Financial Post Identifies Gaps in Insurance Industry Statements on Extreme Rain Causes, Flood Losses Trends, and Effective Mitigation Strategies

Terence Corcoran's article today covers a lot of the science and engineering that cityfloodmap.com has been exploring and promoting over the past few years. It is great to see many of our findings reflected in the mainstream media now. Wow!

Terence Corcoran is a National Post columnist and one of Canada's leading business writers and editors and he has been writing on the insurance industry, climate change and flooding for a couple decades. In his article today he explores the topics of:

1. Catasrophic loss trends, including flooding and the effects of GDP growth on trends as well as the influence of different data sets - we have explored that extensively in a previous post suggesting loss trends are not increasing as dramatically as the media suggests.

2. Green infrastructure implementation costs - we showed that those are prohibitive as in a previous post looking at Ontario-wide implementation city-by-city, and then again when looking at Ontario-wide lifecycle cost in another post.

3. Green infrastructure can make flooding worse - that is due to infiltration into already stressed wastewater systems as noted by the US Transportation Research Board, WEAO, and Ontario and US cities and local experts, as noted in a previous post.

4. Green infrastructure has questionable cost efficiencies as we see in a Metrolinx 'green' parking lot that is actually benefiting from a 'grey' traditional engineered stormwater detention tank- we have further shown that traditional grey engineered infrastructure has a better return on investment than green infrastructure as assessed in a detailed Class EA study and through a city-wide technology review benefit/cost analysis summarized in this post.

5. Green infrastructure and natural infrastructure does not reduce flood damages - contrary to what is promoted by the insurance industry like in the recent IBC report - it does not reduce flood damages according to the Ontario Society of Professional Engineers, and cannot cost-effectively reduce US river flood damages as described in this post.

6. Storms are not more frequent or intense due to climate change, and the insurance industry has made up "Insurance Fact" statements that has been rejected by insurance companies as reliable advertising - this was explored in a previous post and in our paper in the Journal of Water Management Modeling called "Evidence Based Policy Gaps in Water Resources: Thinking Fast and Slow on Floods and Flow"; https://www.chijournal.org/C449

Thank you Terence Corcoran for helping to shed light on these topics!

Are LIDs Financially Sustainable in Ontario? Philadelphia Green Infrastructure Costs - 1100 Low Impact Development Projects Define Implementation Funding for Long Term CSO & Water Quality Improvement - Comparison with 24 Ontario Projects

Philadelphia Green Stormwater Infrastructure Projects Map - Over 1100
Low Impact Development Projects for CSO Control

See September 2019 Update at Bottom of This Post

Philadelphia has an extensive green infrastructure retrofit program with cost information - recent Ontario low impact development project costs show comparable unit cost for implementation.

***

The City of Philadelphia implements green infrastructure (GI), aka low impact development (LID) best practices (BMPs), to control combined sewer overflows (CSOs).  Having implemented 1100 features in a retrofit setting, Philadelphia has a clear understanding of retrofit implementation costs. The following is a summary of their green infrastructure design construction costs provided by the city program staff:

City of Philadelphia Green Infrastructure / Low Impact Development Best Management Practices - Construction, Design and Planning Budgets Per Total and Impervious Area

Construction Cost
- $175,000 per acre ($432,000 per hectare)

Philadelphia Green Infrastructure Map by SWP / LID Type 

- $270,000 per impervious acre ($667,000 per hectare)

Design Cost
- Design fees typically 20-25% of construction costs

Total Cost (Design & Construction)

Philadelphia Green Infrastructure Map - Spatial Location
of Low Impact Development Measure

- Total costs of $230,000 per acre ($568,000 per hectare)
- Total costs of $350,000 per impervious acre ($865,000 per hectare)

Budgeting
-  $350,000 per impervious acre ($865,000 per hectare) is the overall target/budget cost that is achieved for the program and that does not include contingencies that could be carried for individual projects within the program.
- If estimated costs exceed $400,000 per acre ($988,000 per hectare) based on design estimates and project cannot be re-scoped, it is deemed too expensive and does not go ahead.

In Ontario, green infrastructure has been promoted for stormwater management in new developments since the Ministry of Environment's 1991 Interim Guidelines. Green infrastructure measures were promoted as part of a 'source control' approach and features that promoted infiltration were called Best Management Practices (BMPs). Since then, Ontario cities have developed design targets for achieving specific water resources management goals and have implemented LID BMP measures in appropriate locations. In the City of Markham and York Region, his history was summarized in a National Water and Wastewater Benchmarking Initiative Stormwater Task Force presentation:

Green Infrastructure / Low Impact Development LID Design Tool and Lifecycle Costing NWWBI Stormwater Task Force Robert Muir City of Markham from Robert Muir

The presentation above summarized LID implementation costs for nine (9) recent Ontario projects including bioswales, bioretention, infiltration galleries and permeable pavement. Theses cost are receiving close attention as LID implementation targets in some regions have been increased, e.g., through the Lake Simcoe Protection Act to meet environmental protection / phosphorus reduction goals, and as generic province-wide targets are now being evaluated by the Ministry of Environment and Climate Change.

Additional Ontario LID project implementation costs have been compiled with information shared by Ontario municipalities and also the Lake Simcoe Regional Conservation Authorit. This expands/updates the project costs in slide 17 of the above presentation. These costs include construction, design, administration and in-kind staffing efforts related to implementation of LID projects in the City of Markham (2 projects), City of Brampton (1 project) Town of Whitchurch-Stouffville (1 project), City of Ottawa (2 projects), Town of Ajax (1 project), City of Mississauga (3 projects), Town of Newmarket (2 projects), City of London (7 projects), Town of East Gwillimbury (1 project), Town of Uxbridge (1 project), Town of Aurora (1 project), Town of Innisfil (1 project).

The project costs and unit costs per total catchment are are shown below:

Ontario Green Infrastructure / Low Impact Development Best Management Practice Implementation Costs (No Adjustment for Inflation to 2018 Dollars) - Normalized Unit Costs Per Catchment Area Managed

This is a link to the above compiled Ontario LID costs (let me know if you have projects to add or can suggest edits / updates): Excel - Ontario Low Impact Development BMP / Green Infrastructure Implementation Cost Summary - 24 Projects

The average cost per hectare of $575,000 for these 24 projects is very close to the City of Philadelphia budget cost of $568,000. Cost per impervious hectare treated by the LID BMP would typically be higher (i.e., catchment is less that 100% impervious). Some notes regarding the project costs:

- complete costs are not available for some projects (e.g., Markham Green Road bioswale vegetation)
- one service area has been adjusted based on different sources (e.g., East Gwillimbury area reflect municipality's project brief and not original TRIECA 2017 presentation value).
- one projects has only tender cost estimate available, not actual construction cost (e.g., Newmarket Forest Glenn Rd)
- one project from LSRCA was not included in the list as it did not proceed to construction, but nonetheless incurred design and administration costs (e.g., City of Barrie, Annadale Recreation Centre, design/administration/geotechnical/in-kind staff cost of over $78,000) - this may reflect go/no go decisions on implementation that the others also consider
- most projects are retrofits, however some are new builds (Markham Green Road, Innisfil Fire Station)
- bioswales/enhanced swales require review given the wide range in unit costs per hectare of $51,000 (Uxbridge) to nearly $1.9M (Newmarket), with obvious sensitivity to the drainage area served

Previous cost estimates cited on this blog considered unit costs of approximately $400,000 per hectare and significant concern regarding the financial viability of any widespread implementation across Ontario's 852,000 urbanized hectares. Considering the expanded project cost review and adjusting for inflation, today's Ontario green infrastructure implementation costs can be estimated to be in the order of $600,000 per hectare. This magnitude of cost is comparable to Philadelphia's budgeting cost, considering over 1100 projects. These costs support the concern related to emerging Ontario policies that have not considered implementation cost impacts or financial viability.

