GDS-017 - Development Incentives Policy_2025
Title: Development Incentives Policy
Subject: Development Incentives Policy Category: Growth and Community Services
GDS-017
Policy No.: M&C Report No.: 2025-290
December 15, 2025
Effective Date: Next Review Date: November 2028
Area(s) this policy applies to: Planning, Housing, Office Responsible for review of this Policy:
Community Planning and Housing, Growth and
Grants and Incentives
Community Services
Related Instruments: Policy Sponsor:
GDS-010 Affordable Housing Grant Program Policy Commissioner of Growth and Community
GDS-015 Affordable Housing Soft Cost Grant Services
Policy
GC-001 Acquisition and Disposition of Municipal
Lands
Document Pages:
Policy approved by Common Council: Date
Revision History:
City Clerk's Annotation for Official Record
December 15, 2025
Date of Passage of Current document:
I certify that this Policy was adopted by Common Council resolution as indicated
immediately above.
December 18, 2025
City Clerk Date
For information Contact:
TABLE OF CONTENTS
1. Policy Statement ................................................................................................................................................. 2
2. Scope .................................................................................................................................................................. 2
3. Legislation and Standards .................................................................................................................................... 2
4. Definitions .......................................................................................................................................................... 3
5. Incentive Programs ............................................................................................................................................. 4
6. Monitor And Review ........................................................................................................................................... 8
7. Roles and Responsibilities .................................................................................................................................... 8
8. Building Incentive Reserve ................................................................................................................................... 9
9. Application Requirements ................................................................................................................................... 9
10. Appendix .......................................................................................................................................................... 9
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1. P OLICY S TATEMENT
1.1 The Development Incentives Policy, “the Policy,” establishes performance based financial incentives to
support development and revitalization of key areas of the City.
1.2 The purpose of the Policy is to establish eligibility criteria, application intake, review, approval,
disbursement, and reporting requirements. The Policy ensures that the process is open, transparent and
accountable to the public, while also allowing for incentives to change at set intervals according to market
trends and with the City’s changing needs and strategic objectives.
1.3 The Policy also outlines the standards and guidelines that govern the management, accounting, and
monitoring of the Building Incentive Reserve, within the City’s Growth Reserve.
2. S COPE
2.1 The Policy provides a framework to guide the following development incentives:
Large-Scale Development Incentive Program
3. L EGISLATION AND S TANDARDS
3.1 This policy aligns with and conforms to the following legislative and policy instruments:
Local Governance Act
Community Planning Act
City of Saint John Municipal Development Plan
City of Saint John Affordable Housing Action Plan
City of Saint John FAS-003 Operating and Capital Reserves Policy
City of Saint John FAS-004 Operating Budget Policy
City of Saint John FAS-020 Long-Term Financial Plan Policy
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4. D EFINITIONS
Active Retail/Commercial Ground Floor Use: means a non-residential use located on the ground floor of a building
that is physically designed and constructed to accommodate active, publicly accessible uses that contribute to street-
level animation and pedestrian activity. Eligible spaces may include: direct at-grade access from a public street or
publicly open space, a high level of ground floor transparency (e.g. minimum 60% glazing along the public frontage),
and finished ceiling heights and servicing capacity suitable for retail, food service, medical offices, or other active
commercial uses. Office, storage, or other non-active commercial configurations are not considered eligible. No
more than 900 square metres of active retail/commercial ground floor space per development project will be
considered.
Affordable Housing Unit: There are several ways affordable housing is defined by The Canada Mortgage and Housing
Corporation (CMHC) according to the available program and target population.
For the purposes of the Large-Scale Development Incentive Program, an affordable unit means a unit that complies
with a CMHC or provincial program for a minimum 10-year period tied to new construction of affordable housing
units, and for which scores a minimum of 10 points in Schedule C, under Housing Affordability.
Applicant: An individual, organization or business that submits a completed grant Application for consideration, in
accordance with the eligibility criteria and requirements set out in this policy and any associated program guidelines.
Application: A formal request made by an eligible Applicant, including all required documentation, and supporting
materials specified in the policy.
Building Permit: As defined in By-law BC-1 - A By-law Respecting the Construction, Repair and Demolition of
Buildings and Structures in The City of Saint John.
Building Permit Estimate: The total building permit estimate as defined in By-law BC-1, including multiple phased
permits.
Construction Start Date: The date on which physical site work commences for a project, as defined by the pouring
of footings and foundation walls.
