Challenges and opportunities to managing flood risk

Although Ontario has a well-established approach to managing flood risk, the reality is that there have been significant property and casualty losses associated with extreme weather events in the past several years. According to Canada’s Parliamentary Budget Officer, the estimated annual DFAA costs resulting from floods are the largest of the weather events (others being hurricanes, convective storms and winter storms) representing 75% of all weather-related expenditures (refer to Estimate of the Average Annual Cost for Disaster Financial Assistance Arrangements due to Weather Events (PDF)).

The public should understand that the risk of flooding cannot be eliminated, but it can be reduced. There are considerable challenges to managing flooding especially when governments are having fiscal challenges. However, there are many opportunities to improve on the current approaches to managing flood risk.

6.1 Prevention

6.1.1 Gaps in policy and technical guidance

Components of the current technical guides and associated standards are outdated and need to be updated to reflect emerging environmental concerns and new land use policies.

Beginning in 2016, the MNRF initiated work to better understand and start to address current gaps in policy, and document issues and concerns with technical guidance, including many of the components highlighted in sections below. In some circumstances, specific conservation authorities have developed and adopted their own policies and technical guides which may not be consistent with MNRF’s guidance or the Provincial Policy Statement (PPS).

This section is included specifically to highlight the gaps in policy and technical guidance. Subsequent sections get into more detail and result in specific recommendations.

6.1.1.1 Lack of guidance for considering climate change

Changes made to the PPS in 2014 direct municipalities to consider the potential impacts of climate change that may increase the risk associated with flooding and other natural hazards. Furthermore, draft proposed edits to the PPS released for consultation in 2019 suggest the need for municipalities to “prepare for the impacts of a changing climate” (see Section 5.2.1).

Climate change has the potential to alter watershed hydrology, such that existing hydrologic procedures, analyses and modelling may require adjustments or adaptations to adequately represent the range of potential hydrologic effects and to support modelling of affected flows and levels using hydraulic analyses to inform floodplain mapping. The MNRF’s Technical Guide – River & Stream Systems: Flooding Hazard Limit, which is used to help implement the PPS, was approved in 2002 and does not include the latest information on climate change. In recent years, there have been substantive changes in technology and an enhanced understanding of climate change considerations with regards to hydrologic modelling and associated influences on the hydraulic analyses required to develop floodplain mapping.

Existing policies and technical guidelines provide very little guidance on how to incorporate climate change consideration into planning and permitting decisions. Background work to derive options for integrating climate change considerations into the MNRF’s technical guidance has been ongoing since 2016 and would be integral to an update of the flooding technical guidance.

In 2017, the MNRF commissioned a study that produced a report titled: “Flooding Hazard Climate Change Advisory and Option Report.” The report identified ways in which climate change considerations can be integrated into the Technical Guide - River and Stream Systems: Flood Hazard Limit. Deliverables from this project will make significant contributions to ensuring that a range of options for addressing climate change and climate change adaptation that are consistent with provincial policy are available for consideration as the MNRF works towards enhancing implementation of Ontario’s existing flood hazard policies, while best addressing future climate considerations.

The MNRF (Water Resources Section) currently sits on the Steering Committee of a Natural Resources Canada funded study that will develop climate change information on future ice conditions and storm extremes for use in coastal infrastructure development, policies, programs and practices on the Great Lakes. Findings and data generated by this study will help inform updates to the MNRF’s technical guidance for the Great Lakes and connecting channels related to flooding, erosion and dynamic beach. Recent high levels and associated erosion on Lake Erie and Lake Ontario (specific areas of focus for the study), make the results of this study particularly timely.

6.1.1.2 Climate change resiliency of existing flood standards

Flood standards specified in the MNRF’s technical guidance for rivers and streams are based on the greater of the 100-year flood (which forms the minimum standard), floods produced by a specified meteorological event (e.g. Hurricane Hazel or Timmins Storm) or an observed flood greater than the 100-year flood level. Presently, little guidance exists for developing future climate informed flood standards, particularly for river and streams. While some have suggested incorporating arbitrary freeboard in floodplain mapping to account for uncertainty as a qualitative approach for assessing the uncertainties of flood impacts from climate change, little substantive information is available in the published literature, or in use by other jurisdictions to support this approach from a scientific perspective. Acknowledging this gap, the Flooding Hazard Climate Change Advisory and Options Report commissioned by the MNRF in 2017 also included considerations of a range of options for integrating climate change considerations to inform Ontario’s flood standards.

6.1.1.3 Outdated guidance on floodproofing standards

Floodproofing standards are currently addressed in the MNRF’s Technical Guide – River & Stream Systems: Flooding Hazard Limit. Floodproofing information and standards identified therein are based on science and approaches from the 1980s. Floodproofing as addressed in the Technical Guide includes considerations of types of floodproofing, sound engineering practice related to construction and structural integrity, vehicular access considerations, and additional aspects related to flooding as a threat to life, including general rules regarding independent and combined functions of depth and velocity to support safe access and egress, and safe movement for most individuals in flood waters.

Work is wrapping up on an investigation and synthesis of current best practices, procedures, methodologies and technical considerations related to the field of floodproofing to protect people and property from flooding related natural hazards. This includes an evaluation of guidance presented in “Appendix 6 – Floodproofing” of the MNRF’s Technical Guide – River & Stream Systems: Flooding Hazard Limit in the context of current and up-to-date protocols, procedures, methodologies and technical considerations. The evaluation will further include flooding as a threat to life to identify gaps and/or areas in the Technical Guide to highlight where the currency of the existing document would benefit from modifications and/or updates. A key deliverable is the development of considerations outlining appropriate options for updating the floodproofing guidance to support a revised Appendix 6.

Based on findings of background research and evaluation relative to the existing Technical Guide, the MNRF is considering producing a report proposing technical information requirements, specifications and standards related to floodproofing to enhance the currency of techniques and technical considerations, and promote consistency in the application of floodproofing measures across the province.

This floodproofing review has implications for other MNRF natural hazard technical guides that refer to floodproofing (i.e. Great Lakes St. Lawrence flooding, erosion and dynamic beach) and has linkages to aspects of other policies and legislation such as the Ontario Building Code and the PPS documentation. Endorsement of newer methods could provide an additional range of options for Ontarians to manage and mitigate the impacts of flooding on dwellings.

6.1.1.4 Outdated guidance on hydrologic and hydraulic modelling

The hydrology and hydraulic chapters of the Technical Guide – River & Stream Systems: Flooding Hazard Limit are considerably dated. This includes reference to obsolete modelling software and to a lesser extent, standard practices.

The MNRF has completed initial research to identify methods and options for updating the sections associated with hydrology and hydraulics in the Technical Guide to account for technological and methodological advancements. With regards to hydrologic modelling, this includes an assessment of technologies and modelling protocols, practices and platforms for informing water level computations and flood line delineation, addressing the types of hydrologic models, model selection and calibration.

With regards to hydraulics, efforts included analyses to support improving the suitability of hydraulic analyses for estimating water levels throughout a wide range of rivers and river characteristics within Ontario. This involved guidance around choosing a hydraulic modelling technique, and direction around the use and applicability of 2-dimensional (2D) modelling, including guidance and standards for its use and interpretation. Guidance and requirements related to hydraulic model calibration, testing and sensitivity analysis were included, as were additional guidance on evaluating uncertainty in model parameters and the resulting impacts on model simulations and the associated range of error in modelled results.

While the above focus is on the riverine flooding guidance, the Great Lakes St. Lawrence and Large Inland Lakes guidance suffers from similar issues. Less effort has been placed on these documents.

6.1.1.5 Outdated guidance on surveying and mapping standards

In 1986, the MNRF adopted flood-related survey and mapping standards based on guidelines developed by the federal government under the cost shared Federal/Provincial Flood Damage Reduction Program, which ran from 1977 to 1992.

In 2002, to support municipal implementation of the PPS, the MNRF consolidated, developed and approved a series of natural hazards technical guides including the Technical Guide – River & Stream Systems: Flooding Hazard Limit.

In the Flooding Hazard Limit Guide, there is a placeholder: Section J, “Surveys and Mapping”, for new provincial direction on mapping standards and techniques.

Given the MNRF 1986 guidance is out of date, current mapping practice by municipalities and conservation authorities is to use best professional engineering judgement. Substantive advancements continue to be made rapidly in surveying and mapping standards and data acquisition, including in the areas of remote sensing, geomatics and mapping technologies and practices as discussed in other sections of this report.

With the recent release of the Federal Geomatics Guidelines for Flood Mapping, as part of the Federal Flood Mapping Guidelines Series, there is an opportunity to glean information from this document which may serve Ontario well and align, where suitable, the geospatial data requirements for flood modelling and mapping (go to Federal Flood Mapping Guidelines Series).

Updated standards are required to ensure consistency and adequacy of floodplain mapping across the province. The MNRF commissioned a review of jurisdictional surveying and mapping standards for flood mapping in 2016 and is in the process of evaluating options for updates to the appendix. A document titled: “Survey and Mapping Specifications and Standards Report” produced in 2018 for the MNRF was reviewed internally by the Ontario Public Service Elevation Coordination and Consultation Committee. This Committee brings together elevation experts from all relevant ministries and partner agencies to provide coordination and expertise on elevation data-related projects, acquisitions and issues. Feedback, technical comments and edits provided by this group are being incorporated into a final draft document, including considerations noted above related to the federal geomatics guidelines.

6.1.1.6 Other policy or technical gaps

Other gaps in provincial policies and technical guidelines include:

• Lack of policy direction/technical guidance regarding drought. While the topic of drought is outside the scope of this review, it needs to be considered in the context of lowering reservoirs to capture more water and reduce the impacts of flooding, and whether a subsequent drought will prevent the reservoir from being refilled.
• Direction around the use of 2-dimensional (2D) and/or combined 1-dimensional/2-dimensional (1D/2D) hydraulic models. For example, is it necessary to consider floodplain storage in flood hazard mapping, and if so, which is the appropriate model.

Filling some of these gaps could help streamline approval processes by providing greater clarity and certainty around how to address these issues.

