ecological functions served by these ponds if being used as replacements for wetlands? It seems like we are decades behind in NL sometimes. Other parts of Canada have realized the inherent value of wetlands in planning and civil engineering. Seems like we are 20 years late to the party and are making some bad decisions already realized elsewhere. Has the city looked at best practices from elsewhere? on Facebook Share Are holding ponds relaxing wetlands? What is the cost and size of a constructed holding pond that would provide ecological benefits matching 1 hectare of wetland? And what is the list of ecological functions served by these ponds if being used as replacements for wetlands? It seems like we are decades behind in NL sometimes. Other parts of Canada have realized the inherent value of wetlands in planning and civil engineering. Seems like we are 20 years late to the party and are making some bad decisions already realized elsewhere. Has the city looked at best practices from elsewhere? on Twitter Share Are holding ponds relaxing wetlands? What is the cost and size of a constructed holding pond that would provide ecological benefits matching 1 hectare of wetland? And what is the list of ecological functions served by these ponds if being used as replacements for wetlands? It seems like we are decades behind in NL sometimes. Other parts of Canada have realized the inherent value of wetlands in planning and civil engineering. Seems like we are 20 years late to the party and are making some bad decisions already realized elsewhere. Has the city looked at best practices from elsewhere? on Linkedin Email Are holding ponds relaxing wetlands? What is the cost and size of a constructed holding pond that would provide ecological benefits matching 1 hectare of wetland? And what is the list of ecological functions served by these ponds if being used as replacements for wetlands? It seems like we are decades behind in NL sometimes. Other parts of Canada have realized the inherent value of wetlands in planning and civil engineering. Seems like we are 20 years late to the party and are making some bad decisions already realized elsewhere. Has the city looked at best practices from elsewhere? link

    Are holding ponds relaxing wetlands? What is the cost and size of a constructed holding pond that would provide ecological benefits matching 1 hectare of wetland? And what is the list of ecological functions served by these ponds if being used as replacements for wetlands? It seems like we are decades behind in NL sometimes. Other parts of Canada have realized the inherent value of wetlands in planning and civil engineering. Seems like we are 20 years late to the party and are making some bad decisions already realized elsewhere. Has the city looked at best practices from elsewhere?

    markwilson asked 11 months ago

    The City is not changing the Development Regulations regarding wetlands because of stormwater detention ponds. Section 3.9(d) of the City’s Stormwater Management Policy states “The City encourages the use of natural and engineered Wetlands in Stormwater management.” Furthermore, the City requires all detention ponds be vegetated with appropriate species to become naturalized and aesthetically pleasing.

