Benjamin Graham's Investing Voting Machine vs Weighing Machine Contrast Decision Making Based on Sentiment vs Value - What Are The Lessons for Infrastructure Investment for Flood Mitigation and Ontario's Environment Plan?

In last summer's Donville Kent Asset Management ROE Reporter Jason Donville and Jessie Gamble share Benjamin Graham's insightful quote:

"In the short run, the market is a voting machine - reflecting a voter-registration test that requires only money, not intelligence or emotional stability - but in the long run, the market is a weighing machine".

How does this apply to investing infrastructure? Is there also a "voting machine" at play in our industry when it comes to picking policies and technologies for flood mitigation? There certainly is. Is there also a "weighing machine" that will ultimately show us the merit of our decision making over time? Yes again.

Jason and Jessie comment how a focus on fundamentals and performance, including return on equity (ROE), 'weighs' value in an investment that in the long run will pay off, regardless of the frustrating volatility of short term 'voting' in the market, where decisions are made based on emotion.

Every stock on the TSX have a ROE value and a price to earnings ratio (PE) so that an investor knows what benefits (annual earnings) come at what cost (stock price). All stocks also have a price to earnings growth (PEG) reflecting the increase in value over time.

The concepts of ROE, PE, or PEG in infrastructure investing (aka city building and remediation) is a little more complex than in the stock market. Price: The price for infrastructure investing is somewhat volatile with construction projects tendered in an open market whereby hundreds of individual tender items that make up an infrastructure project are priced and multiplied by tender quantities and them aggregated into a total project bid price - for example one tender item in a flood remediation project may be 1800 mm diameter concrete pipe, and contractors will bid on that item considering the quantity involved, the environmental conditions for installation (depth, trench shoring requirements, adjacent infrastructure to isolate/protect from damage, etc.), etc.. Earnings: Typically municipal infrastructure does not have earnings - an exception might be privatized toll roads that are build and operated under P3 arrangements.

In the stock market the cost of the investment and benefits (capital gains and distributions) are all assigned to the same investor. In infrastructure investing, cost are borne by municipalities, passed on to taxpayers, and benefits accrue to taxpayers (hopefully in proportion to their funding contributions) and also to others like the insurance industry who can benefit from lower flood claims etc. over time. Sometimes costs are partially funded more widely, such as through the recent federal Clean Water and Wastewater Fund (CWWF) or through the upcoming federal Disaster Mitigation Adaptation Fund (DMAF). In an upcoming paper presented at the Water Environment Association of Ontario's 2019 Annual Conference I'll touch on the principles that have been in place for almost a century when it comes to funding water resource infrastructure projects. Kneese (What Ever Happened to Cost Benefit Analysis?) described the evolution of cost-benefit analysis in the United States dating back to the beginning of the 20th century when the Federal Reclamation Act of 1902 required economic analysis of projects, and 1936 when the Flood Control Act established a welfare economics feasibility test that benefits “to whomsoever they may accrue” must exceed costs.

Some infrastructure investments are mandated through regulation such as in the water supply realm where human health is paramount and even high cost investments are warranted to meet safety goals. ROE, or return on investment (ROI), are not considerations.

In contrast, in the flood control realm, most investment decisions are discretionary and must be justified through public and political will and in most cased be funded locally. In Ontario, the majority of flood mitigation municipal projects, including basement flood risk reduction, are funded through municipal taxes or water rates with some grant offsets. Exceptions include works on municipal drains funded through local Drainage Act assessments of contributing and benefiting properties, or in Markham, Ontario's Flood Control Program where a city-wide Stormwater Fee is dedicated 100% to funding flood mitigation activities. Some cities will offer rebates to property owners on stormwater utility fees who implement on-site measures to provide system benefits (e.g., Kitchener, Mississauga), but there is not a rigorous assessment of benefits achieved relative to rebates provided.

Do flood mitigation projects rigorously consider ROI? - that is, the ratio of deferred flood damages that infrastructure investments achieve relative to the cost on the discretionary infrastructure investment? Typically no. Investment decisions may be based on achieving specific outcomes, like meeting a standard of performance or level of service, regardless of the investment cost. Typically, in Ontario, the Environmental Assessment process guide infrastructure investment decisions such that preferred solutions to a 'Problem Statement' are evaluated qualitatively based on performance (i.e., how well is the problem addressed or solved by an alternative solution) and on capital and long term operating costs. However, the relationship between costs and performance benefits is not typically evaluated and decisions to implement a particular solution are not tied quantitatively to ROI. Where costs or other impacts are excessive relative to the benefits, the mandatory "Do Nothing Alternative" may be selected as the preferred solution, essentially stating that the ROI of potential solutions is inadequate.

Sometimes an infrastructure investment to achieve flood risk reduction is a 'no-brainer'. Examples include the Lower Don River landform to protect the West Don Lands from Don River flooding. In that case a berm and bridge upgrades with costs in the tens of millions of dollars freed up land development worth a billion. The Environmental Assessment did not even have to do economic cost-benefit analysis to settle on that solution. Opportunities for such "10-baggers" investments with benefits an order of magnitude greater than costs are rare. What is more typical is that the high ROI is not so obvious. For example in the case of Calgary's Springbank Off-Stream Flood Storage reservoir the benefit-cost analysis shows benefit cost ratios between 1.32 and 2.07 depending on the damage estimate and proposed level of service (IBI Group, 2015). And then where benefits are limited, meaning the flood risks are marginal, and mitigation costs are high, there may be no positive return at all - benefits may be less than costs. This range of benefit-cost ratio was explored on a sewershed-by-sewershed basis in the City of Stratford City-wide Storm System Master Plan in 2004 - but that is perhaps a very rare example of rigorous benefit cost analysis for local infratructure investments.

Because of the qualitative nature of the alternative evaluation in Ontario's Environmental Assessment process it can be considered to be part voting machine and part weighing machine, that is, there is some 'weighing' of alternative value but the decision is a qualitative 'vote' when it comes to ROI. For many small infrastructure investments this approach is reasonable. For high cost challenges facing municipalities, like those related to flood control, a more rigorous ROI assessment is required - why? - because there is an apparent risk of over-investing in low ROI solutions and under-investing in high-performance solutions with high long term value.

Enter Infrastructure Canada's DMAF. This $2 billion federal fund targets projects valued at over $20 million that will be implemented over the next 10 years. Unlike other funding programs like CWWF, DMAF applications will have to assess the ROI (benefits/costs) of the project and achieve a minimum ratio of 2:1. The benefits may be direct flood damage reduction values over the service life of the project, as well as other non-commensurate benefits (environmental benefits). The costs are the infrastructure investment capital and operating cost.

A focus on cost effectiveness is welcome in the realm of infrastructure policy setting, planning and funding. The is a healthy debate around policies for traditional grey and emerging green infrastructure investment, for example. As proposed in the WEAO 2019 paper noted above, and in the upcoming article in WEAO Influent's magazine, cost effectiveness screening is essential for given limited resources and the need to prioritize infrastructure investments to get the most bang for the buck. Unfortunately there appears to be a lot of 'voting machine' behaviour promoting technologies that have uncertain performance, high cost, but strong emotional drivers.

As noted in the Made-in-Ontario Environment Plan, "When the government does invest in environmental programs, taxpayers should not have to watch their hard-earned dollars be diverted towards expensive, ineffective policies and programs that do not deliver results." - that means we need a Benjamin Graham weighing machine, carefully assessing costs and benefits of policies and programs, as opposed to a voting machine fed by emotion and ideology. Ontarian's should demand the same careful focus on ROE or ROI for their infrastructure investments that Donville Kent has embraced in their equity investments.

Extreme Rainfall Trends Toronto and Mississauga - Extending Annual Maximum Series with Environment Canada Data

Environment and Climate Change Canada (ECCC) updates the Engineering Climate Datasets periodically including annual maximum series (AMS's) that reflect annual rainfall extremes over various durations, and also the derived rainfall statistics (intensity-duration-frequency (IDF) curves)) used in engineering design.

Municipalities updating their design standards and practitioners involved in hydrotechnical studies can wait for official updates or complete them in-house. Raw data is available from Environment Canada for a small fee, and can be screened for data gaps / errors and then processed to identify the maximum rainfall each year over the standard periods of 5 minute to 24 hours.

To review local design standards to account for any changes in rainfall intensity, my work team obtained raw data for the Pearson Airport and Toronto City (Bloor Street) climate stations in late 2017 to extend the ECCC analysis. The official Version 2.3 datasets extend to 2007 for Toronto City and 2013 for Pearson Airport - the added raw data extends to cover most of 2017 and 2016 respectively. After screening for anomalies, extended AMS's were analyzed using a Gumbel distribution to generate updated IDF curves.