6.1.1.7 Limited training, outreach and awareness

Limited provincial resources are currently directed towards training, outreach and awareness of the MNRF’s policies, technical standards and guidelines. Such outreach is typically limited to ad hoc requests for presentations to various groups or events (e.g. annual conferences, workshops).

Limited training, outreach and awareness can contribute to misunderstanding, competing interpretations, and a lack of clarity and consistency in standards and policy requirements. Some stakeholders, including the Association of Municipalities of Ontario, have requested increased training and outreach with municipalities, developers and conservation authorities on the basis that it would help ensure services were undertaken more consistently across the province.

6.1.2 Policies, standards, regulations and legislation

In her 2017 report, Ontario’s Auditor General raised the following concerns:

The provincial emergency management program does not focus on all five components of emergency management: prevention, mitigation, preparedness, response and recovery. Currently, the focus of the emergency management program in Ontario is mainly on only two of the five components—preparedness and response—with the Ministry of Municipal Affairs also undertaking activities related to recovery through the disaster financial assistance programs.

2017 Annual Report Volume 1, Office of the Auditor General of Ontario, Emergency Management in Ontario (PDF))

While these concerns apply to the province’s overall approach to emergency management, they may also apply to the province’s approach to flooding.

Prevention-based approaches have been repeatedly shown to be more effective in reducing the impacts of flooding and other natural hazards. As outlined within the five core components of emergency management, flood prevention relies on the use of non-structural measures, such as land use planning and permitting and building controls to keep people and property out of hazardous areas. In Ontario, land use restrictions are put in place by municipalities to prevent new or intensified development in areas prone to flooding and other natural hazards. Land use restrictions are also put in place by conservation authorities who are required to regulate development (in areas prone to natural hazards) for impacts to the control of natural hazards as set out in regulation (i.e. flooding and erosion) and for interference with a watercourse or a wetland.

While regulations and land use restrictions have been in place for a few decades in Ontario, concerns have been raised noting that these policies and associated technical requirements may not be adequately enforced and too easily ignored in response to the financial incentives or other incentives (such as infill development in historic communities) that encourage new and intensified development in or adjacent to flood-prone areas. These incentives often encourage greater reliance on tools contained within other core components of the emergency management framework, such as the use of mitigation measures (e.g. flood protection berms, floodproofing), preparedness systems (e.g. flood warning systems), and response (e.g. temporary sandbag dikes) and recovery programs (e.g. disaster assistance and/or insurance) that do not require strict adherence to a prevention-first approach to managing the impacts of flooding.

Clearly, more focus on prevention is needed, and strengthening existing policies and standards by enshrining them in legislation (or by regulation) is required.

As mentioned in Section 5.2.2, the MNRF is proposing a regulation under the Conservation Authorities Act that outlines how conservation authorities regulate development and other activities for impacts to the control of natural hazards and public safety. The proposed regulation will make rules for development in hazardous areas more consistent to support faster, more predictable and less costly approvals.

6.1.2.1 Consideration of risk in floodplain management policies

There are two main approaches to managing flooding and other natural hazards: a hazards-based approach and a risk-based approach.

A hazards-based approach focuses on determining where hazards exist and then taking steps to prevent activities from occurring in those areas. A risk-based approach focuses on determining the risks posed by natural hazards, and then taking steps to further reduce those risks to acceptable levels. In the case of flooding, a hazards-based approach seeks to delineate the floodplain and prevent development from occurring within it. A risk-based approach seeks to identify the risks associated with development in a floodplain and find ways to reduce those risks through enhanced floodproofing, flood forecasting and warning, and other measures. Adopting a risk-based approach allows individuals to proceed with a given activity (e.g. development within a floodplain) provided that sufficient measures can be put in place to keep risks as low as reasonably achievable.

While there is some support for a risk-based approach, developing and successfully rolling out a risk-based planning and/or permitting framework would be a complex and resource-intensive task requiring new provincial policy direction in several areas including defining acceptable levels of risk.

The MNRF’s current approach to managing flooding and other natural hazards straddles these two approaches by taking a hazards-based approach to limiting new development and taking a risked-based approach to reduce risks associated with existing development located in hazardous areas (e.g. as with Special Policy Areas). Risk-based flexibility is also provided for development in the flood fringe in areas where the two-zone concept is applied, subject to floodproofing consistent with MNRF standards. This seems to be at odds with what some conservation authorities believe, as they have advocated for taking a risk-based approach to mitigate urban food risk. They recommend that the Province contemplate how to incorporate a consideration of risk when updating floodplain implementation guidelines.

6.1.2.2 Provincial Policy Statement review – proposed policies

Overall, I am in agreement with the existing polices under the Provincial Policy Statement (PPS) Review, in particular with Section 3.0 Protecting Public Health and Safety. This Special Advisor on Flooding report covers some of the content in the PPS Review, which is based on my review of a considerable amount of background information, what I heard while meeting with municipalities and conservation authorities, and from submissions received by municipalities, CAs and other agencies. The proposed PPS policies are supported by some of the recommendations I’ve made in this report, such as the need for updated technical guidelines; entrenching elements of the technical guides (such as standards) in legislation; and reviewing and updating the MNRF’s technical guides to support the use of flood protection landform

6.1.3 Floodplain and flood risk mapping

Having accurate floodplain maps help communities make efficient and effective planning decisions. The Office of the Auditor General suggests that up-to-date floodplain maps would allow municipalities to better plan for future growth in areas of low flood risk, and build infrastructure and resiliency in high-risk flood areas.

6.1.3.1 Limitations of existing geomatic data and mapping

The management of floodplains and other hazardous areas begins with their identification. Knowing the location of these areas can help streamline approval decisions and ensure areas not subject to flooding and other natural hazards can be developed.

Several issues exist associated with data and mapping used to delineate floodplains and other areas. CAs report that a large percentage of their floodplain mapping require some form of an update. This takes into consideration all elements of floodplain mapping, including the age, limitations and accuracy—not just the currency of existing mapping alone. It is important to note that particularly in areas of the province where development pressures are low, age of mapping is not necessarily an indicator that mapping is out-of-date or “outdated.”

6.1.3.2 Updates to floodplain data and mapping

The cost of updating floodplain mapping can be prohibitive to municipalities and CAs, as it requires high resolution elevation data.

Recent base data acquisitions funded by the Ontario Ministry of Agriculture, Food and Rural Affairs (OMAFRA) and in partnership with the MNRF, including the use of Light Detection and Ranging (lidar) technology, have significantly reduced the cost burden to CAs and municipalities associated with base data acquisition, particularly in south-central and southwestern Ontario.

Considerable work has been undertaken by municipalities and conservation authorities in the province over the last several years to update floodplain mapping with matched federal funding provided through the federal government’s competitive, merit-based National Disaster Mitigation Program (NDMP). Flood mapping was a specific funding stream of NDMP. Under NDMP, only applications related to the municipal land use planning and mitigation were eligible, and projects related to CA regulatory limit mapping to support the implementation of conservation authority regulations made under the Conservation Authorities Act were not eligible. The Province included a specific requirement for conservation authority proposals— that municipal support for the project be demonstrated through a letter of support from the affected municipality or municipalities (including regional governments). Furthermore, if the conservation authority planned to use a municipal levy to cover project costs, that the letter of support must also reference the municipalities support for the levy funding mechanism. By way of the letter of support, municipalities were also required to commit to the flood mapping being integrated into Official Plans to guide future development outside of flood-prone areas.

From 2015 to 2019, municipalities and conservation authorities received approximately $9 million towards updating flood maps across Ontario, for a total investment of at least $18 million in flood mapping.

Across all five NDMP intakes and all four funding streams, a total of $40.58 million in federal funding was secured by Ontario applicants. Including applicant matched funding, this means that no less than $81 million in total funding has been secured for flood-related initiatives through all five intakes of NDMP.

6.1.3.3 Expanding regulatory flood lines

Many factors can contribute to the expansion of regulatory flood lines. These lines are dynamic in nature and can expand and move as development in the watershed changes, altering rainfall-runoff characteristics and associated flood generation. Land use change can contribute to larger amounts of water being more quickly delivered to streams and rivers. The larger volume of water in rivers and streams acts to expand flood lines, covering larger areas of land adjoining streams and rivers with water under the flood standard. In addition, acquisition of new and more accurate survey and mapping data combined with revised hydrologic and hydraulic modelling can result in considerable differences in the extent of regulatory flood lines between current and updated flood hazard mapping, particularly when based on full build-out projections related to a 20-year official plan.

Regulatory flood lines and associated floodplains are expanding or are expected to expand, bringing more existing development, and areas targeted for new development, into flood-prone areas. This can be particularly true in areas using a 1:100-year storm event to delineate regulatory flood lines; however, areas currently using a 1:250-year storm event (e.g. areas within the Upper Thames River watershed) are also finding significant expansions in regulatory flood lines. Areas using a regional regulatory storm (i.e. Hurricane Hazel or the Timmins Storm) are less likely to see significant increases in the size of regulated floodplains as these events have higher return periods (lower chance of occurring).

Regulatory flood lines and floodplain mapping should be updated along with updates to municipal official plans. It is important that flood hazard identification incorporated into municipal planning documents, through mapping or otherwise, reflect a full build-out condition of the upstream watershed based on the current official plan. This level of rigour is intended to provide people and property downstream a level of assurance that flood hazards are accounted for, and that the influence of future land development on flooding is considered. As this mapping is used by municipalities for land use planning purposes, mapping is generally current until the next Official Plan update and based on a (+/-) 20-year planning horizon.

Many areas of southern and southwestern Ontario have experienced and continue to experience rapid urban development. Many municipalities have been highlighting the need to update flood hazard mapping to capture the effects of land use development occurring since mapping was last completed and to use the most current data and technologies (i.e. lidar, 2D hydraulic modelling where appropriate, etc.).

Expansion of regulatory flood lines can be a concern for municipalities, developers and existing homeowners regarding the impacts of expanded lines on future growth opportunities, the ability to invest in and protect existing homes, and property values. To date, 73 flood mapping projects across southern Ontario have been funded by the federal National Disaster Mitigation Program (NDMP) with the aim of updating existing floodplain mapping across more than 30 municipalities. These studies could result in expanded regulatory flood lines, and associated concerns from the development community and others regarding the potential impacts of updated flood lines on existing and planned development within these municipalities.

