The sudden replacement of…

The sudden replacement of Ontario Regulation 97/04 which governs the content of conservation authority regulations under the current Section 28(1) of the Act PLUS all existing conservation authority regulations (O.Reg. 42/06, O.Reg. 146-148, O.Reg. 150-153, O.Reg. 155-172, O.Reg. 174-182, and O.Reg. 319/09) with one new piece of legislation to define the NARROWEST protection for “property’ is most unwise. The previous regulations took years of study and amendments based upon experience and changes within the landscape. One new simplified regulation obliterates previous accumulated knowledge because the current Ontario government prefers to overlook the accumulative collaborative knowledge implicit in those regulations.

Now, Conservation Authorities are supposed to act as a 'promoter' of development with new duties to:
• Exempt low-risk development activities from requiring a permit including certain alterations and repairs to existing municipal drains subject to the Drainage Act provided they are undertaken in accordance with the Drainage Act and Conservation Authorities Act Protocol;
• Allow conservation authorities to further exempt low-risk development activities from requiring a permit provided in accordance with conservation authority policies;
• Require conservation authorities to develop, consult on, make publicly available and periodically review internal policies that guide permitting decisions;
• Require conservation authorities to notify the public of changes to mapped regulated areas such as floodplains or wetland boundaries; and
• Require conservation authorities to establish, monitor and report on service delivery standards including requirements and timelines for determination of complete applications and timelines for permit decisions.

How many times does the word ‘permit’ appear in that list? Four out of five times. The natural functions and values of forests and wetlands, as they relate to flood prevention, have been lost.

All I can say is ‘Make haste in waste; repent at leisure’. The Conservative government seems to be constructing a flood-prone Fool’s Paradise with these changes.

Ontario’s newly-minted “local flexibility” seems to elevate facilitation of “’low-risk” development activities in areas prone to potential flooding without actually defining what “low-risk” means. Let’s not be foolish here. Currently, Ontario’s conservation authorities tend to define a 100-year storm in terms of the aftermath of Hurricane Hazel in 1954. Yet, we can see that areas of eastern Ontario (Ottawa and Gatineau) and parts of Quebec have experienced 100-years storms at least twice within the last three years.

In 2017, Houston, Texas was doused with what was called a 500-year storm, causing widespread damage as Hurricane Harvey dropped SIX TIMES the rainfall of Hurricane Hazel within a shorter period. It appears Houston’s problems were compounded by its political belief in unlimited growth.

Ontario ought to read and learn from the following report: https://www.nytimes.com/2017/08/30/us/houston-flooding-growth-regulatio… The article explains how a foolhardy political focus on growth and development in the absence of reliable regulations made the flooding situation even worse.

Hurricane Hazel may no longer be the appropriate ‘metric’ for measuring a 100-year storm, an event that is occurring more frequently now. Conservation Authorities are the repositories for information about flooding and how it can be controlled. The provincial government wants to over-ride that knowledge.

Over-development and associated soil compaction, pavement and roadways are already a primary cause of flooding now. Ontario MUST pay attention to recent research about the causes of flooding in southern Ontario, specifically in the Toronto area, published in the Journal of Cleaner Production, Vo. 174 (2017, published 2018) p. 1929 to 1641, entitled ‘Assessing Urban Areas Vulnerability to Pluvial Flooding using GIS applications and Bayesian Belief Network Model’ available at https://www.sciencedirect.com/science/article/pii/S0959652617327245?via…

Engineers from the University of British Columbia, and the University of Windsor, collaborated on this research. Their study concluded a PRIMARY cause for flooding relates to on-going dense ever-widening contiguous developments, based upon paved and impermeable surfaces. Rainfall has nowhere to go when it races off paved surfaces. Efforts to channel rainfall by building more culverts to carry the water away do not solve the problem of poorly-designed communities. That simply translates into even more flooding, particularly downstream! Once the lowest level is reached, water collects in rising and widening pools.

Time for a quick jog down memory lane: in 2013, Toronto Police used boats to rescue 1,400 passengers from a partially submerged GO train in the city when the Don Valley was deluged after rainfall raced off all those paved surfaces upstream. During the rescue, one woman noticed a frog on the train, and an unwilling water snake was also washed aboard. This rescue took six hours. I don't think we can overlook the effects of more pavement and roads as they relate to faster water flow ... and that episode was not simply the result of heavier rainfall. Time to scrutinize the effects of too much development, both upstream and downstream.