Selected AMS charts for Pearson Airport and Toronto City stations are shown below:

Toronto City Maximum Annual 24-Hour Rainfall 1940-2017
Toronto City Maximum Annual 1-Hour Rainfall 1940-2017
Pearson Airport (Toronto International) Mississauga Maximum Annual 24-Hour Rainfall 1950-2016

Pearson Airport (Toronto International) Mississauga Maximum Annual 1-Hour Rainfall 1950-2016
Pearson Airport (Toronto International) Mississauga Maximum Annual 5-Minute Rainfall 1950-2016
What do the charts show?

  • Long duration rainfall intensities are decreasing (24-hour period)
  • Moderate duration intensities are mixed up and down (1-hour period)
  • Short duration intensities are decreasing
Note these are not strong trends, and for example the r-squared value for the 1-hour Pearson chart is only 0.002. A previous post shows what happens to design intensities based on these observed rainfall trends, although only using the ECCC datasets and not extended records - see previous post. This is a nice summary considering 21 stations in southern Ontario with over 30 years of record:

Ontario IDF Trends for Extreme Rainfall Climate Change Effects

Colleagues share that ECCC is updating the analysis for about 100 station records later the year. We'll see if there is any change in AMS trends and significance and derived IDF values compared to the current Version 2.3 Engineering Climate Datasets.

A recent op ed in the Financial Post suggests that analysis of data up to 2012 is not sufficient to assess rain trends as the CBC/Radio-Canada Ombudsman Guy Gendron recently did. Based on the analysis here, adding a few more years to the record is not going to change the overall picture. Its best to focus on other factors affecting flood risk and not the past rainfall trends in regions like southern Ontario. What are some of these other factors?

1) Expanded urbanization as shown in this post showing southern Ontario urban area growth since the mid 1960's and also in this post quantifying urbanization in GTA watersheds,

2) More extensive foundation underpinning, lowering some basements into harms way (closer to sewer back-up levels) as shown in this post on Toronto underpinning permits,

3) System modifications to reduce overflows for environmental protection like in this post referring to infrastructure impacts in Toronto Area 32,

4) Operational decisions that ignore known risks and put people in harm's way like in this post reviewing the July 8, 2013 GO Train flood in the Don River Floodplain,

5) Encroachment on overland flow paths, i.e., lost rivers in urban areas, putting properties at risk of pluvial flooding as this presentation analyzing flooding within overland flow path areas in Toronto in the May 200, August 2005 and July 2013 storms.

Detailed spatial analysis shows that most basement flooding can be explained by 2 factors of i) sanitary sewer inflow and infiltration rates (normalized for catchment area and design return period in a calibrated hydrodynamic model), and ii) the percent full of the sanitary sewers during extreme events - these 2 factors numerically explain over 60% of insurance back-up risks at a postal-code scale of accuracy.

What does this mean? Municipalities need to i) reduce extraneous flows in a cost effective manner in the short term, ii) upgrade sanitary sewer capacity where residual flows are high compared to capacity, iii) upgrade critical storm sewers where design standards are limited and overland flooding stresses adversely affect properties (pluvial flooding at the surface, inflow stresses below the surface), iv) offer private property isolation subsidies (backwater valves and foundation drain disconnection) to provide timely cost-effective risk reduction.

What to do where? It all starts with risk screening, as illustrated in our previous post describing tiered screening for riverine, sanitary and storm systems risks prepared for the Intact Centre on Climate Adaptation for their existing communities 'best practices' document, and another post describing such tiered screening with quantified risk factors prepared for Green Communities Canada's Urban Flooding Collective project.  What about a city-wide perspective on how much to budget for a comprehensive program of flood risk reduction incorporating these tactics? See a recent post that explored the cost-effectiveness of various municipal-wide strategies - look for more details at the 2019 WEAO Annual Conference, and look for even more in future national standards on benefit/cost analysis for flood mitigation we are developing for the National Research Council.

Weathering the Storms with Ontario's Environment Plan - Understanding Challenges and Opportunities for Flood Resilience in Ontario

As Ontario develops its Environment Plan, how it build resilience to extreme weather and mitigate flood damages in our communities should be a key consideration. To do so, we will need to identify and pursue technically-effective and financially-sustainable approaches to reduce flood risks. The following post explores reporting on floods, examines risk factors driving flood losses, and discusses challenges and opportunities for risk mitigation solutions that policymakers can consider. Further analysis on the role of green and grey infrastructure, including benefit-cost analysis to help guide infrastructure investment priorities, will be presented at the Water Environment of Ontario annual conference and proceedings - stay tuned!
R. Muir
Feb. 2, 2019

Flooding and Extreme Weather (Climate Change) in the Headlines

Flooding and concerns with severe weather continue to dominate headlines especially when summer storms impact Ontario municipalities, whether in Toronto in 2018, Windsor in 2017, Burlington in 2014, Toronto in 2013, Ottawa in 2009, Peterborough in 2004 or Stratford in 2002. Similarly, spring river flooding and high lake levels like those across the Grand River watershed in 2018 or around Lake Ontario in 2017 are often accompanied by declarations of a ‘new normal’[i] of extreme conditions due to more frequent or intense storms as a result of climate change. These recent events are associated with high economic losses and, tragically, have even resulted in loss of life[ii]. Therefore the need for strategic infrastructure planning that addresses flood resiliency and addresses these impacts in a timely and sustainable manner continues to be a priority for Ontario municipalities and water management agencies.

Understanding the engineering factors affecting flooding, sometimes misreported in the media, can help explain risks and identify opportunities for ‘weathering the storms’ and improving community resilience, including evaluating the role of emerging natural/green technologies promoted in the media, and in some industry circles[iii], and now being considered in Ontario water management policies.

What Causes Flooding?

The majority of summer storm impacts affecting Ontario municipalities result from how cities were built and how they have grown - that is, a combination of long-standing limitations in historical infrastructure capacity and urbanization pressures over many decades[iv]. Simply put, sewer pipes designed and installed fifty to one hundred years ago were never sized to handle extreme weather conditions responsible for today’s flooding, and were intended to accommodate lower amounts of development - designing to effectively convey runoff overland following very heavy rain only became a common practice in Ontario in the 1980’s. Similarly, flooding along river valleys and around lakes results from the long-standing intrinsic risks facing historical settlements due to their location relative to expected high water levels - planning to effectively situate development above and beyond these flood plains became common in only the 1950’s and later decades with the continued advancement of flood hazard mapping and regulation.

In the media today, infrastructure design limitations and urbanization stresses are sometimes identified as factors contributing to flooding, but they seldom recognized as the dominant factors to be managed - as a result there is a tendency to speculate on changes in weather patterns as opposed to recognize the basic physical limitations present under today’s or yesterday’s weather conditions.

Is Flooding Getting Worse?

Yes, in some cases. No, in others. The frequency and severity of flood events along rivers may have increased due to historical growth in watersheds that took place before modern engineered runoff control practices. Urbanization can increase flood risk due to higher runoff, flow rates and water levels and intensification in high risk zones can increase exposure to these risks, making flood conditions and flood impacts worse[v]. Such higher risks can occur across large watersheds as well as within local neighbourhoods beyond river valleys and where historical development may have buried small local creeks, limiting the capacity for rainwater to safety runoff during extreme weather. It is commonly accepted that increases in flood risk accompany growth in Gross Domestic Product (GDP) - Ontario’s GDP has increased by 35% from 2000 to 2017[vi], suggesting the potential for more at risk property. But in rural watersheds, unaffected by urbanization, changes in winter temperatures have actually lowered spring flows and flood risk, by increasing the amount of steady melt runoff throughout the winter (i.e., due to dramatically more frost-free days)[vii].

Complicating the situation, infrastructure systems may be constrained over time which can also make localized flood impacts worse. Sometimes improvements made to transportation systems, such as constructing underpasses to reduce traffic disruptions and improve safety at historical at-grade railway crossings, exposes resulting low lying roadways to more frequent flooding[viii]. Similarly, wastewater collection system retrofits to enhance water quality protection, like the installation of control tanks or the adjustment of regulator structures to prevent wastewater overflows to waterways, can incrementally increase local flood risks as wastewater is held back in the sewer system to protect the environment[ix]. Infrastructure systems are therefore complex and their design may involve trade-offs between competing performance goals (e.g., flooding vs. environmental protection). In addition, the capacity of sewer systems can be reduced by a range of other local factors, such as inadvertent encroachment by utilities cross-bored through sewer pipes or the build-up of calcite deposits or other debris between regular maintenance cycles. While these factors can worsen flood risk by lowering infrastructure capacity, the exposure of individual properties may increase at the same time as well, aggravating flood damage potential. For example the practice of lowering basements through foundation underpinning to enhance living spaces can increase the risk of damage further just by shifting vulnerable property closer to any high water or wastewater levels in city sewers[x].

