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 [. . .] .” 

CONCLUSION

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: http://www.rcinet.ca/en/2018/09/19/how-to-mitigate-the-effects-and-flood-damage-from-climate-change/

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.

FOREWORD

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.


http://www.rcinet.ca/en/2018/09/19/how-to-mitigate-the-effects-and-flood-damage-from-climatechange/

http://www.rcinet.ca/en/2018/11/19/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.

COMPLAINT

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.

RESPONSE FROM NEWS DEPARTMENT

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.

REPONSE FROM MR. MUIR

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.

INTERVIEW WITH MR. MUIR AND ACCOMPANYING ARTICLE

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.

SECOND COMPLAINT BY MR. MUIR

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
data.”

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.

SECOND RESPONSE FROM RCI

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.”

REQUEST FOR REVIEW

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.”

REVIEW

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
):

“Accuracy
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.”

“Balance
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
flooding.”

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
frequency.”

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
events.”

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,
that:

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

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
interview:

“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.

CONCLUSION

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

WEATHERING THE STORM: DEVELOPING A CANADIAN STANDARD FOR FLOOD-RESILIENT EXISTING COMMUNITIES

I'm glad Intact Centre on Climate Adaptation could build on my work for their new report WEATHERING THE STORM: DEVELOPING A CANADIAN STANDARD FOR FLOOD-RESILIENT EXISTING COMMUNITIES https://www.intactcentreclimateadaptation.ca/wp-content/uploads/2019/01/Weathering-the-Storm.pdf

The report relied on input including this blog post prepared for the Intact Centre authors' consideration: Reducing Flood Risk from Flood Plain to Floor Drain Developing a Canadian Standard for Design Standard Adaptation in Existing Communities  https://www.cityfloodmap.com/2018/02/reducing-flood-risk-from-flood-plain-to.html
(e.g., as noted in the March 2018 draft of the Intact Centre report)

The Intact Centre Weathering the Storms report has some gaps regarding the key question of the role of green infrastructure, natural infrastructure and engineered low impact development practices, in terms of mitigating existing urban flood risks. In other reports, Intact Centre has advocated strongly for green infrastructure as a core flood risk mitigation measure - as in the 2018 report  Combating Canada’s Rising Flood Costs: Natural infrastructure is an underutilized option, co-written with IBC and IISD which stated (page 4):

“Nature conservation and climate resilience go hand in hand,” said Craig Stewart, Vice-President, Federal Affairs, IBC. “This report emphasizes that coastal and inland flood risk can be reduced by conserving and restoring natural infrastructure, such as wetlands and coastal marshes, and that the return on investment of natural infrastructure can at times exceed that of built infrastructure, such as dams and dikes. Nature can be our best friend in lowering the risk of exposed communities.”

That Combating Canada's Rising Flood Cost report also promoted "green infrastructure" measures like open creeks, natural ponds and underground storage tanks to mitigate existing flood risks saying (see page 4):

"Fortunately, as documented in this report, flood risk can be limited through conservation and restoration of natural infrastructure features, such as ponds, wetlands and vegetated areas. This report demonstrates how to quantify the benefits and costs of these natural features as a strong complement or a viable alternative to grey infrastructure option for flood mitigation."

and

"natural infrastructure merits consideration alongside grey infrastructure solutions as a means of limiting flood risk across all levels of government and all jurisdictions"

Unfortunately, the Combating Canada's Rising Flood Cost report had many gaps in terms of the rigour in which flood benefits were assessed in case studies, such that analysis was characterized as 'number stretching" and "concept massaging" in a review in the Financial Post (see Terence Corcoran article here). My review of those case studies agrees with the Financial Post assessment, since engineering and economic analysis was lacking - for example, one-time capital cost differences were reported as recurring annual ecosystem services for one case study (Oakville natural channel), local flood damages were replaced with higher, arbitrary 'meta-analysis' values for another (Manitoba wetland). In addition, the report's key case study (Brampton Metrolinx parking lot) misclassified a conventional grey infrastructure storage tank as green infrastructure, and relied on arbitrary river flood damage values a tributary with no actual river flood damage risks. A review of these and other case studies was in my 2018 CWWA annual conference presentation - see presentation here.