The Ontario Society of Professional Engineers (OSPE) has recently highlighted concerns with the implementation of green infrastructure in Ontario in comments on Ontario's Long-Term Infrastructure Plan (my bold emphasis on the recommendations)

"....OSPE recommends that the Government of Ontario:

i. Critically apply the proposed ‘risk lens’ to infrastructure investments related to extreme
weather adaptation, recognizing variations in observed and predicted trends across the
province.

ii. Evaluate adaptation measures such as green infrastructure for stormwater management,
often cited as key mitigation measure, using the same ‘risk lens’ and consider the cost-
effectiveness of those infrastructure investments.

iii. Recognize that green infrastructure must be viewed through the same lens as
conventional infrastructure, adhering to established asset management principles and
full cost accounting—meaning it must be addressed up-front and directly, considering
system-wide costs."

OSPE has also commented on the limited role of green infrastructure for flood control and life cycle cost concerns in response to Ontario's draft Watershed Planning Guidance.

"Recommendation:

Green infrastructure LID implementation costs should be acknowledged to be potentially higher
than conventional grey infrastructure design, particularly for retrofits, and funding for additional
incremental retrofit costs should be considered in the comprehensive evaluation of alternative
management solutions beside green infrastructure and LIDs, including enhanced conventional
grey infrastructure designs with pollution prevention activities. Higher retrofit costs compared to
greenfield implementation should also be acknowledged.

Consideration for disproportionate costs should be acknowledged as a prohibitive constraint in
general and for linear development retrofits or widespread watershed implementation. A more
strategic approach to green infrastructure implementation, based on local needs and
considering local constraints (infiltration impacts and property flooding) is warranted."

"Recommendation:

The additional lifecycle cost associated with green infrastructure should be acknowledged to
support budgeting for long term operation, maintenance and depreciation.

The cost impacts of green infrastructure in existing communities should also be quantified
including costs in communities that are susceptible to infiltration stresses and sewer back-up
risks, additional treatment costs as infiltrated water is collected in foundation drains and
conveyed to treatment plants and cost of reduced service life of cast iron and ductile iron
watermains due to chloride infiltration in right-of-ways (i.e., accelerated corrosion). Such a
robust and holistic economic analysis can then support more strategic, financially sustainable
implementation policies for green infrastructure."

Let's work toward this sustainable implementation policies for all infrastructure - including green infrastructure - considering costs and strategic goals and specific performance outcomes. Low impact development implementation costs in the order of $600,000 per hectare, as shown through local and other jurisdictions, are simply not sustainable on a broad, system-wide basis.

RJM

***

September 2019 Update

Additional projects have been reviewed in Ontario and a couple have been added from Edmonton, Alberta.  The resulting average cost per hectare (area-weighted) is $581,000.  The following table presents a summary of cost per LID type (porous/permeable pavement, rain garden/bioletention, bioswale and infiltration/exfiltration).

The Ontario/Alberta costs now represent almost 8 hectares of catchment area, close to the EPA BMP database catchment area for projects with costs data (middle column).  Note that the Ontario/Alberta project costs may include several types of LID types in the treatment train.

Green Infrastructure Implementation Constraints in Flood Prone Partially-Separated Wastewater Systems

So what happens when green infrastructure infiltrates runoff into the ground in a densely-developed city? Does it disappear and sustain an aquifer and watercourse baseflows? That's the theoretical benefit. Or does it end up in foundations drains (weeping tiles) making its way to the local wastewater treatment plant on low rain days and contributing to sewer back-ups on the high rain days? its the latter. It is surprising how quickly foundation drains respond to surface water inputs - Toronto Water presented at the National Research Council expert panel this week that it takes only 4 minutes for surface water to end up in foundation drains!

Municipal wastewater engineers have know this for a while - that systems with no apparent direct inflows of rainwater or runoff respond quickly to rainfall. My work on a Municipal Class Environmental Assessment in Kitchener, Ontario showed the greatest correlation of wastewater peak wet weather extraneous flows was to the 5-minutes rainfall intensity. Often we expect groundwater collection systems in cities respond slowly to rainfall volumes - they don't. The respond rapidly to short duration rainfall.

So what does this have to do with green infrastructure and the suite of sweet low impact development measures many are going gaga over? Well, its the impact of GI and LID runoff infiltration on wastewater systems. Quick and clear impact. At the NRC expert panel this week I summarized a list of documents that expressed concern for GI and LID wastewater system impacts including aggravated basement flooding due to this infiltration. This is the list:

1) Water Environment Association of Ontario (July 17, 2017 memo) 

Identifies concerns of interference with wastewater systems (flood impacts), water distribution systems (chlorides/corrosion), human health impacts to drinking water distribution (compliance with Procedure F-6-1), excessive costs:

https://drive.google.com/open?id=1T3vXEJ_nBi8e30KpcawVTfFPKx7A6y_v

2) City of Ottawa (February 23, 2017 letter)

Indicates "While the intent appears to be not to "make things worse or better" (specifically with respect to current condition runoff volumes), there should be recognition of situations in older neighbourhoods (with partially separated sewers, for example) where increased infiltration should be avoided given the cumulative impacts over time that could raise groundwater levels leading to increased risk of basement flooding, increased I & I to sanitary sewers, etc.”:

https://drive.google.com/open?id=12IQjlaKvbCakqx7Brw9DJ97Oi5a0OHx-

3) City of Barrie (July 10, 2017 letter) 

Identifies financial impacts, capital cost increase of 200%, lifecycle cost increase of 550%, concerns for “damage to private properties and excessive sewer infiltration”, LIDs “highly susceptible to failure due to sand accumulation” :

 https://drive.google.com/open?id=1HDd24FpFmLsFTAA7kEdC5mk8N8Oau8Ox

4) City of Guelph (June 28, 2017 memo)

"Guelph downtown stone rubble masonry heritage buildings are prone to flooding with raised groundwater elevation; any additional infiltration measures using LIDs may aggravate basement flooding due to leaky masonry walls and severe impacts on the buildings structural stability; in addition, impacts on aged infrastructures such as, watermain corrosion, potable water quality interference (F-6-1) and enhanced sanitary infiltration can be anticipated.”

https://drive.google.com/open?id=1OAnqraDz9NuBD1ZCsY4dzeDXeyZzf66-

5) City of Markham (July 14, 2017 memo)

Identifies sanitary infiltration impacts, adjacent property impacts, excessive capital cost based on completed tenders, high soft cost, high lifecycle costs, chlorides/watermain corrosion:

https://drive.google.com/open?id=1RGwiyeaqihdmjI2owDY0R-Cw9CcGbEKu

6) Ministry of the Environment / Workshop on Stormwater Quality Best Management Practices (1992)

Identifies impacts of on-site infiltration source controls called Best Management Practices (BMPs):
 " - basement leakage problems related to infiltration near housing
   - surcharging of sanitary sewers by short circuiting of infiltrated water”
Therefore the impacts of green infrastructure have been long-known in Ontario. Unfortunately, green infrastructure is often cited as a panacea for water resources challenges in Ontario, often when only narrow view of is taken that ignores existing municipal infrastructure systems and practical constraints associated with the infiltration of large quantities of chloride and contaminant-laden stormwater runoff.