There are some dramatic examples of infrastructure failures that could suggest flood impacts are getting worse, such as the wash-out of Finch Avenue West in Toronto during the August 2005 storm[xi]. A review of historical failures in the Toronto region, however, suggests a significant decrease in these types of failures as the design and construction practices for roads and bridges have improved - more resilient engineering practices are now resulting in more limited instances of washouts and lower vulnerability compared to the early and mid 1900’s[xii], despite an increasing number of roadways and structures in our communities.

Sometimes dramatic flooding events are deemed unprecedented in the media and the event may be explained by more severe weather and climate change effects. Careful review of data records may contradict such suggestions, for example in the case of the stranded Toronto commuter train along the Don River in July 2013. While some media reports suggested the event was unprecedented, records indicate that higher flooding occurred weeks before the incident[xiii] and a comprehensive inquiry in the 1980’s revealed long-standing railway risks dating back to the 1800’s. A review of media archives shows the Toronto commuter train was stranded in the same location in 1981 as well[xiv].

Overall, some flood impacts are getting worse, often due to a range of under-reported factors. Over time historical infrastructure design limitations become apparent, sometimes accentuated by urbanization over previous decades. Infrastructure failures, including roadway and bridge wash-outs are fortunately extremely isolated despite some dramatic examples. In some cases, dramatic flood events may reflect limited operational practices to manage long-standing risks, as opposed to any changes in intrinsic risk factors.

Are Storms Bigger and More Frequent Due To Climate Change?

Not necessarily. While the number of flood events may appear to be on the rise due to urbanization stresses and other considerations, bigger and more frequent storms is not a key factor in many Ontario cities. In fact, numerous engineering studies[xv] to review design standards in the face of climate change concerns and the official Engineering Climate Datasets have shown extreme rainfall trends across southern Ontario have remained unchanged for decades[xvi]. This runs counter to common media suggestions that link any flood trends directly to rainfall trends, but often in the absence of any rainfall analysis or comprehensive consideration of local runoff hydrology and infrastructure hydraulic factors.

In some regions, such a northern Ontario, increases in rainfall intensity have been observed in historical rainfall records. While many climate change models predict more extreme rain intensities in the future in Ontario due to climate change, there is a high degree of uncertainty, and some models predict decreasing extremes[xvii].

So based on observations and statistical analysis, storms are not necessarily more severe, despite recent media statements to the contrary that may even state there is a definitive change in baseline conditions that affects every single extreme weather event[xviii]. Notwithstanding the lack of clear historical trends, precautionary engineering design must always consider safety factors to account for potential changes in storm frequency or severity, and consider the natural unpredictability of weather systems. There is a significant opportunity for professional engineers and specialists to educate the media and non-technical stakeholders on severe weather trends affecting flooding.

The recent call for ‘immediate action’ on climate change effects by executives from Intact Financial and Sun Life[xix] shows that flood risk factors are not well understood.

Are Water Levels Higher Today Due To Climate Change?

Not necessarily. While 2017 Lake Ontario levels were certainly well above average levels, long term records show that historical high levels were only barely exceeded by a few centimetres in 2017[xx]. Occasionally breaking records is something that should be expected to occur to some degree over any long record period - consider that in the second year of any water level recording that if the first year had average levels, there is a 50% chance of ‘breaking the record’ in the second year. Even where there are long term observations like on the Great Lakes, records should be expected to be broken and considered when planning land uses or designing vulnerable infrastructure.

Expanding encroachment upon the lakeshore environment, whether from residential development (e.g., Toronto Island), or the early spring use of beaches by volleyball leagues (e.g., Woodbine Beach), can accentuate conflicts with high water levels that are largely reflective of the ‘old normal’ and not higher water levels due to a changing climate. In the media, it is common to report on high water levels without a broad consideration of historical water level data which can serve to mischaracterize the rarity of particular levels. Sometimes the nature of community encroachment has changed more than the water levels, making the impacts of high water levels more severe.

In some water systems, operational considerations can affect water levels regardless of variability in the climate and weather inputs. This is a consideration for Lake Ontario and St. Lawrence River levels that are controlled based on multiple, sometimes-competing objectives (hydropower supply, commercial navigation, water supply, recreational boating, flood and low water level management, and habitat enhancement) as well as northern lakes in ‘cottage country’ where levels are also controlled based on a range of objectives.

Strategies for Achieving Sustainable Flood Resiliency

The Ontario government has set a framework for achieving resiliency through acts, regulations and guidelines that support municipalities in evaluating resiliency, reporting infrastructure performance, and planning necessary improvements in level of service with long-term asset management strategies[xxi]. While the focus is often on climate change resiliency, significant opportunities for risk reduction lie in improving resiliency to today’s climate given historical design limitations and recent growth pressures. Focusing on today’s infrastructure investment challenges should be pursued as an effective strategy for achieving flood resiliency today while also delivering future climate resiliency as a co-benefit. In other words, necessary ‘design standard upgrades’ can achieve ‘climate adaptation’ goals as well.

There are opportunities for promote how appropriate safety factors can be incorporated into design standards to guide municipalities when considering future climate resiliency - this may require the collaboration of several ministries that are responsible for interrelated natural hazards (river flood risks), stormwater management (urban flood risks), and building standards (property-scale risks) and that affect flooding from ‘flood plain to floor drain’.

OSPE has recently commented on emerging policies related to flood risks and stormwater management in Ontario, addressing flood risk factors and highlighting challenges for achieving sustainable mitigation. OSPE's 2017 report “Weathering the Storms: Municipalities Plead for Stormwater Infrastructure Funding”[xxii] prepared with the Ontario Sewer and Watermain Construction Association and the Residential and Civil Construction Alliance of Ontario identified that “significant investments will be required to maintain or bring municipal stormwater infrastructure up to a good or better condition rating” and noted that there is considerable apprehension on climate change effects among Ontario municipalities. A strategy that focuses on today’s risks would effectively address future effects and one that implements technically-effective and cost-effective infrastructure solutions would ensure that the significant investments would be worthwhile.

What is the Role of Grey and Green Infrastructure?

To help guide infrastructure priorities OSPE has commented on Ontario’s draft Watershed Planning Guidance identifying concerns with the effectiveness of emerging technologies to address flood risks[xxiii]. In earlier comments on Ontario’s Long Term Infrastructure Plan OSPE recommended that comprehensive cost analysis was required for green infrastructure (low impact development measures, like rain gardens, permeable pavement, infiltration trenches, etc.)[xxiv]. The need to evaluate both technical and cost effectiveness of green infrastructure is especially important today as it is being promoted in emerging Ontario policies surrounding stormwater management, and is currently being promoted by several groups, especially within the insurance industry[xxv], as a viable solution to achieving flood risk reduction. Often this promotion is being done based on limited technical input, sometimes with gross economic proxies used in place of necessary engineering analyses[xxvi].

Analysis of the cost-effectiveness of various infrastructure solutions for reducing flood damages has been completed to reinforce the need for comprehensive financial analysis to further guide infrastructure policies and priorities. Full lifecycle costs of traditional grey infrastructure (i.e., storm sewers and sanitary sewers) and emerging green infrastructure solutions were evaluated considering both initial capital and on-going operation and maintenance costs. In the case study, grey infrastructure was shown to be cost-effective at reducing flood damages – in fact for every dollar invested in sewer upgrades, two dollars of insured damages are prevented. When total losses are considered, grey infrastructure prevents five dollars of damage. A more important finding was that the effectiveness of grey infrastructure was one to two orders of magnitude higher than green infrastructure[xxvii]. These are important observations to guide infrastructure investments in Ontario as part of asset management plans, or other flood control strategies. Firstly, grey infrastructure investments are absolutely worthwhile and can increase the level of service at a reasonable cost. Secondly, green infrastructure appears to have been oversold as a potential tool for flood risk reduction, delivering only pennies of benefits for every dollar spent.

Promoting green infrastructure as a flood mitigation solution for critical infrastructure is now pervasive, especially from the insurance industry. Recently, executives from Intact Financial and Sun Life suggested the need to “improve and even transform the design, delivery, efficiency, resilience and greening of infrastructure projects”[xxviii].  This appears to be a counter-productive approach, as green infrastructure spending represents a significant opportunity cost considering more cost-effective traditional infrastructure measures. Furthermore, OSPE’s comments on Ontario’s draft Watershed Planning Guidance cautioned that green infrastructure can make flooding worse:

“The adverse impacts of green infrastructure infiltration on wastewater systems, in which the
majority of flooding in Ontario is concentrated due to historical municipal servicing practices and
standards, has been overlooked in the statement promoting green infrastructure as a flood
control measure.”