Development Incentive Review Committee: An internal municipal committee composed of representatives from
planning and housing, finance, real estate, and other relevant departments, responsible for reviewing, evaluating,
and making recommendations on development incentive applications in accordance with this policy.
Financial Viability: The demonstration of sufficient resources and management to sustain the project plan and meet
obligations without undue reliance on additional external supports.
Grant Agreement: A legal agreement entered between the applicant and the municipality that outlines the terms,
conditions, obligations, and timelines under which a development incentive grant will be administered.
Grant Payment Start Date: The date on which the first disbursement of the grant is issued to the applicant,
contingent upon compliance with the conditions outlined in the Grant Agreement.
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Incremental Tax Increase: The difference between the local tax collected in the year of application, prior to any
development occurring, and the first year of operation, after the re-assessment of the subject property.
Non-Residential: All other property except residentially assessed property. This includes commercial, industrial,
institutional, and mixed-use spaces where the residential component does not represent the primary use.
Penthouse: A residential unit above the highest full storey of a building and set back from the primary building
façade. A penthouse typically is differentiated from the main floors through architectural design, private outdoor
terrace space, and/or a larger floor area intended for luxury.
Three-Bedroom Unit: A residential unit containing three bedrooms, but which excludes a penthouse.
Total Building Cost: The full cost to construct the building from start of construction to occupancy, including all hard
costs (materials, labour, building systems, structured parking) and all soft costs (design and engineering fees,
contingency, financing costs, developer fees, and construction management). It does not include land acquisition
costs or HST.
Total Grant: The total grant per the executed Grant Agreement the Applicant has been deemed eligible to receive,
which includes the base grant rate and any top ups per Schedule B.
5. I NCENTIVE P ROGRAMS
5.1 Large-Scale Development Incentive Program
Purpose
The purpose of the Large-Scale Incentive is to attract high-density residential development to key infill
sites within and adjacent to the City’s urban core and inner harbour waterfront areas that align with
the Municipal Plan’s vision.
The Large-Scale Incentive Program was premised on a Development Incentive Review, which
undertook financial analysis of several development prototypes in terms of their financial viability. This
review is to be updated regularly, and Program offerings are anticipated to evolve according to
changing need and market conditions.
The Large-Scale Incentive Program proposes a clear, predictable, and competitive incentive while also
balancing fiscal sustainability and protection of City interests. The value of the Large-Scale Incentive
should not exceed new revenue generated because of the development, with tax revenue being
retained to contribute toward necessary servicing and infrastructure costs. A benchmark of at least
50% of tax revenue has been chosen to be retained for needed services, infrastructure, and other
amenities.
5.1.1 Eligibility Requirements
5.1.1.1 The proposed development must be located within Schedule A – Eligibility Area.
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5.1.1.2 The proposed development must have a minimum Total Building Cost of $40,000,000.
5.1.1.3 The proposed development must contain at least 150 residential units and achieve a minimum density of
400 units per net hectare.
5.1.1.4 The proposed development must comply with all City By-Laws, including the Municipal Development Plan
and Zoning By-law at the time of Application.
5.1.1.5 The Construction Start Date must not occur prior to an Application being received and accepted by the City,
except where Common Council has approved otherwise.
5.1.1.6 The proposed development must be located on a property owned by the Applicant or be under written
agreement, provided to the City and satisfactory to the City, with the owner for acquisition by the Applicant.
5.1.1.7 The Application must include:
a. A completed application form signed by an authorized signing officer.
b. Proof of planning approval (e.g. zoning approval).
c. A project description and schedule.
d. Design level drawings e.g. Class C (schematic, massing, floor plans, elevation).
e. Simplified pro forma including:
i. Total development cost,
ii. Operating assumptions,
iii. Rent assumptions.
f. Evidence of other funding or incentives if applicable (CMHC, Province).
g. Any other relevant documentation reasonably requested by the City necessary to evaluate and
score the application.
5.1.1.8 All Applications will be reviewed by the Development Incentive Review Committee in accordance with this
Policy and scored according to the Application Evaluation (Schedule C).
5.1.1.9 The Development Incentive Review Committee will deem whether an Application is complete.
5.1.1.10 All proposed developments must obtain a minimum score of 60 points to be considered eligible.
5.1.2 Grant Agreement Process
5.1.2.1 The Development Incentive Review Committee’s review and recommendation will be forwarded to the
City’s Chief Financial Officer, Planning Director / Commissioner of Growth and Community Services, and
Chief Administrative Officer for review in the form of a memorandum to the Application, stating the total
funding request and status of the Building Incentive Reserve.