7) US Transportation Research Board / Evaluation of Best Management Practices for Highway Runoff Control, Issue 565 (2006)

Identified inflow and infiltration (I/I) risks with infiltration green infrastructure (BMPs) in urban areas:
“In urban areas, unrestricted infiltration may exacerbate infiltration and inflow (I/I) problems in both separate and combined systems”

https://books.google.ca/books?id=jKR-CF7PG6AC&printsec=frontcover&source=gbs_ge_summary_r&cad=0#v=onepage&q&f=false

7) City of Seattle / Street Edge Alternatives Project (city web site)

Identified bioretention groundwater impacts to adjacent properties through engineering analysis, indicating that green infrastructure introduces property flood risks:

"Our original hope for retaining flows and allowing infiltration into the native soils throughout the length of the block was not possible because some homes had an existing groundwater intrusion problem. To limit the potential for stormwater to adversely impact the residences of concern, our geotechnical engineers identified some swales that needed an impermeable liner.” :

http://www.seattle.gov/UTIL/EnvironmentConservation/Projects/GreenStormwaterInfrastructure/CompletedGSIProjects/StreetEdgeAlternatives/DrainageImprovements/index.htm

We could go on and on. The InfraGuide on inflow and infiltration, the CSA guideline on IDF curves - these all note the issue with infiltration stresses on wastewater systems.

Green energy in Ontario gave us smart metres that did not improve the flow of money. Green infrastructure can give us smart swales that will not improve the flow of groundwater .. OK, in partially-separated sewersheds.

Urban groundwater flow has been called the darkest of the dark arts, making hydrology look like algebra - call wastewater systems groundwater infiltration analysis something fancy like the RTK method and it sounds scientific, but there is really just a mysterious system of 'urban karst' of hidden pathways and problems lurking under the surface. A black box. Those of us in the industry who have worked closely on wastewater smoke and dye tests know that adjacent laterals 'speak to each other' and the subsurface flow is erratic and unpredictable.

As Jeff Goldblum said in Jurassic Park, 'Nature Finds a Way', and the natural flow of infiltrated water finds a way too ... right into foundation drainage and overtaxed wastewater systems. As Adrienne Barbeau said in The Fog "Be afraid, be very afraid" ... as there is huge fog surrounding green infrastructure and low impact development measures - we should re afraid of what these things will do to our wastewater systems.

Green Infrastructure Infiltration Increases Urban Flood Risks? GI Benefits in New Development Can Worsen Existing Infrastructure Stresses in Old Developments.

Cincinnati Bioswale

There is no doubt that Green Infrastructure (GI) or Low Impact Development (LID) measures are an essential tool in a water manager or municipal engineer's modern tool kit. In new developments, distributed green infrastructure, and even more centralized features, including rain gardens, bioswales, perforated pipes or pavers and infiltration galleries can help manage typical water balance impacts of urbanization by reducing downstream erosion stresses, sustaining natural heritage features like wetlands and streams that are often home to sensitive aquatic and terrestrial species. GI and LID measures do this largely by infiltrating urban runoff from hardened impermeable surfaces like rooftops and roadways or parking lots into the ground (see Ontario Ministry of Environment and Climate Change Interpretation Bulletin, February 2015). In some areas of the province that rely on groundwater for municipal water supply, these measures may also help sustain source water quantity and make aquifers more resilient to climate variability, especially long term droughts (e.g., see page 159, Policy ID REC-1 in APPROVED SOURCE PROTECTION PLAN: CTC Source Protection Region, 2015).

But....

In existing development areas, especially those built before the 1980's, infiltrating water into the ground as part of a GI or LID retrofit can have a significant downside for old muncipal infrastructure and private properties. That is because older infrastructure is sensitive to groundwater levels that drives infiltrated runoff into utility trenches, thorough cracks between joints of municipal sanitary sewers and service laterals, and into 1000's of kilometers of foundation drains surrounding properties with basements - drains that in many older areas connect to the sanitary sewer and ultimately drain to the municipal wastewater treatment plant.

This post explores how GI and LID infiltration stresses in old development areas can affect flooding risks, sewer overflow risks and watewater treatment costs in Ontario cities.

The risks from infiltration on wastewater systems is well-known. The Ontario Municipal Knowledge Network (OMKN) has highlighted the cost of treating infiltrated water and inflows in its 2008 General Inflow & Infiltration Management Practices - Best Practices Summary Report, also noting the first challenge related to Inflow and Infiltration (I&I or I/I) management is: "Protecting customers from basement flooding". Other concerns are "Increased flow to wastewater treatment plants and increased operating costs at the plants due to the excess volume of water requiring treatment". The OMNK's Best Practices Report Inflow and Infiltration - Increasing System Knowledge Through Flow Monitoring notes the drivers for managing I&I in Peel Region:

"There have been two catalysts for the Region’s I/I programs and studies: exceedance of system and plant capacities leading to sewer overflow and basement flooding occurrences"

More recently, infiltration has been noted as a concern by the insurance industry in terms of the lost wastewater system capacity and the impacts on basement flooding and insurance losses / damages. The Institute for Catastrophic Loss Reduction's investigations have recently indicated that " I/I directly contributes to flooding by filling up pipes with water, using up capacity that could convey larger storms".

And the potential impacts of GI and LID measures on wastewater system infiltration in Ontario was recognized ages ago -the former Ministry of the Environment conducted a Workshop on Stormwater Quality Best Management Practices in 1992 following the introduction of on-site infiltration source control LIDs called Best Management Practices (BMPs). The comprehensive Workshop Summary prepared by Marshall Macklin Monaghan Limited identifies concerns with on-site infiltration measures and these included:

“- basement leakage problems related to infiltration near housing

- surcharging of sanitary sewers by short circuiting of infiltrated water”

Lets look at quantifiable impact of groundwater infiltration on wastewater systems. For background, let's notes that groundwater infiltration is classified into two types in the sanitary sewer design profession:

• Groundwater Infiltration (GWI)
• Rainfall Dependent Inflow and Infiltration (RDII)

Groundwater Infiltration , Rainfall Dependent Inflow and Infiltration,
and other wastewater flow components to assess GI and LID Impacts.
From "An Approach for Estimating Groundwater Infiltration Rates
into Wastewater Collection Systems under Typical Year Conditions",
Zhang et. al. 2013

GWI is considered one component of Dry Weather Flow (DWF) which also includes Base Wastewater Flow (BWF). The hydrographs at right show these components of wet weather flow and are from An Approach for Estimating Groundwater Infiltration Rates into

Wastewater Collection Systems

under Typical Year Conditions by Li Zhang, Fang Cheng, Robert Herr, Gregory Barden, Hunter Kelly and Edward Burgess in " Journal of Water Management Modeling, R246-21. doi: 10.14796/JWMM.R246-21

Many GI and LID features are designed to get rain runoff or snow melt into the ground. The benefit in new development areas is that these practices sustain aquifer levels that in turn preserve baseflow rates to creeks (i.e., 'environmental flows') that sustain natural features. But the disbenefit in old areas is that raising groundwater levels raises GWI, using up sanitary sewer capacity that is no longer available during a big storm. As a result, when GWI goes up, so does basement flooding / sewer back-up risk because the previous wastewater system conveyance capacity is no longer available.