Increased urbanization, exacerbated by the influences of a changing climate, can create a situation whereby areas that were considered to be outside of the floodplain, and managed and developed without specific consideration of the flood hazard, may be subject to a greater flood hazard and associated flood inundation. To better understand how this issue is being addressed internationally to provide context on how Ontario may approach them in the future, the MNRF commissioned a jurisdictional analysis of expanding floodplains in a policy and planning context. A scan of the literature conducted early in the project revealed that most jurisdictions have moved beyond a regulatory hazard-based approach to defining and managing regulatory flood lines, and instead now focus on managing floods in-line with a risk-based approach. Most international jurisdictions, rather than using a single likelihood of flood hazard to define flood lines and the flooding hazard limit, have transitioned to consideration of multiple likelihoods, and also of the number and type of exposed elements in the floodplain.

The project therefore focused on considerations for supporting the adoption of a risk-based management approach for riverine and lake flooding in Ontario, including approaches and opportunities for managing changing flood lines, with a view to understanding and managing flood risks in the context of Ontario’s policy and planning landscape.

6.1.3.4 Technical guidance that governs floodplain mapping

While the Mapping and Geomatics Services Section of the Mapping and Information Resources Branch of the MNRF has been able to provide guidance on lidar acquisitions and the management of legacy datasets to other provincial agencies, recent projects under the National Disaster Mitigation Program (NDMP) have supported lidar acquisitions by municipalities and CAs on a project-by-project basis. Ontario does not have defined flood survey and mapping guidance or standards available to support consistent survey data acquisition and mapping by conservation authorities, municipalities and developers. Updated technical guidance is needed to determine what level of detail is required for floodplain mapping and how these expectations may differ in rural or urban areas.

This lack of coordination has led to gaps in coverage for many areas of the province; duplication of effort; inconsistent data standards and data access; and increased costs.

Technology, tools and approaches to deliver modern digital floodplain mapping have changed since the most recent update of floodplain mapping technical and implementation guidelines was last completed in 2002. Work recently commissioned by the MNRF to develop surveying and mapping specifications, and standards for flood hazard mapping (in support of an update to the natural hazard technical guides), will make considerable headway in advancing mapping consistency across the province.

A couple of conservation authorities have reported that new technologies and approaches have been piloted or developed amongst the conservation authority community along with CA guidelines for developing new digital floodplain mapping. Case studies and CA guidelines can be provided by the CA community to assist the Province with assessing the new approaches and developing the new provincial guidelines for hazard and flood risk mapping. They have even offered secondments of CA personnel to the MNRF to help transfer knowledge and experience, and to create a collaborative approach to updating the technical guidelines.

6.1.3.5 Costs associated with updating floodplain mapping

In 2013, Conservation Ontario estimated that a one-time investment of $24.8 million was required to update floodplain mapping and modelling in Ontario for areas where CAs have been established. A study on floodplain mapping commissioned by Public Safety Canada estimated that the costs of mapping currently unmapped floodplains in Ontario could be as high as $119.6 million (2014). More recently, in 2017, Conservation Ontario estimated the cost of an update being approximately $136 million; however, it is not clear if this cost only includes areas of the province where conservation authorities have been created.

The National Disaster Mitigation Program (NDMP) was an effective federal program that provided 50% funding to complete updated floodplain mapping. That program ends in March 2020. Either a new federal or provincial, or combination of a federal/provincial program could provide the necessary funding.

The federal government continues to advocate and encourage adaptation and preparedness for climate variability. One of the most practical adaptations is emergency preparedness and response plans, which help make communities more resilient to climate change. Floodplain mapping and the associated models supporting floodplain mapping are fundamental to the creation of effective emergency preparedness plans for floods. A case could be made to the federal government to fund the creation of modern digital floodplain mapping as adaptation and preparedness for climate change and severe weather events.

It has been suggested that the Province discuss the opportunity to take a strategic, multi-year, multi-agency planning approach to an extended program, in order to address known gaps in floodplain mapping. As currently established, the National Disaster Mitigation Program (NDMP) is based on interested parties applying for funding. It has also been suggested that the Province advocate to the federal government for continued funding of the NDMP or development of a successor program, recommending the end date of the program be extended for 10 years, from March 2020 to March 2030. As such, the federal government investment in floodplain mapping would help achieve its goal of encouraging adaptation in preparation for climate change and extreme weather events.

6.1.3.6 Proposed Elevation Mapping Program

Regardless of whether the federal government extends the NDMP, there is a need to establish an Elevation Mapping Program within the MNRF’s Mapping and Geomatics Services Section. This program will ensure more complete coverage of the province; centrally manage a cross-agency funding model; leverage existing multi-ministry governance and budgeting capacity of the Land Information Ontario (LIO) program; reduce total costs and bureaucracy for all provincial agencies; consider cross-discipline business requirements; allow for consistent standards to be collected; align with other provincial, state and national elevation programs (Manitoba, Quebec and New Brunswick, Canada and the United States); centrally manage elevation data procurement, quality control, data management and data distribution; and leverage staff knowledge and skills to address future changes in acquisition requirements and technology (e.g. bathymetric lidar).

Establishing an Elevation Mapping Program will align with current government priorities:

• Ontario’s Open Data Directive by maximizing access to government data;
• Ontario’s Data Integration Initiative by supporting standards for data management, and releasing non-sensitive government data to promote transparency, spur innovation and economic growth; and
• Ontario’s Digital and Data Task Force driving innovation using emerging data technologies.

This program would require net-new annual funding for data acquisition and for data storage and distribution.

6.1.3.7 Provincial custodian for floodplain mapping Information

Lidar data is a modern approach and an important component of producing floodplain maps. It is expensive but can be affordable if two or more agencies team up to acquire the data. The Mapping and Geomatics Services Section (MGSS) of the Mapping and Information Resources Branch of the MNRF has a multi-year program for planned topographic lidar data acquisitions within southern Ontario. The program is intended to assist with identification of priority areas for future data collection, and to reduce duplication of effort by identifying where data may have already been collected or is planned to be collected by other government agencies.

Engagement with municipal, conservation authorities, and provincial and federal agencies has identified that flood mapping information (geospatial data, reports, and flood maps) created through the historic Federal Damage Reduction Program (FDRP) and National Disaster Mitigation Program (NDMP) projects are not seamlessly and centrally managed or accessible. On the latter point, some mapping has been acquired on the vendor’s condition of restricted access only by the client.

The lack of a consolidated data management solution for flood mapping data is resulting in:

1. inability for provincial programs to incorporate data into their operations, including emergency management and response;
2. increased risk of data loss;
3. inconsistent data standards; and
4. inability to reference the data for lidar acquisition planning.

Accordingly, there is a need to identify a provincial custodian for flood mapping information in order to clarify data ownership; determine requirements for data management, storage and access; and leverage Land Information Ontario’s existing geospatial infrastructure to support data maintenance, access and dissemination at minimized costs.

If a single provincial custodian is to be established, consideration would need to be made for ownership (intellectual property) of the flood mapping information, as it is mainly held by municipalities. Policy, regulations and legislation would likely need to be updated to identify a requirement for all provincial agencies to provide flood mapping information up to the provincial custodian. Some municipalities and CAs are moving to new Open Data standards and publishing regulatory flood lines on their websites. Policy, regulations and legislation would also likely need to be updated to require that floodplain maps produced at the local level are provided to and integrated into a common provincial floodplain map repository.

6.1.4 Roles and responsibilities

Several different agencies share roles and responsibilities for the management of flooding and other natural hazards. The reality is that some prevention, mitigation, preparedness and response roles have to be shared between municipalities and multiple ministries by nature of the services they provide.

However, it was pointed out at some of the municipal engagement sessions, that when roles and responsibilities are shared amongst several different agencies, it diffuses control, expertise, and ultimate decision-making and accountability among the agencies.

6.1.4.1 Unclear roles in emergency management

Chapter 3 of the 2017 Auditor General’s Annual report raised concerns regarding the current governance structure for emergency management noting that:

The current governance structure for emergency management in Ontario is not effective for overseeing a province-wide program. Oversight of emergency management in Ontario is the responsibility of the Cabinet Committee on Emergency Management. However, this committee has not met for several years. Concerns about the overall oversight of emergency management in the province were brought to the government’s attention as far back as 2005 in an internal review report, Emergency Management Processes in the Ontario Public Service. The report concluded: At the enterprise level, processes are not currently sufficient to ensure that Ontarians and the resources of the Province are adequately protected against emergencies and disasters.

2017 Annual Report Volume 1, Office of the Auditor General of Ontario, Emergency Management in Ontario (PDF).

While the report focused on the broader umbrella of emergency management, similar concerns could apply specifically to the management of flooding and other natural hazards.

The Office of the Fire Marshall and Emergency Management (OFMEM) within the Ministry of the Solicitor General is taking action to address the Auditor General’s recommendations and other reviews. Following is a summary of some of the initiatives planned or currently underway:

• AG recommendation to strengthen Emergency Management and Oversight – Emergency Management Ontario (EMO) will establish inter-ministerial and a multi-level governance framework (e.g. Cabinet Committee on Emergency Management) to support decision-making, collaboration and information sharing.
• AG recommendation to update all risk assessments and response plans – EMO to review existing provincial risk assessments and the provincial emergency response plan; and re-establish province-wide Continuity of Operations Program and directly support development of municipal continuity programs.

6.1.4.2 Unclear roles and responsibilities for identifying hazardous areas

While the MNRF generally takes the position that municipalities are exclusively responsible for identifying hazardous areas, provincial policy is unclear and at times contradictory, and has created some confusion over who is responsible for identifying hazardous areas.

The Emergency Management and Civil Protection Act, 2009 (EMCPA) requires both provincial ministries and municipalities to identify and assess the various hazards and risks to public safety that could give rise to emergencies.

Section 2.1(3) regarding municipalities states: “In developing its emergency management program, every municipality shall identify and assess the various hazards and risks to public safety that could give rise to emergencies and identify the facilities and other elements of the infrastructure that are at risk of being affected by emergencies.” 2002, c.14, s.4.