And in a recent report, TOO SMALL TO FAIL: Protecting Canadian Communities from Floods, Intact Centre notes "Flood Risk Mitigation Projects" include rain gardens, bioretention, and permeable pavement and that these are practical and can be applied nationally calling these (page 13):

"practical adaptation solutions that could be replicated in communities across Canada to limit flood risk at a local level"

That earlier report concludes that (page 38):

"If future projects are deployed on scale, the additive benefits could materially reduce the costs of flooding at the provincial and federal level."

But, despite the strong promotion in earlier reports, the new Weathering the Storm report only weakly advocates for natural infrastructure preservation and low impact development practice (green infrastructure) consideration alongside grey infrastructure to address overland flooding, and the cost-effectiveness is left up in the air. The new report notes (see page 34):

"Maintain natural infrastructure (e.g., wetlands and watercourse corridors) and consider low impact development practices to complement grey infrastructure solutions for stormwater management"

The report notes the Capital Cost is "Med" (i.e., medium) and the Ease of Implementation is "Moderate". This is misleading as it conflates two completely different strategies. Maintaining wetlands and natural corridors in existing communities has no capital cost, not medium capital cost, and is certainly an effective damage mitigation planning policy. Historically, it has been proven that Ontario's floodplain management policies have lowered flood damages relative to other jurisdictions that do not have proactive management and preservation of valley corridors (see example comparison with Michigan).  But low impact development practices have a very high capital cost and a very high operation and maintenance cost too. To put a range of risk management measure capital costs into perspective we can look at Markham's '"green" land use policies, lot-level best practices and programs, and its sewer capacity upgrade programs (grey infrastructure), and compare those unit costs to low impact development (green infrastructure) unit costs (updated 2019-01-26):

Preserving Wetlands and Watercourse Corridors: $ 0 / hectare (lands are dedicated to City)
Sanitary Downspout Disconnection & Backwater Valve Subsidy Program:  $ 1,300 / hectare
Sanitary Sewer Capacity Upgrades: $ 11,000 / hectare
Storm Sewer Capacity Upgrades: $ 120,000 / hectare
Low Impact Development / Green Infrastructure Retrofits: $726,000 / hectare

So the Intact Centre report mixes a no cost land use policy with a very high cost physical intervention, and averages a medium cost. This can only create confusion as to what types of green infrastructure are truly cost-effective. While earlier reports cite specific practices as flood control measures, e.g., with the Too Small to Fail report identifies i) Mississauga's water quality bioswales and permeable pavement, ii) Dionis-Désilets retention basin vegetation planting, and iii) Halifax St Mary's Boat Club shoreline stabilization, the Intact Centre Weathering the Storm report does not even define what low impact development practices it has considered, and only refers to green infrastructure once in a case study (see page 29), however that was in the context of non-flood considerations of "drinking water supply, water quality, soil erosion, water balance, and overall public well-being". Hopefully there can be clarifications in follow-up work.

As the new Intact Centre report applies to "Existing Communities" it is unclear if "Maintain natural infrastructure" reduces risk at all or just maintains existing risk. The title to Section 4.4 Selected Physical Interventions to Reduce Flood Risk, suggests reduction was intended.

Comments shared by those in the acknowledgement list for the report included the need to downplay the role of low impact development measures, and the need to consider cost effectiveness of measures and not just cost. Those comments do not seem to be reflected in the report but the limitation is acknowledged that  (page 33) "Further, capital cost rankings are not normalized with
consideration of performance effectiveness." - this is in contrast with recent Intact Centre reports that make strong conclusions on cost-effectiveness, and relative effectiveness compared to conventinal practices - By including low impact development measures as a medium cost flood mitigation measure, the Intact Centre report appears to support earlier Intact Centre reports (like Too Small to Fail) that had essentially "reclassified" water quality improvement projects, such as Mississauga's Lakeview permeable pavement and bioretention units, as a flood mitigation projects.  The earlier Intact Centre/IBC/IISD report Combating Canada's Rising Flood Costs, also "reclassified" a conventional grey infrastructure storage tank on a Metrolinx parking lot as a "green infrastructure" project. Clearly there is a need for more clarity on what low impact development practices or green infrastructure measures are, and what their individual costs are. Without this, it is challenging to determine what practices or measures are truly cost-effective and to what degree they should be considered in overall risk reduction strategies.