What is the Role of Ontario’s Professional Engineers?

Just as OSPE asserted that the government must restore the oversight of professional engineers in the detailed planning and design of Ontario’s power grid to prevent missteps from happening[xxix], OSPE asserts the role of professional engineers in the development of infrastructure investment priorities to mitigate flood impacts in a cost-effective and timely manner. To identify these investments, Ontario’s Municipal Engineers Association has a well-established Class Environmental Assessment process[xxx] for guiding municipalities in developing master plans and local projects to address local flooding issues in existing communities. The process evaluates cost, social, technical and environmental considerations and can be followed to identify appropriate infrastructure investments. Ontario’s professional engineers can ensure that appropriate technologies are evaluated and selected, planned and funded, and then designed and implemented – such infrastructure can provide flood protection to Ontario communities and lasting value to residents and businesses who fund these investments through municipal taxes, in some cases stormwater utility fees.  

[i] Isabella O’Malley. Canada in 2030: New normal of extreme weather events. September 7, 2018.
[ii] James Matthews, The Toronto Star. Searchers brace for tragedy after child swept from mother’s arms into raging Grand River. February 21, 2018.
[iii] IBC-ICCA-IISD. Urgent action needed to curb possible debilitating loss of natural infrastructure assets in Canada: IBC/Intact Centre/IISD Report.
[iv] Barry J. Adams, Fabian Papa. Urban Stormwater Management Planning with Analytical Probabilistic Models, ISBN: 978-0-471-33217-6
[v] Trevor Dickinson, Ramesh Rudra, Kishor Panjabi. Climate Change & Urban Development Have Impacted Streamflows in Southern Ontario. September 27, 2018.
[vi] Statista. Gross domestic product of Ontario, Canada from 2000 to 2017 (in million chained 2007 Canadian dollars).
[vii] Trevor Dickinson and Ramesh Rudra. Disentangling Impacts of Climate & Land Use Change on Quantity & Quality of River Flows in Southern Ontario. Undated.
[viii] The Huffington Post Canada. Toronto Flood: Ferrari Abandoned In Tunnel (TWITTER). July 9, 2013.
[ix] Genivar. Investigation of Chronic Basement Flooding, Eastern Beaches (Area 32), Final Project File. Section 6 Assessment of Existing Systems. May, 2012.
[x] Robert Muir. Basement Underpinning and Sewer Back-up Risks - How Lowering Basements Increases Flood Damage Potential in Canadian Cities Undergoing Intensification. July 27, 2018.
[xi] Jennifer Wells. Climate change: How Toronto is adapting to our scary new reality. The Toronto Star. August 19, 2012.
[xii] The Metropolitan Toronto and Region Conservation Authority. A History of Flooding in the Metropolitan Toronto and Region Watersheds. Undated. (review of wash-out trends:
[xiii] Robert Muir. Evidence Based Policy Gaps in Water Resources: Thinking Fast and Slow on Floods and Flow. Journal of Water Management Modeling. 2018.
[xiv] Robert Muir. GO Train flooded in 1981 too. Media misses mark suggesting new normal for extreme weather and flooding.
[xv] Ontario Society of Professional Engineers. Response to Ontario’s Draft Watershed Planning Guidance 2017 (5) Climate Change Extreme Weather Risks in Ontario, page 12). April 7, 2018.
[xvi] Ramesh Rudra Changes in Rainfall Extremes in Ontario. International Journal of Environmental Research. July, 2015.
[xvii] Poulomi Ganguli and Paulin Coulibaly. Assessment of Future Changes in Intensity-Duration-Frequency Curves for Southern Ontario using North American (NA)-CORDEX Models with Nonstationary Methods.
[xviii] CBC News. The National. How climate change and extreme weather will change how we live. September 19, 2018.
[xix] Charles Brindamour and Dean Connor. Climate resilience must be part of every government’s agenda. The Globe and Mail. September 25, 2018.
[xx] Robert Muir. Toronto Island Flooding 2017 - Were Lake Ontario Levels Extreme? No, Barely Above Historical Maximum Levels. September 30, 2017.
[xxi] Robert Muir. Extreme Weather Resiliency and Climate Adaptation Through Strategic Asset Management & Infrastructure Investments. Association of Municipalities Ontario 2018 Annual Conference. August 21, 2018.
[xxii] Ontario Society of Professional Engineers, The Residential and Civil Construction Alliance of Ontario , and The Ontario Sewer and Watermain Construction Association. Weathering the Storms: Municipalities Plead for Stormwater Infrastructure Funding. 2017.
[xxiii] Ontario Society of Professional Engineers. Response to Ontario’s Draft Watershed Planning Guidance 2017. April 7, 2018.
[xxiv] Ontario Society of Professional Engineers . Engineers Respond to Ontario's Long-Term Infrastructure Plan 2017 (EBR 013-1907). January 27, 2018.
[xxv] About Insurance Bureau of Canada, Intact Centre on Climate Adaptation, and International Institute for
Sustainable Development. Combatting Canada’s Rising Flood Costs: Natural infrastructure is an underutilized option. September, 2018.
[xxvi] pwc in collaboration with Autocase. Assessing the business case for green infrastructure through a Total Economic Valuation approach, Final Draft. November, 2017.
[xxvii] Robert Muir and Fabian Papa. Economic Analysis of Flood Damage Reduction for Grey and Green Infrastructure – Cost Benefit Analysis Considering Insured and Total Losses, Erosion Remediation Offsets, Lost Productivity Value, and Willingness to Pay for Surface Water Quality Improvements. September 17, 2018.
[xxviii] Charles Brindamour and Dean Connor. Climate resilience must be part of every government’s agenda. The Globe and Mail. September 25, 2018.
[xxix] Ontario Society of Professional Engineers. Ontario Wasted More Than $1 Billion Worth of Clean Energy in 2016. Society Notes, The official blog of the Ontario Society of Professional Engineers. June 29, 2017.
[xxx] Municipal Engineers Association. Municipal Class Environmental Assessment (MCEA). October 2000, as amended in 2007, 2011 & 2015.

On the question of "Are Storms Bigger and More Frequent Due To Climate Change?" - the CBC Ombudsman has recently consulted Environment and Climate Change Canada (ECCC) in response to complaints on reporting inaccuracy and ECCC indicated: “For Canada as a whole, observational evidence of changes in extreme precipitation is lacking.”

CBC has corrected their original reports that claimed 100-years storms were increasing, as detailed in the earlier post: CBC articles corrected 

CBC Ombudsman Decision Finds Lack of Journalistic Integrity in Reporting on Extreme Storm Trends and Climate Change

Excerpt: The journalist, Marc Montgomery, frankly admitted that he had decided from the start that he would “not give an inch” to the complainant. That attitude, unfortunately, violates the JSP, specifically the section that calls on CBC/Radio-Canada employees to “act responsibly and to be accountable,” which goes on to say “we [. . .] are honest [and we] do not hesitate to correct any mistake [. . .] .” 


The two articles by journalist Marc Montgomery entitled How to mitigate the effects of flood damage from climate change and Response to a climate change story, posted online on 
September 19 and November 19, 2018, respectively by Radio Canada international (RCI), failed to comply with the CBC/Radio-Canada Journalistic Standards and Practices (JSP) regarding accuracy and impartiality. The corrections eventually made to the two articles were not compliant with best practices, and violated the JSP principles on correction of errors and honesty. As a result of the multiple shortcomings noted in my examination of this matter, I am recommending that Radio-Canada review the RCI complaints processing procedure; provide training on the JSP to RCI staff; make the necessary corrections to the two articles in question so
as to restore the accuracy and balance that are lacking; clearly indicate in the two articles that they were the subject of a review by the Office of the Ombudsman and include a link to that review; and, lastly, publish a notice of correction in the Mises au point (Erratum) section of the Radio-Canada website.

Guy Gendron
Ombudsman, French Services, CBC/Radio-Canada
January 28, 2019

Kudos to the CBC Ombudsman for recognizing failed journalistic integrity in their reporting on extreme storm trends and climate change, and in dealing with my complaint. The extensive review and decision below is in response to CBC reporting on publication by Insurance Bureau of Canada, Intact Centre of Climate Adaptation and International Institute on Sustainable Development on natural infrastructure entitled "Combatting Canada’s Rising Flood Costs: Natural infrastructure is an underutilized option, September, 2018". This blog's review of that report is here in several posts including i) Wetlands and Natural Infrastructure for Flood Mitigation - Ontario Feasibility Assessment Suggests Limited Potential - Studies Note Conflict Between Preserving Biodiversity and Flood Attenuation and ii)  Storm Warts, The Floods Awaken, A New Hope for Cost-Effective Investment in Flood Management Infrastructure, #NWWC2018 Robert Muir.