Section 5.1(2) regarding provincial ministries states: “In developing an emergency management program, every minister of the Crown and every designated agency, board, commission and other branch of government shall identify and assess the various hazards and risks to public safety that could give rise to emergencies and identify the facilities and other elements of the infrastructure for which the minister or agency, board, commission or branch is responsible that are at risk of being affected by emergencies.”

Provincial guidelines direct municipalities to identify floodplains and other hazardous lands to incorporate these areas into their Official Plans, plan amendments, zoning bylaws and associated approvals. Municipal planning authorities, under Section 3 of the PPS (2014), are to direct development to areas outside of hazardous lands (including the floodplain identified by the limit of the flooding hazard). As per the preface of the MNRF’s Technical Guide – River and Stream Systems: Flooding Hazard Limit (2002), the Province has empowered municipalities to assume responsibilities for the management of flood risk areas, and the associated liability and the risk relative to planning for new land uses in and around these areas.

Conservation authorities also invest with provincial and municipal funding in identifying hazardous areas for carrying out their delegated role in reviewing municipal planning documents for consistency with the PPS and to support administering their regulation. While the MNRF is responsible for identifying hazardous areas in areas where no municipalities or CAs have been established, some municipalities advocate that this responsibility should extend to any area where a CA has not been established and that expecting municipalities to identify hazardous areas places an unrealistic burden on small, rural municipalities.

Municipalities can choose to rely on the services of CAs to undertake floodplain mapping but are not required to do so. While some municipalities and conservation authorities partner together to create maps, others do not. In these cases, municipalities contract consulting engineering firms to complete the floodplain mapping work, as do CAs in some instances.

6.1.4.3 Conflicting policy direction and technical advice

Shared roles and responsibilities can lead to conflicts over provincial policy direction when multiple agencies have differing perspectives on a given issue, and where other agencies are creating and disseminating guidance materials that are not consistent with MNRF endorsed policy or technical guidelines.

The MNRF provides policy direction and technical guidelines to municipalities and conservation authorities to support their planning and regulatory roles. Many CAs have their own policies in place that, at times, are used to supersede or are seen to contradict provincial policy and technical guidelines.

Some conservation authorities and municipalities view technical guidance provided by the MNRF as simply guidance to be used by engineers and other professionals to help guide their decisions, and allowing them to apply their own policies or professional judgement to decide.

Additional technical guidelines concerning the management of flooding and other natural hazards, although not necessarily provincially endorsed are also prepared and released by academia, the Standards Council of Canada, and the National Research Council.

There is no specific recommendation to deal with this issue as other recommendations provided in this report, such as enshrining flood hazard policies and technical standards in legislation, if adopted, should take care of the conflicting policy direction and technical advice.

6.1.4.4 Conflicts between planning and permitting decisions

While municipal planning and conservation authority permitting processes are related, they are distinct processes with distinct requirements.

Differences between planning and permitting requirements were noted by some stakeholders as causing conflicts between regulatory and municipal planning decisions. Some stakeholders commenting during the review questioned the ability of a CA to refuse an approval for projects previously approved under the Planning Act. Similar concerns have been raised regarding the pressures placed on municipalities, the Province and CAs in balancing growth and the management of hazards, particularly in municipalities with very specific growth targets.

6.1.4.5 Perceived conflicts of interest

Municipalities are ultimately responsible for making local planning decisions. Some stakeholders have raised concerns that this creates a conflict of interest for municipalities, as there is a perceived financial incentive not to limit development in areas prone to flooding and other natural hazards, despite potential future recovery and relief costs.

Some sectors have raised concerns that members of a conservation authority, who are primarily municipal officials, were pressured to approve projects that are deemed to be “in the interest of” municipalities, and that the lack of clarity and consistency in requirements made it difficult for a CA to say no to proposals that member municipalities want, particularly if they feel as though that decision may risk future funding.

Again, there is no specific recommendation to deal with this issue as other recommendations provided in this report, such as enshrining flood hazard policies and technical standards in legislation, if adopted, should take care of the perceived conflict of interest.

6.1.4.6 Role of the provincial One Window Planning Service

The provincial One Window Planning Service is the organizational structure and process established to support the move to a policy-led land use planning system. It entails the Ministry of Municipal Affairs and Housing (MMAH), in consultation with partner ministries and, where applicable, conservation authorities under their MNRF delegated role, providing municipalities, planning boards, development applicants and the public with “one-stop” access for provincial land use planning services, with a focus on where MMAH exercises its statutory functions under the Planning Act.

Under the provincial One Window Protocol and an associated memorandum of understanding, MMAH consults with conservation authorities regarding natural hazard impacts of policy and development proposals for which it is the decision maker. Where no conservation authority has been established, the MNRF undertakes this review. Municipal planning documents approved by MMAH include all upper-tier and single-tier Official Plans (OPs), and some upper-tier and single-tier Official Plan Amendments (OPAs). MMAH is also the decision-maker for applications from territory without municipal organization where there is no planning board. Under the provincial One Window Protocol, the Minister of Municipal Affairs and Housing is the only provincial minister who can appeal municipal planning decisions to the Local Planning Appeal Tribunal. In some circumstances, public bodies, including conservation authorities, that provided comments before a municipal decision was made can also appeal municipal planning decisions.

6.1.4.7 The federal government

The release of the Federal Flood Mapping Guideline Series has created confusion on the flood modelling and mapping landscape of Ontario and other provinces/territories, related to roles and responsibilities between the provinces and the federal government. The incorrect assumption among some practitioners is that the federal “guidelines” supersede those of the province. However, this series of federal documents does not replace or supersede any provincial legislation, technical standards, policy or assigned roles and responsibilities of provincial and municipal governments and their agencies in natural hazard management and mitigation. The development and implementation of flood management legislation, regulation, standards, policy and flood mitigation measures is primarily a provincial/territorial responsibility.

The federal government may intend these federal guidelines as a basis for further specification as defined by a province. However, Ontario already has its “specifications” and will adopt what is pertinent to the province, through any subsequent updates that the MNRF makes to existing guidance. The overall confusion which seems to be exacerbated by each subsequent federal guideline release has resulted in engineering staff in MNRF’s regional offices needing to reaffirm the precedence of the MNRF’s natural hazard technical guides when working with proponents and consultants.

6.1.4.8 Provincial watchdog

In many jurisdictions, there is a “provincial watchdog” role by a minister over a specific subject, area or discipline. The Ontario Great Lakes Protection Act legislative framework is a good example of what new legislation could be considered by the Province to improve the existing flood policy framework. As examples, the legislation could:

• Establish a lead minister for all flood related policy, standards, regulations and legislation.
• Establish the Minister of Natural Resources and Forestry, as the lead Minister given that the MNRF is already lead administrative ministry having overall government responsibility for hazard management policies/programs.
• Direct that the Minister of Natural Resources and Forestry to work with the ministers responsible for the other Acts that touch on flooding (as identified in Section 5.2) on issues raised above and re-listed here:
  • Clarifying roles in emergency management;
  • Clarifying roles and responsibilities for identifying hazardous areas;
  • Clarifying policies;
  • Clarifying technical advice;
  • Eliminating conflicts between planning and permitting decisions;
  • Eliminating conflicts of interest;
  • Reviewing the role of the provincial One Window Planning Service and the appeal mechanism; and
  • Reinforcing that provincial guides, standards, etc., take
• Provide the lead minister with the authority to amend flood hazard related planning policies.
• Provide the lead minister with the authority to direct public bodies (including other ministries, municipalities, CAs, etc.) to carry out defined actions.

6.1.4.9 Lack of awareness of property owners

Often when floodplain properties are sold the seller isn’t aware of, or doesn’t openly disclose, the fact that the property is located in the floodplain nor the risk of flooding that is associated with the property. Disclosure is not required during real estate transactions. However, it was reported that financial institutions are now looking at the risk of providing mortgages to flood risk properties, and some real estate agents are disclosing the risk to protect their own liability. Even if this was being done everywhere, it is too late in the process and potential home buyers should know up front before making an offer and applying for a mortgage.

6.2 Mitigation

As Ontario metropolitan areas continue to grow, they face increasing pressures to develop—by growing outward, through the construction of new communities at the urban fringe, and growing upward, by accommodating more residents in existing urban areas. Provincial policies such as those contained within “Growth Plan for the Greater Golden Horseshoe” (2006) as well as within the Provincial Policy Statement, include density targets and other policies designed to limit outward growth and the creation of urban sprawl, and to promote greater densification and infill development within existing built-up areas.

Across larger scales, limiting sprawl helps to mitigate increased flooding caused by development by maintaining natural and pervious surfaces within a watershed that help to reduce and slow stormwater runoff. At the same time, targets for increased densification and infill development places additional pressure on municipalities to utilize currently undeveloped areas in existing settlement areas, including floodplains and other hazardous areas, and increase densities in already developed areas that are located in hazardous areas due to historic settlement patterns, such as designated Special Policy Areas. In some instances, urban areas targeted for further intensification and growth may be partially, or wholly, within flood-prone areas.

6.2.1 Great Lakes/St. Lawrence River shorelines

As discussed in Sections 4.6 and 4.7, the shorelines of the Great Lakes and the St. Lawrence River have and continue to be significantly impacted by very high lake levels and erosion.

It would be ideal if everyone lived, carried on a business or installed infrastructure (roads, water, sewer, etc.) far away from the edge of the shoreline, as shoreline erosion is a natural event, and occurs under both high and low water situations and in between. However, legacy development and conversions of quaint little cottages into primary residences has resulted in a very large number of properties being at risk. This is exacerbated by the fact that there are neighborhoods with ground elevations below the shoreline and the current lake level.

Mitigation of shoreline erosion is a very complicated challenge. For areas of intense development, the common mitigation option is shoreline protection, such as dikes, erosion protection and shoreline stabilization. There are many different examples of these structures that exist today and some are more resilient than others. Of course, removing or moving structures further away from the shoreline is another option.