To help look at cost-effectiveness in this report, I had provided comments to the authors from August to October, 2018, however these were not accepted for consideration.  This included earlier analysis on grey and green cost effectiveness that has been refined and is that is summarized below. This analysis could fill that gap left in the Intact Centre report, showing how considering low impact development to complement grey infrastructure would affect total cost and benefit/cost ratios for flood mitigation.  In addition the effectiveness at achieving other watershed benefits such as water quality improvements and erosion mitigation can also be measured, considering the broader triple bottom line benefits of green infrastructure. This analysis summarized below is based on retrofitting Markham's pre-1980 service areas that are being evaluated as part of its city-wide Flood Control Program and its city-wide Wastewater Servicing Master Plan.  The study area is equivalent to an area of approximately 2360 hectares, or 25% of the city's urban area. Further results of this analysis will be presented in the Spring 2019 Water Environment of Ontario and conference and the 2019 TRIECA conference.

The table below illustrates a range of flood mitigation strategies within 25% of the pre-1980 urban area:

Strategy A - 100% grey infrastructure,
Strategy B - 100% green infrastructure, and
Strategy C - 90% grey + 10% green infrastructure,

The table includes the benefit/cost ratios associated with each strategy. Ratios are shown for flood damage mitigation, water quality improvement and erosion repair mitigation. Contact me if you would like to see the detailed calculations behind these values, or wait for distribution of the WEAO conference paper.

Grey and Green Infrastructure Benefit-Cost Ratios for Flood Damage Reduction, Water Quality Improvements and Erosion Mitigation (Pre-1980 Service Areas, City of Markham) - Approved Flood Control Program reflects Scenario A Grey Infrastructure approach.
The key take-away is that grey infrastructure (Scenario A) has the highest cost-effectiveness and highest benefit/cost ratio - this approach, with the majority of costs associated with storm sewer upgrades, aligns with the city's approved Municipal Class EA recommendations and Flood Control Program.  The green infrastructure / low impact development practices approach (Scenario B) has a very low benefit/cost ratio such that cost exceed benefits - over half of the Scenario B benefits are intangible based on a willingness to pay for water quality improvements. A blended approach with only 10% green infrastructure in the retrofitted urban area (Scenario C) reduces cost-effectiveness and the benefit/cost ratio relative to a 100% grey infrastructure approach (i.e., benefit/cost for flood mitigation drops from 2.52 to 0.80, making a strategy that adds 10% green infrastructure lose over two thirds of its cost effectiveness). Given these costs, it is clear that the Intact Centre's classification of grey infrastructure sewer upgrades is incorrect. The report notes (page 34) this physical intervention:

"Increase the size of deficient storm and sanitary sewers to allow for additional conveyance capacity"

has a "High" capital cost and that the ease of implementation is "Complex". In fact the capital cost and lifecycle cost of grey infrastructure are significantly lower than that of green infrastructure / low impact development practices. Further, the cost-effectiveness to provide flood damage reduction, shown in the benefit/cost ratio, is high which implies a low cost for the performance achieved.

The following chart shows how incorporating a range of green infrastructure (between Scenario A and Scenario B) affects total costs and benefit/cost ratios. In brief, given the high cost of green infrastructure, implementation of any amount in a strategy only lowers the overall cost-effectiveness (lower benefit/cost ratio). While some water quality improvement and erosion mitigation benefits accrue as more green infrastructure is implemented, the triple bottom line benefits do not offset the additional costs. This holds true even with generous water quality benefits that consider an intangible 'willingness to pay' for such improvements.


It is a long-standing principle that flood mitigation measures be cost effective, and that benefits of deferred damages exceed project costs. Watt promotes this in Hydrology of Floods in Canada and Eckstein has done so since his founding work at Harvard in the 1950's. Maximizing benefits requires that incremental measures in a strategy proceed only where incremental benefits exceed incremental costs. Given that most urban flood reduction strategies are founded on proven, low cost engineering methods (i.e., grey infrastructure capacity upgrades), any further consideration of green infrastructure would have to demonstrate further incremental benefits exceeding cost - this consideration does not appear to be justifiable given the unit cost for implementation, especially within a strategy that has already reduced damages with core measures, making further incremental benefits harder to realize. The analysis above shows that even adding 10% green infrastructure to a strategy (10% of pre-1980's urban areas, which is only 2.5% of total urban areas) drops cost-effectiveness for flood control by over two thirds. Given the limited resources available for infrastructure upgrades to address flood risks, and most likely some funding limits, it would appear to unwise to limit total flood mitigation benefits that could be achieved by considering green infrastructure in the strategy. Keeping spending constant, 25% of a city could be retrofitted with Strategy A - 100% Grey Infrastructure, while only 8% of that city could be retrofitted with Strategy C - 90% Grey Infrastructure + 10% Green Infrastructure with similar funding. Higher costs with Strategy B - 100% Green Infrastructure would allow only 1% of urban areas to be retrofitted -note this reflects operation and maintenance costs as well as capital costs.