Groundwater Infiltration GWI Increases with Higher Precipitation.
From "An Approach for Estimating Groundwater Infiltration Rates
into Wastewater Collection Systems under Typical Year Conditions",
Zhang et. al. 2013

Can we quantify how infiltration affects GWI? Yes - using climate records and monitored wastewater flow rates, studies have correlated GWI rates to the amount of precipitation. At right, GWI in Cincinnati shows a strong correlation to precipitation on an annual basis. More precipitation means more infiltration, meaning higher GWI.

March Groundwater Infiltration GWI Increases Correlated
with Previous 15 Day Precipitation Total.
From "An Approach for Estimating Groundwater Infiltration Rates 
into Wastewater Collection Systems under Typical Year Conditions",
Zhang et. al. 2013

Seasonal influences of precipitation on GWI have also been found, with the highest spring GWI rates affected by precipitation over the previous 15 days. Zhang et. al's analysis in Cincinnati shows that if the previous 15 days were dry (no rain) the GWI flow at the plant was below 60 MGD, while with 2 inches of precipitation (about 50 mm), the GWI rate increased to about 90 MGD, a 50% increase.

Zhang et. al concluded "Significant positive

linear relationships were found between GWI and precipitation both annually

and monthly. The annual relationship showed that the adjusted R2 of the

regression result is 0.78, indicating that 78% of the varation of the yearly average

WWTP GWI can be explained by the annual precipitation."

LID Runoff Reduction Benefits Can Lead to Groundwater Infiltration Stresses

In old developments with no GI or LID, limited precipitation infiltrates. It generally just runs off, collected in storm sewer systems. So only a small fraction of runoff is infiltrated. Monitoring by Credit Valley Conservation of the Elm Drive bioswale LID show the change in runoff when LIDs are retrofitted, indicating "69% of all rainfall is detained and infiltrated" in one study. The graph at right illustrates the runoff reduction benefit. Some detained runoff is evaporated or transpired by soil and vegetation in the LID feature, but some is infiltrated into the ground where it contributes to GWI and a portion of RDII. 

If half the runoff captured in the LID infiltrates, that would be equivalent to 35 % of rain infiltrating, as opposed to about 10% or less without the LID measure (i.e., 25% more infiltration). In the Toronto area, considering about 700 mm of rainfall a year, that would be like adding 25% x 700 mm = 175 mm of water into the ground each year (about 7 inches). In Cincinnati, 7 inches of annual precipitation increased GWI by 20% - that is before any runoff transformation or evaporation losses. So adding 7 inches of water directly into the ground with an LID would have an even more pronounced impact on GWI, with potentially more than a 20% increase. Added to this long term, slow GWI response impact, would also be short duration RDII increases that even further reduce wastewater system capacity as the extreme events infiltrate into LID measures as well. Practitioners know that even fully separated wastewater systems where inflow sources have been addressed can have large RDII components, suggesting that infiltration can have a fast response as well, taking away peak flow capacity. 

The take-away is that what is a benefit to new developments is not typically one in old developments, across cities with existing GWI and RDII stresses and resulting basement flooding risks and treatment costs that can be made worse by infiltrating rain the previously was runoff.

Any positive impacts to wastewater systems with GI and LID measures? Yes, potentially a few in some isolated areas.

Consider existing infrastructure
impacts when evaluating green
infrastructure and low impact
development measures effects on
groundwater, wastewater
system capacity and operating costs.

There area where GI and LID may contribute to positive wastewater system performance is in combined sewer areas. In those areas, holding back runoff in GI and LID measures that would enter combined sewers could reduce combined sewer overflows (CSO's) - but not all Ontario cities have combined sewers. In Toronto, only 23% of the systems are combined. Also, GI can be expensive compared to other technologies (about $400,000 per hectare in capital costs, or about $1.3M-1.5M per kilometre of retrofitted roadway). An often cities have F-5-5 control strategies and operation improvements that make GI and LID implementation redundant. For example in Toronto, wastewater and stormwater runoff from combined sewer areas will collected and fully treated as part of projects needed for operational improvements (e.g., to regularly maintain and bypass the main Coxwell Ave. sewer) - so adding LID and GI measures on top of other infrastructure projects that will already virtually eliminate CSO's would appear to be redundant, with high incremental added costs and limited marginal benefits.

Environmental Impacts of Green Infrastructure Construction - CO2 Emissions for Soil Removal and Aggregate Extraction & Transportation, Ontario Impacts

Etobicoke Infiltration System - Green Infrastructure for
Stormwater Infiltration and Low Impact Development

Like any infrastructure that requires material resources and energy to construct, green infrastructure is no different than grey infrastructure. This post looks at a typical low-impact-development (LID) feature for stormwater runoff control and estimates the CO2 impacts of its initial construction, excluding traffic impacts during construction, and excluding impacts for ongoing operation and maintenance, or rebuilding at end of lifecycle. Emissions are then scaled up across Ontario in light of green infrastructure policies being considered province-wide. The GHG emissions are huge for building green infrastructure !

For this example, consider a perforated pipe and gravel trenches for infiltration of stormwater runoff, like the Etobicoke Infiltration system pioneered in pre-amalgamation City of Toronto. This is a typical green infrastructure configuration - see Ryerson University's Planning and Design Manual at this link. We can assume a simple arrangement with the perforated pipe and gravel trench beyond the roadway, say in the boulevard.

Napkin - engineer's friend ... especially when
they run out of envelopes to scribble on the back of.

The construction of the perforated pipe infiltration system requires transport of various materials to and from the construction for initial construction. Lets assume we are considering 1 cubic metre of infiltration storage volume in the system. Some activities and their resulting kilometre-tonnes of transportation are estimated on this blog-napkin, if you will, aka an educated Fermi Estimate:

1) excavation, transport and disposal of native soil material - if the facility is in a retrofit setting the sodium adsorption ratio of the soil (due to road salt chloride accumulation over time) means reuse could be limited. Assume the disposal site may be a distance of 40 km from the construction site. For each cubic metre of infiltration storage, lets assume a 40% voids ratio in the gravel infiltration trench, meaning each cubic metre needs 1/0.4 - 1.2 cubic metres of soil disposed, and at a density of about 2 tonnes per cubic metre. So 40 x 1.2 x 2 = 96 km-tonnes of native soil haulage.


2) transport and placement of clear stone - assume aggregate comes from a quarry 40 km away from the site. For each cubic metre of infiltration storage, and our 40% voids ratio in the gravel, each cubic metre of storage needs 1/0.4 - 1.2 cubic metres of clear stone. At a density of 1.6 tonnes per cubic metre (3/4 inch clear stone), there is 40 x 1.2 x 1.6 = 76.8 km-tonnes of gravel haulage.