These mitigative measures are extremely expensive and sometimes can’t protect to the water levels seen recently. Property owners are responsible for covering the cost of these works on private property, which is the same in many jurisdictions across Canada.

In Ontario (and similarly in other jurisdictions), municipalities may consider using local improvement charges (see Ontario Regulation 586/06 under the Municipal Act, 2001) to: first, assist with the construction and financing of a shoreline protection project for a group of private property owners (that may provide economy of scale for the design and construction of the works); and second, imposing a local improvement charge which may help make the financial commitment of the overall cost of the shoreline protection works on their property easier for the private property owner by spreading it out over 20 years or more.

Further, in the case of low-lying neighborhoods inland that rely on the protection works, the municipality could consider if charges might be included as part of the calculation of a larger benefitting area and therefore the cost of the works might be spread out among all benefitting properties, and not just the properties along the shoreline.

In my review of Ontario statutes, I discovered a piece of older legislation that is not currently used titled: The Shoreline Property Assistance Act. Under this legislation, the province may offer a Shoreline Property Assistance Program under which municipalities may issue debentures (subsequently purchased by the Treasurer of Ontario) to fund loans to private property owners to construct works such as retaining walls, dikes, breakwaters, groynes, cribs and other structures for the rehabilitation or protection of shorelines, including repairs and improvements to existing works. The funds may also be used by private property owners for raising, relocation or repairs to buildings. The Shoreline Property Assistance Program was cancelled by the Province in 2010 and not currently available to municipalities.

Municipalities may still consider offering loans to private property owners. One municipality in southwestern Ontario, the Town of Essex, has recently approved a new loan program for shoreline residents.

6.2.2 Ottawa River

6.2.2.1 Meteorological and hydrological conditions

The meteorological and hydrological conditions during the spring freshet period in the Ottawa River basin can vary widely and the inability to forecast, with any precision, mid-to-long term conditions presents an ongoing challenge. The storage capacity within the basin is finite and the goal of integrated management of the reservoirs is to effectively apply the use of reservoir storage to reduce downstream flows at the most critical periods of spring flooding. The appropriate use of the available storage is typically applied by reducing reservoir discharges during the periods when flows from the uncontrolled sectors of the basin are high (first peak) and then increasing discharges as this flow in the lower tributaries begins to decrease. The challenge then becomes one of increasing reservoir discharges, to prevent overfilling the storage reservoirs, but at the same time not causing downstream flow to exceed the initial peak.

Due to the topography of the Ottawa River basin, the use of reservoir storage in the upper part of the river has an exaggerated effect on reducing the first peak in the upper sections of the river (Mattawa-Pembroke) because of their proximity to the reservoirs. In years where the spring runoff in Abitibi-Timiskaming greatly exceeds the storage capacity of the principal reservoirs, a second peak along the lower river reach can occur. The area of the highest constriction on the river is below Pembroke in the Westmeath/Lac Coulonge area, and the effective use of reservoir storage in the Abitibi-Timiskaming area can be seen by two peaks that are close in size but both significantly lowered due to the use of reservoir storage. The basin topography and use of reservoir storage then often results in a second peak that is lower in the southern sections of the basin but higher in the more northerly sectors even though under natural conditions, without reservoir storage, the first peak would have been higher throughout. These are broad operational strategies that are impacted by the specific meteorological and hydrological conditions that vary significantly from year to year.

The uncontrolled/unregulated portion of the drainage basin contributed significantly to the flooding in both the 2017 and 2019 floods. For instance, in 2019, the Water Survey of Canada streamflow gauge on the Petawawa River, in operation since 1915, experienced its highest flow on record in April 2019, with a peak flow 46% higher than its previous historic peak value recorded in April 1995. An analysis of flood magnitudes in the absence of existing water management structures and reservoirs (which regulate the other 40% of the drainage basin) was undertaken by the Ottawa River Regulation Planning Board following the 2017 flood. For example, results showed that under the 2017 flood at Lac Deschenes, water levels would have been approximately one metre higher had there been no dams or reservoirs within the Ottawa River drainage basin.

6.2.2.2 Existing development in the floodplain and floodway

Many areas affected by flooding in 2019 (and 2017) were legacy development or development that predates Ontario’s floodplain planning policies. Some of the more significantly affected areas in the vicinity of Westmeath, Rhoddy’s Bay, Braeside and Constance Bay, among other areas, are generally situated within the floodplain of the Ottawa River under the 1% flood (pursuant to mapping prepared under the Canada-Ontario Flood Damage Reduction Program during the 1980s and early 1990s) and updated mapping completed by the municipalities and or a conservation authority (where available). Many of these areas are also mapped to be in the floodway, where flood depths exceed one metre and/or flow velocities above one metre per second can create significant hazards for developments.

Many of the dwellings that dot the landscape along the Ottawa River in the above noted villages and hamlets were once modest camps that were transitioned into seasonal cottages, and now many exist as permanent year-round residences. Significant investments have been made to these residences throughout the years; however, for the most part they are not flood proofed to the flood standard (1% flood).

While clearly unfortunate, it was not a surprise to see in person that many of the areas affected by flooding were very close to the river and there was a relatively small difference in elevation between the foundations (main floors) of many residences and the elevation of the river under normal water conditions in early September 2019. A tour of some areas provided evidence that some property owners were already in the process of raising their residences to a higher level and possibly some included moving their structures further from the river’s edge.

Recommendations in other sections of this report can also apply to this section on the Ottawa River.

6.2.3 Riverine, Lake

6.2.3.1 Maintaining wetlands and pervious surfaces

Estimates suggest that 68% of the wetlands originally present in southern Ontario were lost by the early 1980s (State of Ontario’s Biodiversity Report, 2010). An additional 4% has been lost since this time (State of Ontario’s Biodiversity Report, 2015). However, a recent assessment has shown that the rate of loss appears to be decreasing (State of Ontario’s Biodiversity Report, 2015). While land conversion is the primary cause of wetland loss in southern Ontario, pollution, invasive species, alteration to natural water levels, and climate change also pose serious threats.

Ontario’s Great Lakes coastal wetlands have experienced similar historical losses and degradation over the past 200 years. It is estimated that by 1984, 35% of wetlands along the Canadian shores of Lakes Erie, Ontario and St. Clair had been lost, with the greatest losses occurring between Toronto and the Niagara River. Loss and degradation continue today, largely resulting from shoreline alteration, water level control, nutrient and sediment loading, invasive species, dredging and development. Upstream land use practices also have an impact, particularly through runoff from urban and industrial development, agricultural lands and impervious surfaces. Despite some localized loss and degradation, wetlands in the northern part of Ontario (Hudson Bay Lowlands and Ontario Shield ecozones) remain largely intact.

Wetlands act as natural stormwater management ponds, slowing the speed of flood waters and storing large quantities of surface water. Maintaining, restoring or constructing wetlands can be a cost-effective way of reducing flood risks and associated costs. A study commissioned in part by the MNRF in 2017 found that maintaining wetlands can reduce flood damages and costs by 29% in rural areas and by 38% in urban areas. The Insurance Bureau of Canada (IBC) has also recently issued a report documenting the ability of wetlands to reduce flood damages, and promoting wetlands and other natural infrastructure as “a viable alternative to grey infrastructure option[s] for flood mitigation” and “a cost-effective way to mitigate material financial losses that would otherwise result from flooding.” (Combatting Canada’s Rising Flood Costs, September, 2018: Combatting Canada’s Rising Flood Costs: Natural infrastructure is an underutilized option PDF).

6.2.3.2 North Bay/Mattawa area

As discussed in Section 4.2, there are two distinct watersheds in the MNRF North Bay District—the Sturgeon-Nipissing-French and the Upper Ottawa River. In the engagement session, it was quite apparent from representatives from both areas, that each area had their own distinct experience through the spring freshet.

In general, there was much more collaboration between all interested parties in the Sturgeon-Nipissing-French area, and although difficult decisions needed to be made regarding what area would see more water and when, at the end of the day everyone had the opportunity for input, everyone was well informed of the situations in the entire watershed, and everyone signed off on the final decisions. This resulted in a successful outcome in the sense that they did the best they possibly could in a bad situation.

Also as discussed in Section 4.2, the City of North Bay undertook a contingency plan to protect the wastewater treatment plant. However, if Lake Nipissing had reached a critical elevation, the wastewater treatment capabilities would have been severely limited, and there was no ability to bypass the plant and temporarily discharge (during the extreme flood event scenario) directly to the lake, which meant that a huge area of the City of North Bay would experience sewer backup and a few thousand residents would have needed to be evacuated.

Based on their experience with the 2019 flood, but also events in previous years, the North Bay/Mattawa session participants suggested that the Lake Nipissing operational guidelines be reviewed.

6.2.3.3 The Muskoka/Magnetawan Rivers/Lakes

The Muskoka and Magnetawan Rivers are both complex systems with many factors impacting water levels, including physical geography, rainfall, snowpack and temperatures. They are both cascading systems and both originate on the western slopes of Algonquin Provincial Park. Dam operations are guided by the Muskoka Water Management Plan and Dam Operations Manual, and the Magnetawan Dam Operations Manual. There are no conservation authorities in either watershed, meaning the MNRF Parry Sound Work Centre and other dam owners are responsible for water management operations.

The public and residents have high expectations that the dam operations will maintain relatively static water levels and prevent floods. However, the dams are not flood control structures and have very limited capacity to store or hold back flood waters, as they have little to no lake or reservoir capacity. As a result, in a large volume, rapid runoff flood, the dams have limited capacity to reduce peak water levels. The greater the flood event, the less ability the MNRF/dam operators have to mitigate the impacts.

The dams were originally constructed to facilitate the transport of logs to sawmills and aid in commercial navigation. Over time, the operational emphasis has evolved from commerce and transportation to the provision of a balance of social/recreational, environmental and economic interests. To meet these interests, and to the extent possible, the MNRF operates the dams to maintain water levels within ranges identified in the established dam operating plan. These plans were formalized in the Water Management Plans, and are based on normal conditions. The general public and stakeholders have been critical of how the dams are operated, not only with high water conditions but low water conditions as well.