  • Share Wetlands provide values that no other ecosystem can. This should be taken into consideration before making any further decisions. According to Table 5 of the 'Wetlands Study – Phase 2A' document, only out 11 out of 67 field sides will be protected! These are very scary numbers considering that all 67 are protected now! Looks like more analyses are needed to understand why and if the biodiversity/quality of wetlands decreased. And instead of classifying the remaining 56 field sites as unprotected, we must focus on restoring the quality of these wetlands. I wonder if any Biology professors have been involved in the assessment/ranking of the wetlands. Are there any scientists who can take responsibility to confirm that some particular fields are not important and therefore should not be protected anymore? Where does the number 6 come from to define the borderline to classify the fields? I see some 'Moderate' ranked fields having the score of 4.99 and 4.83. Does it mean that even a 'Moderate' rank is not enough to be protected? Can we be 100% sure that removing 'Low' and 'Low-moderate' fields from our protection, will not result in a further decrease in biodiversity in NL in general? Was any analysis done to assess the consequences of moving 'protected' to 'unprotected' for other neighboring ecosystems? on Facebook Share Wetlands provide values that no other ecosystem can. This should be taken into consideration before making any further decisions. According to Table 5 of the 'Wetlands Study – Phase 2A' document, only out 11 out of 67 field sides will be protected! These are very scary numbers considering that all 67 are protected now! Looks like more analyses are needed to understand why and if the biodiversity/quality of wetlands decreased. And instead of classifying the remaining 56 field sites as unprotected, we must focus on restoring the quality of these wetlands. I wonder if any Biology professors have been involved in the assessment/ranking of the wetlands. Are there any scientists who can take responsibility to confirm that some particular fields are not important and therefore should not be protected anymore? Where does the number 6 come from to define the borderline to classify the fields? I see some 'Moderate' ranked fields having the score of 4.99 and 4.83. Does it mean that even a 'Moderate' rank is not enough to be protected? Can we be 100% sure that removing 'Low' and 'Low-moderate' fields from our protection, will not result in a further decrease in biodiversity in NL in general? Was any analysis done to assess the consequences of moving 'protected' to 'unprotected' for other neighboring ecosystems? on Twitter Share Wetlands provide values that no other ecosystem can. This should be taken into consideration before making any further decisions. According to Table 5 of the 'Wetlands Study – Phase 2A' document, only out 11 out of 67 field sides will be protected! These are very scary numbers considering that all 67 are protected now! Looks like more analyses are needed to understand why and if the biodiversity/quality of wetlands decreased. And instead of classifying the remaining 56 field sites as unprotected, we must focus on restoring the quality of these wetlands. I wonder if any Biology professors have been involved in the assessment/ranking of the wetlands. Are there any scientists who can take responsibility to confirm that some particular fields are not important and therefore should not be protected anymore? Where does the number 6 come from to define the borderline to classify the fields? I see some 'Moderate' ranked fields having the score of 4.99 and 4.83. Does it mean that even a 'Moderate' rank is not enough to be protected? Can we be 100% sure that removing 'Low' and 'Low-moderate' fields from our protection, will not result in a further decrease in biodiversity in NL in general? Was any analysis done to assess the consequences of moving 'protected' to 'unprotected' for other neighboring ecosystems? on Linkedin Email Wetlands provide values that no other ecosystem can. This should be taken into consideration before making any further decisions. According to Table 5 of the 'Wetlands Study – Phase 2A' document, only out 11 out of 67 field sides will be protected! These are very scary numbers considering that all 67 are protected now! Looks like more analyses are needed to understand why and if the biodiversity/quality of wetlands decreased. And instead of classifying the remaining 56 field sites as unprotected, we must focus on restoring the quality of these wetlands. I wonder if any Biology professors have been involved in the assessment/ranking of the wetlands. Are there any scientists who can take responsibility to confirm that some particular fields are not important and therefore should not be protected anymore? Where does the number 6 come from to define the borderline to classify the fields? I see some 'Moderate' ranked fields having the score of 4.99 and 4.83. Does it mean that even a 'Moderate' rank is not enough to be protected? Can we be 100% sure that removing 'Low' and 'Low-moderate' fields from our protection, will not result in a further decrease in biodiversity in NL in general? Was any analysis done to assess the consequences of moving 'protected' to 'unprotected' for other neighboring ecosystems? link

    Wetlands provide values that no other ecosystem can. This should be taken into consideration before making any further decisions. According to Table 5 of the 'Wetlands Study – Phase 2A' document, only out 11 out of 67 field sides will be protected! These are very scary numbers considering that all 67 are protected now! Looks like more analyses are needed to understand why and if the biodiversity/quality of wetlands decreased. And instead of classifying the remaining 56 field sites as unprotected, we must focus on restoring the quality of these wetlands. I wonder if any Biology professors have been involved in the assessment/ranking of the wetlands. Are there any scientists who can take responsibility to confirm that some particular fields are not important and therefore should not be protected anymore? Where does the number 6 come from to define the borderline to classify the fields? I see some 'Moderate' ranked fields having the score of 4.99 and 4.83. Does it mean that even a 'Moderate' rank is not enough to be protected? Can we be 100% sure that removing 'Low' and 'Low-moderate' fields from our protection, will not result in a further decrease in biodiversity in NL in general? Was any analysis done to assess the consequences of moving 'protected' to 'unprotected' for other neighboring ecosystems?