The Intact Centre Weathering the Storm report provides some very limited estimates of green infrastructure cost-effectiveness, and implies a favourable benefit/cost performance.  But the report fails to identify the flood benefits relative to other benefits, and it ignores local flood damage data in published research, substituting instead IBC/Intact Centre/IISD's 'meta-analysis' presented in the Combating Rising Flood Cost report. The Weathering the Storm report states (page 42):

"Performance monitoring results: In 2017, University of Saskatchewan researchers assessed the net economic benefits of Pelly’s Lake project at $3,700,148 CAD, assuming a 20-year life cycle and 3% discount rate. This assessment reflected the value of flood attenuation, nutrient load reduction (phosphorus and nitrogen) and carbon dioxide offset benefits."

In fact, the benefits quoted above were based on generic literature search flood benefits cited by IBC/Intact Centre/IISD and not the University of Saskatchewan's published research. The Combating Rising Flood Cost report reveals this as follows (page 20):

"In 2017, University of Saskatchewan researchers assessed the economics of Pelly’s Lake and disseminated their analyses in three peer-reviewed publications.61, 62, 63 The return on investment analysis that follows is based on these publications, with Table 3 summarizing the key inputs in the calculation."

Those Table 3 values are repeated in the Weathering the Storm report. So the Weathering the Storm report is not in fact University of Saskatchewan's assessed flood benefits. Rather benefits are per IBC/Intact Centre/IISD's earlier report stating (page 20):

"The unit flood risk reduction benefit ($740 per hectare) applied to Pelly’s Lake is adapted from two published meta-analyses of the benefits provided by wetlands in agricultural landscapes."

As noted on this blog in a previous post, the IBC/Intact Centre/IISD "meta-analysis" inflates the flood benefits from only a few percentages of total benefits using University of Saskatchewan published values to 20% of benefits.  It is questionable if terminology "performance monitoring results" should be used to characterize this "meta-analysis" based only on global literature values.  Also, the Weathering the Storm report fails to note the cattail harvesting benefits of the Pelly's wetland would not be consistent with the suggested approach of "Maintaining natural infrastructure (wetlands ...", due to the obvious habitat interference with such an activity.  Based on flood benefits alone, the Pelly's Lake project benefits would be less than the cost.

Conclusions in the Weathering the Storm report notes some next steps but fails to identify the need for robust benefit-cost analysis on mitigation measures, especially those green infrastructure measures heavily promoted in other recent Intact Centre reports.  Table 4 implies that green infrastructure that relies on infiltration would be part of mitigation strategies as it notes an advanced flood risk information requirement as "Detailed/discrete soil data to inform intelligent application of source control techniques (practices applied to reduce water runoff where it originates)". But no further examples of "source controls" are noted in the report, although these can be expected to include the "low impact development practices" identified for consideration in Section 4.4.2.  The Weathering the Storm Report capital cost classification for physical interventions is questionable in relation to green infrastructure relative to grey infrastructure - it does not appear to represent costs identified locally or in the US, nor reflect fundamental cost-effectiveness ranking as illustrated in the benefit/cost of various strategies above.  The report also conflates diverse types of green infrastructure, wetland preservation and low impact development practices, in a single 'catch all' group, despite the vastly different costs associated with these - correspondence with one of the authors in early 2018 revealed that no distinction is considered between the broad groups of green infrastructure including natural assets (wetlands), enhanced assets (rain gardens) or engineered assets (permeable pavement) - see definitions here. In the case studies, only meta-analysis is presented for an engineered wetland, and the flood benefits are not clearly identified, but rather aggregated with a range of other benefits.  Those benefits included 'cattail harvesting' that would not be practical in most instances where wetlands are valued for their natural heritage value, and where harvesting would have an adverse environmental impact.  Hopefully the gaps in the Weathering the Storm report can be explored in the development of national standards.