While there is growing development along the shorelines within the Magnetawan River watershed, there is significant development along the shorelines within the Muskoka River watershed. Accordingly, there is keen interest from local stakeholders and municipalities in the Muskoka River Water Management Plan.

In August 2018, the Province announced a $5 million Muskoka Watershed Conservation and Management Initiative to better identify risks and issues facing the Muskoka Region. The government also committed to matching tax-deductible donations up to an additional $5 million. By protecting this particular watershed and working with the local community, this initiative will help the Province develop a comprehensive approach to watershed management, which can inform current actions and future development.

On August 7, 2019, the Minister of Environment, Conservation and Parks announced the appointment of nine members to the Muskoka Watershed Advisory Group. The Advisory Group is tasked with providing advice and recommendations to the Minister on measures to protect the health of the watershed and support the economic growth in the region. An effective watershed management approach is important to the residents of the Muskoka, especially as the watershed faces pressures and stresses from increased development, increasing contaminants and nutrient loads, and intense and frequent flooding caused by extreme weather events.

6.2.3.4 County of Haliburton/Trent Severn Waterway

Haliburton County is a large geographic area with multiple municipalities and infrastructure jurisdictions, including the Trent Severn Waterway (Parks Canada), the Province of Ontario (Ministry of Transportation, MNRF), the Crowe Valley Conservation Authority, the County of Haliburton, and the four local municipalities of Algonquin Highlands (Dysart et al, Highlands East and Minden Hills). This situation is somewhat unique with the number of watersheds and federal dams.

Six watersheds are represented in Haliburton County, but the majority of the County is located outside the jurisdiction of a conservation authority. The municipality of Highlands East is located within the jurisdiction of the Crowe Valley Conservation Authority.

Water originating in Haliburton County supplies water to the Trent Severn Canal but also for 47 downstream drinking water systems for communities such as Bobcaygeon Fenelon Falls, Lindsay, Peterborough and Trenton. There are 28 Trent-Severn Waterway (TSW) controlled dams above the village of Minden and the agency leads its own processes associated with dam operations and water level management. During high water conditions and flooding, TSW convenes conference calls to advise the MNRF and conservation authorities of current and predicted short-term dam operations strategies. Within the area, the MNRF operates four dams with specific operation plans, but these are operated in conjunction and collaboration with TSW operations.

As a result of the Haliburton County experiences with flooding over the last few years, there are now regular “spring freshet” conference calls held by staff of the MNRF and Trent-Severn Waterway, along with elected officials and administrative officials from emergency services, public works, etc. This collaboration has been reported as a success for helping disseminate information to the front-line people working to combat the flooding impacts, including municipal staff, conservation authority staff and the public.

A collaborative agency called the Upper Trent Water Management Partnership (UTWMP) was formed among the municipalities of Algonquin Highlands, Dysart et al, Minden Hills, Highlands East, North Kawartha, Trent Lakes, and the Coalition for Equitable Water Flow. The mission of UTWMP is to speak as a single voice for all stakeholders on water management issues affecting the reservoir and flow-through lakes, and to provide local water management leadership.

The County has partnered with Trent Severn Waterway, Kawartha Region Conservation Authority, Ganaraska Region Conservation Authority, and the Upper Trent Water Management Partnership to form a steering committee to oversee the completion of lidar, hydrology and mapping.

The County was successful in receiving National Disaster Mitigation Program (NDMP) funding for airborne lidar survey data for the Burnt and Gull River Watersheds; however, additional funding to complete data analysis, hydrologic and hydraulic models and floodplain maps was denied as this work wouldn’t be complete before the program end date of March 2020. It is the intent of the County to apply for funding to complete this work if the program is extended.

6.2.3.5 Southwestern Ontario

As mentioned in Section 6.2.1 above, the shorelines of the Great Lakes and the St. Lawrence River have and continue to be significantly impacted by very high lake levels and erosion. The focus in that section is mainly on mitigation methods using typical infrastructure solutions and associated funding mechanisms. However, municipalities are looking for bigger picture solutions as they acknowledge that these are not affordable.

The municipalities and conservation authorities in southwestern Ontario held a Roundtable Information meeting on September 19, 2019, in London, Ontario. The meeting was attended (in person or by phone) by municipalities (Chatham-Kent, Leamington, Windsor, Essex, Kingsville. Tecumseh, Pelee Island, Amherstburg, LaSalle, Elgin), conservation authorities (Lower Thames, Essex Region, St. Clair Region, and Kettle Creek), provincial departments, federal departments, the Great Lakes St. Lawrence Collaborative and Zuzek, Inc. (consultant). A summary from the meeting resulted in the following statements:

High water levels and floods of 2019 must be viewed as a warning/wake up call. Change is needed – maintaining the status quo in policy and practice cannot continue. Municipalities cannot afford the infrastructure problems our current development approach creates, let alone future costs associated with climate change. There is an opportunity for the Provincial Government to work with Conservation Authorities and the Federal Government to lead a revolution on shoreline management. The shorelines, the ecosystems they support, the biodiversity, and ecosystem goods and services are simply too valuable to treat them like undeveloped subdivisions.

The Roundtable also resulted in a number of recommendations, some of which have been captured in other areas of this report, but I am highlighting one here:

6.2.3.6 Flood protection land forms

Some municipalities are considering the use of “flood protection landforms” to open hazardous areas up to new or intensified development. This is the approach currently being taken by the City of Toronto to open lands east of the Don River to development—a $1.25 billion development project supported by all three levels of government. The approach taken was permitted as a “one-off” and represents a considerable deviation from the MNRF’s natural hazard technical guides and the Provincial Policy Statement, as documented in a protocol signed by the City of Toronto, the Ministry of Municipal Affairs and Housing and the MNRF.

Existing ministry policies do not support using flood protection landforms to open new areas for development. Specifically, the MNRF’s Technical Guide – River and Stream Systems: Flooding Hazard Limit (2002) does not support the use of flood protection landforms (e.g. berms, dikes, flood walls, and other such structural methods) as permanent flood control structures or to facilitate development in hazardous areas. Flood protection landforms can result in increases in upstream flood levels, increases in downstream flows and increases in downstream velocities. The construction of flood protection landforms can create new or aggravate existing hazards and would therefore not be consistent with Section 3.0 of the Provincial Policy Statement. Flood protection landforms and other structural measures can be overtopped making flooding worse, and they often inspire a false sense of security thereby encouraging further development in hazardous areas. Structural measures are associated with high costs, during construction and in perpetuity afterwards. Inspection, certification, maintenance, operation and repair are ongoing, often unaffordable for local communities. New construction adds to the existing municipal infrastructure deficit.

Increasing development pressures and high-profile projects, such as the Lower Don Development project, is forcing the Ministry to defend its current approach to hazard management and how best to balance the use of prevention versus protection to manage flooding and other natural hazards.

While prevention-based approaches have been repeatedly shown to be more effective in reducing the impacts of flooding and other natural hazards, flood protection landforms do have a role to play in certain situations, and the approach taken to develop the lower Don area is an excellent example. The value of the proposed real estate development has justified the great expense of ensuring that all the issues and concerns of a permanent landform and the intense development behind it in the floodplain were appropriately dealt with, including being adaptive to climate change by building higher than the design flood. While flooding will always be potentially a risk, the risk has been reduced.

There is a strong possibility that the protocol for the lower Don area and the City of Toronto’s flood protection infrastructure projects will set a precedent for other areas in the province. To ensure that developers, municipalities and conservation authorities adhere to strict requirements and conditions to permit such a development in the hazard lands, this new category, the requirements and conditions should all be enshrined in legislation (regulation).

6.2.4 Urban/flash flooding (pluvial flooding)

There are many examples of pluvial flooding in urban areas that have resulted in major disruptions of service and significant impacts on property, businesses, homes and people.

This type of flooding occurs during heavy rainfall events independent of an overflowing river or stream. The ground cannot absorb the water as quickly as it falls, especially in urban areas with a lot of hard surfaces like pavement. Drainage systems (such as human-made and natural channels, roadways, storm and combined sewers) can quickly become overwhelmed, causing water to pond in parking lots, flow into streets and nearby homes and structures, or back up into basements.

Floodplain mapping is not really practical, as overland and sewer flooding can occur anywhere in the urban area. This is partly because of the spatial variability of the “eye” of the rainstorm, but also due to the local topography, unique development (legacy and new), and the type of drainage systems in each neighborhood.

Challenges with pluvial flooding include increased imperviousness over time; inadequate surface drainage plan; private property being lower than the streets (either the grade at the house or reverse slope driveways); reliance on storms sewers that are designed for smaller rainstorm events; sedimentation of channels and sewers; blocked culverts or curb inlets; inflow and infiltration; sewer and channel design capacity limitations in older neighborhoods; deteriorated sewers; reduced sewer or wastewater treatment plant capacity due to high water levels in the receiving stream (and lack of proper gates); and failures of pumping stations or wastewater treatment plants.

There is a substantial difference between managing floods in newer greenfield development and historically developed areas, and some of the latter areas are subject to intensification or infill development pressures. In the greenfield areas, non-structural and structural mitigation methods, including green infrastructure, can be incorporated as part of the development. In older areas, municipalities are faced with significant costs to rehabilitate, enhance or build new flood protection infrastructure for drainage systems. There are also challenges for municipalities when a newer greenfield development must utilize an existing drainage system downstream through an existing development.

Stormwater management in Canada has been evolving over the years, and system components are not only dealing with the quantity of stormwater but the quality as well (pollution reduction and erosion protection). Installation of regional stormwater management (retention or detention) ponds or linear naturalized channels has achieved both objectives, although quality improvement to a lesser degree.

6.2.4.1 Use of regional flood control facilities

Development practices are also changing and exposing potential regulatory gaps.

Stormwater management facilities are regulated in Ontario by the Ministry of Environment, Conservation and Parks (MECP). Under the Environmental Protection Act, an approval is issued for the purpose of stormwater management works to provide for an enhanced level of water quality control, erosion protection, and attenuation of post-development storm flows up to and including the 100-year storm event. Regional Flood Control Facilities (RFCFs) are increasingly being constructed in some areas to help mitigate flooding in urban areas. RFCFs are stormwater management ponds that are designed to control flooding associated with much larger regional storm events (e.g. Hurricane Hazel for GTA communities) exceeding the 1% storm and well above and beyond the capacity of traditional stormwater management (SWM) ponds.