The OECD indicates pollution for truck transport in a report that indicates 140 grams of CO2 emitted per tonne-km. So adding 1 +2 above, a total of about 173.8 km-tonnes of green infrastructure construction to achieve 1 cubic metre of runoff storage results in 173.8 x 0.14 = 24.3 kg of CO2 emissions.

3) quarrying gravel - based on 4.32 kg CO2 emitted per tonne from this source, each cubic metre of infiltration storage with 40% voids requires 1/0.4 - 1.2 cubic metres of clear stone. At a density of 1.6 tonnes per cubic metre again, there is 4.32 x 1.2 x 1.6 = 8.29 kg CO2 per cubic metre of storage.

The MOECC is targeting 25 mm or more of green infrastructure storage and/or treatment which means per hectare of urban development with 50% rain/runoff there is 10,000 x 0.025 x 0.5 = 125 cubic metres of runoff and green infrastructure storage needed. So 125 x 24.3 = 3037.5 kg of CO2 emitted per hectare of urban area retrofitted with this low impact development feature. That is just haulage. To quarry the gravel adds 8.29 x 125 = 1036.8 kg per hectare. Total is 4074.3 kg per hectare of green infrastructure runoff treatment. Is that big?

Ontario has 825,000 hectares of untreated urban area.

Given the Ontario-wide 852,000 hectares of urban area that would need green infrastructure retrofits under the draft MOECC policy, the Ontario-wide CO2 emitted to initially build green infrastructure would be 852,000 x 4074.3 = 3,471,303,600 kilograms of CO2 emitted. Say 3.5 million tonnes of CO2 added.

So over 3 billion kilograms to build green infrastructure to manage runoff - you could argue there is some nominal climate mitigation offset-benefit if there is some type of vegetated pre-treatment filter before the perforated pipe / gravel infiltration. If so, that would be offset by the frequent inspection and minor maintenance visits by municipal crews, year after year.

Note in Canada the per capital emission was 20.1 tonnes CO2 equivalent in 2015 according to Environment and Climate Change Canada. So retrofitting green stormwater infrastructure in Ontario will emit CO2 equivalent to all the CO2 emitted by 172,000 Canadians over an entire year. That is just initial construction.

So that is just a neat Fermi Problem on green infrastructure to consider along the the other considerations on cost, cost-effectiveness, impacts to existing infrastructure, and need for scientifically-based local targets for green infrastructure. Currently, MOECC is considering blanket green infrastructure retrofit targets that do not consider any cost constraints or any no environmental impacts of construction like CO2 emissions. Earlier posts note that impacts to iron watermains and flood prone sanitary sewer systems was ignored. Let's hope a more holistic approach emerges that recognizes that we can't build millions of tonnes of infrastructure, green, grey or purple, and not have big impacts to emissions etc.

Green infrastructure for stormwater management, just like green energy for power supply has significant negative impacts. It should not be viewed as a panacea for urban stormwater and water resources management issues in Ontario. Check out this post on costs and other impacts.

Expensive Green Infrastructure Retrofits Unaffordable for Ontario Road Network - Low Impact Development's Financial Impact is Staggering

Ontario urban areas requiring LID retrofits with proposed
 MOECC policy on volume control for stormwater runoff

Get ready for municipal and provincial tax increases to pay for a new proposed green initiative in Ontario.

A previous post estimated the cost of proposed 'greening' policies in Ontario, specifically to retrofit the province with low impact development, LID, green infrastructure. The previous cost was determined considering urban areas defined in Ontario GIS datasets. The cost was $332 billion dollars considering a unit retrofit cost of $390,000 per hectare (10,000 sq.m) of catchment draining to each retrofit LID feature, which averages unit costs of completed projects as well as literature values for other LID technologies. The total cost considered 852,045 hectares of urban land in Ontario municipalities that does not have LID servicing according to high volume control targets proposed in draft MOECC LID guidance. But that cost excluded LID road retrofits in areas outside Ontario municipal boundaries. That old cost sounds like a bargain if we now add in the costs for roads outside municipalities! 

Ontario roadway network requiring GI green infrastructure retrofits with
proposed MOECC policy on volumetric controls for urban runoff / recharge

A new cost estimate based on Ontario's road network mapping and an awarded construction tender cost in York Region shows an even higher, unaffordable cost for low impact development, green infrastructure retrofits. The cost is $376 billion dollars with a $258 billion dollar cost for municipal roads and $118 billion dollars for roads outside municipalities. That total costs considers 278,307,020 kilometres of roadway in Ontario and a green infrastructure additional costs of $1.35 million per kilometre of LID retrofitted roadway. Roadways outside municipalities have a length of 87,203,550, according to GIS datasets available from the province.

Why look at Ontario roadways as the basis for assessing green infrastructure retrofits? Because the proposed Ontario policy for LID retrofits mandates the addition of this new infrastructure whenever a road is repaved or rebuilt and whenever new infrastructure is added (like a new sewer for flood control or a new watermain).

Here is the cost per each Ontario municipality for green road retrofits based on road lengths from Ontario GIS sources and the $1.35 million per kilometre unit retrofit cost:

Low Impact Development LID / Green Infrastructure Retrofit Cost per Ontario Municipality
LEGALNAME1 Ontario Municipality  per Open Data GIS Dataset	Roadway Length With LID Retrofit Required (metres)	Retrofit LID Cost at $1.35M Per Kilometre (Green Road Cost)
City of Barrie	609211.75	$822,435,863
City of Belleville	511338.39	$690,306,827
City of Brampton	1970211.528	$2,659,785,563
City of Brantford	531107.503	$716,995,129
City of Brockville	146093.801	$197,226,631
City of Burlington	972684.596	$1,313,124,205
City of Cambridge	712912.156	$962,431,411
City of Clarence-Rockland	392040.939	$529,255,268
City of Cornwall	303512.987	$409,742,532
City of Dryden	180764.392	$244,031,929
City of Elliot Lake	394905.447	$533,122,353
City of Greater Sudbury	2693460.888	$3,636,172,199
City of Guelph	619596.026	$836,454,635
City of Hamilton	3542392.528	$4,782,229,913
City of Kawartha Lakes	3252603.987	$4,391,015,382
City of Kenora	362644.032	$489,569,443
City of Kingston	1094613.238	$1,477,727,871
City of Kitchener	1032717.523	$1,394,168,656
City of London	1990808.466	$2,687,591,429
City of Mississauga	2443271.925	$3,298,417,099
City of Niagara Falls	863326.67	$1,165,491,005
City of North Bay	673623.501	$909,391,726
City of Orillia	202702.678	$273,648,615
City of Oshawa	744481.595	$1,005,050,153
City of Ottawa	6990005.798	$9,436,507,827
City of Owen Sound	131376.175	$177,357,836
City of Pembroke	105894.431	$142,957,482
City of Peterborough	433936.725	$585,814,579
City of Pickering	647494.477	$874,117,544
City of Port Colborne	339912.941	$458,882,470
City of Prince Edward County	1123901.013	$1,517,266,368
City of Quinte West	862893.943	$1,164,906,823
City of Sarnia	622722.771	$840,675,741
City of Sault Ste. Marie	580594.497	$783,802,571
City of St. Catharines	797352.234	$1,076,425,516
City of St. Thomas	207006.43	$279,458,680
City of Stratford	186998.578	$252,448,080
City of Temiskaming Shores	309026.51	$417,185,788
City of Thorold	263606.99	$355,869,437
City of Thunder Bay	938653.173	$1,267,181,784
City of Timmins	863127.741	$1,165,222,450
City of Toronto	6657317.792	$8,987,379,019
City of Vaughan	1437527.578	$1,940,662,230
City of Waterloo	549894.14	$742,357,089
City of Welland	405113.246	$546,902,882
City of Windsor	1325026.504	$1,788,785,780
City of Woodstock	290832.431	$392,623,782
County of Brant	1360738.654	$1,836,997,183
Haldimand County	1544911.091	$2,085,629,973
Municipality of Arran-Elderslie	473630.036	$639,400,549
Municipality of Bayham	317616.616	$428,782,432
Municipality of Bluewater	526055.641	$710,175,115
Municipality of Brighton	342695.313	$462,638,673
Municipality of Brockton	587083.158	$792,562,263
Municipality of Brooke-Alvinston	313557.134	$423,302,131
Municipality of Callander	108899.059	$147,013,730
Municipality of Central Elgin	371697.958	$501,792,243
Municipality of Central Huron	548817.082	$740,903,061
Municipality of Centre Hastings	225959.657	$305,045,537
Municipality of Charlton and Dack	80220.698	$108,297,942
Municipality of Chatham-Kent	3637304.9	$4,910,361,615
Municipality of Clarington	1241185.755	$1,675,600,769
Municipality of Dutton/Dunwich	367777.33	$496,499,396
Municipality of French River	340502.493	$459,678,366
Municipality of Gordon / Barrie Island	186732.419	$252,088,766
Municipality of Greenstone	773001.1	$1,043,551,485
Municipality of Grey Highlands	876546.751	$1,183,338,114
Municipality of Hastings Highlands	745040.14	$1,005,804,189
Municipality of Highlands East	716014.551	$966,619,644
Municipality of Huron East	727266.639	$981,809,963
Municipality of Huron Shores	486565.585	$656,863,540
Municipality of Killarney	128569.832	$173,569,273
Municipality of Kincardine	636138.048	$858,786,365
Municipality of Lambton Shores	546814.48	$738,199,548
Municipality of Leamington	410712.656	$554,462,086
Municipality of Magnetawan	352908.348	$476,426,270
Municipality of Markstay-Warren	273184.478	$368,799,045
Municipality of Marmora and Lake	278156.36	$375,511,086
Municipality of McDougall	278164.957	$375,522,692
Municipality of Meaford	568453.205	$767,411,827
Municipality of Middlesex Centre	799312.314	$1,079,071,624
Municipality of Morris-Turnberry	359703.452	$485,599,660
Municipality of Neebing	566143.4	$764,293,590
Municipality of North Grenville	518411.883	$699,856,042
Municipality of North Middlesex	635555.6	$858,000,060
Municipality of North Perth	543091.778	$733,173,900
Municipality of Northern Bruce Peninsula	587259.546	$792,800,387
Municipality of Oliver Paipoonge	367118.28	$495,609,678
Municipality of Port Hope	438825.219	$592,414,046
Municipality of Powassan	199408.819	$269,201,906
Municipality of Red Lake	157031.392	$211,992,379
Municipality of Shuniah	401885.724	$542,545,727
Municipality of Sioux Lookout	244535.551	$330,122,994
Municipality of South Bruce	503807.529	$680,140,164
Municipality of South Huron	478854.274	$646,453,270
Municipality of Southwest Middlesex	536734.657	$724,591,787
Municipality of St.-Charles	127228.602	$171,758,613
Municipality of Temagami	1884132.957	$2,543,579,492
Municipality of Thames Centre	557452.228	$752,560,508
Municipality of the Nation	666833.16	$900,224,766
Municipality of Trent Hills	684788.245	$924,464,131
Municipality of Tweed	516288.753	$696,989,817
Municipality of Wawa	138464.435	$186,926,987
Municipality of West Elgin	411372.456	$555,352,816
Municipality of West Grey	910801.499	$1,229,582,024
Municipality of West Nipissing	1980866.136	$2,674,169,284
Municipality of West Perth	635020.33	$857,277,445
Municipality of Whitestone	328691.713	$443,733,813
Norfolk County	2147169.561	$2,898,678,907
Town of Ajax	464279.651	$626,777,529
Town of Amherstburg	325249.136	$439,086,334
Town of Arnprior	79360.952	$107,137,285
Town of Aurora	269299.074	$363,553,750
Town of Aylmer	42152.021	$56,905,228
Town of Bancroft	207944.632	$280,725,253
Town of Blind River	258574.508	$349,075,586
Town of Bracebridge	675275.312	$911,621,671
Town of Bradford West Gwillimbury	365127.572	$492,922,222
Town of Bruce Mines	20364.997	$27,492,746
Town of Caledon	1071922.44	$1,447,095,294
Town of Carleton Place	66024.627	$89,133,246
Town of Cobalt	16076.321	$21,703,033
Town of Cobourg	145245.652	$196,081,630
Town of Cochrane	299050.764	$403,718,531
Town of Collingwood	184447.122	$249,003,615
Town of Deep River	110191.63	$148,758,700
Town of Deseronto	15718.621	$21,220,138
Town of East Gwillimbury	408145.785	$550,996,810
Town of Englehart	16809.68	$22,693,068
Town of Erin	364205.649	$491,677,626
Town of Espanola	97189.573	$131,205,924
Town of Essex	452002.584	$610,203,488
Town of Fort Erie	589570.242	$795,919,827
Town of Fort Frances	85080.966	$114,859,304
Town of Gananoque	46461.681	$62,723,269
