In their wetlands alteration application, the developer’s consultant delineated wetlands only on the subject site, while off-site wetlands were estimated. Their total of wetlands delineated and estimated is 1.5 hectares. Independent informal delineation using field measurements and ground probes in the wetland showed at least 2.5 hectares of freshwater wetlands immediately contiguous to the subject site, with several more hectares of undelineated freshwater wetlands connected by surface waters extending from the site.

While we agree that new wetlands can be created elsewhere to compensate for the .45 hectares of wetlands to be directly altered by the excavation and paving proposed for this development, this will not compensate for some of the indirect impacts. These include changes in stormwater runoff quantity and quality, which could affect surface and groundwater, and lowering of the water table that sustains the wetlands, which could be caused by over pumping of groundwater by wells servicing the proposed development.

Groundwater holding tanks might help reduce peak water demands for the proposed development’s wells, but would not help prevent drawdown of the wetland’s shallow water table, which is connected through cracks to the deep water table of the wells. (The same thing is true for the surrounding dug wells.) Lowering the water table in the ancient live peat bogs connected to the project site could impact their important functions, including nutrient retention, stormwater attenuation, and carbon sequestration (holding greenhouse gases).

According to Nova Scotia law, if 2 hectares or more of wetlands could be “disturbed” by a proposed development, an environmental assessment can be required by Nova Scotia Environment. For this reason, it is important to properly delineate wetlands connected to the site, especially since they are over, not under, 2 hectares, and to carefully assess indirect, not just direct, potential disturbances to them.

Independent informal delineation also identified a 270 square meter saltwater wetland adjoining the subject site. This was not mentioned by the developer’s consultant, who should delineate this wetland. This area meets the size threshold to be classified as a wetland in Nova Scotia, and as a salt marsh, it is a wetland of special significance, which should be protected from harm. The proposed sewage treatment plant for this development and polluted runoff from paved surfaces could adversely impact this salt marsh.

A detailed report on these wetlands is available here, as is an additional letter of concern submitted to the city.