While traditional SWM ponds are considered to pose a relatively low risk to downstream landowners, the risks associated with the increased use of RFCFs are largely unknown, and they are not regulated by the MNRF. RFCFs retain significant volumes of stormwater runoff and could cause significant flood damages if they were to fail, raising concerns that the use of these facilities creates new, or aggravates existing, flood hazards, particularly when built immediately upstream of residential areas.

Due to their design, RFCFs function more like dams than traditional SWM ponds (i.e. they provide flood control function). Unlike dams, there are no provincially approved structural design standards for RFCFs.

The construction of these structures can be viewed as creating new hazards and thereby conflicting with provincial policy direction which states that “planning for stormwater management shall not increase the risks to human health and safety and property damage.” In addition, the MNRF’s Technical Guide specifies that stormwater management facilities are not to be used to provide any reduction in flood flows, and accounting for their storage in flood hazard mapping artificially reduces the extent of regulatory flood lines and is non-compliant with the MNRF’s Technical Guide.

While many of these RFCFs are being constructed to support greenfield development, they are also being used in existing developments, often in highly urbanized landscapes. In some instances, RFCFs are being constructed for the purpose reducing flood flows and freeing up flood hazard lands for intensified development by artificially reducing the size of floodplains (i.e. redrawing flood lines) downstream of RFCFs, through amendments to existing flood hazard maps (i.e. floodplain maps) used to guide land use planning decisions. The MNRF views this as putting people and property in harm’s way and contrary to the MNRF’s Technical Guide and the Provincial Policy Statement (PPS).

While the construction of these structures has been limited, they are becoming more common (more than 50 of these structures within 46 Ontario communities) as determined by a study commissioned by the MNRF. Apparently, many of them are being built larger than their original design specifications with the aim of holding back even larger volumes of water. A prevalent perception observed when collecting data for the study was that RFCFs protect downstream landowners and these larger ponds contribute to safety rather than increased risk. The study documented that one-third of the RFCFs examined represented an increased risk to downstream communities in the event of a failure. Furthermore, the risks and consequences of failure of these facilities is not typically a design consideration. Important factors determining risk of RFCFs included the size of the pond and the embankment height, with the most influential factor in determining the risks of these facilities being the pond configuration and landscape setting (e.g. elevation of pond relative to downstream receptors) specifically in relation to populated areas.

The above issue raises the point that there is a lack of clarity around the MNRF’s role in urban flooding. To date, the MNRF’s focus has been on flooding from waterbodies (rivers, streams and lakes), suggesting that “urban flooding”—owing to its linkage with stormwater management and development infrastructure—should be borne by ministries with mandates related to those components (i.e. MECP, MOI, MMAH, etc.).

6.2.4.2 Municipal by-laws – pre-development rates of runoff

One of the methods to reduce the impact of intense rainstorm events on drainage systems is to limit new development to “pre-development” rates of stormwater runoff. All the new hard surface means that rain or snowmelt water will runoff at a much greater rate than previous agricultural use or natural habitat. By limiting the runoff to the pre-development rate, the drainage system downstream will see no more water after development than before development.

For a new subdivision, restricting to pre-development rates may be achieved with a combination of conventional stormwater management techniques (i.e. dry or wet pond) and other low impact development practices. For multi-residential or commercial situations, such as a high-rise tower or shopping mall, detention of the stormwater can be achieved by on-site storage (roof-top, underground tank, open retention basin or parking lot storage) and/or by using permeable surfaces.

6.2.4.3 Municipal by-laws – flood protection measures for private property

Flood protection of private property is not just a municipal responsibility but also a property owner responsibility. We put locks on our doors because we can’t expect that the police service will protect our houses from intruders. Neither can we expect that the drainage system will protect us from all storm events. Accordingly, residents and other property owners have a responsibility to protect from pluvial flooding by the installation of backwater valves, sump pits and pumps, sealing doors and windows, disconnecting downspouts from the sanitary sewer, and building up the earth around the foundation and window wells, etc.

6.2.4.4 Intact Centre on Climate Adaptation

The Intact Centre on Climate Adaptation (Intact Centre) is an applied research centre with a national focus located within the Faculty of Environment at the University of Waterloo. The Intact Centre was founded with a gift from the Intact Financial Corporation. The Intact Centre works with homeowners, communities, governments and businesses to identify the impacts of extreme weather and climate change, and to develop the practical tools needed to help communities adapt to these changes and minimize impacts.

A particular focus of the Intact Centre over the last three years has been the development and testing of a variety of tools that have advanced flood risk reduction in Canada. From 2016 to 2018, the Intact Centre’s Home Flood Protection Program developed a home flood risk assessment tool and assessor training program, and delivered over 500 flood risk assessments to residents in Ontario and Saskatchewan. Learnings from the program delivery contributed to the publication of a national guideline for basement flooding protection (CSA Z800-18) in 2018. Additionally, in April 2019, a report titled: “Water on the Rise: Protecting Canadian Homes from the Growing Threat of Flooding” was released by the Intact Centre summarizing the top flood risks associated with residential homes and the best practices for motivating action in order to reduce risk.

The Intact Centre is committed to working with municipal and provincial governments to educate residents. The Intact Centre has also published several other reports on flooding, all of which can be found on their website (Intact Centre on Climate Adaptation).

6.2.5 Funding for permanent works

Following significant events, there is always a demand for funding for more permanent works (infrastructure such as a dam, bridge, shoreline protection work, erosion control infrastructure, etc. that will be designed, used and remain in place over the long term) by local officials and the general public. Given the financial pressures that governments are facing currently, a potential immediate source would be existing programs, such as the Ontario Community Infrastructure Fund (OCIF) program, the Federal Investing in Canada Infrastructure Program (ICIP), the Ontario Water Erosion Control Infrastructure (WECI) program, and the Ontario Financing Authority green bond program.

Recommendation #31

That the Ministry of Infrastructure work specifically with the MNRF on the design of future intakes of the Green stream of the Investing in Canada Infrastructure Program to ensure flood-related projects are eligible.

The Province’s Water Erosion Control Infrastructure (WECI) program is an effective provincial-municipal cost-share program for maintenance of water control infrastructure that reduces flooding, mitigates flood damages and disruption to the economy. Currently, the program is funded through the MNRF capital program budget on a fiscal year basis, and it is suggested that a multi-year budget be established for some larger maintenance projects that may span many years to provide flexibility for future potential fluctuations in funding requests.

The Ontario Financing Authority runs a green bond program that includes five categories— Clean Transportation; Energy Efficiency and Conservation; Clean Energy and Technology; Forestry, Agriculture and Land Management; and Climate Adaption and Resilience. Under the last category, the following projects will generally be considered eligible—flood protection and stormwater management; extreme weather resistant infrastructure and municipal infrastructure for clean and/or drinking water; wastewater treatment; sustainable urban drainage systems; and other forms of flooding mitigation. (See more details at Province of Ontario Green Bonds.)

6.3 Preparedness

6.3.1 Monitoring and data management

6.3.1.1 The hydrometric agreement

There is always an argument for better hydrometric data; however, the fiscal realities likely mean that there will be no significant increase in funding for the hydrometric network.

6.3.1.2 Climate (weather) monitoring

While there is heavy reliance on the hydrometric network, it is recognized that weather “inputs” are critical to understanding and predicting events. Citizen science is an effective tool in gaining additional precipitation information (such as through the Community Collaborative Rain, Hail and Snow Network or CoCoRAHS), typically at a lower cost and at low risk.

6.3.1.3 Data management

Beyond the MNRF, there are a number of other organizations or agencies that collect or have data that would be beneficial toward enhancing flood forecasting.

6.3.1.4 Satellite Remote Sensing

Although currently operationally working in an emergency management environment, the MNRF’s Remote Sensing Science Group is not an emergency management tasked group. The recent launch of the three RADARSAT Constellation Mission satellites highlights a significant opportunity to improve flood and ice monitoring, but will require additional provincial resources to coordinate, process, interpret and disseminate information in near real time. The portfolio of satellite imagery products and services the Remote Sensing Science Group supports to aid the emergency management products and services is growing year upon year.

Currently the Remote Sensing group supports emergency management flood monitoring only during the spring flooding season.

Additional remote sensing satellite monitoring opportunities (e.g. snow extent and snow water equivalent) remain unexplored/unexploited provincially due to resourcing.

6.3.2 Flood forecasting and warning

Flood forecasting and warning plays an important role in achieving the provincial objective of reducing risk to life and reducing property damages. It is particularly important to residents located in a floodplain where permanent mitigation works do not exist. The flood forecasting and warning system is very reliant on the provincial hydrometric network (stream gauges), from which the data is used to make decisions of when to issue flood warnings, operate infrastructure (such as dams), and provide real-time status reports on flooding on different reaches of a river. The stream gauge networks also provide an important history of flooding.

Flood forecasting and warning requires integration with municipal emergency response. However, there is inconsistent resourcing for flood forecasting and warning across the province. Conservation authorities are not present in all areas of the province. In areas without conservation authorities, flood forecasting and warning is the responsibility of the local MNRF work centre. Not all conservation authorities and districts are consistently equipped or resourced in order to provide flood forecasting and warning services.

Updated floodplain mapping provides the opportunity to produce new products to aid in flood forecasting and warning, and emergency response. Floodplain maps can provide a fundamental base for designing and developing response plans for a range of floods. Updated hydrology modelling for floodplain mapping can be leveraged to create new up-to-date flood forecasting models. Flood forecasting and warning systems can be designed to reflect the local watershed characteristics and be risk-based. More sophisticated complex warning systems can be implemented where the risk is highest, and less complex systems where there is lower risk and more lead time.

An ideal system would include developing real-time flood forecasting models that merge hourly forecasts with radar and real-time gauge data, the use of machine learning algorithms for data assimilation, and ensemble forecasting for areas where flood vulnerability has been identified. Flood messages should target people within affected geographic areas and consider the use of Common Alerting Protocol – Canadian Profile format. This would increase coordination, interoperability and efficiency between agencies. Over the long term, this could integrate with the Canadian Alert Ready platform and mobile telephone public safety apps.

