Thank you for the…

Thank you for the opportunity to comment on the MOECC’s Approach to Climate Adaptation. The Regional Public Works Commissioners represent senior public works and environmental services managers in Ontario’s largest regions and single tier municipalities, who are collectively responsible for over 75% of public infrastructure in Ontario. Adapting to climate change, particularly in developed urban areas, represents a significant challenge to our members.

Ontario’s municipalities need support in preparing for, responding to and recovering from extreme weather events and other climate change impacts. Protection of critical infrastructure from extreme weather events, on which so many Ontarian’s depend, is a key priority. Assistance from the province towards this end is critical.

The range of areas in public works and environmental services that require adaptation is staggering, from sanitary collection systems to pumping stations and treatment facilities, from stormwater structures and embankments, to public transit, bridges and roads, from parks and urban forestry, to buildings. Adaptation in these areas in turn need to be integrated into other areas such as public health, electricity, transportation, land use planning and development, food security, and emergency services. It will also require coordination with partners outside of municipal government, including provincial ministries and agencies, private utilities, and residents and businesses in each community.

Start from the top RPWCO advocates for an approach to adaptation that starts from the very beginning of the planning process- adapting systems and plans that will ultimately manifest themselves on the ground at the project/services level. This includes adapting asset management plans and service levels, master plans, Officials Plans, emergency plans, among others.

Open-ended Provincial Adaptation Requirements Currently, provincial climate adaptation policies such as those under the Provincial Policy Statement provide very broad direction to municipalities, but fail to provide the means to meet the policies, in terms of formalized methodologies, guidelines, criteria, data , technical know-how and financing. In doing so, these provincial requirements leave much to interpretation with respect to when and how the requirement should be met, creating a patchwork of approaches across the province.

New Adaptation Organisation There are many aspects to adaptation. Integration and coordination across disciplines and sectors is essential for successful implementation. As such, it is important that the board of the new provincial adaptation organization brings together board members and staff with cross-disciplinary representation, and practical design and operational experience. This should not be exclusively a research-driven agency. It must be focused on practical implementation of adaptation measures.

We recommend that the Province consult municipalities extensively before establishing the new adaptation organization to better understand municipal adaptation capacity gaps and needs. We further recommend that proposed provincial plans, and allocation of resources by the new adaptation organization, be targeted first and foremost to address existing municipal adaptation capacity gaps.

Guidance and Design Criteria that reflects local circumstances The new provincial climate adaptation organization should be tasked with working with the municipal sector to develop new guidelines and design criteria or endorsing existing guidelines and design criteria developed by third parties such as the Canadian Standards Association (CSA) or the ISO (ISO 14064 for GHG Reporting, ISO 50001 for Energy Management and other Canadian Standards such as CSA S6 for highway bridge design etc.) In doing so, the new adaptation organization should leverage existing expertise and resources, including the Clean Air Partnership and the Ontario Centre for Climate Impacts and Adaptation Resources (OCCIAR). Guidelines and methodologies for updating flood hazard lines and IDF curves, for identifying risk to storm structures infrastructure like culverts and bridges, and for modelling riverine and urban stormwater are some of the areas where further guidance is needed.

It is important that this guidance remains non-mandatory. The guidelines must allow for the municipality to address the effects of climate change that are most prevalent, and of relevance to our communities’ unique geographic location and infrastructure system maturity, as well as our resources and capacity.

Financial Impact Even once climate change considerations are integrated into plans, systems and models, high risk infrastructure is identified, and needed adaptation actions are developed, there remains the financial feasibility of implementation. To take just one example, changing the design flood used for stormwater modelling has significant implications for existing infrastructure, from pipe size to outlet flow to pumping and treatment capacity (if a combined system) to maintaining water quality in receiving waters. Municipalities have limited financial and technical capacity to undertake these significant infrastructure improvements.

This will take a long time and significant resources, yet climate change impacts are being felt right now and municipal resources are limited. Targeted financial support from the Province to accelerate this adaptation process at the local level is needed. RPWCO would welcome dialogue with the province on financial support for adaptation and to improving infrastructure resiliency and municipal recovery efforts.

Climate Projections There is considerable debate and little consensus on the best methodology to determine reliable local climate projections based on downscaled global projections. This is particularly true for predictive models on precipitation. Provincial assistance in setting a standard methodology or guideline for how municipalities should complete local climate projections or vulnerability assessments, similar to how they recently released draft guidelines for community emissions reduction planning, would be helpful.

Consistent reporting methodology The Province should recognize that many municipalities are already required to report out through different programs on adaptation initiatives. For example, the Global Covenant of Mayors for Climate and Energy, requires that cities complete a vulnerability assessment and adaptation plan. Any new requirements or guidelines should be consistent with these international standards so that municipalities are not required to duplicate efforts due to differing methodologies.