5.1.2.2 All Applications will be required to enter into a Grant Agreement with the City stipulating a grant payment
schedule, compliance requirements, and all conditions.
5.1.2.3 Ownership and Partnership Disclosure
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Prior to execution of the Grant Agreement, the applicant must provide documentation confirming the
project’s ownership and partnership structure, including:
a) Identification of the legal entity that will own and/or develop the project, including the full legal name,
jurisdiction of incorporation (if applicable), and registry number.
b) Identification of all partners, shareholders, members, or beneficial owners with a controlling interest
in the project (typically 20% or greater), including the percentage of ownership held by each.
c) Identification of the entity authorized to act as the project’s agent, including signing authority for legal
agreements with the City.
d) Disclosure of any joint venture agreements, limited partnership agreements, or development
management agreements relevant to project delivery.
e) Disclosure of any changes to the ownership structure that occur after submission of the application
and up to the execution of the Grant Agreement, with the requirement that material changes must be
reported to the City within 30 days.
5.1.2.4 Before entering into the Grant Agreement, the Total Grant will be calculated in accordance with Schedule
B, with the Total Grant divided evenly over a 10-year period.
5.1.2.5 Applicants may be eligible to receive the Building Permit Fee Grant. The Building Permit Fee Grant provides
100% reimbursement of permit fees upon completion of the project toward one of the following eligible
uses:
a) Community benefit(s) negotiated at the time of rezoning or subsequent to, including public parks or
open space improvement, pedestrian or transit infrastructure, community facilities, public art, or
environmental enhancements.
b) Affordable housing provided the Applicant scores a minimum 20 points in Schedule C, Housing
Affordability.
c) Site challenges or accessibility considerations as identified in Schedule C which are extraordinary to
those identified in Schedule E - Pro Forma Input Assumptions.
5.1.2.6 Prior to disbursement, applicants must provide proof of incurrence of such costs related to eligible Building
Permit Fee Grant uses to the satisfaction of the City.
5.1.2.7 The Building Permit Fee Grant is disbursed upon completion of the project in accordance with the approved
building permit.
5.1.2.8 No Grant Agreement will be entered into with an Applicant unless:
a) The Applicant has the legal capacity and authority to undertake the proposed development and accept
the grant.
b) The Applicant is not bankrupt, insolvent, or under creditor protection.
c) There are no pending or ongoing legal proceedings that could affect the proposed development.
5.1.2.9 All Grant Agreements must be approved by Common Council.
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5.1.2.10 Within 12 months of Common Council approval, the applicant must provide documentation demonstrating
that the project is financially viable and able to proceed, including:
a) Confirmed lender term sheet or equivalent financing commitment letter signed by a recognized
financial institution or CMHC-approved lender; and, if not already included,
b) Evidence that the project’s Total Building Cost meets the minimum eligibility threshold using one of the
following:
i. Third-party cost consultant estimate;
ii. Contractor estimate or Guaranteed Maximum Price (GMP) contract; or
iii. CMHC underwriting documentation.
Failure to submit these items results in expiry of the conditional approval.
5.1.2.11 Any development that has received financial assistance under GDS 007 Urban Development Incentives
Policy Program shall have the value of such assistance deducted from the final grant amount awarded under
this policy, to prevent duplication of grant benefits.
5.1.3 Disbursement Requirements
5.1.3.1 The Construction Start Date for the proposed development must occur within two years of the execution
of the Grant Agreement, otherwise the Application will expire and be null and void.
5.1.3.2 The development must be completed and the Building Permit fulfilled within six years of the executed Grant
Agreement, otherwise the Application will expire and be null and void.
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5.1.3.3 The first disbursement will commence August 1, one year following project completion, with any future
disbursements occurring on the anniversary date.
5.1.3.4 In any given year, excluding the year in which the Building Permit Grant is paid, the Total Grant shall not
exceed 50% of the Incremental Tax Increase generated by the development. Where such cases occur, the
City reserves the right to amend the agreement and reduce the grant payment accordingly.
5.1.3.5 Prior to the first disbursement, the Applicant must provide written confirmation and/or applicable
documentation to the satisfaction of the City that:
a) There have been no material changes to plans submitted in the Application that would affect the
Minimum Eligibility Requirements set out in Section 5.1.1, or calculation of the Total Grant per 5.1.2.5.