Town of Georgina	579886.843	$782,847,238
Town of Goderich	72756.121	$98,220,763
Town of Gore Bay	19487.885	$26,308,645
Town of Gravenhurst	733781.335	$990,604,802
Town of Greater Napanee	511466.933	$690,480,360
Town of Grimsby	251820.813	$339,958,098
Town of Halton Hills	531445.601	$717,451,561
Town of Hanover	53897.404	$72,761,495
Town of Hawkesbury	58832.159	$79,423,415
Town of Hearst	99949.439	$134,931,743
Town of Huntsville	821582.761	$1,109,136,727
Town of Ingersoll	85720.272	$115,722,367
Town of Innisfil	573651.096	$774,428,980
Town of Iroquois Falls	295127.011	$398,421,465
Town of Kapuskasing	123221.579	$166,349,132
Town of Kearney	533097.986	$719,682,281
Town of Kingsville	446498.878	$602,773,485
Town of Kirkland Lake	95204.891	$128,526,603
Town of Lakeshore	905414.526	$1,222,309,610
Town of Lasalle	220848.528	$298,145,513
Town of Latchford	157348.309	$212,420,217
Town of Laurentian Hills	1107806.058	$1,495,538,178
Town of Lincoln	450686.8	$608,427,180
Town of Marathon	77083.984	$104,063,378
Town of Markham	1397425.979	$1,886,525,072
Town of Mattawa	27509.98	$37,138,473
Town of Midland	149073.214	$201,248,839
Town of Milton	836239.235	$1,128,922,967
Town of Minto	323938.9	$437,317,515
Town of Mississippi Mills	491706.164	$663,803,321
Town of Mono	346690.541	$468,032,230
Town of Moosonee	61657.614	$83,237,779
Town of New Tecumseth	422609.534	$570,522,871
Town of Newmarket	314408.47	$424,451,435
Town of Niagara-on-the-Lake	395114.46	$533,404,521
Town of Northeastern Manitoulin and the Islands	283205.93	$382,328,006
Town of Oakville	982334.902	$1,326,152,118
Town of Orangeville	126976.695	$171,418,538
Town of Parry Sound	64337.777	$86,855,999
Town of Pelham	288845.968	$389,942,057
Town of Penetanguishene	102355.421	$138,179,818
Town of Perth	48111.989	$64,951,185
Town of Petawawa	311887.38	$421,047,963
Town of Petrolia	48165.789	$65,023,815
Town of Plympton-Wyoming	408769.281	$551,838,529
Town of Prescott	38686.203	$52,226,374
Town of Rainy River	17209.322	$23,232,585
Town of Renfrew	69354.518	$93,628,599
Town of Richmond Hill	688323.893	$929,237,256
Town of Saugeen Shores	306747.783	$414,109,507
Town of Shelburne	35743.102	$48,253,188
Town of Smiths Falls	68365.875	$92,293,931
Town of Smooth Rock Falls	79871.583	$107,826,637
Town of South Bruce Peninsula	586613.57	$791,928,319
Town of Spanish	47908.552	$64,676,545
Town of St. Marys	59296.848	$80,050,745
Town of Tecumseh	281423.843	$379,922,188
Town of the Blue Mountains	371581.89	$501,635,552
Town of Thessalon	25209.716	$34,033,117
Town of Tillsonburg	131618.723	$177,685,276
Town of Wasaga Beach	268670.559	$362,705,255
Town of Whitby	674167.595	$910,126,253
Town of Whitchurch-Stouffville	466689.699	$630,031,094
Township of Addington Highlands	591316.843	$798,277,738
Township of Adelaide-Metcalfe	360395.038	$486,533,301
Township of Adjala-Tosorontio	412807.018	$557,289,474
Township of Admaston/Bromley	428521.518	$578,504,049
Township of Alberton	82158.406	$110,913,848
Township of Alfred and Plantagenet	410060.47	$553,581,635
Township of Algonquin Highlands	1001759.859	$1,352,375,810
Township of Alnwick/Haldimand	533661.735	$720,443,342
Township of Amaranth	299053.848	$403,722,695
Township of Armour	195124.622	$263,418,240
Township of Armstrong	87254.96	$117,794,196
Township of Ashfield-Colborne-Wawanosh	625708.955	$844,707,089
Township of Asphodel-Norwood	207208.151	$279,731,004
Township of Assiginack	184054.954	$248,474,188
Township of Athens	122669.414	$165,603,709
Township of Atikokan	210339.319	$283,958,081
Township of Augusta	332621.746	$449,039,357
Township of Baldwin	42295.904	$57,099,470
Township of Beckwith	276789.592	$373,665,949
Township of Billings	174653.773	$235,782,594
Township of Black River-Matheson	511572.46	$690,622,821
Township of Blandford-Blenheim	466096.319	$629,230,031
Township of Bonfield	224340.81	$302,860,093
Township of Bonnechere Valley	568149.944	$767,002,424
Township of Brethour	48856.465	$65,956,228
Township of Brock	526774.919	$711,146,141
Township of Brudenell, Lyndoch and Raglan	831333.656	$1,122,300,436
Township of Burpee and Mills	115289.638	$155,641,011
Township of Calvin	152558.53	$205,954,015
Township of Carling	213345.777	$288,016,799
Township of Carlow/Mayo	224345.236	$302,866,069
Township of Casey	72437.905	$97,791,172
Township of Cavan-Monaghan	385797.411	$520,826,505
Township of Central Frontenac	695205.884	$938,527,943
Township of Central Manitoulin	361506.578	$488,033,880
Township of Centre Wellington	619625.378	$836,494,260
Township of Chamberlain	87018.941	$117,475,570
Township of Champlain	228098.586	$307,933,091
Township of Chapleau	29081.644	$39,260,219
Township of Chapple	311635.629	$420,708,099
Township of Chatsworth	601718.275	$812,319,671
Township of Chisholm	206489.366	$278,760,644
Township of Clearview	629191.652	$849,408,730
Township of Coleman	181722.915	$245,325,935
Township of Conmee	126593.165	$170,900,773
Township of Cramahe	309178.344	$417,390,764
Township of Dawn-Euphemia	522805.062	$705,786,834
Township of Dawson	237410.684	$320,504,423
Township of Dorion	191073.903	$257,949,769
Township of Douro-Dummer	430814.376	$581,599,408
Township of Drummond/North Elmsley	406955.991	$549,390,588
Township of Dubreuilville	80899.864	$109,214,816
Township of Ear Falls	133729.338	$180,534,606
Township of East Ferris	191300.404	$258,255,545
Township of East Garafraxa	195402.812	$263,793,796
Township of East Hawkesbury	259167.931	$349,876,707
Township of East Luther Grand Valley	163781.414	$221,104,909
Township of East Zorra-Tavistock	281994.21	$380,692,183
Township of Edwardsburgh/Cardinal	373730.18	$504,535,743
Township of Elizabethtown-Kitley	541706.306	$731,303,513
Township of Emo	133270.426	$179,915,075
Township of Enniskillen	320615.56	$432,831,006
Township of Essa	341697.212	$461,291,236
Township of Evanturel	84821.571	$114,509,121
Township of Faraday	182460.043	$246,321,058
Township of Fauquier-Strickland	346889.692	$468,301,084
Township of Front of Yonge	155914.801	$210,484,981
Township of Frontenac Islands	223025.36	$301,084,236
Township of Galway-Cavendish and Harvey	668382.213	$902,315,988
Township of Gauthier	36240.843	$48,925,138
Township of Georgian Bay	1138404.474	$1,536,846,040
Township of Georgian Bluffs	565633.703	$763,605,499
Township of Gillies	80726.11	$108,980,249
Township of Greater Madawaska	1096522.321	$1,480,305,133
Township of Guelph/Eramosa	348024.638	$469,833,261
Township of Hamilton	413236.447	$557,869,203
Township of Harley	93682.365	$126,471,193
Township of Harris	67468.497	$91,082,471
Township of Havelock-Belmont-Methuen	492837.956	$665,331,241