You can look for the original CBC article here:

But this is what you will find:

But if you want to read the original article, check out this web archive of the article that said "So-called “100 year events” are now occurring sometimes only a few years apart":

The CBC reporter Marc Montgomery offered me an interview in response to data gaps on storm trends I noted on in his article - I thank him for that. But that interview was posted along with his attempts to discount the information I shared (his attempt to "not give and inch" in responding to real data). Again the original interview is not available as the CBC endeavours to correct the failings in journalistic standards of practice. My original interview "Response to a Climate Change Story" web page site is here, and it shows the Oops! as well. But a web archive also shows this interview page at this link (November 20, 2018 archive) and here at this link (November 20, 2018 archive) which shows my comments to the article as of November 19, 2018.

Thankfully, CBC has corrected the original article and my interview article to address violations in journalistic standards of practice. Here is the original article with a clear explanation of the violation - link. And my interview article is corrected here at this link.

Below is the CBC Ombudsman's full review and decision (sorry, unformatted for now), also available at this link as an easier to read pdf.


Review by the Office of the Ombudsman, French Services, CBC/RadioCanada of two complaints asserting that the articles by journalist Marc
Montgomery entitled How to mitigate the effects of flood damage from
climate change and Response to a climate change story, posted on
September 19 and November 19, 2018, respectively by Radio Canada
international (RCI), failed to comply with the CBC/Radio-Canada
Journalistic Standards and Practices regarding accuracy and impartiality.


This case involves English-language news articles and interviews posted to the Radio Canada
international (RCI) website under the titles How to mitigate the effects of flood damage from
climate change and Response to a climate change story.

The complaints, the responses by
RCI, and the many supporting documents submitted by each party were also written in English.
Complaints concerning RCI, regardless of broadcast language, are the purview of the
CBC/Radio-Canada French Services Ombudsman; that is why I have reviewed them. This review
was initially written in French before being translated into English.


The complainant, Mr. Robert Muir, is an Ontario engineer with a long career in flood risk
mitigation as a consultant and municipal engineer. On October 7, 2018, he wrote to the Office of
the Ombudsman to report what he believed to be errors in the article posted on the RCI site on
September 19, 2018. The article was condensed from an interview with Mr. Blair Feltmate, head
of the Intact Centre on Climate Adaptation at the University of Waterloo and the lead investigator
for a study commissioned by the Insurance Bureau of Canada (IBC).

In Mr. Muir’s view, the interview and the article contained erroneous data on trends in
precipitation in Canada – specifically regarding episodes of extreme rainfall so intense that they
are considered to occur at 100-year intervals. In addition, Mr. Muir complained that the article
cited no sources to corroborate Dr. Feltmate’s theory, which holds that climate change is the
reason why extreme rainfall events have become more frequent in Canada. The complainant
further alleged that another of Dr. Feltmate’s claims was incorrect, namely that preservation and
creation of wetlands (ponds, marshes, etc.) in urban and near-urban areas are economically
advantageous and easy-to-implement measures for reducing flood risk. Mr. Muir added that the
Ontario Society of Professional Engineers, of which he is a member, had previously voiced its
disagreement on this issue to Natalia Moudrak, co-author of a report produced last year by
Dr. Feltmate on the value of natural infrastructure.

Citing several expert studies and national data from Environment Canada, the complainant
asserted that “there has been no change in extreme rainfall statistics in southern Ontario, and in
fact many decreasing trends.” This, he wrote, contradicted Dr. Feltmate’s theory that there is a
correlation between climate change and increased flood damage. Mr. Muir therefore asked that
the article be amended to reflect this.

To further substantiate his position, the complainant noted that he had been successful in a
similar complaint filed with the CBC English Services Ombudsman in 2015, and four complaints
against three insurance companies (Intact Financial, Aviva Canada and RSA) before Advertising
Standards Canada, which had forced the insurers to amend their claims regarding the frequency
of storms. He added that the media should be wary of statements by insurance companies as
well as claims by researchers such as Dr. Feltmate, who is not a climatologist, and whose
research is funded by an insurance provider.

As the procedure dictates, I began by asking RCI management to respond to the complainant.


On October 24, 2018, Mr. Soleïman Mellali, Web Editor-in-Chief, RCI, replied to Mr. Muir in a very
long message containing some twenty citations and links to many news articles and reports from
various bodies, covering multiple aspects relating to climate change as well as precipitation.

The response from RCI began with an acknowledgement that the key assertion of the article in
question – that 100-year extreme rainfall events are now happening just a few years apart – was
“neither entirely true, nor entirely wrong.” As a result, Mr. Mellali wrote, the article had been
amended to read as follows:

“Scientists consulted on this question generally concluded that while actual rainfall
amounts in Canada have not varied much, when, where and how they occur have.”

RCI added that other weather anomalies, like sudden episodes of warm temperatures resulting in
early snow melting, have combined to cause record flooding in recent years.

I see no use in listing here the majority of the points in the response, as they consist mainly of a
list of excerpts from reports and news articles that establish a link between global warming and
weather phenomena around the world – e.g., hurricanes, rising temperatures, heat waves –
which was not the subject of the complaint.

The other references deal with the impacts of such phenomena: drought, forest fires, coastal
erosion, destruction of crops, and increases in damage claims to insurance companies. Many of
the studies cited are forward-looking; that is, they predict future changes. While interesting, this
information is not germane to the issue raised in the complaint: the assertion that climate change
has led to increased extreme rainfall in Canada, which in turn is allegedly the main reason for
increased property damage from flooding.

Only one other point in the response is truly relevant to my review of the issue raised, and that is
a statement attributed to Xuebin Zhang, a Senior Research Scientist with Environment Canada.
This was not mentioned, but it was drawn from email correspondence between journalist
Marc Montgomery, the author of the article in question, and this Canadian climate expert.

Dr. Zhang wrote:
“Annual mean precipitation has increased, on average, in Canada, with a larger percent
increase in northern Canada. For Canada as a whole, observational evidence of changes
in extreme precipitation is lacking. However, in the future, extreme precipitation is
projected to increase in a warmer climate.”

Later, the RCI response quotes Dr. Feltmate, who was asked to provide counter-arguments to the
Mr. Muir’s complaint that no evidence was provided for the claim that extreme precipitation is
increasing in Canada. According to Dr. Feltmate, a decrease in the number of Environment
Canada recording stations is the reason why many local climatological events go undetected.

Dr. Feltmate wrote:
“Thus, it can be misleading to depend singularly on Environment Canada recording
stations to document precipitation events that lead to flooding.”

Lastly, Mr. Mellali concluded his response by inviting the complainant to be interviewed by RCI, to
give him the opportunity to have his point of view heard.


On the same day RCI’s response was received, October 24, 2018, the complainant responded
that he was not satisfied with it. He noted that the correction made to the article did not address
his complaint regarding the inaccuracy of the original statement that 100-year extreme
precipitation events are now more frequent in Canada. Mr. Muir persisted in asking RCI to
produce data to prove this.

Mr. Muir added that climate change has resulted in less snow accumulation during the winter,
which in turn has limited spring flooding. He therefore wondered what data RCI was using in
support of its reply that melting snow now leads to record levels of flooding.

The complainant wrote that the latest Engineering Climate Datasets show a slight decrease (of
0.2%) in the overall intensity of rainfall and in no change as concerns 100-year extreme rainfall
events. Storms of more modest intensity – classified as events with return periods of between 2
and 25 years – are those that have seen the most marked decrease, he added. It is these data
that engineers use to design municipal infrastructures, Mr. Muir wrote, asking that RCI disclose
what data it used to support the new claim added to the article: that “while actual rainfall amounts
in Canada have not varied much, when, where and how they occur have.” In the absence of
concrete data on “when,” “where” and “how” rainfall is changing, Mr. Muir requested that the
article be amended once more to acknowledge that the RCI interviewee (Dr. Feltmate) had no
evidence to support his claim, and that it was mere speculation on his part.

As to Dr. Feltmate’s statement, included in RCI’s response, that the absence of data is
attributable to an insufficient number of Environment Canada recording stations, the complainant
asked the following questions:

“Are you suggesting that there is not enough data to prove decreasing trends in rainfall
but there is enough to prove increasing trends? How can you have it one way?”