If any changes have occurred, the City reserves the right to cancel or amend the Grant Agreement
accordingly.
b) The development was completed in compliance with all City By-laws and terms and conditions of the
Building Permit, with the Applicant being in receipt of an Occupancy Permit or a Certificate of
Successful Completion pursuant to By-law BC-1.
c) All applicable building and development fees have been fully paid by the Applicant.
5.1.3.6 Prior to any disbursement, the Applicant must provide written confirmation and/or applicable
documentation to the City that:
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a) All water and sewer charges have been fully paid.
b) All property taxes have been paid. For the purposes of verifying 5.1.3.4, the Applicant must provide
current year Notice of Assessment for the property and proof of payment in the form of a receipt or
tax certificate.
c) The proposed development is in good standing with all the terms and conditions set out by other
funders of the project.
d) The Applicant is not bankrupt, insolvent, or under creditor protection.
e) There are no pending or ongoing legal proceedings.
f) The Applicant is confirmed to be the current owner of the property as determined by Certificates of
Registered Ownership (CRO).
g) Rent rolls confirming the maintenance of any affordable housing units.
h) Any applicable community benefit(s) have been provided in accordance with Section 5.1.3.5.
5.1.3.7 Should a community Benefit(s) not be provided within two years of the completion of the project, per the
Grant Agreement or another agreement between the City and Applicant, the City reserves the right to
amend the Agreement and reduce future payments to recoup a portion or all of the Building Permit Fee
Grant.
5.1.3.8 Should any Affordable Housing Unit not be maintained over the 10-year grant period, the City reserves the
right to amend the Agreement and reduce future payments to recoup a portion of the Total Grant, including
the Building Permit Fee Grant or any applicable top up grants.
5.1.3.9 Disbursement of grant funds will be made based on availability of sufficient resources in the Building
Incentives Reserve Fund, as provided in the City’s annual operating budget and/or replenished per the
mechanism set out in the Policy.
6. M ONITOR A ND R EVIEW
6.1 Large-Scale Development Incentive Program
The Large-Scale Development Incentive Program will be reviewed at regular three-year intervals and
adjusted in accordance with changes in construction cost indices and inflation. Market conditions will also
be monitored by further financial feasibility analysis to ensure the incentive funding remains relevant to
changing market trends, meets the goals of this policy, and continues to align with City plans and by-laws.
7. R OLES AND R ESPONSIBILITIES
7.1 Common Council is responsible for approving all Incentive Programs.
7.2 Common Council is responsible for approval of all Large-Scale Incentive Program Applications.
7.2 Growth Committee is responsible for receiving annual updates on incentive programs and reviewing and
making recommendations on any new programs.
7.3 The Development Incentive Review Committee is responsible for evaluating all Large-Scale Incentive
Program applications in accordance with respective policy and scoring all applications.
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8. B UILDING I NCENTIVE R ESERVE
8.1 The Building Incentive Reserve is situated within the Growth Reserve. The purpose of the Building Incentive
Reserve is to ensure sufficient resources to fund future incentive commitments anticipated to exceed current
annual operating budget.
8.2 No more than 30% of the annual operating budget for development incentives shall be funded through the
Building Incentive Reserve.
8.3 The Building Incentive Reserve will maintain a rolling 10-year liability forecast and contain enough funds to cover
at least two years in average liabilities forecasted.
8.4 New revenue generated by incentivized projects under the Large-Scale Incentive Program will be monitored
over the full 10-year period, with at least 60% of new revenue added to the appropriate incentive operating
budget or incentive reserve through the budgetary approval process.
9. A PPLICATION R EQUIREMENTS
9.1 Applications shall be made by completing the appropriate program application form.
9.2 Legal names of the property owner(s) are required, including any directors of a corporation. Appropriate
authorization of the application is required according to the ownership structure.
9.3 All costs associated with the preparation of the application are the responsibility of the applicant. The City will
not pay any costs incurred by the applicant in the preparation and submission of an application under this policy,
or any costs incurred in relation to the execution and delivery of a Grant Agreement.
10. A PPENDIX
10.1 Large-Scale Development Incentive Program
Schedule A – Eligibility Area
Schedule B – Grant Rates
Schedule C – Application Evaluation
Schedule D – Application Form
Schedule E – Pro Forma Input Assumptions
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