    Maria_Yulmetova asked 11 months ago

    To provide some background, the City listed about 20 significant wetlands to be protected in the previous Development Regulations. The Phase 1 Wetland study in 2019 identified over 3500 wetlands using high resolution imagery, which were all protected in the new Envision St. John’s Development Regulations. Not all these 3500 wetlands are significant, and Council decided to move to a Phase 2 Study to complete a functional assessment of a smaller number of wetlands currently under development pressure. The assessment method, WESP-AC, is used by other Atlantic Provinces to provide a score for each of the 5 main function groups. These were weighted, as you note, to provide the total score. The weighting scheme was developed internally but based on a methodology used by the province of Alberta. They have their own method for wetland functional assessments, but it is similar. They have four main functions: Hydrologic Health, Water Quality, Ecological Health, and Human Use. These are weighted at 30%, 30%, 30%, and 10% respectively to provide a total score. If we correlate this to the City’s methodology and WESP-AC, the City does place slightly more value on the Hydrologic Health (40% St. John’s versus 30% Alberta), but Water Quality is the same at 30% and the Ecological Health is same also at 30% (combined Aquatic Support 15%, Aquatic Habitat 10%, and Transition Habitat 5% - total 30%). 

    The minimum scoring of 6 was a Council decision and not based on any external advice but on a number of factors. One being that while only 12 of 68 wetlands in the Phase 2 study will be protected as a wetland, a further 47 of these are associated with streams and will therefore be protected as a floodplain. (Wetlands are often located on edges of rivers and ponds. Also open water is a classification of wetland.) When considered this way, 88% of the wetlands will be protected as either wetlands or floodplains. 

    The labels Low, Moderate, and High are based on percentiles, meaning that it’s ranked that way relative to the data set. 