Lastly, Mr. Muir disputed the accuracy of a sentence in the article, which begins “As costs mount
to deal with the huge financial burden and loss due to floods [. . .] .” In his opinion, the increase in
damage claims made to insurers is attributable to all instances of bad weather, as well as fires,
while those resulting solely from flooding have not seen any marked increase, if one excludes
one “anomaly” in 2013.

In conclusion, the complainant accepted RCI’s invitation to be interviewed so that he could outline
his concerns in more detail and explain why he found the response from RCI unsatisfactory.


On November 2, 2018, Mr. Mellali formally repeated his invitation to Mr. Muir to be interviewed by
journalist Marc Montgomery. The interview was recorded on November 15 and posted online on
November 19, along with an article entitled Response to a climate change story.


Two days later, on November 21, 2018, as well as the following day, Mr. Muir again wrote to
Mr. Mellali, asking that multiple corrections be made to the article accompanying his interview.
The complainant began by stating that the interview had mainly concerned extreme rainfall
intensity data, but that the article was illustrated with a graphic of annual precipitation, which is a
different subject.

Mr. Muir went on to say that the text of the story implied that his remarks on the lack of any trend
toward increased extreme precipitation had to do with “one local region only” (southern Ontario).
In fact, he wrote, this is not that case, as proved by the matters that he had brought to the
attention of Advertising Standards Canada regarding three insurance companies. In that regard,
he reiterated that, in spite of his repeated entreaties, RCI had still not provided national data on
extreme precipitation that would support the idea that they are increasing across Canada. He
added that he had nevertheless quoted, during his interview, an excerpt from an Environment
Canada paper confirming no increase in extreme precipitation across the entire country. He
attached to his complaint a link to the study report in question, which dates from 2014.
Mr. Muir also asked that the article include a reference to an open letter in which the Ontario
Society of Professional Engineers discounted the lBC / Intact Centre report on wetlands for urban
flood mitigation.

His request was based on the fact that the article accompanying his interview “cherry-picks” from
that IBC report – written, he points out, by a University of Waterloo biologist.

The report, he
added, was not peer-reviewed, is therefore “not a professional document,” and is “not the type of
material CBC should be referring to for advice on infrastructure, or advice on flood mitigation.”
Moreover, he wrote, page 2 of the report includes a disclaimer whereby the Intact Centre makes
no warranty as to the accuracy of the information contained in its report.

In a second message, on November 22, 2018, Mr. Muir expressed doubt about the truthfulness of
the second paragraph of the article accompanying his interview. It reads:
“Here in Canada, the Insurance Bureau of Canada in a commissioned report said its
payouts from natural disasters have doubled every five years since 1980, and the
majority of those claims are from flooding due in large part to climate change.”

In the complainant’s opinion, that claim is false. He maintained that the IBC data show that fewer
than a third of claims since the early 1980s have been for flooding due to rainstorms, electrical
storms or hurricanes. In addition, he wrote, “[t]he data also shows that the proportion of water
damage as a percentage of total catastrophic losses is decreasing over the past 10 years.”
Mr. Muir therefore wondered how a “majority of claims” could possibly be from flooding if less
than a total of the claims were for water damage, and how the increase in claims could be
attributable to climate change if Environment Canada data show no significant increase in
extreme precipitation. In his opinion, other factors besides increased heavy rainfall explain the
increasing trends in flood-related damages, and those factors are related not to meteorology
(storm extremes) but to hydrology (land-use planning). In his opinion, the RCI article perpetuates
the “disproved . . . theory/concept” of the insurance industry, which is “not based on any real

As required by the procedure, and because this was a new complaint concerning a different
article, although related to the first, I asked RCI to respond.


On December 4, 2018, Mr. Soleïman Mellali, Web Editor-in-Chief, RCI, wrote to the complainant
acknowledging that the graphic of annual rainfall used to illustrate the article about the interview
with Mr. Muir “[did] not fully relate to the interview” and that it would therefore be removed.
Regarding the other matters raised in the complaint, RCI confined its response to one of them
only, defending Dr. Blair Feltmate’s qualifications. Mr. Mellali began by forwarding an explanation
by Dr. Feltmate regarding the disclaimer in the report he authored about using wetlands for urban
flood mitigation. The researcher wrote:

“Scores of scientists, engineers, conservation authorities, insurers, etc., review and sign
off on every paper published by the Intact Centre. The legal disclaimer we add is a legal
requirement by the University of Waterloo.”

In its response, RCI added that Dr. Feltmate, “a recognised world expert on climate adaptation,”
had been invited to Europe to give a presentation at the Global Commission on Adaptation,
chaired by Ban Ki-moon; asked by the Government of Canada to chair the Pan-Canadian
Framework on Clean Growth and Climate Change – Expert Panel on Adaptation; and invited by
the Ontario Society of Professional Engineers to give a presentation at a 2019 working meeting.
RCI also noted that it had submitted the initial article and the interview with Dr. Feltmate to
Dr. Neil Comer, a well-known climatologist and adjunct professor at the University of Toronto, for
review. Dr. Comer wrote:

“I certainly did not read, nor hear from Blair [Feltmate] in this link, anything approaching
unreasonable from a purely climatological aspect.”


On the same day RCI’s response was received, December 4, 2018, Mr. Muir wrote to the Office
of the Ombudsman to request a review of the matter.

He began by referring again to the Insurance Bureau of Canada and Intact Centre report on
wetlands for urban flood mitigation mentioned in the article accompanying the interview with him.
In his opinion, by referring to that report, RCI was “promoting positions on matters that [the
report’s authors] are not licensed to formally advance.” “Real engineering studies,” he wrote, “do
not have disclaimers saying they are not professional advice.”

Mr. Muir then took the opportunity to ask for clarifications regarding Dr. Feltmate’s claim that the
Intact Centre’s reports are reviewed and approved by experts. In Mr. Muir’s opinion, there is no
“formal sign-off” procedure, but rather a list of persons consulted in preparing the reports, and this
is not to be confused with “formal peer review.”

Two days later, on December 6, Mr. Muir wrote the Office of the Ombudsman again to reiterate
that there is no formal process of approval for Intact Centre reports, and to emphasize that in the
two study reports that are the subject of this matter (2017 and 2018), there are not even any lists
acknowledging who may have been consulted. He added that there was no “general consultation”
involved in the preparation of the two reports. “Unfortunately,” he concluded, “CBC is taking
insurance industry-funded ‘glossy’ reports to be equivalent to formal technical information but
they are not.”


This case is needlessly complicated. The two parties have taken it in directions that they ought
not to have, and as a result, reviewing it has become tremendously tedious.

At its core, the matter is relatively simple. Examination of the complaints invokes the accuracy
and balance principles of the CBC/Radio-Canada Journalistic Standards and Practices (JSP6

We seek out the truth in all matters of public interest. We invest our time and our skills to
learn, understand and clearly explain the facts to our audience. The production
techniques we use serve to present the content in a clear and accessible manner.”

We contribute to informed debate on issues that matter to Canadians by reflecting a
diversity of opinion. Our content on all platforms presents a wide range of subject matter
and views.

On issues of controversy, we ensure that divergent views are reflected respectfully, taking
into account their relevance to the debate and how widely held these views are. We also
ensure that they are represented over a reasonable period of time.”

My review of the complaints will also refer to part of the CBC/Radio-Canada mission statement7
quoted in the introduction to the JSP, which calls upon the public broadcaster to “act responsibly
and to be accountable”:

“To act responsibly and to be accountable
We are aware of the impact of our work and are honest with our audiences. We do not
hesitate to correct any mistake when necessary nor to follow up a story when a situation
changes significantly. We do not plagiarize. (…)”

Study of the complaint

Mr. Muir’s initial complaint concerned, essentially, the accuracy of two pieces of information in the
article that accompanied the interview with Dr. Feltmate. First, that episodes of extreme rainfall,
those considered to occur once every 100 years, are now sometimes occurring only a few years
apart; second, the researcher’s claim that preserving and creating wetlands (e.g., ponds,
marshes, etc.) in urban and near-urban areas are economically advantageous measures for
reducing flood risk.

The complainant also lamented the article’s lack of sources that would corroborate the main point
made by Dr. Feltmate in his interview: that climate change has led to extreme rainfall events
becoming more frequent in Canada. The quote is as follows:

“We are experiencing storms of greater magnitude, more volume of rain coming down
over short periods of time these days due to climate change. That is causing massive

Mr. Muir stated that Environment Canada data show that “there has been no change in extreme
rainfall statistics in southern Ontario, and in fact many decreasing trends.” He also cited the
response to a complaint that he made to CBC on a similar topic in November 2015, in which the
public broadcaster acknowledged, after checking with Environment Canada, that “[t]here has
been no significant change in rainfall events over several decades.”