Other specific areas of interest to RPWCO

Of the many areas that are impacted by climate change, RPWCO has identified five areas related to adaptation on which it would welcome dialogue with MOECC and associated ministries on provincial support in tackling these adaptation-related challenges.

1.Integrated urban stormwater management planning in light of climate change Urban stormwater management planning needs to incorporate consideration of climate change, but provincial guidance so far has not sufficiently explained how to do this in the built urban environment. The MOECC’s draft stormwater and LID guide is focused on significantly increasing retention to deal with stormwater from an average rain event. However, the proposed approach does not adequately deal with more extreme storms associated with climate change. It is these extremes that are the greatest challenge, when the ground is fully saturated and the priority must be to convey the water away from areas that pose a risk to public safety, such as low lying transportation routes. The impact on water quality of intense rain water or snow melt entering waterways in enormous quantities must also be considered, with Lake Erie being a case in point. How to balance these various priorities represents a major challenge for municipalities. Municipalities would welcome dialogue with MOECC and other ministries on

•Updates to IDF curves and guidance on methods to integrate consideration of climate change including drought, increased precipitation, snow melt, into stormwater models.

•Advice on tools for municipalities to plan for uncertainty, including sensitivity, risk based analysis and how this would be integrated into infrastructure design.

•Advice on integrating multiple factors- population growth and climate change impacts, into water/wastewater/stormwater system design.

•Identify approaches, methodologies to map urban flood risk areas.

•Information and analysis on knock on effects of integrating climate change impact numbers into stormwater models, IDF curve, and impact on existing infrastructure, e.g. capacity of existing outlets are impacted.

•Different design and adaptation approaches needed for different weather events and climate extremes, e.g. small precipitation events, short duration high intensity ‘microburst’ storms, multiple day duration storms or ice storms, convergence of events (snow melt on frozen land, multiple days of precipitation), extended droughts, intense wind events, intense heat events .

•Evaluation of urban flooding from a watershed perspective and the role of conservation authorities.

2.Evaluating the resilience of critical infrastructure to withstand shocks, stresses from extreme weather events Understanding the probability and potential risks extreme weather and other climate change impacts on critical infrastructure must be understood to make informed decisions on how best to increase resilience of municipalities. Provincial support in this specialized area is needed to support municipalities in the development of appropriate adaptation policies and to prioritize adaptive actions. Further, modern urban infrastructure systems, some publicly managed, some privately owned and operated, are highly interdependent. Infrastructure interdependence can be physical, cyber-based, and geographic. Infrastructure systems with critical interdependencies (caused by automation, resource constraints or the nature of the services provided) are at a higher risk of failure from climate hazards. Quebec’s ice storm of 1998 was the most dramatic and costly example of these critical infrastructure interdependencies and cascading failure. Provincial assistance in understanding these interdependencies and methods to reduce the risk of cascading failures during and after extreme storm events would be beneficial.

3.Reducing inflow and infiltration into sanitary collection systems Infiltration of ground and storm water from poorly constructed collection systems in new subdivisions and private service connections in existing development contribute significantly to flow in collection systems. This uses capacity that could otherwise serve additional development or accommodate increased flows from intense storms and snowmelts. It also contributes to treatment costs. There is much that can be done within the municipal sector and in partnership with the development and construction industries to improve this situation. Reducing Inflow and infiltration (I&I) can be reduced by improving construction and maintenance of private sanitary sewer connections. A review of Ontario Building Code standards for private connections, as well as a review of construction and inspection standards to reduce I&I is recommended. Further, identification of best practices for the construction, testing and inspection of new sanitary sewer systems through subdivision development would be helpful in further reducing I&I.

4.Informing private property owners about steps they can take to protect and recover from extreme weather events, insurance coverage, and provincial disaster recovery assistance. An increasing number of homeowners are experiencing flooding of their homes, including those both inside and outside identified flood prone areas. There are a number of challenges faced by these homeowners: -They are not aware they are in floodprone areas -They have limited or no insurance -They are not aware of actions they can take to reduce their risk of flooding or they cannot afford to take the actions. Few insurance companies provide overland flooding insurance coverage. Some insurance companies will limit the number of claims from a policy holder for residential damage from flood events. This patchwork of insurance coverage puts pressure on municipal governments to fill the void. The Province provides some compensation to residents and municipalities that meet a certain threshold following a significant flooding event, through its Disaster Recovery Assistance for Ontarians Program and its Municipal Disaster Recovery Assistance Program. Coordinated provincial and municipal communication to homeowners to raise awareness about actions that may be taken to reduce their stormwater footprint and prevent basement flooding would be helpful, including actions they can take to mitigate risks. The Province could also provide more public information on insurance coverage that is available, and engage with insurance companies to encourage them to offer affordable overland flood policies would reduce the pressure on the province and municipalities to fill the void. More information on municipal and residential eligibility for the Provincial Disaster Recovery Assistance Program would also be helpful.

[Original Comment ID: 212108]