    • Low ranked wetlands are scored in the bottom 25% - scores less than 3.815
    • Low-Moderate are in the 25-50% range – scores between 3.815 - 4.618
    • Moderate in the 50%-75% range – scores between 4.618 - 6.866
  • Share The "Wetland Study Report (Oct 11, 2023)" referenced as part of this proposal explains the weighting scheme devised by the City in its assessment of the overall WESP-AC score, as follows: "Hydrologic Grouped functions are assigned a weight of 0.4; Water Quality Support Grouped functions are assigned a weight of 0.3; Aquatic Support Grouped functions are assigned a weight of 0.15; Aquatic Habitat Grouped functions are assigned a weight of 0.10; and Transition Habitat Grouped functions are assigned a weight of 0.05." This weighting scheme, chosen by the City: (a) favours (40% weight) infrastructural-relevant metrics (water retention ("Hydrologic Group")); (b) heavily weighs the "water quality" metric (which few wetlands in St. John's have high scores for anyway due to low pollution in our City, which by weighting by 30% thereby dilutes the resulting score); (c) significantly suppresses the contribution from environmental factors (only 30% in total contribution from the remaining 3 categories). The chosen score weighting scheme thus appears designed to favour the removal of wetland protections. Would you have any documentations from independent environmental experts regarding this weighting scheme? Would you have any documentation from independent environmental experts regarding whether a score of "6", under this custom weighting scheme, is an environmentally sound cut-off for protection? Neither of these important questions are addressed in the cited report. The report merely states the outcome of the work performed, as contracted by the City. Importantly, *how* the final scores were computed, and *how* they were used by the City to write the proposed regulatory change to Section 4.10, are not addressed in the cited report. While it is great that this update to the map has been performed, there does not appear to be a sound case made for why section 4.10 of the regulation should also be changed. Can a new proposal be present where those two independent changes are decoupled from each other? on Facebook Share The "Wetland Study Report (Oct 11, 2023)" referenced as part of this proposal explains the weighting scheme devised by the City in its assessment of the overall WESP-AC score, as follows: "Hydrologic Grouped functions are assigned a weight of 0.4; Water Quality Support Grouped functions are assigned a weight of 0.3; Aquatic Support Grouped functions are assigned a weight of 0.15; Aquatic Habitat Grouped functions are assigned a weight of 0.10; and Transition Habitat Grouped functions are assigned a weight of 0.05." This weighting scheme, chosen by the City: (a) favours (40% weight) infrastructural-relevant metrics (water retention ("Hydrologic Group")); (b) heavily weighs the "water quality" metric (which few wetlands in St. John's have high scores for anyway due to low pollution in our City, which by weighting by 30% thereby dilutes the resulting score); (c) significantly suppresses the contribution from environmental factors (only 30% in total contribution from the remaining 3 categories). The chosen score weighting scheme thus appears designed to favour the removal of wetland protections. Would you have any documentations from independent environmental experts regarding this weighting scheme? Would you have any documentation from independent environmental experts regarding whether a score of "6", under this custom weighting scheme, is an environmentally sound cut-off for protection? Neither of these important questions are addressed in the cited report. The report merely states the outcome of the work performed, as contracted by the City. Importantly, *how* the final scores were computed, and *how* they were used by the City to write the proposed regulatory change to Section 4.10, are not addressed in the cited report. While it is great that this update to the map has been performed, there does not appear to be a sound case made for why section 4.10 of the regulation should also be changed. Can a new proposal be present where those two independent changes are decoupled from each other? on Twitter Share The "Wetland Study Report (Oct 11, 2023)" referenced as part of this proposal explains the weighting scheme devised by the City in its assessment of the overall WESP-AC score, as follows: "Hydrologic Grouped functions are assigned a weight of 0.4; Water Quality Support Grouped functions are assigned a weight of 0.3; Aquatic Support Grouped functions are assigned a weight of 0.15; Aquatic Habitat Grouped functions are assigned a weight of 0.10; and Transition Habitat Grouped functions are assigned a weight of 0.05." This weighting scheme, chosen by the City: (a) favours (40% weight) infrastructural-relevant metrics (water retention ("Hydrologic Group")); (b) heavily weighs the "water quality" metric (which few wetlands in St. John's have high scores for anyway due to low pollution in our City, which by weighting by 30% thereby dilutes the resulting score); (c) significantly suppresses the contribution from environmental factors (only 30% in total contribution from the remaining 3 categories). The chosen score weighting scheme thus appears designed to favour the removal of wetland protections. Would you have any documentations from independent environmental experts regarding this weighting scheme? Would you have any documentation from independent environmental experts regarding whether a score of "6", under this custom weighting scheme, is an environmentally sound cut-off for protection? Neither of these important questions are addressed in the cited report. The report merely states the outcome of the work performed, as contracted by the City. Importantly, *how* the final scores were computed, and *how* they were used by the City to write the proposed regulatory change to Section 4.10, are not addressed in the cited report. While it is great that this update to the map has been performed, there does not appear to be a sound case made for why section 4.10 of the regulation should also be changed. Can a new proposal be present where those two independent changes are decoupled from each other? on Linkedin Email The "Wetland Study Report (Oct 11, 2023)" referenced as part of this proposal explains the weighting scheme devised by the City in its assessment of the overall WESP-AC score, as follows: "Hydrologic Grouped functions are assigned a weight of 0.4; Water Quality Support Grouped functions are assigned a weight of 0.3; Aquatic Support Grouped functions are assigned a weight of 0.15; Aquatic Habitat Grouped functions are assigned a weight of 0.10; and Transition Habitat Grouped functions are assigned a weight of 0.05." This weighting scheme, chosen by the City: (a) favours (40% weight) infrastructural-relevant metrics (water retention ("Hydrologic Group")); (b) heavily weighs the "water quality" metric (which few wetlands in St. John's have high scores for anyway due to low pollution in our City, which by weighting by 30% thereby dilutes the resulting score); (c) significantly suppresses the contribution from environmental factors (only 30% in total contribution from the remaining 3 categories). The chosen score weighting scheme thus appears designed to favour the removal of wetland protections. Would you have any documentations from independent environmental experts regarding this weighting scheme? Would you have any documentation from independent environmental experts regarding whether a score of "6", under this custom weighting scheme, is an environmentally sound cut-off for protection? Neither of these important questions are addressed in the cited report. The report merely states the outcome of the work performed, as contracted by the City. Importantly, *how* the final scores were computed, and *how* they were used by the City to write the proposed regulatory change to Section 4.10, are not addressed in the cited report. While it is great that this update to the map has been performed, there does not appear to be a sound case made for why section 4.10 of the regulation should also be changed. Can a new proposal be present where those two independent changes are decoupled from each other? link