Regarding the second part of his complaint, Mr. Muir noted that the Ontario Society of
Professional Engineers has publicly presented its opposition to Dr. Feltmate’s opinion, which is
stated in a 2017 report on flood risk mitigation measures.

The response to these criticisms could – and should – have been a simple one.

Let us first examine the contentious sentence in question. It reads:

“So called ‘100 year events’ are now occurring sometimes only a few years apart.”

That would be an accurate statement if the article was considering all climate-related events –
including tornadoes, droughts, heat waves, and forest fires – but that is clearly not the case here.
First of all, the article is about flooding, as can be seen from the many photographs illustrating it;
furthermore, the sentence immediately preceding the contentious sentence reads:
“In recent years, the news has been full of stories of bigger and more violent storms, and
massive rainfall and flooding.”

Thus, when the article goes on to mention “so-called ‘100 year events,’” it is clear that the events
being referred to are episodes of extreme rainfall.

One only had to examine the official Environment Canada data for Ontario as well as for the
entire country to acknowledge that the claim made in the article was inaccurate. Such
acknowledgement would at the same time have addressed the complainant’s criticism regarding
the lack of data to corroborate Dr. Feltmate’s claim about the increased frequency of extreme
rainfall events in Canada. To make that correction, and for it to be meaningful, the writer would no
doubt have had to change more than just the sentence in question – which, I admit, would have
contradicted, in part, the theory described in the article and the accompanying interview with
Dr. Feltmate. Thus the first two sentences in the article, after being amended transparently, per
best practices, would have been replaced by something along these lines:

“Although in recent years the news has been full of stories of bigger and more violent
storms, and massive rainfall and flooding, there is nothing to prove that this type of
precipitation event has been on the rise in Canada. Data compiled by Environment
Canada since the 1950s show that there has been no significant change in their

An insert should then have been added, explaining that the previous version of the article, as well
as part of the interview with Dr. Feltmate, contained inaccuracies in that respect, and that this
prompted RCI to publish the clarification.

In addition, the date of the most recent update (in this case, the correction) should have been
added at the head of the article, next to the original posting date. Of course, all of this would have
affected the article’s overall credibility. That is not the intended aim; rather, it is a consequence of
the inaccuracy pivotal to the article and the accompanying interview.

Admitting that an error has been found in an article is no cause for shame, and is not tantamount
to an admission of professional misconduct. It is possible for an interviewee to make a false
claim, whether inadvertently or otherwise, and for it to escape the notice of a journalist or host.
Dr. Feltmate has a PhD, is the head of the Intact Centre on Climate Adaptation at the University
of Waterloo, where he teaches in the Faculty of Environment, and is the lead author of a study
commissioned by the Insurance Bureau of Canada, which was the subject of the interview by
journalist Marc Montgomery. It was not unreasonable for the latter to quote the interviewee’s
remarks in the brief article accompanying the interview, even if in the process he involuntarily
conveyed incorrect information from the interviewee. I remind the reader that this was not a story
contrasting differing views on an issue, let along an investigative piece: it was an interview in
which the author of a study report outlined its main conclusions.

Rather that rectify the error by clearly acknowledging it through an explicit note in the text of the
online article, as best practices dictate, RCI chose to work around the problem. It wrote to the
complainant that the sentence at issue was “neither entirely true, nor entirely wrong,” removed it
from the text of the online article without providing any explanation to readers, and replaced it
with a sentence that had no real connection to the complaint:

“Scientists consulted on this question generally concluded that while actual rainfall
amounts in Canada have not varied much, when, where and how they occur have.”

The matter at hand here, however, is not increased total annual precipitation; as it is not total
rainfall in one year that can cause infrastructure overflow problems, and therefore flooding, but
episodes of extreme rainfall, or exceptional spring floods. (I will refrain from commenting here on
all of the other factors related to land-use planning that may in large part explain increased
flooding.) Once again, what should have been acknowledged was that the original text said that
extreme rainfall events were increasing – a claim refuted by Environment Canada data.
A study published by the Environment Canada Climate Research Division, which examined data
from 1953 to 2012, found that “[n]o consistent changes were found in heavy rainfall events.”
In my view, the response provided by RCI did not amount to a correction, but a substitution,
which does not comply with the values of transparency and accuracy articulated in the JSP,
specifically in the section that calls on CBC/Radio-Canada to “act responsibly and to be
accountable.” All the more so given that the amendment to the article was not accompanied by
any real explanation; only a note at the very end, which reads as follows and does not at all
appear to constitute acknowledgement that the original text contained a significant inaccuracy:

“[T]his article has been modified to include citations from experts (Zhang, Mann,
Flannigan) regarding the intensity and frequency of warming and extreme climate related

Moreover, whereas RCI informed the complainant, in its response, that the article had been
amended such that the sentence he had complained about had been replaced with another, in
fact five new paragraphs were added to the text. They deal with climate change around the world
and its effect on droughts, heat spells, wildfires, hurricanes in the United States, and the increase
in extreme rainfall events that is predicted to accompany warmer global temperatures. Here
again, this failed to address the complaint made by Mr. Muir, who had not questioned the
existence of climate change; he had merely asserted that there is no proof that climate change
has led to increased extreme rainfall episodes in Canada, as Dr. Feltmate claimed.
The admission that rising global temperatures have not had that effect in Canada is not a denial
that those temperature increases are happening. The response by RCI to Mr. Muir’s complaint,
however, gives the impression that this is how the complaint was construed – hence the
abundance of file attachments and links to articles and studies attesting to the reality of global
warming, and still others predicting that it will in the future result in increased extreme rainfall. I
note the inclusion, buried in the middle of the lengthy response from RCI, of an excerpt from
email correspondence with Xuebin Zhang, Senior Research Scientist, Environment Canada. He
is, incidentally, one of the authors of the Environment Canada study cited above. Dr. Zhang wrote
to journalist Marc Montgomery, while the latter was preparing his draft response to the complaint,

“For Canada as a whole, observational evidence of changes in extreme precipitation is

I must take RCI to task for not having drawn the obvious conclusion regarding the truthfulness of
the sentence that Mr. Muir complained about.

As regards Mr. Muir’s second grievance, I do not believe it is up to RCI to arbitrate a dispute
between the Ontario Society of Professional Engineers and a university research centre about
whether it is appropriate to mitigate flooding by rehabilitating wetlands in urban and near-urban
areas. Dr. Feltmate – a biologist – advocates that solution; Mr. Muir and the Ontario Society of
Professional Engineers do not share his opinion. RCI cited excerpts from the reports by the Intact
Centre accurately, without endorsing those conclusions. Furthermore, Mr. Muir had the
opportunity – two opportunities, in fact – to speak out and restate the facts as he sees them. First,
RCI published four comments by him below the initial article. Then, RCI invited him to be
interviewed to react to Dr. Feltmate’s claims.

Further considerations

In his reply to the first response from RCI, the complainant disputed some of its contents; for
example, the assertion that spring floods are now more severe because of climate change.

I will refrain from commenting on these secondary issues, as they do not concern the contents of
either of the RCI articles, but rather the correspondence between RCI and Mr. Muir. I feel the
case is already complex enough and there is no need to make it more so.
Second complaint
I note first of all that Mr. Muir did not complain about the interview per se, nor about its tone or the
nature of the questions asked of him by Mr. Montgomery. His comments were limited to the
contents of the accompanying article,9
entitled Response to a climate change story, posted on
November 19, 2018.

Mr. Muir complained that the article contained a graphic illustrating increases in annual rainfall in
Canada, which he deemed irrelevant because the interview (and indeed his complaint about the
first article) was about data on extreme rainfall events: this was the fundamental objection, the
reason for his dispute with RCI. I note with satisfaction that RCI acknowledged the merits of that
complaint and consequently removed the graphic. Unfortunately, in removing it RCI did not follow
best practices with regard to transparency. First, no date was provided to show when the article
had been updated; more important still, the note added at the foot of the article to explain the
change appears to me to be unduly insincere. It states: “the story has been modified to remove a
graphic from Environment Canada deemed not entirely relevant to the interview.” Acknowledging
an error in this manner (saying “not entirely” merely pays lip service to the issue) is counter to the
requirements of the JSP. The graphic was irrelevant, period.

Next, Mr. Muir complained that the article implied that his statement about the lack of any trend
toward increased extreme rainfall concerned only one region, southern Ontario. Two sentences
are at issue here. The first stated: Mr. Muir “maintains that in his region of southern Ontario,
rainfall levels are decreasing [. . .] .” Later, the article adds:

“It is entirely possible that small localised areas may experience different situations from
the global trend which points to human activity causing substantial climatic changes in
weather patterns and increasing damage to infrastructure.”