Township of Head, Clara and Maria	1100836.108	$1,486,128,746
Township of Hilliard	71298.048	$96,252,365
Township of Hilton	134205.645	$181,177,621
Township of Hornepayne	67535.621	$91,173,088
Township of Horton	183048.22	$247,115,097
Township of Howick	323191.264	$436,308,206
Township of Hudson	114012.68	$153,917,118
Township of Huron-Kinloss	510866.435	$689,669,687
Township of Ignace	53726.418	$72,530,664
Township of James	38561.013	$52,057,368
Township of Jocelyn	138472.153	$186,937,407
Township of Johnson	129152.633	$174,356,055
Township of Joly	138926.603	$187,550,914
Township of Kerns	72252.459	$97,540,820
Township of Killaloe, Hagarty and Richards	419923.023	$566,896,081
Township of King	511603.128	$690,664,223
Township of La Vallee	161565.322	$218,113,185
Township of Laird	129711.819	$175,110,956
Township of Lake of Bays	706825.761	$954,214,777
Township of Lake of the Woods	168147.366	$226,998,944
Township of Lanark Highlands	730141.745	$985,691,356
Township of Larder Lake	54658.155	$73,788,509
Township of Laurentian Valley	631360.54	$852,336,729
Township of Leeds and the Thousand Islands	709493.998	$957,816,897
Township of Limerick	158475.284	$213,941,633
Township of Loyalist	419060.734	$565,731,991
Township of Lucan Biddulph	179608.308	$242,471,216
Township of Macdonald, Meredith and Aberdeen Additional	148981.378	$201,124,860
Township of Machar	163695.145	$220,988,446
Township of Machin	263325.06	$355,488,831
Township of Madawaska Valley	877412.68	$1,184,507,118
Township of Madoc	219539.625	$296,378,494
Township of Malahide	437657.466	$590,837,579
Township of Manitouwadge	57177.357	$77,189,432
Township of Mapleton	560984.13	$757,328,575
Township of Matachewan	103072.967	$139,148,505
Township of Mattawan	344897.423	$465,611,521
Township of Mattice-Val Côté	95378.273	$128,760,669
Township of McGarry	33570.823	$45,320,611
Township of McKellar	139461.414	$188,272,909
Township of McMurrich-Monteith	149589.032	$201,945,193
Township of McNab/Braeside	319334.617	$431,101,733
Township of Melancthon	333520.671	$450,252,906
Township of Minden Hills	779964.122	$1,052,951,565
Township of Montague	223674.913	$301,961,133
Township of Moonbeam	133002.408	$179,553,251
Township of Morley	216959.676	$292,895,563
Township of Mulmur	299503.381	$404,329,564
Township of Muskoka Lakes	1161698.953	$1,568,293,587
Township of Nairn and Hyman	74891.495	$101,103,518
Township of Nipigon	60340.843	$81,460,138
Township of Nipissing	212188.627	$286,454,646
Township of North Algona Wilberforce	381456.138	$514,965,786
Township of North Dumfries	289747.239	$391,158,773
Township of North Dundas	547013.455	$738,468,164
Township of North Frontenac	672059.243	$907,279,978
Township of North Glengarry	613801.404	$828,631,895
Township of North Huron	213074.403	$287,650,444
Township of North Kawartha	529539.749	$714,878,661
Township of North Stormont	480349.235	$648,471,467
Township of Norwich	548449.737	$740,407,145
Township of O'Connor	86238.645	$116,422,171
Township of Opasatika	67522.379	$91,155,212
Township of Oro-Medonte	874662.256	$1,180,794,046
Township of Otonabee-South Monaghan	425364.485	$574,242,055
Township of Papineau-Cameron	885874.698	$1,195,930,842
Township of Pelee	69418.636	$93,715,159
Township of Perry	222366.071	$300,194,196
Township of Perth East	729113.274	$984,302,920
Township of Perth South	371548.972	$501,591,112
Township of Pickle Lake	122105.951	$164,843,034
Township of Plummer Additional	200011.721	$270,015,823
Township of Prince	50140.005	$67,689,007
Township of Puslinch	340140.103	$459,189,139
Township of Ramara	487067.132	$657,540,628
Township of Red Rock	32506.443	$43,883,698
Township of Rideau Lakes	951878.09	$1,285,035,422
Township of Russell	284287.986	$383,788,781
Township of Ryerson	123051.135	$166,119,032
Township of Sables-Spanish Rivers	377357.127	$509,432,121
Township of Schreiber	22597.321	$30,506,383
Township of Scugog	602260.906	$813,052,223
Township of Seguin	671234.044	$906,165,959
Township of Severn	812368.461	$1,096,697,422
Township of Sioux Narrows-Nestor Falls	405012.076	$546,766,303
Township of Smith-Ennismore-Lakefield	538607.327	$727,119,891
Township of South-West Oxford	446958.837	$603,394,430
Township of South Algonquin	1019119.914	$1,375,811,884
Township of South Dundas	634243.59	$856,228,847
Township of South Frontenac	1063377.171	$1,435,559,181
Township of South Glengarry	686396.357	$926,635,082
Township of South Stormont	542344.264	$732,164,756
Township of Southgate	611738.5	$825,846,975
Township of Southwold	370682.321	$500,421,133
Township of Springwater	642081.943	$866,810,623
Township of St. Clair	733226.746	$989,856,107
Township of St. Joseph	188945.745	$255,076,756
Township of Stirling-Rawdon	282663.086	$381,595,166
Township of Stone Mills	565690.305	$763,681,912
Township of Strathroy-Caradoc	453458.052	$612,168,370
Township of Strong	213603.785	$288,365,110
Township of Tarbutt and Tarbutt Additional	69658.612	$94,039,126
Township of Tay	275816.685	$372,352,525
Township of Tay Valley	635624.736	$858,093,394
Township of Tehkummah	92425.55	$124,774,493
Township of Terrace Bay	75824.959	$102,363,695
Township of the Archipelago	338958.622	$457,594,140
Township of the North Shore	125531.685	$169,467,775
Township of Tiny	527800.318	$712,530,429
Township of Tudor and Cashel	200594.785	$270,802,960
Township of Tyendinaga	318107.995	$429,445,793
Township of Uxbridge	472508.995	$637,887,143
Township of Val Rita-Harty	98061.395	$132,382,883
Township of Wainfleet	365592.281	$493,549,579
Township of Warwick	329161.013	$444,367,368
Township of Wellesley	306139.172	$413,287,882
Township of Wellington North	522294.311	$705,097,320
Township of West Lincoln	510034.714	$688,546,864
Township of White River	57307.86	$77,365,611
Township of Whitewater Region	593988.5	$801,884,475
Township of Wilmot	405100.184	$546,885,248
Township of Wollaston	137561.126	$185,707,520
Township of Woolwich	499580.27	$674,433,365
Township of Zorra	629535.545	$849,872,986
United Townships of Dysart, Dudley, Harcourt, Guilford, Harburn, Bruton, Havelock, Eyre and Clyde	982302.439	$1,326,108,293
Village of Burk's Falls	15935.807	$21,513,339
Village of Casselman	32924.076	$44,447,503
Village of Hilton Beach	9417.124	$12,713,117
Village of Merrickville-Wolford	165185.505	$223,000,432
Village of Newbury	8292.416	$11,194,762
Village of Oil Springs	17105.186	$23,092,001
Village of Point Edward	34901.939	$47,117,618
Village of South River	18602.01	$25,112,713
Village of Sundridge	15806.683	$21,339,022
Village of Thornloe	8806.679	$11,889,017
Village of Westport	8501.531	$11,477,067
Ontario	87,203,550.00	$117,724,792,500
Total	278,307,020 km	$ 375,714,476,425