    The "Wetland Study Report (Oct 11, 2023)" referenced as part of this proposal explains the weighting scheme devised by the City in its assessment of the overall WESP-AC score, as follows: "Hydrologic Grouped functions are assigned a weight of 0.4; Water Quality Support Grouped functions are assigned a weight of 0.3; Aquatic Support Grouped functions are assigned a weight of 0.15; Aquatic Habitat Grouped functions are assigned a weight of 0.10; and Transition Habitat Grouped functions are assigned a weight of 0.05." This weighting scheme, chosen by the City: (a) favours (40% weight) infrastructural-relevant metrics (water retention ("Hydrologic Group")); (b) heavily weighs the "water quality" metric (which few wetlands in St. John's have high scores for anyway due to low pollution in our City, which by weighting by 30% thereby dilutes the resulting score); (c) significantly suppresses the contribution from environmental factors (only 30% in total contribution from the remaining 3 categories). The chosen score weighting scheme thus appears designed to favour the removal of wetland protections. Would you have any documentations from independent environmental experts regarding this weighting scheme? Would you have any documentation from independent environmental experts regarding whether a score of "6", under this custom weighting scheme, is an environmentally sound cut-off for protection? Neither of these important questions are addressed in the cited report. The report merely states the outcome of the work performed, as contracted by the City. Importantly, *how* the final scores were computed, and *how* they were used by the City to write the proposed regulatory change to Section 4.10, are not addressed in the cited report. While it is great that this update to the map has been performed, there does not appear to be a sound case made for why section 4.10 of the regulation should also be changed. Can a new proposal be present where those two independent changes are decoupled from each other?

    Sam B. asked 11 months ago

    Thank you for your submission. I will forward your questions pertaining to the Wetland Study to the Manager of Development - Engineering. 

    The City is proposing to update Section 4.10 to accurately reflect and explain the changes that are being proposed to Map 4. 

    To provide some background, the City listed about 20 significant wetlands to be protected in the previous Development Regulations. The Phase 1 Wetland study in 2019 identified over 3500 wetlands using high resolution imagery, which were all protected in the new Envision St. John’s Development Regulations. Not all these 3500 wetlands are significant, and Council decided to move to a Phase 2 Study to complete a functional assessment of a smaller number of wetlands currently under development pressure. The assessment method, WESP-AC, is used by other Atlantic Provinces to provide a score for each of the 5 main function groups. These were weighted, as you note, to provide the total score. The weighting scheme was developed internally but based on a methodology used by the province of Alberta. They have their own method for wetland functional assessments, but it is similar. They have four main functions: Hydrologic Health, Water Quality, Ecological Health, and Human Use. These are weighted at 30%, 30%, 30%, and 10% respectively to provide a total score. If we correlate this to the City’s methodology and WESP-AC, the City does place slightly more value on the Hydrologic Health (40% St. John’s versus 30% Alberta), but Water Quality is the same at 30% and the Ecological Health is same also at 30% (combined Aquatic Support 15%, Aquatic Habitat 10%, and Transition Habitat 5% - total 30%). 

    The minimum scoring of 6 was a Council decision and not based on any external advice but on a number of factors. One being that while only 12 of 68 wetlands in the Phase 2 study will be protected as a wetland, a further 47 of these are associated with streams and will therefore be protected as a floodplain. (Wetlands are often located on edges of rivers and ponds. Also open water is a classification of wetland.) When considered this way, 88% of the wetlands will be protected as either wetlands or floodplains. 