Considering the complainant’s repeated requests that RCI acknowledge that it was false to claim
that extreme rainfall episodes are on the rise, whether in southern Ontario or across Canada;
considering the multiple documentation he provided to RCI in support of that position; and
considering RCI’s clear and repeated refusals to acknowledge the error, I must conclude that
Mr. Muir was justified in interpreting those two sentences as a further attempt to downplay his
point of view and even distort its meaning. First, by scaling it down to a simple regional
perspective, and then by once again confusing the concepts of extreme rainfall events and overall
precipitation. I sought to understand the source of this muddled situation. The journalist,
Marc Montgomery, frankly admitted that he had decided from the start that he would “not give an
inch” to the complainant. That attitude, unfortunately, violates the JSP, specifically the section
that calls on CBC/Radio-Canada employees to “act responsibly and to be accountable,” which
goes on to say “we [. . .] are honest [and we] do not hesitate to correct any mistake [. . .] .”

A further aspect of Mr. Muir’s second complaint is his request that the article about his interview
contain a link to a document from the Ontario Society of Professional Engineers that discounts
the IBC and Intact Centre report on wetlands for urban flood mitigation (produced in 2017 by the
Intact Centre and largely written by Dr. Feltmate). RCI refused to comply with that request.
Under normal circumstances, I too would have refused. The choice of the angle and key points of
a story is the prerogative of the editorial staff. There will always be people ready to say that a
news story should have covered such-and-such an issue, should have mentioned an aspect that
was not, or should have provided another perspective. Regardless of the merits of such
criticisms, they would – if accommodated – deny one of the core elements of freedom of the
press: the freedom to choose the topic of a story and in turn to determine what aspects are worth
including in that story.

In the case that concerns us, however, I believe that Mr. Muir’s request was justified, considering
once again the manner in which he was presented: as nothing more than a municipal engineer
concerned only with data about the region he is familiar with, which may be a statistical anomaly;
a man who nevertheless opposes the conclusions of a serious academic study supported by the
Canadian insurance industry and those of the most recent report of the Environmental
Commissioner of Ontario on the importance of preserving wetlands as a means of preventing
flooding in urban areas. The document from the Ontario Society of Professional Engineers,
however, clearly shows that Mr. Muir’s objections are not merely a matter of his opinion. The
letter, signed by the organization’s president, states that “green infrastructure comes with high
lifecycle costs and is not considered an effective measure for achieving flood resiliency under
severe rainfall.”

I wrote above that it is not within the Ombudsman’s purview to referee this technical debate
pitting the insurance industry–funded studies of the Intact Centre on one side against Ontario’s
civil engineers on the other. I also believe that it is not up to RCI to take a position on the issue,
unless its opinion were the conclusion of an in-depth journalistic investigation. We are a long way
from that. And yet, taken together, the two RCI articles and the many links accompanying them,
all of which are to documents substantiating Dr. Feltmate’s view, give the reader the impression
that the case has been tried and Mr. Muir is an isolated voice preaching in the desert. This is not
consistent with the balance principle of the JSP, which states:

“On issues of controversy, we ensure that divergent views are reflected respectfully,
taking into account their relevance to the debate and how widely held these views are.”
In the case that concerns us, it stands to reason that the position of engineers – those who
design water drainage infrastructures – is entirely relevant with regard to the usefulness and
effectiveness of the measures advocated by Dr. Feltmate. It is true that Mr. Muir had the
opportunity to express that position in the interview that he gave to RCI. That should therefore
have been all the more reason for the article introducing the interview to be accompanied by a
link to the letter as a “supporting document.” Ultimately, had there been no link at the foot of the
article, the absence of the supporting document would be understandable.

But there are nearly ten such links, each pointing to documents that appear to be there to
undermine Mr. Muir’s position, which compounds the overall lack of balance here.
Speaking of missing links, I note that RCI had failed to include, in the original article, a referral to
the second one, despite the fact that it is a follow-up. When I mentioned this omission to them as
part of our discussions about this complaint, RCI management told me it had resulted from an
error in communication. They had asked that the referral be included; they told me the correction
would be made immediately, and it was. However, the link to the “follow-up” is so discreet that
there is little chance of it being noticed. It is written as follows:

“Counterpoint response to the IBC study- RCI: Nov 19/18.”

Can the average reader be expected to grasp, from those few words, that they constitute a
hyperlink to a follow-up to the RCI article they are reading? Will they understand that the main
theory being asserted in the article they are reading has been discounted by the official body
representing Ontario’s engineers? Will they suspect that the existence of the data on which the
article is founded – Dr. Feltmate’s claim that extreme rainfall events are on the rise in Canada – is
challenged in the follow-up article? I do not think so, and that is why I believe once again that this
further correction was inconsistent with best practices and does not live up to the “honesty”
principle of the JSP.

The reference to the Insurance Bureau of Canada report
Mr. Muir also challenged the accuracy of the second paragraph of the article accompanying his

“Here in Canada, the Insurance Bureau of Canada in a commissioned report said its
payouts from natural disasters have doubled every five years since 1980, and the
majority of those claims are from flooding due in large part to climate change.”
He stated that this assertion is false, advancing several arguments that cast doubt on the
accuracy, not of the sentence, but of the information it contains. Allow me to explain: while it is
true that a report of the Insurance Bureau of Canada states these things, that does not mean they
are true. Thus Mr. Muir was not questioning the journalist’s text so much as the report that it
describes. This situation resembles the first point of his first complaint, in which he criticized the
article accompanying the interview with Dr. Feltmate for perpetuating inaccurate information
about an increase in episodes of extreme rainfall in Canada.

In its response to the second complaint, RCI did not address that grievance, and merely
defended Dr. Feltmate’s qualifications by listing the conferences at which he has been invited to
speak. In my opinion this did not do justice to the seriousness of the arguments put forward by
Mr. Muir, which by that time he had shared with RCI. Yes, the sentence in question is rigorously
accurate in that it properly represents the position of the Insurance Bureau of Canada, but the
fact that it appears in the introduction to the article about the interview with Mr. Muir, without
noting that Mr. Muir disagrees with all of its points, appears to me to contradict the balance
principle of the JSP.

It seems to me that there are two possible solutions for correcting this situation: remove that
paragraph from the text of the article and attach an explanation for the change, or retain the
paragraph but follow it immediately with an account of the Mr. Muir’s objections to the Insurance
Bureau of Canada’s statements.

The scientific validity of the information reported
Finally, the two parties in this affair debated the scientific validity of the Intact Centre’s reports.
Were they peer reviewed or not? How many peers took part? Does the presence of a disclaimer
of responsibility in the reports mean they have no scientific value? And if so, should RCI have
refrained from citing them? In Mr. Muir’s opinion, RCI was promoting positions of the Insurance
Bureau of Canada report authors, who were “not licensed to formally advance” them. In short, he
wrote, RCI was “taking insurance industry-funded ‘glossy’ reports to be equivalent to formal
technical information.”

On this point, I cannot find in favour of the complainant. Information reported in the media comes
from a wide variety of sources. It does not have to be scientifically validated by a peer-review
process; in fact, it rarely is. Any citizen, association or interest group is entitled to speak their
mind, defend their point of view and engage in public debate. In doing so, they are not required to
have their positions approved beforehand by a panel of scientists. And it is a good thing they are
not, one might well argue; otherwise citizens’ freedom of expression would be greatly
constrained. I therefore reject Mr. Muir’s contention that RCI should report only the assertions of
“licensed” experts.


The two articles by journalist Marc Montgomery entitled How to mitigate the effects of flood
damage from climate change and Response to a climate change story, posted online on
September 19 and November 19, 2018, respectively by Radio Canada international (RCI), failed
to comply with the CBC/Radio-Canada Journalistic Standards and Practices (JSP) regarding
accuracy and impartiality. The corrections eventually made to the two articles were not compliant
with best practices, and violated the JSP principles on correction of errors and honesty.
As a result of the multiple shortcomings noted in my examination of this matter, I am
recommending that Radio-Canada review the RCI complaints processing procedure; provide
training on the JSP to RCI staff; make the necessary corrections to the two articles in question so
as to restore the accuracy and balance that are lacking; clearly indicate in the two articles that
they were the subject of a review by the Office of the Ombudsman and include a link to that
review; and, lastly, publish a notice of correction in the Mises au point (Erratum) section of the
Radio-Canada website.

Guy Gendron
Ombudsman, French Services, CBC/Radio-Canada
January 28, 2019