6.4 Emergency response

6.4.1 Emergency operations

As first discussed above in Section 6.1.4.1, Chapter 3 of the 2017 Auditor General’s report raised concerns regarding the current governance structure for emergency management in Ontario.

The Office of the Fire Marshall and Emergency Management (OFMEM) within the Ministry of the Solicitor General, is taking action to address the Auditor General recommendations and other reviews. The following are two additional initiatives planned or currently underway that will improve emergency operations around floods:

1. AG recommendation to enhance Emergency Management program capacity – Emergency Management Ontario (EMO) to enhance readiness for large-scale emergencies; adopt and meet international/national best practices; mandate use of the Incident Management System; and enter into mutual assistance agreements with neighbouring jurisdictions.
2. AG recommendation to increase support to municipalities and emergency management partners – EMO to enable the Provincial Emergency Operations Centre (PEOC) to more quickly deploy resources to supplement local capacity; implement emergency management software to support provincial-municipal information and resource sharing; enhance capacity to deploy humanitarian aid; and implement emergency management supply chain/ program.

During my engagement sessions, I did receive a lot of feedback from municipalities about improvements they would like to see implemented by EMO. In short, once they declare an emergency and request assistance from the Province, they want the Province to be more involved in coordinating a response and ensuring that the municipality has access to the resources and expertise it needs. Municipalities also request that the Province condense their requirements for reporting during an event, as it distracts from the actions needed to fight a flood, including reducing the amount of paperwork and daily reporting during a flood to multiple people at EMO.

Another complaint of municipalities was how the Canadian Forces (CF) were deployed. Municipalities do not understand the process as to how the Province engages the CF, and more importantly what activities the CF are approved to implement. In one municipality, the CF was distributing potable water when the municipality needed their help building sandbag dikes.

However, the focus should be on how the municipalities ask for assistance with specific needs rather than how to ask for a specific group’s assistance. The Province should determine best how to support the request and whether it can be done without federal support.

6.4.2 Communications

A better job could be done with communication and information dissemination before, during and after a flood, but most critically during a flood. Municipalities and residents demand good information so they can make informed decisions. Timely information is also key, such as forecast peak water levels, to allow appropriate preparations to be made to protect people and property.

Many smaller municipalities and CAs don’t have the resources to hire technical and communications specialists (either full-time or part-time) to answer public inquiries during a flood event. They get questions such as: “Who do I approach to ask for assistance with sandbagging?” or “What is the forecast peak water level at X location?” or “How do I build a sandbag dike?”

6.5 Recovery

6.5.1 Compensation for damages and rebuilding

6.5.1.1 Compensation programs

In many of the municipal engagement sessions, many smaller municipalities advised me that achieving the damage threshold of 3% of their total own purpose taxation (revenue) to be eligible for financial assistance is difficult. Further, if a municipality did not meet the 3% threshold, they were also excluded from the “build back better” pilot.

As discussed in Section 5.3.2, partly in response to flooding in spring 2019, the Ministry of Municipal Affairs and Housing created a $1 million pilot project designed to help municipalities repair flood damaged roads, bridges and other infrastructure to a higher standard so they can better withstand extreme weather. As part of a $1 million pilot project, the province will provide municipalities that qualify for MDRA funding with up to 15% above the estimated cost of rebuilding damaged public infrastructure to make it more resilient to extreme weather. This is a very important program, as the investment to “build back better” will reduce flood damage in future events and therefore provides a return on the investment.

There is no “build back better” component under the Disaster Recovery Assistance for Ontarians (DRAO) program. Under that program, assistance is based on the cost of returning a property to a functional level, which includes meeting building code requirements. Eligible costs may include floodproofing as required to obtain a building permit. Under the applicable provisions of the Building Code Act, the municipality must not issue a building permit in a regulated flood zone unless the conservation authority (or the MNRF in areas with no CA) has issued the required permit, which would include floodproofing requirements. DRAO does not cover floodproofing that is not required to obtain a building permit.

However, in municipal engagement sessions I heard several stories of individuals who repaired their houses after the 2017 flood only to be flooded again in the 2019 flood, and who claimed that had they been able to “build back better” after the 2017 flood that their damages in 2019 would have been eliminated or reduced. It is not clear if the damages were caused by flooding that exceeded the design flood or designated flood protection level for the area.

At another municipal engagement session, I was advised that a home on leased land on a First Nation reserve and leased by a “non-status” person is not eligible under either the federal or provincial disaster assistance programs. The DRAO does not have any eligibility restrictions on leased land except if it is on First Nation reserve land. Indigenous Services Canada offers disaster assistance programs on First Nation reserves but only “status” residents are eligible. There are two possible ways to address this—the federal government could expand its program to include non-status individuals leasing on reserve land, or the province could expand its program to include reserve land. There would be a number of considerations that would come into play with the latter, including that provincial planning and building regulation policies do not apply on reserve land.

6.5.1.2 Relocation and buyouts

A number of individuals and groups who participated in the review were interested in a buyout program being made available to residents living in floodplains whose homes were severely damaged by the 2019 flood events.

Buyouts can be beneficial when it is anticipated that the cost of more frequent emergency response activities and disaster assistance costs will outweigh the cost of providing those homeowners with fair market value for their homes. Also, buyouts are sometimes necessary when it is not technically feasible to meet floodproofing criteria, although this situation is not common. These programs can be highly contentious depending on how market value is determined and whether these programs are optional or forced onto residents in high-risk areas.

6.5.2 Insurance

Section 5.1.5 discussed that financial assistance for most flooding events in Ontario is largely provided by the Province or costs are borne by the property owner.

The flooding costs borne by property owners in Ontario are due to the limited insurability of flood risk areas. However, insured catastrophic losses in Canada (mostly related to water damage) are significantly increasing. Accordingly, the Insurance Bureau of Canada has been conducting research and producing reports on this issue.

Overland flood insurance is available from a number of insurance companies active in the Ontario marketplace, however it is not available for high-risk properties, or if it is available, it is prohibitively expensive or available with a limited cap, and as a consequence virtually all high-risk zones remain uninsured or underinsured. Overland flood insurance premiums for high risk flood zones can average over $10,000, while the average premium for all other perils combined in these areas is in the order of $1,000.^{footnote 1[1]}

The limited insurability of flood risk places the burden for post disaster reconstruction and recovery on homeowners and taxpayers who are funding disaster relief spending from federal and provincial governments.^{footnote 2[2]}

Currently, for every dollar of insured losses borne by insurers in Canada, three to four dollars are borne by governments and home and business owners.”^{footnote 3[3]} (PDF)

Although the market is now starting to change, residential coverage for overland flooding has historically not been available in Canada on the basis that it lacks economic viability. However, this is starting to change.

As of spring 2019, 16 insurers offer overland flood products available to approximately 77% of Canadian property owners, with approximately 34% of Canadians having at least some insurance for overland flood risk.^{footnote 1[1]}

Residential insurance for overland (pluvial and fluvial) flooding started to become available in Canada in 2015. The emergence of private flood insurance represents a significant redistribution of the financial risks associated with flooding. Despite significant costs to governments (who are typically compelled to provide disaster relief to flooded areas), individual private home and business owners also bear significant costs as disaster relief in Ontario is limited and only covers costs for the restoring “essential property” to a basic standard, up to a limit. Insurance will help to pool individual costs across broader society (who in the future will manage their own financial risks through flood insurance). Further on the concept of pooling costs, the Insurance Bureau of Canada recently released a report in June 2019 titled: “Options for Managing Flood Costs of Canada’s Highest Risk Residential Properties” (Options for Managing Flood Costs of Canada’s Highest Risk Residential Properties A Report of the National Working Group on Financial Risk of Flooding PDF) with input from a members of a private-public sector working group on financial management of flood risk. The report focuses on ways to better manage costs of overland flooding for high risk properties across Canada and advances three potential options:

1. Pure Market Solution: risk borne by homeowners;
2. Evolved Status Quo: risk borne by blend of homeowners and governments; and
3. Create a High-Risk Flood Insurance Pool.

Option 3, the creation of a high-risk insurance pool for properties otherwise not able to access affordable flood insurance to cover losses and which would include capping or subsidizing premiums, was advanced as a preferred option. Work is continuing on this option; however, it is postulated that this “pool” could be capitalized through a fund contributed by governments, and then be supported by insurance premiums paid into the pool and levies assessed on all homeowners or municipal rate payers.

There may be opportunities for the Province and the federal government to work with the insurance market to make flood insurance more available to more Ontarians (and Canadians) through increased investments in the identification and management of flood risks. Effective hazard maps are a pre-condition for establishing an effective flood insurance program. The risks associated with offering flood insurance cannot be adequately assessed without accurate, up-to-date mapping.

6.5.3 Waste materials and landfills

Smaller municipalities raised the issue of how the significant waste materials from a flood can negatively impact the capacity of a local landfill. Used dirty sandbags, flooded contents from a house or cottage (such as furniture, appliances, etc.) and if the house or cottage is destroyed, all the material from the structure’s demolition, can quickly use up landfill capacity. These municipalities claim that even if the waste can be accepted at an alternative landfill, it would most likely have to be hauled further away and the costs of hauling were a concern. And finally, municipalities expressed concern over the time period for the permitting process for establishing a new landfill (or expanding an existing landfill), which may exceed the time remaining before an existing landfill has reached capacity.

Disposal costs are in fact eligible costs under the Municipal Disaster Recovery Assistance (MDRA) program, but there has to be an actual cost incurred by the municipality. For example, if the municipality uses a private landfill and pays the tipping fees, those would be eligible. If the municipality does more runs with their garbage trucks, the overtime costs and additional fuel costs, etc., would be eligible. However, the MDRA is oriented to actual paid expenditures, meaning if a municipality has their own small landfill, there is nothing in the MDRA program to compensate them for the “room” or capacity of the landfill that is used up from flood-related waste materials and reduces the future lifespan of the landfill site, because there is no “out-of-pocket” cost incurred.