  • Share Firstly just for clarification regarding the areas designated "requiring further study" in yellow on the proposed map, will they be treated as protected while further assessments are taking place? As noted earlier there's no timeline for further assessments. Secondly, according to the map 4 proposal, the largest losses of protection will be wetlands that are in very close proximity to urban/residential areas. Is there a justification for removing their protected status beyond not having scored above 6 on the report's scale? For example, SL-9 Southlands, as noted by the report, "While it did not score High on as many wetland functions as some other sites based on the WESP-AC protocol, this study highlights that there are few wetlands of this size remaining adjacent to the developed areas of St. John’s that have not yet been extensively altered. It is also associated with several watercourses and it is recommended to establish a 20 m buffer around this entire wetland..." Loss of protections for urban wetland systems seems very shortsighted, considering the benefits wetlands provide are needed the most in urban areas. on Facebook Share Firstly just for clarification regarding the areas designated "requiring further study" in yellow on the proposed map, will they be treated as protected while further assessments are taking place? As noted earlier there's no timeline for further assessments. Secondly, according to the map 4 proposal, the largest losses of protection will be wetlands that are in very close proximity to urban/residential areas. Is there a justification for removing their protected status beyond not having scored above 6 on the report's scale? For example, SL-9 Southlands, as noted by the report, "While it did not score High on as many wetland functions as some other sites based on the WESP-AC protocol, this study highlights that there are few wetlands of this size remaining adjacent to the developed areas of St. John’s that have not yet been extensively altered. It is also associated with several watercourses and it is recommended to establish a 20 m buffer around this entire wetland..." Loss of protections for urban wetland systems seems very shortsighted, considering the benefits wetlands provide are needed the most in urban areas. on Twitter Share Firstly just for clarification regarding the areas designated "requiring further study" in yellow on the proposed map, will they be treated as protected while further assessments are taking place? As noted earlier there's no timeline for further assessments. Secondly, according to the map 4 proposal, the largest losses of protection will be wetlands that are in very close proximity to urban/residential areas. Is there a justification for removing their protected status beyond not having scored above 6 on the report's scale? For example, SL-9 Southlands, as noted by the report, "While it did not score High on as many wetland functions as some other sites based on the WESP-AC protocol, this study highlights that there are few wetlands of this size remaining adjacent to the developed areas of St. John’s that have not yet been extensively altered. It is also associated with several watercourses and it is recommended to establish a 20 m buffer around this entire wetland..." Loss of protections for urban wetland systems seems very shortsighted, considering the benefits wetlands provide are needed the most in urban areas. on Linkedin Email Firstly just for clarification regarding the areas designated "requiring further study" in yellow on the proposed map, will they be treated as protected while further assessments are taking place? As noted earlier there's no timeline for further assessments. Secondly, according to the map 4 proposal, the largest losses of protection will be wetlands that are in very close proximity to urban/residential areas. Is there a justification for removing their protected status beyond not having scored above 6 on the report's scale? For example, SL-9 Southlands, as noted by the report, "While it did not score High on as many wetland functions as some other sites based on the WESP-AC protocol, this study highlights that there are few wetlands of this size remaining adjacent to the developed areas of St. John’s that have not yet been extensively altered. It is also associated with several watercourses and it is recommended to establish a 20 m buffer around this entire wetland..." Loss of protections for urban wetland systems seems very shortsighted, considering the benefits wetlands provide are needed the most in urban areas. link

    Firstly just for clarification regarding the areas designated "requiring further study" in yellow on the proposed map, will they be treated as protected while further assessments are taking place? As noted earlier there's no timeline for further assessments. Secondly, according to the map 4 proposal, the largest losses of protection will be wetlands that are in very close proximity to urban/residential areas. Is there a justification for removing their protected status beyond not having scored above 6 on the report's scale? For example, SL-9 Southlands, as noted by the report, "While it did not score High on as many wetland functions as some other sites based on the WESP-AC protocol, this study highlights that there are few wetlands of this size remaining adjacent to the developed areas of St. John’s that have not yet been extensively altered. It is also associated with several watercourses and it is recommended to establish a 20 m buffer around this entire wetland..." Loss of protections for urban wetland systems seems very shortsighted, considering the benefits wetlands provide are needed the most in urban areas.