This study found that population density is the most significant factor affecting the Flood Vulnerability Index because it is associated with the greatest impact on land cover and landscape conversions. Land cover related parameters and slope are the second most significant factors. Comparing North York to Toronto, the researchers noted, “areas with relatively higher Intensity-Duration-Frequency" values in North York district have lower Reported Basement Flooding, this could be due to their higher vegetation cover and lower population density. While rainfall is a factor in pluvial flooding, it was not the primary reason behind basement flooding in Toronto during the period when the study was done – but basements were flooding, nonetheless. In other words, Toronto has far more paved surfaces, so water is forced to flow overland, resulting in heavier flooding. One has to wonder how all those vast paved surfaces 'upstream' in Vaughan, the City Above Toronto, may be contributing to flooding in areas of Toronto 'downstream' -- as water flows downhill from Vaughan into Toronto.

Together, Bill 66 and the Ontario Environment Plan already under-estimate the growing problems of expansive compacted non-porous surfaces in urban and suburban areas, which create ideal conditions for excessive flooding … even during normal rainfall. Now, the Province intends to relax to the responsibilities of the Conservation Authorities to the point of near irrelevance! The clearing and levelling of more landscape in preparation for continued paving and dense development suggests flooding is written right into development policy at the Ministry of Housing and Development. Yet, in March 2018, the Insurance Bureau of Canada (IBC) announced bluntly, “Flooding is the new fire” in Ontario.

The IBC’s statement acknowledged extensive pavement and dense developments as major contributors to flooding, juxtaposing them with all the out-of-control wildfires in Fort McMurray, and more recently in B.C. and even Ontario … placing the blame on patterns of new development that have almost eradicated natural systems in the blinkered human focus on clearing, levelling, piping and paving for more new developments. Patterns of human activities are exacerbating feedback systems linked to global climate change.

In her December 2017 report, Ontario’s Auditor General, Bonnie Lysek, had some tough words for the province regarding its general lack of preparedness for such flooding emergencies, despite their increasing frequency across the province. Despite that rebuke, Ontario seems ready to constrain Conservation Authorities so there is even LESS protection and preparedness when it comes to flood risks in Ontario.

Conservation Authorities have the EXPERIENCE and EXPERTISE to assess flooding risks, and they should not be fettered by the current political ideology that reveals a blinkered fascination with paving even more of the landscape.

After understanding the ways in which over-development contributes to flooding, the province must then consider how increasing precipitation in this part of the world, as presented by the U.N.’s International Panel on Climate Change, and as experienced in reality in this province recently, indicates that we MUST prepare for more heavy precipitation and associated flooding in the future.

Premier Ford was reported to be in the Huntsville area recently, and he attributed the flooding there to climate change. The climate IS CHANGING. I'd hate to think we have to wade through several more flooding episodes before we will say there is enough HARD evidence that the 100-year storm is going to be a more common and frequent event ... even if we pretend there is not enough evidence to say it is the 'new norm' right now, it would be so foolish not to pay attention to what is happening elsewhere in the province ... and elsewhere.

The role of Conservation Authorities should not be constrained and reduced to near insignificance because certain politicians prefer to accept input from cloying developers over that of qualified geologists, hydrogeologists, atmospheric scientists and climatologists. Politicians bleat about the need for more training in STEMs (science, technology, engineering, mathematics) while few seem to show any actual aptitude or interest in those areas. Let science do its job, and let politicians be guided by science.

Surely, politicians do not REALLY believe that towns and municipalities can be expected to metastasize and grow forever outwards (and into each other's territories) without diminishing and degrading the natural functions of the landscape upon which they depend? Such metasta-cities are unsustainable.

Go back to understanding the value of natural systems. We know natural floodplains spread water out, thereby slowing its progress. Areas of undisturbed soil, and stands of mature trees absorb about 36% of rainfall with which they have contact. The deep and massive root systems of trees and forests perform an essential function when it comes to flood control. For example, one mature eastern white pine will absorb about 100 gallons/day. A fully mature Oak may absorb twice that amount. Minimally disturbed landscapes sound like pretty good bulwarks against flooding alongside resilient well-planned communities, and they do the job for free.

Don’t forget to include the value of the ‘oxygen budget’, produced by trees and mature forests, since all life is dependent on the oxygen released from those leafy canopies. Pavement and asphalt do not contribute to better air quality, nor oxygen production. Quite the reverse, in fact.