    JHal asked 11 months ago

    Yes, the wetlands that require further study are protected until further assessment is completed and an amendment to Map 4 is also completed. 

    The change in status is based on the scoring. 

  • Share Is there a deadline for comments on Facebook Share Is there a deadline for comments on Twitter Share Is there a deadline for comments on Linkedin Email Is there a deadline for comments link

    Is there a deadline for comments

    Lynda Hendrickson asked 11 months ago

    The deadline for comments was May 28, 2024. The question and answer section will remain open.

  • Share Given the large number of "further study required" wetlands, the effectiveness of the amendment is closely tied to undertaking that work. Has the further study work been planned/budgeted? Thanks! on Facebook Share Given the large number of "further study required" wetlands, the effectiveness of the amendment is closely tied to undertaking that work. Has the further study work been planned/budgeted? Thanks! on Twitter Share Given the large number of "further study required" wetlands, the effectiveness of the amendment is closely tied to undertaking that work. Has the further study work been planned/budgeted? Thanks! on Linkedin Email Given the large number of "further study required" wetlands, the effectiveness of the amendment is closely tied to undertaking that work. Has the further study work been planned/budgeted? Thanks! link

    Given the large number of "further study required" wetlands, the effectiveness of the amendment is closely tied to undertaking that work. Has the further study work been planned/budgeted? Thanks!

    rgreene asked 12 months ago

    A timeline for further assessment has not yet been established.

  • Share Can the City provide the scientific explanation for use of the WESP-AC as tool for determining whether a wetland should be protected or not? Can the City provide any scientific support for, or examples of the WESP scoring cut-off (i.e., <6) method the City is using to determine which wetlands should not be protected? What is the justification for not protecting wetlands in watersheds that already experience flooding, and that are projected to experience greater flooding (e.g., Waterford River watershed, Leary's Brook watershed), when their role in flood mitigation is well understood? on Facebook Share Can the City provide the scientific explanation for use of the WESP-AC as tool for determining whether a wetland should be protected or not? Can the City provide any scientific support for, or examples of the WESP scoring cut-off (i.e., <6) method the City is using to determine which wetlands should not be protected? What is the justification for not protecting wetlands in watersheds that already experience flooding, and that are projected to experience greater flooding (e.g., Waterford River watershed, Leary's Brook watershed), when their role in flood mitigation is well understood? on Twitter Share Can the City provide the scientific explanation for use of the WESP-AC as tool for determining whether a wetland should be protected or not? Can the City provide any scientific support for, or examples of the WESP scoring cut-off (i.e., <6) method the City is using to determine which wetlands should not be protected? What is the justification for not protecting wetlands in watersheds that already experience flooding, and that are projected to experience greater flooding (e.g., Waterford River watershed, Leary's Brook watershed), when their role in flood mitigation is well understood? on Linkedin Email Can the City provide the scientific explanation for use of the WESP-AC as tool for determining whether a wetland should be protected or not? Can the City provide any scientific support for, or examples of the WESP scoring cut-off (i.e., <6) method the City is using to determine which wetlands should not be protected? What is the justification for not protecting wetlands in watersheds that already experience flooding, and that are projected to experience greater flooding (e.g., Waterford River watershed, Leary's Brook watershed), when their role in flood mitigation is well understood? link

    Can the City provide the scientific explanation for use of the WESP-AC as tool for determining whether a wetland should be protected or not? Can the City provide any scientific support for, or examples of the WESP scoring cut-off (i.e., <6) method the City is using to determine which wetlands should not be protected? What is the justification for not protecting wetlands in watersheds that already experience flooding, and that are projected to experience greater flooding (e.g., Waterford River watershed, Leary's Brook watershed), when their role in flood mitigation is well understood?

    prsvns asked 12 months ago

    Please refer to the Wetlands Study - Phase 2A. There is information on the WESP-AC and the scoring system in that report.